Privacy policy for the Vortex Street Fund website

1. Controller

The controller for the processing of personal data on this website within the meaning of Art. 4(7) GDPR is the provider of the website. You may send privacy enquiries to the email address below or to our Berlin contact address.

2. Principles and Scope

We process personal data only to the extent necessary to provide this website and to handle your enquiries. In financial services, data minimisation carries particular weight: this website deliberately does not collect bank details, portfolio data or identity document data.

Information required to enter into a business relationship – for example under statutory identification requirements – is collected only after personal contact and outside this website. We inform you separately about that processing.

This privacy policy applies to the website including all of its subpages. Linked third-party services are governed by their own privacy notices.

3. Website Access and Server Log Files

When you access this website, your browser necessarily transmits data that our server records in log files. The following data is processed:

• IP address of the requesting device
• date and time of access
• name and URL of the page or file requested
• volume of data transferred and notification of successful retrieval
• the previously visited page (referrer), where transmitted
• browser type, browser version, operating system and language setting

This processing is technically necessary in order to deliver the website, ensure its stable operation and detect attacks. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in the secure and uninterrupted operation of the site. This data is not combined with other data sources and is not evaluated for advertising purposes. Log files are deleted after 30 days unless they are exceptionally required for longer to investigate a specific security incident. The website is hosted by a service provider that processes the data exclusively on our instructions; a data processing agreement under Art. 28 GDPR is in place. [The name and registered office of the hosting provider will be added before go-live.]

4. Language selection and analytics cookies

The website language is selected through the URL: /de for German and /en for English. No cookie is set or read for language selection.

This website uses Google Analytics (measurement ID G-S4KDTENGBH) to understand how the website is used. The Google tag loads when a page is opened; analytics cookies may be set and information about your use of the website may be sent to Google.

5. Contact Form

You can use the contact form to request a confidential initial conversation. The following data is processed:

• Mandatory information: first name, last name, email address, country of residence and your acknowledgement that you have read this privacy policy
• Optional information: telephone number, approximate size of assets, area of interest, preferred time of contact and your message
• Technical metadata: the time of submission

We use this data solely to handle your enquiry and to contact you. The legal basis is Art. 6(1)(b) GDPR where the enquiry is directed at entering into a contractual relationship, and otherwise Art. 6(1)(f) GDPR (legitimate interest in responding to enquiries). Without the mandatory information we cannot attribute or answer your enquiry; the optional information serves solely to prepare the conversation. Please do not use the form to send special categories of personal data within the meaning of Art. 9 GDPR or confidential bank or portfolio details. Transmission is encrypted via HTTPS.

6. Contact by Email, Telephone or Post

If you contact us directly, we process your contact details and the content of your message in order to respond to your enquiry. The legal basis is Art. 6(1)(b) GDPR for contract-related enquiries and otherwise Art. 6(1)(f) GDPR.

Please note that unencrypted emails can be read by third parties in transit. For confidential information we are happy to agree a secure transmission channel with you.

7. Job Applications

If you send us an application, we process the data you provide solely for the purpose of conducting the application procedure. The legal basis is Sec. 26(1) BDSG in conjunction with Art. 6(1)(b) GDPR.

Application documents are deleted no later than six months after the procedure has been concluded, unless you have expressly consented to longer storage – for instance to be included in a talent pool. If an employment relationship is established, the data is transferred to the personnel file.

8. Fonts and External Content

The fonts used are downloaded when the website is built and are served from our own server. Loading the fonts therefore does not establish a connection to Google servers.

This website embeds no map services, video platforms, social media plug-ins or advertising networks. Google Analytics loads when a page is opened, as described in the analytics cookies section. External services are opened only when you click the relevant link; from that point onwards the privacy notices of the respective provider apply.

9. Recipients of Your Data

Within our organisation, only those units that need your data to handle your request have access to it.

Enquiries submitted through the contact form are sent to our contact address using Resend (Plus Five Five, Inc., San Francisco, USA). This service processes the form details and message content for delivery. The hosting provider also receives the technical connection data required to operate the website.

Data is disclosed to other third parties only where you have consented, where it is necessary for the performance of a contract, or where we are legally obliged to do so – for example towards supervisory, tax or law enforcement authorities. Your data is neither sold nor used for third-party advertising.

10. Transfers to Third Countries

The provider of this website is domiciled in the Bahamas. There is no adequacy decision of the European Commission under Art. 45 GDPR for the Bahamas.

Where personal data is transferred from the European Economic Area to the Bahamas or another third country, this takes place only under the conditions of Art. 44 et seq. GDPR – as a rule on the basis of the European Commission’s standard contractual clauses under Art. 46(2)(c) GDPR together with supplementary safeguards, and in individual cases on the basis of Art. 49 GDPR. You may request a copy of the safeguards agreed using the contact details above.

11. Retention and Erasure

We erase personal data as soon as the purpose of the processing ceases to apply and no statutory retention obligations prevent erasure. In particular, the following periods apply:

• Server log files: 30 days
• Enquiries not followed by a business relationship: erasure once the matter has been conclusively dealt with, and no later than six months after the last contact
• Application documents: six months after conclusion of the procedure
• Records of commercial or tax relevance: six or ten years respectively pursuant to Sec. 257 HGB and Sec. 147 AO

For as long as erasure is not possible because of statutory retention periods, we restrict the processing: the data is blocked and no longer used for any other purpose.

12. Whether You Must Provide Data

You are under no statutory or contractual obligation to provide us with personal data; you can use the website without providing any. To contact us, however, we require the information marked as mandatory. Without it we cannot process your enquiry.

13. No Automated Decision-Making

No automated decision-making, including profiling within the meaning of Art. 22 GDPR, takes place. Your enquiry is read and handled by our staff. We do not assess your personal circumstances for advertising or scoring purposes.

14. Your Rights as a Data Subject

You have the following rights vis-à-vis the controller:

• access to the data processed about you (Art. 15 GDPR)
• rectification of inaccurate data and completion of incomplete data (Art. 16 GDPR)
• erasure of your data, provided no retention obligations prevent it (Art. 17 GDPR)
• restriction of processing (Art. 18 GDPR)
• receipt of the data you provided in a structured, commonly used and machine-readable format, and its transmission to another controller (Art. 20 GDPR)
• objection to processing based on legitimate interests (Art. 21 GDPR)
• withdrawal of consent with effect for the future; the lawfulness of processing carried out until then remains unaffected (Art. 7(3) GDPR)

An informal message to the contact details above is sufficient to exercise these rights. We will respond without undue delay and within one month at the latest. We may request additional information in order to verify your identity.

15. Right to Object under Art. 21 GDPR

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) GDPR.

We will then no longer process the data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or unless the processing serves to establish, exercise or defend legal claims.

Where your data is processed for direct marketing, you may object at any time and without giving reasons; the data will then no longer be used for that purpose.

16. Right to Lodge a Complaint

Without prejudice to any other remedy, you have the right under Art. 77 GDPR to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement.

17. Data Security

We take technical and organisational measures pursuant to Art. 32 GDPR to protect your data against loss, destruction, alteration and unauthorised access. The website is delivered exclusively over an encrypted HTTPS connection, which you can recognise by the padlock symbol in your browser.

Access to enquiries is limited to a restricted group of people bound to confidentiality. Our measures are reviewed regularly and adapted to the state of the art.

18. Changes to This Privacy Policy

We adapt this privacy policy when the legal situation, our services or the procedures we use change. The version published on this page applies to your visit.