Wildstone Capital Limited is the controller for data processing and can be contacted at:
22 Berghem Mews, Blythe Road, London W14 0HN
Email address: email@example.com
In certain circumstances, under the GDPR, you have the rights described below in relation to the processing of your personal data. You can assert your rights by sending a request by post or email to the addresses specified in section 1.
These rights include the following:
2.1 Right of access.
In accordance with Art 15 GDPR, you can ask us for a copy of the personal data we hold about you and a description of how we use that personal data.
2.2 Right to rectification.
In accordance with Art 16 GDPR, if you believe any personal data we hold on you may be inaccurate or incomplete, and you are unable to correct this personal data yourself, you can require us to rectify these inaccuracies.
2.3 Right to erasure.
In accordance with Art 17 GDPR, you can require us to erase your personal data in certain limited circumstances.
2.4 Right to restrict processing.
In accordance with Art 18 GDPR, you can require us to restrict our use of your personal data or object to how it is used in certain limited circumstances.
2.5 Right to data portability.
In accordance with Art 20 GDPR, where we process your personal data using automated means on the basis of either your consent or to perform a contract, you can request that we supply such personal data to another party.
2.6 Right to withdraw consent.
In circumstances where we process your personal data on the basis of your consent, you have the right to withdraw your consent to the processing of your personal data at any time with effect for the future at no additional cost by addressing us e.g. via email as stated above in section 1. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
2.7 Right to object to processing.
In accordance with Art 21 GDPR, if we process your personal data based upon Art 6 para 1 lit e) or f) GDPR, you have the right to object to the processing of personal data concerning you. The processing of your personal data will then cease, unless we have legitimate grounds to continue the processing that override your interests, rights and freedoms, or the processing is for the assertion, exercise, or defence of legal claims.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we can refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it can take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
2.8 Right to lodge a complaint with a supervisory authority.
In accordance with Art 77 GDPR, you have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes data protection law. In the Netherlands, this is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). You can reach the Dutch Data Protection Authority via the contact details provided on their website: https://www.autoriteitpersoonsgegevens.nl/contact.
2.9 Data processing when exercising your rights.
The personal data provided by you when exercising your rights (as per Art 15 to 21 GDPR) will be processed for the purpose of implementing these rights, providing verification hereof and, if applicable, defending legal positions. In this context, your data will be stored for three years as of the complete fulfilment of your rights as a data subject.
The legal basis for this processing is our compliance with our legal obligations (Art 6 para 1 lit c) GDPR in conjunction with Art 15 to 21 GDPR). If the personal data is processed for purposes relating to legal defence, this also constitutes a legitimate interest (as per Art 6 para 1 lit f) GDPR).
You are neither contractually nor legally obliged to provide your personal data; however, the fulfilment of your request to exercise your rights as a data subject can be rejected (as per Art 12 para 2 sen 2 GDPR) if you do not provide the data required to identify you uniquely (after being requested to do so, if applicable).
Even if partial automatic transmission of data takes place when you call up our website, you are not legally or contractually obliged to provide data in connection with the use of our website.
We will collect personal data directly from you. For example, you may give us your personal data by filling in the contact form on our website or by corresponding with us by post, phone, email or otherwise. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns as follows:
4.1 Processing of personal data when accessing the website.
When you visit our website, we collect the data that is strictly necessary for the operation of our website to you. This involves the following personal data which is automatically transmitted to our server by your browser:
- IP address;
- Date and time of your request to the website;
- Time zone difference from Greenwich Mean Time (GMT);
- Content of the request (information about which specific webpage you have visited);
- Access status/http status code;
- Transferred data volume;
- Website requesting the access;
- Browser (information about the browser you use);
- Operating system and its interface (operating system of the computer you use to access the website or app);
- Language and version of the browser software.
The processing of this personal data is based on Art 6 para 1lit f) GDPR. You cannot access our website as a website user without us receiving such data. Our legitimate interest consists in making the use of the website technically possible.
The aforementioned data will be stored for 7 days and then deleted.
4.2 Contact form and contact by email.
We provide a contact form on our website so that you can contact us to request an initial valuation of your advertising site from our team. If you have any questions about Wildstone our website and other enquiries, you can contact us by email.
When you contact us via the contact form or by email, the data you provide (in particular your email address, your first and last name and the text of your enquiry as well as any other information you have provided in the contact form or by email) will be stored by us in order to process your enquiry and answer your questions.
The data processing is justified according to our legitimate interests (Art 6 para 1 lit f) GDPR). We have an interest in contacting you via the website in response to your query. If your request is aimed at the fulfilment of a contractual or pre-contractual measure, Art 6 para 1lit b) GDPR is the legal basis for the data processing.
We will delete the data generated in the course of your enquiry/contact as soon as it is no longer required for processing your enquiry. Insofar as there is a legal obligation to retain data, the data will be stored for the duration of the legally required retention period. The use of the contact form is voluntary for you and is not a prerequisite for the use of the website.
In connection with the contact form and contacting us by email, you are free to send us data via these channels, but without providing us your personal data in the context of contacting us in this way we cannot process and answer any enquiries from you in this respect.
4.3.1 Postal address and existing customer marketing.
We will also use the information you provide (in particular your name and address) to send you marketing information by post about other offers or events.
We will use your contact details received in connection with the sale of a service (in particular your first and last name, your email address, if applicable the name and address of your company as well as any other details you may have provided) for the purpose of direct marketing of similar goods and services by electronic mail, unless you have objected to such use. You can object to this use at any time without incurring any costs other than the transmission costs according to the basic rates.
This processing is based on our legitimate interests within the meaning of Art 6 para 1 lit f) GDPR. We have a legitimate economic interest in informing interested parties, customers and clients about our further offers in order to establish and maintain a long-term customer relationship.
Your data will be stored for this purpose as long as this is necessary for the postal marketing approach and existing customer marketing and you have not effectively objected to the data processing. Insofar as there is a legal obligation to retain data, the data will be stored for the duration of the legally required retention period.
4.4 Recipient of the data
In order to fulfil the processing purposes listed below, we also transfer your personal data to third parties. This may also include the transfer of personal data to European and non-European countries and the storage of personal data outside the European Union (“EU”) or the European Economic Area (“EEA”).
4.4.1 Recipients bound by instructions.
We share your data with service providers bound by instructions, such as IT service providers, who support us in our activities, e.g. as part of the administration and maintenance of the websites and the related systems and/or for other internal or administrative purposes.
Our website is hosted by a service provider. The personal data collected on our website is therefore stored on the service provider's servers. The server locations are also located in European and non-European countries. Insofar as your personal data is transferred to countries outside the EU or the EEA, we will ensure an adequate level of data protection through the use of standard contractual clauses of the EU Commission within the meaning of Art 46 para 2 lit c) GDPR.
If we pass on data to service providers bound by instructions, we do not require a separate legal basis for this.
4.4.2 Independent recipients.
In addition, in individual cases, we also pass on your data to other third parties, such as:
- Professional advisers (including but not limited to legal advisers and financial advisers), insurers, bankers, auditors, financial organisations and administrators;
- Public authorities, courts or other bodies, if we are required by law or by official or court order of an EU member state to disclose personal data to these bodies. These bodies also use the data on their own responsibility.
- Other Wildstone legal entities: We have a legitimate interest in making the work processes efficient and in sharing business processes within the Wildstone group for this purpose.
Insofar as you have explicitly consented, Art 6 para 1 lit a) GDPR is the legal basis for the data transfer. If there is a legal obligation to disclose the data, the legal basis for the data transfer is Art 6 para 1 lit c) GDPR. If, on the other hand, the disclosure is necessary for the fulfilment of a contractual or pre-contractual measure with you as a natural person, Art 6 para 1 lit b) GDPR is the legal basis. Otherwise, the transfer is based on our legitimate interests and the legal basis is Art 6 para 1 lit f) GDPR.
4.4.3 Data transfer to recipients in third countries outside the EU/EEA.
Insofar as any of the above-mentioned data transfers are made to a recipient outside the EU/EEA (to so-called “third countries”), an appropriate level of data protection for the foreign transfer is ensured either by so-called adequacy decisions provided by the European Commission (see https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) or by means of suitable security measures (so-called standard contractual clauses). If you have any questions about such data protection transfers outside the EU/EEA and would like more information about our security measures for the transfer of data to third countries, please feel free to contact us as indicated above (see section 1).
4.4.4 Content Delivery Network.
In order to accelerate access to our website, we use the services of ProspectOne, Królewska 65A/1, PL-30-081 Kraków to ensure that we can deliver our individual web pages to you quickly and flawlessly on your various devices. For this purpose, ProspectOne provides us with its Content Delivery Network (CDN) services. A CDN is a network of regionally distributed servers that are connected via the internet. This means that content, especially large files, can be delivered quickly and optimally, even with large peak loads.
Data processing shall be carried out according to Art 6 para 1lit f) GDPR. Our legitimate interest lies in providing a high-performance website.
We use the following cookies on our website:
5.1 Cookies strictly necessary for the operation of our website (hereinafter “required Cookie”).
These cookies are required for the operation and functionality of the website. They make the website technically accessible, secure and usable and provide essential and basic functionalities, such as navigation on the website, correct display of the website in the internet browser.
5.1 Analytics cookies.
The analytics cookies enable us to gather information on how our website is used in order to improve and ensure its appeal, content and functionality.
5.2.1 Google Analytics.
If you provide us with your consent, we’ll use Google Analytics, a web analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
For this purpose, if you provide us with your consent, cookies are installed on your device. These cookies will collect data such as browser and device information, your IP address, visited websites, and date and time of server request for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. The cookies also collect information about the interactions that users had with ads (clicking a text ad or viewing a video ad). Google will use this information to evaluate your use of the website for us, to create reports on the use of our website and to perform further analyses and evaluations related to the use of our website and internet use. Google can also link this data to other data about you, such as your search history, your personal account, the usage data of other devices and other data that Google has stored about you. Google may also transfer this information to third parties if required to do so by law (e.g. state authorities) or if third parties process this data on Google's behalf.
We will use the data collected to optimise campaigns, retarget and personalise ads. For this purpose, the cookies stored on your device by Google allow you to be retargeted on the one hand (e.g. within the scope of “Google Ads”) on Google's websites and – depending on your interests –when you visit websites of other partners. For this purpose, your browser is identified during advertising delivery and assigned to a target group. This information is used to display relevant and interesting ads to you.
The use of Google Analytics is based on your consent (Art 6 para 1lit a) GDPR).
5.2.2 Better Ads.
If you provide us with your consent, we’ll use Better Ads (d3sv.net) services provided by Better Ads GmbH, Winterstr. 2, D-22765 Hamburg. This service provider allows us to select personalised ads for you, measure ad performance and improve our marketing measures.
The use of Better Ads is based on your consent (Art 6 para 1 lit a) GDPR).
5.3 Marketing cookies.
These cookies enable us to alert you to our relevant advertising campaigns and to show you our personalised content based on your interests, including on third-party websites. In addition, we can use so-called targeting to limit the frequency of appearance of an advertisement and reduce the display of the advertisement for you.
5.3.1 X Conversion Tracking.
If you provide us with your consent, we’ll use the X online advertising program “Conversion Tracking” and the associated pixel tag technology from Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland (“X”). This allows us to track your user behaviour when you have viewed or interacted with ads on X. This gives us a better overview of how successful our campaigns on X are and enables us to continually optimize these campaigns.
If you provide us with your consent, the pixel tag is loaded to or from your device when you respond to an ad we place on X, for example by clicking a link to our website. In this context, a pixel ID is created and stored in a cookie so that we can temporarily analyse your user behaviour.
The use of X Conversion Tracking is based on your consent (Art 6 para 1 lit a) GDPR).
For more information about how X uses your personal data, see the information provided by X.
5.3.2 X Ads.
If you provide us with your consent, we’ll use the Xr Ads from Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland (“X”). X Ads enables us by using pixel tags and cookies to implement targeted advertising, re-targeting and conversion measurements for online advertising. In doing so, offers for specific target groups are played out on the basis of a selection of general criteria, such as demographic characteristics, regions or interests. X Ads also allows us to target ads based on your previous website views. For example, advertisements and references to our offers and content may be displayed if you are interested in certain services, information or offers on our website.
The use of X Ads is based on your consent (Art 6 para 1 lit a) GDPR).
For more information about how X uses your personal data, see the information provided by X.
5.3.3 LinkedIn conversion tracking.
The LinkedIn Insight Tag enables the collection of data on visits to our website, including URL, referrer URL, IP address, device and browser properties, timestamps and page views; this collection only takes place insofar as the user of our web presence is a LinkedIn member and is recognised as such by Linked-In via log-in or cookies; it takes place on the systems of the provider LinkedIn. LinkedIn does not share any personal data with us, but only provides us with aggregated reports about the website target group. LinkedIn also provides remarketing functionalities. This allows us to use this data to display targeted advertising outside of our website without identifying the LinkedIn member. LinkedIn members can control the use of their personal data for advertising purposes in their LinkedIn account settings.
The LinkedIn Insight Tag is used for the purpose of enabling detailed campaign reports and to gain information about the actual visitor target groups of our website and thus our interest in optimised marketing measures.
The use of LinkedIn conversion tracking is based on your consent (Art 6 para 1 lit a) GDPR).
For more information about how LinkedIn uses your personal data, see the information provided in LinkedIn's data protection information.
5.3.4 Meta Ads Conversion Tracking.
If you provide us with your consent, we’ll use the so-called “Facebook Pixel” and the Conversions API of the social network “Facebook” by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Meta”) for the following purposes:
18.104.22.168 Facebook Custom Audiences.
If you provide us with your consent, we’ll use the Facebook pixel and the Conversions API for remarketing purposes to be able to contact you again within 180 days. This allows us to display interest-based advertisements (“Facebook Ads”) to users of the website when they visit the social network “Facebook” or other websites also using this tool. In this way, we pursue the interest in displaying advertisements that are of interest to you in order to make our website or offers more interesting for you.
22.214.171.124 Facebook conversion.
If you provide us with your consent, we’ll also use the Facebook Pixel and the Conversions API to ensure that our Facebook Ads match the potential interest of users and are not annoying. With the help of the Facebook Pixel, we can track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called“conversion”).
The processing of this data by Facebook takes place within the framework of Facebook’s data policy. Special information and details about the Facebook pixel, the Conversions API and its functionality can also be found in the Facebook help area.
We are jointly responsible with Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Meta) for the collection and transfer of data in this process. This applies to the following purposes:
- The creation of individualised or suitable ads, as well as for their optimization.
- Delivery of commercial and transaction-related messages (e.g. via Messenger)
The following processes are therefore not covered by joint controllership:
- The process that takes place after the collection and transmission is within the sole responsibility of Meta.
- The preparation of reports and analyses in aggregated and anonymised form is carried out as a Processor and is therefore within our responsibility.
We have concluded a corresponding agreement with Meta for joint controllership, which can be accessed here: https://www.facebook.com/legal/controller_addendum. This agreement defines the respective responsibilities for fulfilling the obligation under the GDPR with regard to joint controllership.
Further information on how Meta processes personal data, including its legal basis and further information on the rights of data subjects can be found here: https://www.facebook.com/about/privacy.
The use of Meta Ads Conversion Tracking is based on your consent (Art 6 para 1 lit a) GDPR).
Information on the data security conditions can be found here: https://www.facebook.com/legal/terms/data_security_terms and on processing on the basis of standard contractual clauses can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum.
5.4 Legal basis.
The legal basis for the use of required cookies is Sec 25 para 2 no 2 of the German Telecommunication-Telemedia-Act (“TTDSG”) or , with regard to the processing of personal data, on the basis of Art 6 para 1 lit f) GDPR to protect our legitimate interests. In particular, our legitimate interests consist in being able to provide you with a technically optimised website that is user-friendly and tailored to your needs, and to ensure the security of our systems.
For all other cookies, the legal basis for the use of such cookies is your consent to the storage and reading of information on your end device according to Section 25 para 1 TTDSG and, with regard to the processing of personal data, according to Art 6 para 1 lit a) GDPR. Please note that if indicated in the sections on each third party service provider, that information generated by the cookies about your use of the website (including your shortened IP address) to servers outside the EU / European Economic Area your personal data may be transferred to third countries for which there is no adequacy decision by the EU Commission. This may entail various risks for the legality and security of data processing. For this reason, in this case, the service providers have used the standard contractual clauses approved by the EU Commission in accordance with Art 46 para 2 lit c) GDPR. Through these standard contractual clauses, the service providers undertake to comply with the European level of data protection when processing your personal data, even if the data is stored or otherwise processed outside the EU / European Economic Area. You can find the standard contractual clauses provided by the EU Commission at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021D0914. Please consider these circumstances when providing your consent. The consent includes all cookies selected by you and the storage of information associated with them on your terminal device, as well as their subsequent reading and subsequent processing of personal data.
Your consent withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
5.5 Disabling the cookie settings.
Most browsers are pre-set to accept cookies automatically. You can object to the creation of cookies by disabling cookies in your browser’s system settings. Please note, however, that some of the cookies are strictly necessary for the operation of our website, otherwise the page cannot be requested and displayed. By disabling cookies, you will not be able to use parts of the website (without restrictions).
In addition, you can also control the installation of cookies yourself at any time by changing your browser settings and/or deleting all cookies.
5.6 Google Tag Manager.
This website uses the Google Tag Manager.Through this service, website tags can be managed via an interface. The Google Tag Manager only implements tags. This means that no cookies are used and no personal data is collected. The Google Tag Manager triggers other tags, which in turn may collect data. However, the Google Tag Manager does not access this data. If a deactivation has been made at domain or cookie level, it remains in place for all tracking tags, insofar as these are implemented with the Google Tag Manager.
We do not use automation to make specific decisions in regard to profiling.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections will redirect you from our website to the website of the third party and may allow third parties to collect or share data about you. You will recognise this by the change of URL, among other things.
We also have social media presences for the purpose of engaging with you. Our website currently also contains links to the following social media providers: X, LinkedIn, YouTube, Pinterest and Instagram by means of corresponding social media buttons. In order to prevent any unwanted transfer of your usage data (e.g. address of the currently visited page) to these services, you only then access the services by clicking on the link. On the service page, these social networks may collect usage data and possibly user data. We have no influence on the collected data and data processing procedures, nor are we aware of the full extent of the data collection, the purposes of the processing, the storage periods. We also have no information on the deletion of the collected data by the plug-in provider.
Therefore, we inform you according to our current knowledge: Only when you click on the links does your browser establish a direct connection with the servers of the aforementioned services. In this way, the information that you have visited our website indirectly (referrer) is forwarded to these services. If you are already logged in to the service with your personal user account while visiting our website, you can usually "share" the document (so-called "sharing") or leave a comment etc. after clicking on the social media buttons. If you do not wish such data transmission, we advise you not to click on the social media buttons.
The purpose and scope of the data collection by the social services, as well as the further processing and use of your data there, as well as your rights in this regard and setting options for protecting your privacy, can be found in the data protection notices of these services.
Unless otherwise stated, we will delete or anonymise your personal data as soon as it is no longer required for the purposes for which we collected or used it in accordance with the preceding sections. We will also keep your data if we are obliged to do so for legal reasons or if the data is needed for criminal prosecution or to secure, assert or enforce legal claims or if the data is required for a longer period of time for criminal prosecution or for the assertion, exercise or defence of legal claims. This is also our legitimate interest in accordance with Art 6 para 1 lit f) GDPR. Storage then takes place until the relevant process has been completed plus the statutory limitation period.
If data must be stored for legal reasons, processing will be restricted. The data is then no longer available for further use.