Privacy policy
right. based on science GmbH (right°) operates a website under the domain www.right-basedonscience.de, where it informs the public about its activities and provides low-threshold information to the public.
For right°, responsible handling of personal data is a high priority. We want users to know which data is collected and used by right° and when.
Which data is required and processed for which purpose and on which basis depends to a large extent on the type of service that is used by you, or depends on the purpose for which it is required.
We have taken technical and organisational measures to ensure, , to the extent possible for us, that both we as well as external service providers comply with the provisions governing data protection.
The processing of personal data at right° is handled in accordance with the European General Data Protection Regulation (GDPR) (in German) and the Federal Data Protection Act (in German).
1. Basic information
1.1. Responsibility and Data Protection Officer
Responsibility for the processing of personal data lies with the
Dr. Sebastian Müller, LL.M.
Syndikusrechtsanwalt
Große Gallusstraße 16-18
60312 Frankfurt am Main
E-Mail: s.mueller@right-basedonscience.de
Phone: +49 (0)176 62253980
1.2. Personal Data
“Personal data” is any information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and/or an online identifier.
1.3. Protection of minors
Children and persons under 16 years of age should not transmit any personal data to us without the consent of their parents or legal guardians.
Should it happen that persons under 16 years of age do contact right° by email, contact form, letter etc., Points 3.1, 3.3, 3.6 through 3.10 shall apply. Points. 3.4 and 3.11 apply in cases whereby the data is necessary for a visit right°
2. Data processing in connection with visits to Internet pages associated with the domain www.right-basedonscience.de and https://emissions.xdegreecompatible.com
2.1. Data capturing
Whenever a user accesses our website and whenever a file is accessed, data relating to this is temporarily processed in a log file.
More specifically, the following data is stored for every single access/download:
Date and time (time stamp), IP address of the device or server used
Details of the request and target address (log version, HTTP method, referrer, user-agent string),
Name of the file accessed, volume of data transferred (URL including query string, file size in byte) and
confirmation as to whether the request was successful (HTTP status code).
2.2. Cookies and web analytics tools
right° processes data about the users of right°s websites using cookies and similar technologies. This is done to improve our web presence, our offers, and for advertising purposes. Cookies are small text files that are stored on your device and managed by the browser you use. Cookies store information related to your visits to our websites and provide information about them to us, as well as to the cookie providers, if applicable. Cookies may also contain personal data.
Different types of cookies are used on right°s websites:
– Tracking cookies: Tracking cookies make it possible, among other things, to determine how many visitors visit right°s websites and how visitors navigate on the websites. This also includes analytical cookies, which collect the relevant information and make it available for evaluation for statistical purposes.
– Session cookies: Session cookies are only stored for the duration of the current visit to our websites or a browser session. Session cookies make it possible, for example, to assign several browser windows of our websites that are open in parallel to a single user.
– Permanent cookies: Permanent cookies are stored beyond the individual visit to our websites or a browser session. They make it possible to recognize users on repeated visits to our websites and potentially adapt current offers and information to past visits.
– Some cookies are set by right° and are under our control. Other cookies are used by third-party providers on right°’s websites (specifically: LinkedIn, Google Ads, Hubspot). We cannot completely monitor the use of these third-party cookies. Parts of the collected information are provided to right° for analysis and advertising purposes. A detailed description of the analytics and marketing services we use can be found below. Please note that these services store cookies on your device in case of your consent.
2.2.1. Web analytics with Matomo:
right° uses a web tracking tool (“Matomo”) to obtain anonymized information about visitors’ behavior while visiting its websites. From this data, usage profiles can be created under a pseudonym. The cookies stored for this purpose are used exclusively to draw conclusions about usage behavior on the web pages of right° and to regularly review the information offered to users. No personal data is stored or passed on to third parties. The collection and storage of data can be objected to at any time with effect for the future [info@right-basedonscience.de].
2.2.2. LinkedIn Insight Tag:
right°s websites use the LinkedIn Insight Tag. This tool is provided and operated by LinkedIn Ireland Unlimited Company, located in Wilton Place, Dublin 2, Ireland (for more information on LinkedIn, please refer to the website https://www.linkedin.com/legal/impressum).
When users visit right°s websites and give their consent to cookies, the LinkedIn Insight Tag places cookies on visitors’ devices that store information about their activities on our websites. These cookies enable LinkedIn to compare and link visitor data from right°s websites with data from LinkedIn accounts. We wish to point out that LinkedIn only passes this data on to right° in anonymized form. A clear assignment of website visitors to LinkedIn accounts is not possible for right° through this data. right° may use the data provided for the targeted placement of advertisements to website visitors, or persons who have similarities to website visitors, in the LinkedIn network. The exact nature of the data processing depends on whether a visitor to right°’s websites has a LinkedIn account and has given LinkedIn permission to track browsing behavior via cookies and other tracking mechanisms outside of LinkedIn.
Users can change their cookie settings related to LinkedIn at https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out?trk=microsites-frontend_legal_cookie-policy. The cookies used by LinkedIn in connection with the LinkedIn Insight Tag can be viewed at the following address https://www.linkedin.com/legal/l/cookie-table.
right° uses the LinkedIn Insight Tag to measure the success of advertising activities in the LinkedIn network, as well as to target advertising to people who have shown interest in our company and our products in the past.
LinkedIn may use the data collected on right°’s websites via the LinkedIn Insight Tag for analysis for its own purposes. The data collected via the Insight Tag, as well as its use by LinkedIn, are beyond the knowledge and control of right°. The general privacy policy of LinkedIn can be found in the privacy policy at https://www.linkedin.com/legal/privacy-policy.
The legal basis for the use of the LinkedIn Insight Tag is your consent in accordance with Article 6 (1) (a) GDPR. LinkedIn Ireland Unlimited may forward collected data in whole or in part to the parent company in the United States. In this case, this forwarding is also based on your consent in accordance with Article 49 (1) (a) GDPR in conjunction with Article 6 (1) (a) GDPR.
2.2.3. Google Ads:
right°s websites use the Google tag from GoogleAds. GoogleAds is provided and operated by Google Ireland Limited, with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland.
When users visit right°s websites and give their consent to cookies, the Google Tag places cookies on the visitors’ device that store information about their activities on our websites. These cookies enable Google to recognize visitors of right°’s websites on third party websites and to create interest profiles of right°’s website visitors.
GoogleAds enables right° to display advertisements to groups of people according to predefined criteria. Users who have entered certain search terms defined by right° on Google or who correspond to certain demographic or interest-related characteristics, e.g. that they have visited right°’s websites in the past or resemble persons who have visited right° websites in the past, can be targeted with advertising.
right° may use the data provided by Google to analyze the effectiveness of advertising activities and to target advertising to relevant groups of people. The data collected by GoogleAds also includes user behavior on right°’s websites. Google collects data about which pages users have visited and associates this user behavior, for example, with people who have previously interacted with right°’s advertisements. This enables right° to analyze how ads affect visitor behavior on our websites. The information provided by GoogleAds is anonymized and does not allow right° to assign it to individual persons.
Google may use the data collected on right°’s websites via the Google Tag for analysis of its own purposes. The data collected via the Google Tag, as well as their use by Google, are beyond the knowledge and control of right°.
The legal basis for the use of the Google Tag is your consent in accordance with Article 6 (1) (a) GDPR. Google may forward collected data in whole or in part to the parent company in the United States. In this case, this forwarding is also based on your consent in accordance with Article 49 (1) (a) GDPR in conjunction with Article 6 (1) (a) GDPR. Details can be found on the following pages here , here and here.
2.2.3. Hubspot:
right°s websites use the Hubspot Tracking Code. The Hubspot Tracking Code and the data processing based on it are provided and operated by Hubspot (Guild Street, Dublin 1, Ireland).
Website visitors who consent to cookies and right°’s privacy policy and share their contact information with right° via a Hubspot service (e.g., contact forms or the appointment booking system) may receive cookies from Hubspot that can be directly linked to contact information in right°’s Hubspot contact database. In these cases, these cookies allow visitors to rights° websites to be recognized and assigned to the corresponding contact data in the Hubspot customer database. right° wishes to point out that persons who digitally share their contact data with us under consent to our privacy policy and consent to the storage of cookies may not surf right°s websites anonymously, depending on their browser settings.
right° uses the data collected via the Hubspot Tracking Code and provided by Hubspot only for planning and controlling marketing measures.
Hubspot may use the data collected on right°s websites via the tracking code for analysis of its own purposes. The data collected via the Hubspot Tracking Code, as well as its use by Hubspot, are beyond the knowledge and control of right°.
The legal basis for the use of the Hubspot Tracking Code is your consent in accordance with Article 6 (1) (a) GDPR. Hubspot may forward collected data in whole or in part to the parent company in the United States. In this case, this forwarding is also based on your consent in accordance with Article 49 (1) (a) GDPR in conjunction with Article 6 (1) (a) GDPR. More detailed information about Hubspot’s privacy policy and cookies can be found on the following pages here, here, and here.
3. Processing of personal data of those contacting right°
The ways in which personal data is processed depend on the channel of communication used, i.e. whether right° is contacted by email, its contact forms, by mail or by telephone.
3.1. Contacting right° by email
In addition to contacting staff at their personalised official email addresses, or by writing to one of the various office mail boxes, it is also possible to contact right° at: info@right-basedonscience.de, our central inbox. In the latter case, the sender’s IP address will be recorded alongside the date and time of the query. The personal data sent to this central inbox and stored by the unit responsible for forwarding messages to the recipient responsible for the matter in hand will be deleted one year after the message is forwarded.
The units will store the data transmitted by you (e.g. name, first name, address), and at least your email address and all information contained in your email (including any personal data you transmit in this way) for the purpose of contacting you and answering your query.
3.2. Contacting right° by post
If you write a letter to right°, the data transmitted by you (e.g. name, first name, address), and all information contained in your letter (including any personal data you transmit in this way) will be stored for the purpose of contacting you and answering your query. We need to process the personal data you transmit so that we can answer your query.
3.3. Contacting right° by phone
If you call right° by phone, personal data will be processed to the extent that this is necessary for processing your query.
3.4. Contacting right° by contact form
right° uses the service HubSpot to offer the possibility of contacting us digitally via online forms. For this purpose, we forward the data, in case of consent to our privacy policy, to HubSpot, which processes the data on our behalf. If you contact right° via contact forms on right°s websites, personal data may be transferred to service providers in third countries. These third countries may not have an adequate level of data protection. If the data is transferred to the USA, there is a risk that your data may be processed by US authorities for control and monitoring purposes, without you possibly having any legal remedies. The legal basis for the processing of the data provided is your consent in accordance with Article 6 (1) (a) GDPR.
4. Processing of personal data as part of social media use
right° is active on Twitter, Facebook, YouTube, and LinkedIn.
As part of its editorial duties within these social networks, right° processes data of people who interact with right°
We also explicitly draw your attention to the fact that the services used by right° store user data (e.g. personal information, IP address etc.) in line with their own guidelines on data usage and use it for commercial purposes. right° has no influence on the collection and use of data by social networks. We are unable to ascertain the extent, the location and the duration of the data capture, the extent to which the networks meet obligations to delete data, what evaluations and links pertaining to the data are made, and to whom data is forwarded.
For information about the type of data processed by Twitter and for what purposes, consult their Privacy Policy (in German).
For information about the type of data processed by Facebook and for what purposes, consult their Privacy Policy (in German).
For information about the type of data processed by YouTube and for what purposes, consult their Privacy Policy (in German).
For information about the type of data processed by LinkedIn and for what purposes, consult their Privacy Policy (in German).
As some of these companies are based outside the European Union with only one European office in Ireland, their legal interpretation is that they are not bound by European or German data protection rules. This also affects your right of information, the right to have data blocked or deleted, or the possibility to object to your user data being used for advertising purposes.
5. Processing of personal data in the context of provision of information
How and what type of personal data is processed will depend on the channels used to provide information. We distinguish between our newsletters, printed documents, and informational visits to right°
5.1. Data for newsletter distribution
If you subscribe to one of right°’s newsletters, your email address, the date and time of your subscription, and the type of newsletter you have selected will be stored on a server. Your data is being processed on the basis of your consent as per Article 6 (1) (a) GDPR (consent). We use this data exclusively for distributing our newsletters and for statistical analyses designed to measure our system’s performance. We will not transmit your data to third parties who are not acting on our behalf for this purpose, and will not use them for any other internal purposes.
The third parties are recipients of your personal data and act as processors for us as far as the sending of our newsletter is concerned. The storage and processing of the data provided under this section is neither legally nor contractually required. Without your consent and the transmission of your personal data, we will not be able to send out a newsletter to you.
Our subscription system will ask you to confirm your subscription once more (double opt-in) to ensure that you explicitly wish to subscribe to this newsletter.
Upon subscription, your data will be stored on a server and a confirmation message containing a link to the second and final subscription will be automatically sent to the email address you indicated. Unless you confirm your subscription by using the link contained in this email, your data will be deleted after 48 hours.
Only once you have used the confirmation link will your data used for newsletter distribution be stored for as long as you use our newsletter.
Should you decide that you no longer agree to your data being stored for this purpose and that you do not want to use the newsletter service any longer, you can unsubscribe at any time. The data indicated by you will be deleted in this process, unless we are obliged to store it for a longer period of time. To unsubscribe, follow this link. You will need the email address you indicated when you subscribed to the newsletter.
5.2. Ordering printed documents
If you use this website to order brochures, leaflets or other types of printed documents, we will need to process your personal data in order to conduct pre-contractual measures and meet our contractual obligations (provision of printed documents) as per Article 6 (1) (b) GDPR.
You will need to provide the following personal data:
Name
Street, house number
Postcode and town/city
This data will be processed along with your order. If we cannot complete the order process ourselves, your data will be transmitted to third parties (logistics company, if necessary other institutions to the extent that these dispatch the material). Without the above data, we will not be able to process your order. Additional information (whether we should address you as Mr/Ms/Mrs/Dr etc., the name of your company, and the country) is not necessary, but would be helpful for us to prepare your order.
The data provided by you will be anonymised 90 days after the order is completed.
6. Processing of personal data as part of the recruitment process
right° is responsible for the correct processing of your personal data as part of recruitment processes. You can contact our Data Protection Officer. As part of the recruitment process, candidates applying to right° are asked to provide information about themselves, their professional experience, their expert and personal qualifications and training, and, if applicable, information relating to severe disability and/or relevant to ensure equal treatment.
The certificates and diplomas, CVs, cover letters and other documents provided by you as part of the recruitment process contain personal data within the meaning of Art. 4 (1) GDPR. This personal data will be processed and used only to the extent that this is necessary to establish an employer-employee relationship (Art. 88 (1) GDPR in conjunction with Section 26 (1) and (3) Federal Data Protection Act).
Within right°, only members of staff entrusted with the selection process will have access to your personal data. Your personal data will not be disclosed to persons or institutions outside right°.
In our recruitment, we do not use automated decision making. If you complete the recruitment process successfully and are hired by right°, your documents will become part of your HR file, to the extent that they are relevant to the employer-employee relationship. Any additional data that has been transmitted and is not required will be deleted five months after the recruitment process is completed.
If you are not hired by right°, your data will also be deleted five months after the recruitment process is completed. Any application documents submitted to us by post will be returned to you.
Should you revoke your application, we will immediately delete your data and send your documents back.
You have the following rights vis-à-vis right° regarding personal data processed by us: right to information, right to correction, right to restrict processing, right to deletion, right to lodge a complaint with a supervisory authority.
7. Processing of personal data in the context of telephone and video conferences via Microsoft Teams Cloud
Telephone and video conferences are regularly conducted by right° via the Microsoft Teams service via the Internet.
For technical reasons, this service involves intermediate storage of the transmission at the service provider. At the end of the meeting, the data is automatically deleted, unless the meeting organizer has previously activated a recording. right° generally does not use this function in the default settings and announces a recording in advance in individual cases.
Data provided by you in advance (e.g. telephone number, email address) will be processed and stored for the purpose of inviting you to the telephone or video conference and for the traceability of the administrative process. We would like to point out that the processing of personal data is based on Article 6 (1) e DSGVO in conjunction with Section 3 BDSG. There is a corresponding order processing agreement with the service provider Microsoft in accordance with Art. 28 DSGVO. For more information on the handling of personal data there, please refer to the privacy policy of the order processor Microsoft for the Teams Cloud.
You have the following rights vis-à-vis right° regarding the personal data that concerns you: right to information, right to rectification, right to restriction of processing, right to erasure, right to lodge a complaint with a supervisory authority.
8. Registration for events using the events form
The nature of the data collected depends on the specific event. Information provided via the registration form will be transmitted to right°. The sender’s IP address will not be recorded.
If you use our event form to register for an event, your personal data will be collected, stored and processed by right° for the purposes of organising the event. The data will be deleted within 30 days after your visit. In the event of an incident that needs further investigation, the data can be stored for a longer period of time and may be transmitted to the law enforcement authorities. By completing the application, you consent to your data being treated in this way.
The applicant confirms that he/she has informed all of the persons listed as “additional participants” about the fact that their personal data will be collected, stored and processed by right° for the purposes of organising the above event, and that the data will be deleted within 30 days after the visit. The above person(s) have confirmed to the applicant that they consent to this.
The data collected as part of the registration process for an event are collected and processed for the purposes of organising the event. We would like to inform you that data transmitted via the form (which may included personal data provided by you) is processed in line with Article 6(1) (e) in conjunction with Section 3 Federal Data Protection Act, and for the purpose of answering your query.
9. Your rights
You have the following rights with regard to the personal data concerning your person:
Right of access, Art. 15 GDPR
The right of access confers on the data subject a comprehensive right of access to the data concerning his/her person and to certain important information-related criteria, such as the purposes for which it is processed or the duration for which it will be stored. The exceptions to this right regulated in Section 34 Federal Data Protection Act apply.
Right to rectification, Art. 16 GDPR
The right of rectification includes the possibility for the data subject to have inaccurate personal data corrected.
Right to erasure, Art. 17 GDPR
The right to erasure includes the possibility for the data subject to have data deleted by the party responsible. However, this is only possible if the personal data concerning his/her person are no longer needed, are processed unlawfully or if the relevant consent has been revoked. The exceptions to this right regulated in Section 35 Federal Data Protection Act apply.
Right to restriction of processing, Art. 18 GDPR
The right to restrict the processing includes the possibility for the data subject to prevent further processing of personal data concerning his/her person for the time being. A restriction particularly occurs pending verification of the exercise of other rights of the data subject.
Right to object to collection, processing and/or use, Art. 21 GDPR
The right to object includes the possibility for data subjects to object, in a particular situation, to the further processing of their personal data, insofar as this is justified by the exercise of public functions or of public or private interests. The exceptions to this right regulated in Section 36 Federal Data Protection Act apply.
Right to data portability, Art. 20 GDPR
The right to data portability includes the possibility for the data subject to obtain the personal data concerning his/her person from the person responsible in a standard, machine-readable format, in order to be able to forward them to another person responsible if necessary. According to Art. 20 (3) sentence 2 GDPR, however, this right does not apply if the data processing serves the performance of public tasks.
Right to revoke consent, Art. 13 and 14 GDPR
If personal data is processed on the basis of consent, the data subject may revoke such consent at any time for the purpose for which it was given. The lawfulness of the processing undertaken on the basis of this consent remains unaffected until receipt of the revocation.
You can assert the aforementioned rights in writing using the contact details set out in Section 1.1.
Source: Bundesministerium für Wirtschaft und Klimaschutz
10. Privacy policy for the free use of the XDC Portfolio Explorer
10.1. Terms and conditions
External communication of any XDC values is not permitted.
right° based on science GmbH (“right°”) is not an investment advisor and makes no representations as to the advisability of investing in any particular company, investment fund or other vehicle. The user ACKNOWLEDGES THAT NOTHING IN THE SERVICE CONSTITUTES AN INVESTMENT ADVICE OF ANY KIND AND THAT THE SERVICE IS PROVIDED FOR INFORMATIONAL PURPOSES ONLY.
The information contained in this service does not constitute an offer to sell securities or the solicitation of an offer to buy, or recommendation for investment, in any securities.
The user expressly agrees that use of the service is at your own risk. Accordingly, right° and its suppliers shall not be liable in any manner whatsoever for any inaccuracies, errors, omissions, delays, damages, claims, liabilities or losses, regardless of cause, in or arising out of the use of the information provided.
The information used for the preparation of the analyses by right° originates from various sources, namely also from “FactSet Research Systems” (financial data) and “Urgentem” (emission data), among others. This information represents a judgment as of the date of use and is subject to change without notice. Therefore, the information may not be current. The information contained in the analyses of right° has been derived/compiled from sources believed to be reliable, but no representation or warranty, express or implied, is made as to its accuracy, completeness, correctness or timeliness. A change in such information may cause the results of the analyses by right° to change as well. right° is not obligated to update analyses performed in the past.
right° DOES NOT WARRANT THAT THE DELIVERY OF THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, TIMELESS, COMPLETE OR ACCURATE, NOR DOES right° OR THE SUPPLIERS OF right° EXPRESS OR IMPLIED WARRANTIES AS TO THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SERVICE, AND THERE ARE NO EXPRESS OR IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE.
In order to keep the service, as well as the XDC Model itself, current and useful to the user, right° may update or change the service, as well as the XDC Model itself, from time to time (“Release”). right° cannot rule out the possibility that the results determined up to the time of the Release may change. right° is not obliged to update services provided or results determined up to the time of a Release.
right° is entitled to discontinue parts of the service due to a general product discontinuation or the unavailability of data or software from suppliers.
10.2. Confidentiality
All data in the process of the analysis is kept confidential and will not be distributed. None of the data you upload or manually add / remove / change is saved in any manner.
However, for calculation of the XDC values the data is transmitted to the XDC Model. right° sends all data using a secure HTTP channel using SSL (Secure Sockets Layer) encryption, which protects against malicious attacks trying to ‘listen’ to the communication.
For any questions please contact Dr. Sebastian Müller, LL.M., In-house Lawyer, s.mueller@right-basedonscience.de
