Data Privacy Notice

Information on data processing according to Article 13 and 14 General Data Protection Regulation (GDPR)

We take the protection of your personal data very seriously. We treat your personal data with confidentiality and in accordance with the relevant legal provisions. This privacy policy explains how we process your personal data. As a rule, you can use our website without providing personal data. Insofar as we collect personal data (e.g. name, address or e-mail address) on our website, such data is always collected either to facilitate the use of the website or on a voluntary basis.

Who is the responsible data controller and who may you approach?

The responsible data controller is:
Raiffeisen Kapitalanlage-Gesellschaft  m.b.H.
(hereinafter the “Company“ or “Raiffeisen KAG“)
Mooslackengasse 12, 1190 Wien
+43 1 71170-0
kag-info@rcm.at

The Data Protection Officer is:
Data Protection Officer
Am Stadtpark 9, 1030 Wien
+43 1 71707-8603
datenschutzbeauftragter@rbinternational.com

Privacy Policy Raiffeisen Immobilien Kapitalanlage-Gesellschaft m.b.H.

Which data are processed and from which source do they originate?

We process those personal data which we receive from you in the framework of the account relationship or for which you have given your consent for processing. In addition, we process data that has been legitimately obtained from publicly available sources (such as company register, association register, land register or media) or that is legitimately submitted to us by other companies affiliated with the bank. In addition, we process data (tracking data) that occurs when you visit our website. We collect these automatically and usually either based on your input or via cookies.

Relevant personal data may include: your particulars and contact data (such as family name, address, date of birth and place of birth, nationality, etc.) or data relating to your ID or travel documents (such as a specimen of your signature, ID data). In addition, this may include payment and clearing data (for example, payment orders, sales data in payment transactions). Data on marketing and sales, image and/or audio recordings (e.g. video recordings, telephone recordings), electronic log and identification data (apps, cookies, etc.) or AML (Anti-Money Laundering) and compliance data as well as other data equivalent to the above categories.

For which purposes and on which legal basis are the data processed?

We process your personal data in accordance with the provisions laid down in the European General Data Protection Regulation (EU GDPR) and the Data Protection Act 2018.

To perform contractual obligations (Article 6 (1) lit b GDPR)

The purpose of processing personal data (Article 4 (2) GDPR) is to manage capital investment funds within the framework of the 2011 Austrian Investment Fund Act (Investmentfondsgesetz 2011, InvFG) (investment business according to Section 1 (1) line 13 of the Austrian Banking Act (Bankwesengesetz, BWG)); to manage alternative investment funds (AIF) under the Austrian Alternative Investment Fund Managers Act (AIFMG) in connection with Section 3 (2) line 31 InvFG (Section 4 (1) AIFMG); to provide investment advice with regard to financial instruments (Section 5 (2) line 4 lit a InvFG 2011); to manage individual portfolios (Section 5 (2) line 3 InvFG 2011); to manage independent assets and all transactions tied to the management of capital investment funds, especially the performance of our contracts with you, the execution of your instructions, and the performance of pre-contractual measures.

The purpose of data processing is primarily limited to the specific product (e.g. capital investment fund [UCITS, AIF], brokerage) and may encompass portfolio management, portfolio support, consultation and marketing.

The specific details relating to the purpose limitation of data processing addressed here are specified in the individual contractual documentation and terms and conditions (where applicable).

To fulfil legal obligations (Article 6 (1) lit c GDPR)

The processing of personal data may also be required for the purpose of fulfilling various legal requirements (such as under the Austrian Banking Act, the Act on Financial Markets Money Laundering, the Austrian Securities Supervision Act, the Austrian Investment Fund Act, the Alternative Investment Fund Manager Act, etc.) as well as on the basis of regulatory stipulations (e.g. by the European Central Bank, the European banking regulator, the Austrian Financial Market Authority, etc.) which govern Raiffeisen KAG as an Austrian credit institution. Examples of these include:

  • suspicious activity reports to the Austrian Financial Intelligence Unit (Section 16 of the Financial Markets Anti-Money Laundering Act (FM-GwG))

  • providing information to the FMA in accordance with the Securities Supervision Act (WAG)

  • providing information to financial crime authorities within the framework of financial criminal proceedings for intentionally-committed financial crimes

  • evaluation and control of risks

Within the framework of your consent (Article 6 (1) lit. a GDPR)

If you consented to our processing your personal data subject to a purpose limitation (e.g. forwarding data to the recipients named in the consent, subscription of newsletter), your data will be processed only in accordance with the purposes established in the declaration of consent and subject to the scope agreed therein. Any consent issued may be withdrawn anytime with future effect.

To preserve legitimate interests (Article 6 (1) lit f GDPR) generally

Where required, data processing may be pursued in consideration of interests that benefit Raiffeisen KAG or third parties in order to preserve legitimate interests. The following cases constitute data processing that is required to preserve legitimate interests. Examples of these include:

  • the review and optimization of processes to analyze requirements as well as the direct approach of customers

  • certain telephone recordings (telephone conversations regarding fund management)

  • measures to control business transactions and to improve services and products

  • measures to protect customers and employees and the Company’s property

  • measures to prevent and to combat fraud (Fraud Transaction Monitoring), to combat money laundering, the financing of terrorism and crimes that expose assets to risks

  • data processing for the purpose of prosecution

  • the enforcement of legal claims and the defense in the event of legal disputes

  • guaranteeing IT security and IT operation of the Company

  • preventing and solving criminal offences

To preserve legitimate interests (Article 6 (1) lit f GDPR) in the marketing of our services

The analysis of data processed at the Company for the purpose of

  • providing or transmitting individual information and offers of the company to you;

  • developing services and products which target your specific interests and life situations; and

  • improving the user experience of their service facilities like apps and more;

is based on our legitimate interest in the marketing of our services. Data will only be analyzed for this purpose until you object to it.

The following data which the company autonomously collected or which you transmitted to the Company, will be analyzed for this:

Personal data / master data
Gender, title, family name, date of birth, country of birth, nationality, marital status, tax status, vocational training, profession, employer, proof of identity e.g. driver’s license data, income data, address and other contact data e.g. telephone number or e-mail address and postal address, GPS information, securities risk class according to investor profile, living situation as in renter or owner of an apartment or house, family relationships (excluding the personal data of these data subjects), number of persons living in the same household, information disclosed during a consultation e.g. hobbies and interests or planned purchases and car, household invoices, internal rating categories like the analysis of income and expenses situation and asset and liabilities situation by the Company.

Data from services, website and communication (also refer to “additional information for using our website”)
Data for the use of electronic services and Internet pages; functionalities of the Internet pages and apps and e-mail messages between yourself and the Company; information about reputable Internet sites or content and prompted links inclusive of third-party websites; information about response times to content or download errors and the period of use of Internet sites and information on the use of and about the subscription to Company newsletters. This information will be recorded using automated technology like cookies or via web tracking (recording and analyzing the surfing behavior) on the website and using third-party service providers or software (for example, Google Analytics).

Data on user-generated content (also refer to “additional information for using our website”)
Information uploaded to Internet sites or apps of the Company, such as comments or personal posts and photos or videos or similarly.

Who receives my data?

Within the Company, those offices or employees will receive your data who require them to fulfill contractual, legal and/or regulatory obligations and legitimate interests. Moreover, commissioned data processors under contract will receive your data (especially IT and back-office service providers) only if these data are required for them to perform their respective service. All data processors are bound by contract to treat your data confidentially and to process them exclusively in the context of their service delivery performance.

If a legal or regulatory obligation applies, public agencies and institutions (European Banking Supervisors, European Central Bank, Austrian National Bank, Austrian Financial Market Supervisory Authority, financial authorities, etc.) and our bank’s auditor and annual auditors may be the recipients of your personal data.

With regard to forwarding data to other third parties we wish to point out that the Company, as an Austrian credit institution, is obliged to observe banking secrecy obligations pursuant to Section 38 BWG and therefore is obliged to maintain secrecy on all customer-related information and facts which were entrusted to us or made accessible to us by virtue of the account relationship. We therefore may only forward your personal data if you explicitly released us in writing and in advance from the banking secrecy obligation or if we are obliged or authorized by law or due to regulatory provisions to do so. The recipients of personal data in this context may include other credit institutions or financial institutions or similar establishments. We transfer data which we require from you for the performance of the account relationship. Depending on the individual agreement, these recipients may include, for example, correspondent banks, stock exchanges, custodian banks or other undertakings affiliated with the Company (by virtue of official or statutory obligation).

Additional data recipients may include those departments for which you issued the respective consent to us (consent to the processing of data, exemption from banking secrecy obligation).

Is data transferred to a third country or an international organization?

Data will only be transferred to third countries (countries outside the European Economic Area - EEA) if this is necessary for the execution of your orders (e.g. payment or securities orders), if it is required by law or if you have given your consent.

In addition, data may be transferred to the company’s subsidiaries or processors in third countries or to sub-processors of the company’s processors in third countries. Such processors are obliged to comply with European data protection and security standards. Please contact us if you require further information on this matter.

What is the storage period for my data?

We process your personal data, insofar as is necessary, for the duration of the entire account relationship (from initiation to processing until termination of a contract) and, beyond this, according to statutory retention and documentation obligations as stipulated, among others, by the Austrian Business Code (UGB), the Austrian Federal Fiscal Code (BAO), the Austrian Banking Act (BWG), the Austrian Financial Markets Anti-Money Laundering Act (FM-GwG), the Austrian Investment Fund Act and the Austrian Securities Supervision Act (WAG).

Moreover, the storage period must take into consideration the statutory periods of limitation which, according to the Austrian Civil Code (Allgemeines Bürgerliches Gesetzbuch, ABGB) may be up to 30 years in certain cases (the most commonly referred to period of limitation in practice is 3 years).

Which data protection rights do I have?

You have the right of access to your information, the right to rectification, the right to erasure or the right to restrict the processing of your personal data, the right to object to the processing as well as the right to data portability in accordance with the requirements stipulated under data protection laws. If you wish to exercise your rights, please contact kag-info@rcm.at or our data protection officer.

Complaints may be lodged with the Austrian Data Protection Authority, Barichgasse 40–42, 1030 Vienna, www.dsb.gv.at.

Am I obliged to provide data?

Within the context of the account relationship you must provide such personal data as is necessary for the account relationship to commence and to be performed, the collection of which we are obliged to pursue by law. If you do not provide said data to us, we will reject the formation of the contract or the performance of the contract in general, or will no longer be able to perform the existing contract and consequently, will have to terminate it. However, you are not obliged to issue your consent to the processing of data which are irrelevant or not required by law or regulatory provisions in relation to the fulfilment of the contract.

Is there any automated decision-making?

To substantiate and perform the account relationship, we do not use fully-automated decision-making methods in principle as laid down in Article 22 GDPR. Should we apply these methods in the individual case, we will inform you separately of this, provided this is required by law.

Additional information for using our website

a) Cookies
Our websites uses Cookies. Cookies are text files, which are saved during the visit on your terminal. We mainly use Cookies for anonymized analysis about the use of the website. We also use Cookies to offer you additional functions on the website in order to interact easier with the website and to ensure an error-free use (e.g. to facilitate navigation on a website or to save your preferences and settings for your next visit)

Functionality cookies: These cookies are necessary for the basic functions of the website and make it possible to present our content to you and to save your user settings and preferences (e.g. saving your entries in form fields in order to prevent them from being lost). These cookies assign a randomly generated ID to your browser. Data processing occurs on the basis of our legitimate interest in the secure design and convenient use of our content and generally for the provision of our services on the specific website visited. No information is collected about you for the purposes of marketing or statistics. In addition, we can use information for the purposes of fraud prevention and defending against denial of service attacks. This category of cookies cannot be deactivated.

Analytical cookies: This is immediately anonymised information that provides us with insight into the usage, functionality, and user friendliness of websites and apps as well as to market and continuously improve our content. This information is analysed for the purposes of measuring reach and performance: These cookies provide us with information about the number of visitors to the website and page requests as well as the usage behaviour of the visitors to a website or app (e.g. what time the site is accessed most or which pages are visited most frequently). This gives us information that we use to optimise our content with regard to particular interests of our users. We also use these functions to place our content in a targeted manner. This processing occurs until you submit an objection to such processing.

Personal cookies: We use personal cookies as a way to improve the effectiveness and organisation of this website. In particular, we employ cookies with save and remember functions for this purpose. This processing only occurs when consent is granted and for a maximum period of one year/three years as long as this consent is not revoked. The revocation of consent has no effect on the legality of the data processing performed on the basis of the previously granted consent up to the time of revocation.

Cookies can be blocked, deactivated or deleted. Therefore, a variety of different tools are available (including browser controls and settings). You can find information hereto in the “help area” of the web browser you use.

b) Online social media presence
Our online presences in social networks or on platforms serve the communication and information of interested parties or customers. As a rule, user data is processed for market research and advertising purposes, e.g., to create usage profiles. These usage profiles can be used, among other things, to place advertisements that correspond to the user's interests. Cookies are stored on the user's computer for this purpose, with the help of which the user's usage behavior and interests are stored. In addition, user data can also be stored in the usage profiles across devices (this primarily concerns users who are logged in to the relevant platform). It is possible for us to place target group-oriented advertising and to perform an anonymized analysis of the use of our online presence.

The processing of users' personal data is based on your consent (a declaration of consent, e.g., by activating a checkbox or confirming a button). Below you will find details and information on possible data transfers to third countries (countries outside the European Union - EU or the European Economic Area - EEA) based on the provider information on processing and objection options.

c) JavaScript und Zählpixel
On our website, technically necessary cookies and other standard web control elements are used in particular to control and improve our Internet presence (JavaScript and tracking pixels). All data is collected anonymously. This allows us to collect information in order to check for which screen sizes, browsers and operating systems our website should be optimized. JavaScript is a programming language used to evaluate user interactions and to change, reload or generate content.

d) Anonymous statistical evaluation
For anonymous statistical evaluation and extended security precautions during visits to our website, we use services of the company JENTIS GmbH, Schönbrunner Straße 231, 1120 Vienna ("JENTIS"). For this purpose, data is transmitted to JENTIS, which JENTIS evaluates on our behalf in anonymized form. This means that JENTIS GmbH only processes data that cannot be traced back to an identifiable person. In addition, we use JENTIS to anonymize your personal data before transferring it to a third country, thus protecting your data. You can view the data protection provisions of JENTIS at the following link: https://www.jentis.com/privacy-policy/"

e) Google Analytics
This website uses Google Analytics, a web analytics service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies, which are saved on your computer. We process your data based on our legitimate interest in setting up easy-to-use website access statistics (Art 6 (1) (f) GDPR). The information generated by the Cookie about your use of this website (including your anonymized IP address and pseudonymized ID as well as the URLs of the websites accessed) is transmitted to and stored by Google on servers in the USA. This website uses the given opportunity for IP-anonymization by Google Analytics. Your IP address will be shortened by Google within the member states of the European Union or in other signatory states to the Agreement on the European Economic Area.

By using the company JENTIS GmbH, your personal data is anonymized before a potential transfer to a third country. Google thus only receives information that does not allow any conclusions to be drawn about you.

On our behalf Google will use this information, to evaluate the use of the website, to create reports about the website activities and to provide us with other services related to the use of the website and the internet.

You can prevent the general storage of Cookies by adjusting your browser software accordingly. However we point out that in this case you may not be able to use all functions of this website to their full extent.

You can also prevent Google from collecting your data in connection with Google Analytics by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de

In connection with Google Analytics, we also use Google Tag Manager. Google Tag Manager is another Google solution that allows companies to manage website tags via a single interface. Google Tag Manager is a domain without cookies that does not collect any personal data. Google Tag Manager triggers other tags, which in turn may collect data. We hereby expressly advise you of this fact. However, Google Tag Manager does not access this data. If users have opted out at domain or cookie level, this opt-out remains in place for all tracking tags implemented via Google Tag Manager.

For more information on Google's Terms of Use and Google's Privacy Policy, please visit http://www.google.com/analytics/terms/de.html, https://policies.google.com/privacy/partners?hl=de or https://www.google.at/intl/at/policies/.

f) YouTube-Videos
We have embedded YouTube videos on our website, which are stored on "www.youtube.com" and can be played directly from our website. These are all embedded in the so-called "extended data protection mode", which means that no data about you as a user is transmitted to YouTube if you do not play the videos. Only when you play the videos are YouTube cookies stored on your terminal device and data transmitted to Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as YouTube operator. When playing videos stored on YouTube, at least the following data is transmitted to Google Ireland Limited: IP address and cookie ID, the specific address of the page called up from us, the language setting of the browser, the system date and time of the call-up and the identifier of your browser. The data transfer takes place regardless of whether you have a user account with Google, via which you are logged in, or whether there is no user account for you. If you are logged in, this data is directly assigned to your account. If you do not want the assignment to your profile, you must log out before activating the button. YouTube or Google Ireland Limited stores this data as usage profiles and uses it for purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (also for users who are not logged in) for the provision of needs-based advertising and to inform other users about your activities on our website. You have the right to object to the creation of these user profiles, and to exercise this right you must contact Google Ireland Limited as the operator of YouTube. For more information on the purpose and scope of data collection and its processing by Google Ireland Limited, please visit www.google.at/intl/de/policies/privacy. We do not process the data concerned.

g) Newsletter
You have the option to subscribe to our newsletter through our website. For this, we require your e-mail address and your declaration that you consent to the subscription of the newsletter. The consent to the processing of data and forwarding of electronic mail can be withdrawn anytime without having to meet specific formal requirements by using the unsubscribe link forwarded to you by e-mail. You may request the above link by letter sent to Raiffeisen Kapitalanlage-Gesellschaft m.b.H., Mooslackengasse 12, 1190 Vienna, or by e-mail sent to kag-info@rcm.at. Your withdrawal does not affect the lawfulness of any data processing and data forwarding carried out by virtue of a consent that was issued prior to the receipt of said withdrawal. Immediately after we will erase your data tied to the forwarding of the newsletter.

h) "Meine Vermögensverwaltung", "Institutional area"
Certain areas of the website are available to registered users only. By sending the online registration form you confirm that the data that you provided is complete and correct or that you answered the questions asked in the form truthfully. The password-protected online access is only available to our institutional clients and portfolio management clients. You must request your access separately through our homepage or your personal advisor.
You may cancel the online access anytime. To do so, please send your cancellation to the following e-mail address: kag-info@rcm.at, or by letter sent to Raiffeisen Kapitalanlage-Gesellschaft m.b.H., Mooslackengasse 12, 1190 Vienna. Your withdrawal does not affect the lawfulness of any data processing and data forwarding carried out by virtue of a consent that was issued prior to the receipt of said withdrawal. Immediately after we will erase your data tied to logging on to our homepage.

i) Kontaktformular
On our website there is contact form. If you contact us via the form on the website or by e-mail, the data you provide and transmit will be stored by us for the purpose of processing the inquiry and any follow-up questions for a maximum of twelve months. This is done in pursuit of our legitimate interest in offering you the best possible service and providing you with means of exchanging information with us. Should you not wish your data to be passed on and/or stored in this way, please send your respective objection to: Please send your withdrawal of consent to the following e-mail address: kag-info@rcm.at or by letter to Raiffeisen Kapitalanlage-Gesellschaft m.b.H., Mooslackengasse 12, 1190 Vienna, Austria

j) Protokollierung am Webserver
Every time a user accesses our website and every time a file is retrieved or attempted to be retrieved from the server, data about this process is stored in a log file. For us it is not directly recognizable, which user called upon which data. We also do not try to collect this information. This would only be possible in legally regulated cases and with the help of third parties (e.g. Internet service providers). In detail, the following data record is stored for each retrieval: The IP address, the name of the downloaded file, the date and time of the download, the amount of data transferred, the message as to whether the download was successful and the message as to why a download may have failed, the name of your Internet service provider, if applicable the operating system, the browser software of your computer and the website from which you are visiting us.

The legal basis for the processing of personal data is our legitimate interest (in accordance with Art 6 (1) (f) GDPR). This is to detect, prevent and investigate attacks on our website. In addition, we process your personal data in special cases on the basis of the legitimate interests of us or legitimated third parties for legal proceedings or on behalf of legally authorized authorities or courts.
We generally store data for a period of three months to guarantee the security of our homepage. A longer storage only takes place as far as this is necessary to investigate determined attacks on our website or to pursue legal claims.

For the above-mentioned purposes, we have your personal data processed by the following service providers: Raiffeisen Informatik GmbH & Co KG and RAITEC GmbH.

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