Data Protection

Privacy Statement as of May 2021

We, palero capital GmbH (hereinafter also referred to as “palero”), are pleased that you are interested in our website and would like to make your visit as pleasant as possible. Protecting your privacy is very important to us. Therefore, we provide you with information below about how we handle your personal data and about your data protection rights.

A. Data Controller / Data Protection Officer

We are the “Controller” in relation to the processing of your personal data in connection with this website, within the meaning of Article 4 (7) GDPR.

We can be contacted at:

palero capital GmbH
Brienner Straße 10
80333 Munich

Tel.: +49 89 88 98 871-00
Email: contact@palero.de

Managing directors: Christian Daumann, Felix Frohn-Bernau, Conny Wuppermann

If you have any questions about data protection, please contact:

datenschutz@palero.de

This privacy statement applies to this part of our online presence (hereinafter referred to as the “website”) and to other processing as described below in connection with our advertising and communication activities. Our privacy statement does not apply to websites operated by other providers (“third-party websites”) that can be reached via our website. Therefore, within the meaning of Article 4 (7) GDPR, we are not responsible for the processing of your personal data on such third-party websites.

B. Nature and scope of data processing

1. Data processed when you access our website

You are able to visit our website without providing any personal information. We only save the following data in server log files:

Host name of the computer accessing the site
IP address
Date and time of access
Browser type
Operating system
Website visited before ours

We only analyse this data to ensure that the website runs smoothly.

The IP address may be considered personal data because, in certain circumstances, it is possible to work out the identity of the party accessing our site from information provided by the internet provider. However, we only store and process the IP address in anonymised form, so that it is not personally identifiable.

2. Processing data to deal with your enquiries

We collect the personal data that you give us voluntarily when you contact us, particularly if you do so by email.

This data is processed solely for the exchange of emails with you and for the purpose for which you have given us the data, i.e. to deal with your enquiry or to contact you if you have requested us to do so. In such cases, your personal data will be processed with your consent and is permissible in accordance with Article 6 (1)(a) GDPR.

After your enquiry has been dealt with in full, your data will be locked against further use and deleted after any applicable data retention periods have expired, unless you have expressly consented to your data being re-used or unless we otherwise have the right to store it.

3. Processing data for newsletter requests

If you request the email newsletter we offer on our website, we will collect the following personal data from you:

Email address
Confirmation that you have read our privacy statement
Date and time you provided your consent
Optional: forename, surname and company name

The email address and choice of topics are to enable us to send you newsletters by email. We are entitled to process this data in accordance with Article 6 (1)(a) GDPR. We will store your consent and the time at which you ordered the newsletter as a record of the registration process. The legal basis for processing the abovementioned data is our legitimate interest, in accordance with Article 6 (1)(a) GDPR, which arises from our need to record your consent for us to send you the newsletter in order that we can prove, in the event of doubt, that we have your consent. For reasons of our legitimate interest, we will also store your confirmation that you have read the privacy statement, as this will enable us to record that we have met our data protection obligations.

You also have the option of voluntarily providing your forename, surname, salutation and the name of the company for which you work. If you provide us with this data, we will use it to personalise both our emails to you and the newsletter we send. We will be entitled to do so on the basis of the consent you gave us when you voluntarily provided us with the data, in accordance with Article 6 (1)(a) GDPR. You can unsubscribe from the newsletter at any time, either via the link provided in the newsletter or by sending an email to the following address: contact@palero.de. If you withdraw your consent by unsubscribing from the newsletter, we will delete the data you provided when registering for the newsletter, unless the data is subject to statutory retention requirements or we are not otherwise authorised to store it.

4. Processing job applicants’ data

If you apply to us for a job by email or post, we will collect the following data as part of the application process and in order to fill the post:

Salutation, surname and forename
Email address
Further information and documents, such as your cover letter, address, curriculum vitae and certificates that you provide us with in connection with your application

Your data will only be used to make an employment decision in relation to your application and so will only be forwarded to the person responsible for decisions about the post for which you have applied. As part of this process, we will be able to transfer your personal data to our affiliated companies, including our holdings, if this is permitted by the purposes and legal bases described. If you do not apply in response to a specific job advertisement (if you make a speculative application), we will use your data for all of the vacancies that meet your requirements at the time you send in your application.

We are entitled to process the data in this way in accordance with Article 88 GDPR, in conjunction with Section 26 (1)(1) BDSG (German Federal Data Protection Act).

We will delete your data after the application process has been completed, and no later than after a six-month retention period, unless we are legally required or permitted to store it for a longer period.

If applicable, you will receive an invitation for inclusion in our talent pool. Your data will only be stored beyond the six-month retention period if you have given your consent to inclusion in the palero talent pool. We use the talent pool to find suitable applicants for posts. Your data can then be viewed by departments at palero and by employees involved in the appointments process to check your profile against vacancies. We will delete your application data for the talent pool after five years unless you request us to delete it before that time or unless you consent to an extension of the storage period before the end of the five-year period.

5. Use of unsolicited data

If there are other instances where you provide us with your personal data without being asked to do so (e.g. by providing a business card, either in person or by post or email), we will transfer the data to our address management software and store it there. The basis for our actions is Article 6 (1)(f) GDPR and our legitimate interest in the efficient management of our business contacts’ data and in ensuring that such data is used in accordance with data protection regulations. We will delete this data if you ask us to do so, provided the data is not subject to statutory retention requirements or we are not otherwise authorised to store it.

6. Use of cookies

In order to optimise our website, we use cookies to save and analyse information about your visit to our website. Cookies are small text files that are stored on your device to enable you to use the website properly.

In general, you can set your browser so that you are informed when cookies are stored on your computer, you can prevent cookies from being stored, either generally or in specific instances, or you can allow cookies to be stored only in individual instances. In your browser settings, you can also delete stored cookies. The functionality of the website may be restricted without cookies, however. You will find settings options as follows:

for Chrome: chrome://settings/content/cookies
for Firefox: about:preferences#privacy
for Edge: edge://settings/content
for Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac

If the required settings page does not open when you click on the link, we recommend you copy the link manually and open it in a new browser window.

We do not use analysis cookies (for advertising, tracking, etc.) on our website.

C. Your rights

You have the following rights with respect to our processing of your personal data:

1. Withdrawing your consent

You can withdraw your consent with immediate effect at any time.

2. Accessing information

You have a right to access the personal data stored about you. You are also entitled to access the information listed in Article 15 GDPR.

3. Rectification and erasure

In accordance with Article 16 GDPR, you also have the right to have inaccurate personal data rectified and to have incomplete personal data completed and, if the requirements of Article 17 GDPR are met, you have the right to have your personal data erased.

4. Restriction of processing

In accordance with the requirements of Article 18 GDPR, you can restrict the processing of your personal data.

5. Releasing and transferring data

You have the additional right to receive the personal data concerning you, which you have provided us with, in a structured, commonly used and machine-readable format. You also have the right to instruct us to transfer your data to another controller, where this is technically feasible. You only have the right to transfer your personal data where processing is based either on consent, in accordance with Article 6 (1)(a) GDPR, or on a contract, in accordance with Article 6 (1)(b) GDPR, and where the processing is carried out by automated means. You do not have the right to have data transferred to another controller if to do so would adversely affect the rights and freedoms of others (e.g. personal data belonging to third parties, or our business and trade secrets or copyrights).

In general, there will be no cost to you if you exercise any of the abovementioned rights.

In accordance with Article 12 (5) GDPR, if your requests in respect of your rights in accordance with points 2 to 5 above are manifestly unfounded or excessive, in particular because of their repetitive character, we may either

(1) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or

(2) refuse to act on the request.

If you would like to exercise your rights, please contact datenschutz@palero.de or the relevant data protection authority.

D. The right to object

In accordance with Article 21 GDPR, you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you which is based on Article 6 (1)(e) or (f). If you object, we will stop processing your personal data unless we can demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms, or if processing helps establish, exercise or defend legal claims.

E. Obligation to provide data

You are under no legal or contractual obligation to provide us with personal data. You will need to provide the data that is described in section B (see above) as absolutely necessary for us to provide particular services if you want to use those services.

F. Right to lodge a complaint

If you believe that we are not properly complying with our data protection obligations, you may contact the data protection supervisory authorities at any time.

G. Updating this privacy statement

It may be necessary from time to time to update this privacy statement, either because of new legal or official requirements or new information provided on our website. We will provide you with the information at the relevant time. Generally speaking, we would recommend that you consult this privacy statement on a regular basis to check whether there have been any changes. Amongst other factors, you will be able to tell whether any changes have been made if the document status has been updated.