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Datenschutz

The following information provides an overview of how we process data in accordance with the EU General Data Protection Regulation (GDPR) and the rights arising from data protection laws. The protection of your personal data (Personal information, such as name, address, and contact information) when you visit the Sauren Financial Group website (Sauren Finanzdienstleistungen GmbH & Co. KG, Sauren Fonds-Service AG, Sauren Fonds-Research AG) is a high priority for the individual companies of the Sauren Group. Naturally, the aforementioned companies protect your data in accordance with legal regulations. As a general rule, your data is not transferred to third parties outside the Sauren Financial Group, unless the companies of the Sauren Group are legally obligated to do so, or the transfer of data is necessary to fulfill the contractual relationship or to safeguard a legitimate interest, or you have previously given your express consent to such a transfer of your data.

The following information explains the nature, scope, and purpose of data collection and the use of personal data. This Privacy Policy also informs you of your rights. This Privacy Policy applies to all companies within the Sauren Financial Group. Each company within the Sauren Group is independently responsible for complying with this privacy policy and its respective legal obligations.

Name and Address of the Data Controller

The data controller within the meaning of this Privacy Policy is the legally independent company within the Sauren Group whose business activities give rise to the respective processing activity. The data controllers in this sense are:

Sauren Fonds-Service AG
At MediaPark 8 (KölnTurm), 50670 Cologne
Phone: 0221/ 65050 100, Email: info@sauren.de
www.sauren.de

Sauren Financial Services GmbH & Co. KG
At MediaPark 8 (KölnTurm), 50670 Cologne
Phone: 0221/ 65050 100, Email: info@sauren.de
www.sauren.de

Sauren Fonds-Research AG
At MediaPark 8 (KölnTurm), 50670 Cologne
Phone: 0221/ 65050 100, Email: info@sauren.de
www.sauren.de

The joint data protection officer, Ms. Ariane Rack, can be reached at datenschutzbeauftragter@sauren.de to reach.

Collection and Processing of Data

When you access the Sauren Financial Group’s websites or retrieve a file stored on these websites, data is automatically transmitted to our web servers for technical reasons. Web servers store the following information with every request: (such as a page view) Data. Data such as the date and time of access to the websites, the URL of the referring website, the file accessed, the amount of data transmitted, the browser type and version, and the operating system are logged. In addition, the IP address of the requesting computer is recorded. The Sauren Financial Group uses this data solely for standard statistical analysis. (e.g., to determine website traffic). Any additional personal data is collected only if you, as a user of the websites, voluntarily provide this information while using the websites. We also process personal data that we receive from customers or other data subjects in the course of our business relationship.

If you send us an email or contact us via our contact form, your email address and other contact information will be stored and used solely for the purpose of corresponding with you or sending you any informational materials you may have requested.

Use of Personal Data and Legal Basis

If, as a user of the Sauren websites, you have voluntarily provided personal or business data in connection with an inquiry or registration, this data will be used to facilitate the services provided on the website, such as responding to inquiries or sending requested informational materials. The personal data collected in forms for registrations and contact inquiries is used exclusively for this purpose. It is not visible to third parties outside the Sauren Financial Group and will not be disclosed to such parties unless you have previously given your consent.

If you contact us via a contact form, your information will be stored for the purpose of processing your inquiry and in case follow-up questions arise. In general, you must provide a valid email address, and only in individual cases (e.g., when registering for an event) We also require your name so that we can respond to your inquiry and, for example, organize an event. Additional information is optional. This data will not be shared with third parties outside the Sauren Financial Group unless you have given your prior consent.

The Sauren Newsletter keeps you up to date on current topics. When you subscribe to the newsletter, the information you provide—such as your name, address, email address, and so on—will be stored and used to send you the newsletter. To receive the newsletter via email, providing an email address is generally sufficient. Additional information may be provided voluntarily. You can unsubscribe at any time, for example by sending a message to info@sauren.de. The information you provide, such as your name, address, email address, and the like, will not be shared with third parties outside the Sauren Financial Group. For information on the use of short links in the Sauren newsletter or other mailings, please refer to the section titled “Use of Cuttly.”

Data is also processed to enable companies within the Sauren Financial Group to provide services under a contractual relationship with the data subject or to take precontractual steps in response to a request.

To the extent that consent is obtained from the data subject for the processing of personal data, such as when subscribing to our newsletter, requesting promotional materials about the Sauren fund of funds, or when your data is shared within the Sauren Financial Group, Article 6(1)(a) of the General Data Protection Regulation applies (GDPR) as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Article 6(1)(b) of the GDPR serves as the legal basis. This also applies to processing operations necessary for the implementation of precontractual measures.

To the extent that the processing of personal data is necessary to comply with a legal obligation to which our companies are subject, or is in the public interest, Article 6(1)(c) or (e) of the GDPR serves as the legal basis. The latter applies, for example, if Sauren Finanzdienstleistungen GmbH & Co. KG or Sauren Fonds-Service AG, as a financial services institution or financial investment broker, is subject to specific statutory or legal requirements arising, for example, from the Securities Trading Act, the Securities Institutions Act, Money Laundering Act, the Financial Investment Intermediaries Ordinance, or other regulatory requirements.

Is the processing necessary to safeguard a legitimate interest of our companies or a third party? (e.g., advertising, transfer of data within the corporate group, assertion of legal claims, ensuring IT security, measures for business management, and the further development of services and products) and if the interests, fundamental rights, and fundamental freedoms of the data subject do not override the aforementioned interest, the lawfulness of the data processing is established under Article 6(1)(f) of the GDPR.

Secure Data Transmission

The Sauren Financial Group's websites use "SSL encryption" (https://) protected from access by third parties.

Use of Cookies

Our website uses cookies. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) are stored when you visit our site. Cookies do not cause any damage to your device and do not contain viruses, Trojans, or other malware.

The cookie stores information related to the specific device being used. However, this does not mean that we thereby gain direct knowledge of your identity.

One purpose of using cookies is to make your experience with our website more enjoyable. For example, we use so-called session cookies to recognize that you have already visited certain pages on our website. These are automatically deleted when you leave our site.

In addition, to optimize the user experience, we also use temporary cookies that are stored on your device for a specific, predetermined period of time. For more information on cookies, please see our Cookie Policy.

The legal basis for the processing of personal data is Article 6(1)(a) of the GDPR. (Consent) and, with regard to necessary cookies, Article 6(1)(f) of the GDPR, in order to improve the quality of our websites.

Use of Google Analytics 4

To ensure that our websites are tailored to user needs and continuously optimized, we use Google Analytics 4, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; hereinafter “Google.” In this context, pseudonymized user profiles are created and cookies are used. The information generated by the cookie regarding your use of this website, such as

  • Browser type/version,

  • operating system used,

  • Referrer URL (the page you were on previously),

  • Hostname of the connecting computer (IP address),

  • Time of the server request,

are transferred to a Google server in the United States and stored there. With regard to data transfers to the United States, an EU Adequacy Decision has been issued under the EU-U.S. Data Privacy Framework. Google LLC is registered under the Data Privacy Framework, so it can be assumed that an adequate level of protection is in place for the transfer of data to the United States. Additionally, please refer to the European Union’s Standard Contractual Clauses. For more information, please see the provider’s privacy policy at https://www.google.de/intl/de/policies/privacy.

We also use the special “Google Signals” feature in Google Analytics 4. This feature allows us to generate statistics by analyzing the content visited, providing information about the age, gender, and interests of site visitors. However, we cannot link the collected data to any specific individual, and the raw data is generally deleted after a retention period of two months.

The information is used to analyze website usage, to compile reports on website activity, and to provide other services related to website and Internet usage for the purposes of market research and to tailor the design of these web pages to user needs. This information may also be transferred to third parties if required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be combined with other data held by Google. IP addresses are anonymized so that they cannot be linked to you. (IP Masking).

You can prevent cookies from being installed by adjusting your browser settings accordingly; however, please note that in this case, you may not be able to use all features of this website to their full extent.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and prevent Google from processing this data by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de).

As an alternative to the browser add-on—especially for browsers on mobile devices—you can also prevent Google Analytics 4 from collecting data by clicking this link:

Disable Google Analytics

An opt-out cookie will be set to prevent your data from being collected in the future when you visit this website. The opt-out cookie is valid only in this browser and only for our website, and it is stored on your device. If you delete the cookies in this browser, you will need to set the opt-out cookie again.

Using Google Tag Manager

We use Google Tag Manager. This is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, and operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool for organizing, managing, and integrating so-called tags on our website. Tags are pieces of code used, for example, for analytics, tracking, and marketing purposes. These tags from the respective tools come, for example, from services provided by Google LLC itself, such as Google Analytics. In addition, the tags may also come from other companies. Cookies can be set and loaded via Google Tag Manager; Google Tag Manager itself does not collect any personal data. Google Tag Manager consists of program code that is loaded from a Google server (just like a normal website request). The IP address is transmitted during this process but is not (further) processed by Google and is deleted after 14 days. In this context, please refer to Google’s statement: https://support.google.com/tagmanager/answer/9323295?hl=de.

The tools (or "plugins") loaded by Google Tag Manager may, among other things, set cookies and process data. The tools we use are described in this Privacy Policy. Among other things, data is also processed by Google in the United States. In this regard, we refer to the Adequacy Decision regarding the EU-U.S. Data Privacy Framework and the European Union’s Standard Contractual Clauses. Further information on this can be found at https://www.google.de/intl/de/policies/privacy.

Use of Google Ads

We use the Google Ads service. This is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, and operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables companies to reach potential customers in a targeted manner by displaying ads when users enter specific search terms (known as keywords) in their search queries. Google also uses information about the user (e.g., location, websites visited, or data from other (Google) services) to display ads. With Google Ads, we can target you based on your interest profile or the topics you are actively searching for.

Among other things, data is also processed in the United States. With regard to data transfers to the United States, an EU Adequacy Decision has been issued regarding the EU-U.S. Data Privacy Framework. Google LLC is registered under the Data Privacy Framework, so it can be assumed that an adequate level of protection is in place for the transfer of data to the United States. In addition, please refer to the European Union’s Standard Contractual Clauses. For more information, please see the provider’s privacy policy.

Using The Trade Desk

To tailor our website offerings to user needs and continuously optimize them, we use retargeting technology provided by The Trade Desk Inc., 42 N. Chestnut Street, Ventura, CA 93001, USA. In this context, interest-based advertisements are displayed in a targeted manner, and corresponding analyses are enabled. Among other things, data is also processed in the United States.

With regard to data transfers to the U.S., an EU adequacy decision has been issued regarding the EU-U.S. Data Privacy Framework. The Trade Desk Inc. is registered under the Data Privacy Framework, so it can be assumed that an adequate level of protection is in place for the transfer of data to the United States. In addition, please refer to the European Union’s Standard Contractual Clauses. For more information, please see the provider’s privacy policy at https://www.thetradedesk.com/us/privacy.

Using YouTube

We use YouTube to display videos on our websites. YouTube is a video portal operated by YouTube LLC, 901 Cherry Ave., 94066 San Bruno, CA, USA. YouTube LLC, in turn, is a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, is responsible for providing certain services, such as YouTube.

With regard to data transfers to the United States, an EU adequacy decision has been issued regarding the EU-U.S. Data Privacy Framework. The operator of the aforementioned service is registered under the Data Privacy Framework, so it can be assumed that an adequate level of protection is in place for the transfer of data to the United States. In addition, please refer to the European Union’s Standard Contractual Clauses. For more information, please see the provider’s privacy policy at https://www.google.de/intl/de/policies/privacy.

For the purposes of functionality and to analyze user behavior, YouTube LLC permanently stores cookies on your device via your web browser. If you do not consent to this processing, you can prevent cookies from being stored by adjusting the settings in your web browser.

Using Vimeo

We use “Vimeo” on our website to display videos. This is a service provided by Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA.

In some cases, user data is processed on Vimeo's servers in the United States. The transfer of data to Vimeo LLC is based on the European Union's Standard Contractual Clauses. For more information, please visit https://vimeo.com/privacy#international_data_transfers_and_certain_user_rights.

When you visit websites that have a video embedded on them, a connection is established with the servers of Vimeo LLC in the United States to display the video. For technical reasons, it is necessary for Vimeo LLC to process your IP address. In addition, the date and time of your visit to our websites are also recorded.

If you do not consent to this processing, you can prevent cookies from being installed by adjusting the settings in your web browser.

Use of Cookiebot

We use Cookiebot to provide users of our website with a comprehensive cookie notice. This software is provided by Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark. By using this feature, your data may be sent to, stored by, and processed by Cookiebot or Usercentrics. In this process, data is also stored on servers in the United States. Any such data transfer is based on the European Union’s Standard Contractual Clauses. For more information, please see the provider’s privacy policy at https://www.cookiebot.com/de/privacy-policy/.

Using Cuttly

Cuttly is a URL shortening service with link analysis, operated by Web Room Studio Patryk Ruminski, located at ul. Śląska 15A/9, 80-384 Gdańsk, Poland.

Articles in our newsletter or other mailings may include links to additional content, such as video recordings, webinars, or podcasts on the Sauren website www.sauren.de or external websites. We use shortened links for this purpose. When you click on a shortened link, the aforementioned provider generates only anonymous statistics. The use of Cuttly as a service for shortening URLs and anonymously analyzing link usage is intended to ensure a visually appealing design for our newsletters and other communications. Furthermore, it is intended to enable improvements and provide targeted information to users. Personal data is not stored permanently. No data, such as the IP address, is permanently stored. This information is transmitted only temporarily to determine the geographic location (country). It is not possible to identify an individual based on these statistics. These are strictly anonymous statistics.

Data may be transferred to a third country outside the EU/EEA. Such transfers take place only to countries for which an adequacy decision has been issued—and where an adequate level of protection can therefore be assumed—or are based on the European Union’s standard contractual clauses.

For more information, please see the provider's privacy policy at https://cutt.ly/privacy.

Using Storytile

We use participant management software to ensure that web seminars are conducted in a way that meets participants’ needs and is optimized for effectiveness. This is a software service provided by storytile GmbH, Gollierstr. 70, 80339 Munich.

In addition to the standard features for preparing and conducting a webinar (e.g., registration, participant management, etc.), the webinar portal will also provide statistical analyses of participant behavior.

When you use the webinar software, your data is sent to, stored by, and processed by storytile GmbH or, in some cases, by service providers used by storytile GmbH. With regard to data transfers to the United States, an EU Adequacy Decision has been issued under the EU-U.S. Data Privacy Framework, under which certain service providers are registered; therefore, it can be assumed that an adequate level of protection exists for data transfers to the United States. In addition, reference is made to the European Union’s Standard Contractual Clauses. Further information can be found in the providers’ privacy policies at https://www.storytile.net/datenschutzerklaerung.

Using the LinkedIn Insight Tag

We use LinkedIn Insight Tags to obtain detailed reports for our marketing campaigns and to retarget our website visitors. This is a service provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. The LinkedIn Insight Tag enables the collection of data regarding visits to our website, including the URL, referrer URL, IP address, device and browser characteristics (user agent), and timestamps. IP addresses are truncated or, if used to reach LinkedIn members across devices, hashed. The data mentioned above is encrypted, pseudonymized within seven days, and the pseudonymized data is deleted within 180 days. LinkedIn does not share any personally identifiable information about its members with us, but rather provides anonymized reports on the website audience and ad performance. LinkedIn Tags also offer retargeting capabilities, allowing us to use this data to display targeted ads outside of our website without identifying you as a website visitor. LinkedIn also uses non-identifying data to improve ad relevance and reach members across devices. LinkedIn members can control the use of their personal data for advertising purposes in their account settings. Data is also processed in the U.S., among other locations. With regard to data transfers to the U.S., an EU Adequacy Decision has been issued under the EU-U.S. Data Privacy Framework. The operator of the aforementioned service is registered under the Data Privacy Framework, so an adequate level of protection can be assumed for the transfer of data to the United States. Additionally, reference is made to the European Union’s Standard Contractual Clauses. For more information, please see LinkedIn’s Privacy Policy at https://de.linkedin.com/legal/l/dpa.

Use of MiFID Recorder

To offer our customers the option of video consultations, we use the software product MiFID-Recorder. This is a service provided by Etops MIFID Recorder GmbH, Rüdesheimer Straße 11, 80686 Munich.

We use MiFID recorders to conduct advisory consultations via video call and to store the recordings of these consultations in compliance with the law. We process personal master data, communication data (e.g., phone, video, email), contract master data, contract billing and payment data, customer history, and image and audio data (e.g., video and voice recordings).

No data is transferred to a third country outside the EU/EEA. For more information, please see the provider's privacy policy at https://www.mifid-recorder.com/datenschutz/.

Using POSTIDENT

To enable us to offer our investors the option of verifying their identity at a Deutsche Post branch, we use the POSTIDENT procedure provided by Deutsche Post AG. This is a service provided by Deutsche Post AG, Charles-de-Gaulle-Straße 20, 53113 Bonn.

We use POSTIDENT to enable our investors to verify their identity at a Deutsche Post branch in accordance with the law. In the process, we process identification data (e.g., name, nationality, street and house number, ID details) as well as data from the proof of identification (proof data) (e.g., photo or scan of the ID document). Once the identification process is complete, the required data is transmitted to us.

No data is transferred to a third country outside the EU/EEA. For more information, please see the provider's privacy policy at https://www.deutschepost.de/de/p/postident/postident-datenschutzhinweise.html.

Data Retention Period

The length of time personal data is stored is generally determined by statutory retention requirements. Retention requirements under commercial and tax law typically range from six to ten years. Statutory limitation periods can be up to 30 years, but are generally 3 years. If the relevant data is no longer required for the performance of a contract or for other purposes, it is regularly deleted.

Data Subject's Rights

If your personal data is being processed, you, as the data subject, have the following rights with respect to the data controller:

  • pursuant to Article 15 of the GDPR, to request information about your personal data processed by the companies of the Sauren Financial Group. In particular, you may request information regarding the purposes of processing, the categories of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned retention period, the existence of a right to rectification, erasure, restriction of processing, or objection; the existence of a right to lodge a complaint; the origin of your data, if it was not collected by us; and the existence of automated decision-making, including profiling, and, where applicable, meaningful information regarding its details;

  • in accordance with Article 16 of the GDPR, to request without delay the correction of inaccurate personal data or the completion of your personal data stored by us;

  • pursuant to Article 17 of the GDPR, to request the erasure of your personal data stored by the companies of the Sauren Financial Group, unless the processing is necessary for the exercise of the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims;

  • to request the restriction of the processing of your personal data pursuant to Article 18 of the GDPR, provided that you contest the accuracy of the data, the processing is unlawful but you oppose its erasure, and we no longer need the data but you require it to assert, exercise, or defend legal claims, or you have objected to the processing pursuant to Article 21 of the GDPR;

  • In accordance with Article 20 of the GDPR, you have the right to receive the personal data you have provided to the companies of the Sauren Financial Group in a structured, commonly used, and machine-readable format, or to request that it be transferred to another controller;

  • In accordance with Article 7(3) of the GDPR, you may withdraw your consent at any time by notifying the data controllers listed above. As a result, data processing based on this consent may no longer continue in the future, and

  • to file a complaint with a supervisory authority pursuant to Article 77 of the GDPR. As a general rule, you may contact the supervisory authority in your usual place of residence or workplace for this purpose.

Right to Object under Article 21 of the GDPR

If your personal data is processed on the basis of legitimate interests pursuant to Article 6(1)(f) of the GDPR, you have the right, pursuant to Article 21 of the GDPR, to object to the processing of your personal data, provided there are grounds arising from your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right to object, which we will honor without requiring you to specify a particular situation.

If you wish to exercise your right of withdrawal or right to object, simply send an email to info@sauren.de.

Right to Withdraw Consent Under Data Protection Law

You have the right to withdraw your consent under data protection law at any time, effective for the future. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of that consent prior to its withdrawal.

Right to File a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State where you reside, where you work, or where the alleged infringement occurred, if you believe that the processing of your personal data violates the GDPR.

The supervisory authority to which the complaint was submitted shall inform the complainant of the status and outcome of the complaint, including the possibility of seeking judicial remedy under Article 78 of the GDPR.

Use of Contact Information

The use by third parties of contact information published in accordance with the legal requirement to provide an "Imprint" for the purpose of sending unsolicited advertising and informational materials is hereby expressly prohibited. The operator of this website expressly reserves the right to take legal action in the event of the unsolicited transmission of advertising information, such as through spam emails.

Status and Changes to the Privacy Policy

This Privacy Policy is currently in effect and is dated July 2025.

Sauren Financial Group reserves the right to amend this Privacy Policy at any time in accordance with applicable data protection regulations. The most current version of the Privacy Policy is available at any time on the website at https://www.sauren.de/de/legal/datenschutz/ can be accessed and printed by you.

As of March 2026