The VTB Bank (hereinafter referred to as VTB), is pleased that you are visiting our website. Data protection and data security are very important to us. We would therefore like to inform you at this point which personal data we collect when you visit our website and for what purposes it is used.
§1 Data Controller and Scope
The controller according to the EU General Data Protection Regulation (hereinafter: GDPR) and other national data protection acts of the Member States, as well as other data protection regulations, is:
§2 Data Protection Officer
The (external) Data Protection Officer is:
Dr. Karsten Kinast, LL.M.
KINAST Rechtsanwaltsgesellschaft mbH
§3 Principles of Processing Personal Data
Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behaviour. Information that cannot (or only with a disproportionate effort) referred to your person, e.g. by anonymizing the information, is not personal data. The processing of personal data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis. Processed personal data will be deleted as soon as the purpose of the processing has been achieved and there are no longer any legally required retention obligations. If we process your personal data for the provision of certain services, we will inform you below about the specific processes, the scope and purpose of the data processing, the legal basis for the processing and the respective retention period.
§4 Data Processing
Provision and Use of the Website
a. Scope and Purpose of the Processing
When you access and use our website, we only collect the personal data that your browser automatically transmits to our server. This information is temporarily stored in a so-called log file. When you use our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security:
· IP address of the requesting computer
· Date and time of access
· Name and URL of the retrieved file
· The website from which access is made (referrer URL)
· The used browser and, if applicable, the operating system of your computer as well as the name of your access provider
b. Legal Basis
Art. 6 para. 1 lit. f GDPR serves as the legal basis for the data processing. The processing of the mentioned data is necessary for the provision of our services and thus serves the protection of a legitimate interest of our company.
c. Data Deletion and Storage Time
The data subject’s personal data are deleted or restricted as soon as the purpose of the processing is fulfilled. The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection for the user. Further storage may take place in individual cases if this is required by law.
§5 Third Party Transfers
We only share your personal information with third parties if:
· you have given your express consent pursuant to Art. 6 para. 1 lit. a GDPR,
· it is legally permissible and necessary for the fulfilment of a contractual relationship with you pursuant to Art. 6 para. 1 lit. b GDPR,
· there is a legal obligation to pass on the data in accordance with Art. 6 para. 1 lit. c GDPR,
· the disclosure pursuant to Art. 6 para. 1 lit. f GDPR is necessary to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data.
In addition, we use external service providers as part of the administration of the website and the associated data processing on the basis of a data processing agreement (Art. 28 GDPR).
§6 Tracking, Analysis, Cookies
a. Scope and Purpose of Processing
Various types of cookies are used on our website, the types and functions are explained in more detail below.
Our website uses transient cookies that are automatically deleted as soon as you close your browser. This type of cookie makes it possible to record your session ID. This allows various requests from your browser to be assigned to a common session and enables us to recognize your terminal device during subsequent website visits within a session.
Persistent cookies are used on our website. Persistent cookies are cookies that are stored in your browser for a longer period of time and transmit information to us. The respective storage period differs depending on the cookie. You can delete persistent cookies independently via your browser settings.
These cookies are required for technical reasons so that you can visit our website and use functions offered by us. This refers, for example, to the following applications: Banner element to communicate cookie usage, and element to inform visitors about using an outdated browser. In addition, these cookies contribute to a safe and compliant use of the website.
With the help of these cookies, we are able to analyze website usage and improve the performance and functionality of our website. For example, information is collected about how our website is used by visitors, which pages are accessed most frequently, or whether error messages are displayed on certain pages. In addition, cookies are used for processing leads (visitor referrals) by partner companies.
Cookies for marketing and social media:
Advertising cookies (third party) allow you to view various offers that match your interests. Via these cookies, the web activities of users can be recorded over a longer period of time. You may recognize the cookies on different end devices used by you.
The following third-party providers receive personal data via cookies integrated on our website:
(1.) Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses so-called "cookies", which enable an analysis of your use of the website. The information generated by these cookies, for example about the time, place and frequency of your use of this website, is generally transferred to a Google server in the USA and stored there. When using Google Analytics, it cannot be ruled out that the cookies set by Google Analytics may also collect other personal data in addition to the IP address. Please note that Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will use the information generated by cookies on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. According to Google, the IP address transmitted by your browser within the scope of Google Analytics will not be merged with other Google data. You can generally prevent cookies from being stored by setting your browser software accordingly. However, we would like to point out that in this case you may not be able to use all functions of this website to their full extent.
To prevent information about your use of the website from being collected by Google Analytics and transmitted to Google Analytics, you can download and install a plugin for your browser at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
This plugin prevents information about your visit to the website from being transmitted to Google Analytics. Any other analysis is not prevented by this plugin.
We would like to point out that you cannot use the browser plug-in described above when visiting our website via the browser of a mobile device (smartphone or tablet). When using a mobile device, you can prevent the collection of your usage data by Google Analytics by clicking on the following link: Disable Google Analytics.
By clicking on this link, a so-called opt-out cookie is set in your browser. This prevents information about your visit to the website from being transmitted to Google Analytics. Please note that the opt-out cookie is only valid for this browser and only for this domain. If you delete the cookies in this browser, the opt-out cookie will also be deleted. To continue to prevent collection by Google Analytics, you must click the link again. The use of the opt-out cookie is also possible as an alternative to the above plug-in when using the browser on your computer. To ensure the best possible protection of your personal data, Google Analytics has been extended on this website with the code "anonymizeIp". This code causes the last 8 bits of the IP addresses to be deleted and your IP address is thus recorded anonymously (so-called IP masking). Your IP address will be shortened by Google before transmission within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and thus anonymized. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
(2.) Google Ads
We use the technology "Google AdWords" and specifically the conversion tracking. Google Conversion Tracking is an analysis service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). If you click on an ad placed by Google, a cookie for conversion tracking is stored on your PC. The cookies are valid for 30 days and are not used for personal identification. If you visit certain pages of our website when the cookie has not yet expired, Google and also we can recognize that you have clicked on a certain ad and have been redirected to this page. Google AdWords customers each receive a different cookie. Thus, it is not possible to track cookies across the websites of AdWords customers. The data collected using the conversion cookie is used to create conversion statistics for AdWords customers who use conversion tracking. In doing so, customers learn the number of users who clicked on their ad and were subsequently redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. If you do not wish to participate in conversion tracking, you can prevent this by making the appropriate setting in your browser, e.g. in the form of generally preventing the installation of cookies. You can also deactivate cookies for conversion tracking by setting your browser to only block cookies from the web address "googleadservices.com".
(3.) Google Remarketing
b. Legal Basis
Due to the described purposes of use (see §6 a.), the legal basis for the use of technically necessary cookies is Art. 6 para. 1 lit. f GDPR. For all cookies that are not technically necessary, the use is only based on your possibly given consent, Art. 6 para. 1 lit. a GDPR in conjunction with Section 25 para. 1 TTDSG.
Once you have given your consent, you can withdraw it at any time with future effect by clicking the "Manage Cookies" button on the website.
c. Storage Time
As soon as the data transmitted by the cookies is no longer necessary for the purposes described above, this information will be deleted. Further storage may take place in individual cases if this is required by law.
d. Appropriate safeguards for transfers to third countries
All recipients in third countries generally have suitable guarantees for data protection compliance (e.g. Binding Corporate Rules, EU standard contractual clauses). For data transfers to the US appropriate safeguards currently may not exist. There are limitations to the protection of personal data, which result from the national security authority according to US legislation, may access to data transferred from the EU to the US without limitation to the required extent. Against such usage you as the affected person cannot take legal action.
We also point this out to you in the cookie consent.
e. Browser Settings
Most browsers are already set to accept cookies by default. However, you can change your browser settings so that it only accepts certain cookies or no cookies at all. However, we would like to point out that you may no longer be able to use all the functions of our website if cookies are disabled by your browser settings on our website. You can also use your browser settings to delete cookies already stored in your browser. Furthermore, it is possible to set your browser so that it informs you before cookies are stored. Since the different browsers may differ in their respective functions, we ask you to use the respective help menu of your browser for the setting options. If you would like a comprehensive overview of all third-party access to your Internet browser, we recommend that you install specially developed plug-ins.
Our website contains hyperlinks to websites of other providers. When you activate these hyperlinks, you will be directed directly to the other providers' website. You will recognize this when the URL is changed. We cannot assume any responsibility for the confidential handling of your data on these third-party websites, as we have no influence on whether these companies comply with data protection regulations. Please refer to these websites for information about how these companies handle your personal data.
§8 Your Rights as a Data Subject
The GDPR gives you the following rights as a data subject of a processing of personal data:
· According to Art. 15 GDPR, you can request information about your personal data processed by us. In particular, you can request information about the processing purposes, the categories of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, about a transfer to third countries or international organizations and about the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details.
· According to Art. 16 GDPR, you can immediately request the rectification of incorrect or the completion of your personal data stored by us.
· According to Art. 17 GDPR, you can request the erasure of your personal data stored by us, unless the processing is to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend yourself of legal claims is required.
· According to Art. 18 GDPR, you may request the restriction of the processing of your personal data if you dispute the accuracy of the data, the processing is unlawful, we no longer need the data and you object to their deletion because you need them for the assertion, exercise or defense of legal claims. You also have the right under Art. 18 GDPR if you have objected to the processing in accordance with Art. 21 GDPR.
· According to Art. 20 GDPR, you can request to receive your personal data that you have provided to us in a structured, common and machine-readable format or you can request the transfer to another person responsible.
· According to Art. 7 para. 3 GDPR, you can withdraw your once given consent to us at any time. As a result, we are no longer allowed to continue the data processing based on this consent in the future.
· According to Art. 77 GDPR, you have the right to complain to a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work or our company headquarters.
§9 Right to Object
In case the processing of your personal data is based on legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR, provided that there are grounds for doing so that arise from your particular situation or the objection is directed against direct marketing. In the case of direct marketing, you have a general right of objection, which is implemented by us without the need of specifying a particular situation.
§10 Data Security and Security Measures
To prevent manipulation, loss or misuse of your data stored with us, we take extensive technical and organizational security precautions that are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognized encryption methods (SSL or TLS). However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions not within our sphere of responsibility. In particular, data disclosed in unencrypted form - e.g. if this is done by e-mail - can be read by third parties. We have no technical influence on this. It is the user's responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.