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MainFirst Affiliated Fund Managers (Deutschland) GmbH (hereinafter known as MainFirst, you can find information about MainFirst here. is pleased that you are visiting our web site. Data protection and data security when using our web site are very important for us. We would therefore like to provide you with information at this juncture as to which of your personal data we collect when you visit our web site and the purposes for which such information is used.
Since changes in the law or changes in our internal company systems could render it necessary to amend this data protection statement, we would ask you to read through this data protection statement on a regular basis. The data protection statement may be downloaded at any time from, then saved and printed out.   

§ 1 The body responsible and scope of validity 

For the purposes of the EU General Data Protection Regulation (hereinafter known as DSGVO) and other national data protection regulations of the member states plus other data protection rules the responsible body is: 

MainFirst Affiliated Fund Managers (Deutschland) GmbH
Kennedyallee 76
60596 Frankfurt am Main
T.: +49 69 2443744 00

This data protection statement shall apply for the online content of MainFirst, which can be downloaded from the domain as well as various sub-domains (hereinafter known as "our website").

§ 2 Data Protection Officer 

The external data protection officer of the body responsible is:

External data protection officer of MainFirst Affiliated Fund
Managers (Deutschland) GmbH
Herr Rechtsanwalt Dr. Karsten Kinast, LL.M. 
KINAST Rechtsanwaltsgesellschaft mbH 
Hohenzollernring 54 
D-50672 Köln 
Tel.: +49 (0)221 – 222 183 – 0 
E-Mail: mail(at)  

§ 3  What are personal data? 

Personal data are information that could be used to identify personal or factual information about you (e.g. name, address, telephone number or email address). Data with which it is not possible to identify you (or only with a disproportionate level of effort), e.g. through the anonymisation of data, are not classed as personal data.

§ 4 What personal data do we collect, process and use? 

It is possible to use the majority of our online presence without providing personal data.
Only data without personal references will be stored, e.g. the name of your Internet service provider, the website you were referred from, the names of requested files, and their request date. These data are solely for the purposes of improving our services and do not allow conclusions to be made about your person. Nevertheless, it is necessary to provide additional data to the extent that you make use of the services offered by us on our website, such as ordering an Asset Management Factsheet or Newsletter, etc. These concern data required for each procedure, such as the email address provided in order to subscribe to a newsletter.
We use data about you collected by us for the provision of our products and services, to respond to your inquiries, and in the operation and improvement of our websites and applications. In the case of the use our contact form, or if you sign up to receive our Asset Management Newsletter and Factsheet, your personal data is only used by us for the provision of the requested service. Further use of your personal data will not take place.
Your personal data is not disclosed to third parties, or a use of your data for promotional purposes without your consent, except the cases described below, will not take place unless we are legally obliged to disclose data (provision to prosecuting authorities and courts, provision to public bodies that receive these data by law, e.g. social insurance agencies, financial authorities, etc.), or in the case that we turn to third parties who are bound to professional secrecy. In particular, personal data will be used for the following purposes:

a)     Newsletter 
To subscribe to our email-based Asset Management Newsletter and Factsheet Service (hereinafter referred to as "Newsletter"), alongside your consent we require at least your email address to which the newsletter should be sent, and your name. Any additional information is optional and will be used to contact you personally and to personally tailor the contents of the Newsletter, as well as to clarify questions concerning your email address. You are free to decide whether to provide these data. However, without these data, it will not be possible to send you our Newsletter. 
For the purpose of sending out the Newsletter, we generally use the so-called “double opt-in process”, whereby we only send you the Newsletter if you have previously confirmed your subscription via a link for this purpose contained in the confirmation email. Here, we hope to ensure that only you, as the owner of the email address, have consented to receiving the Newsletter. Your confirmation to this effect be carried out promptly after receipt of the confirmation email, otherwise your subscription to the Newsletter will be automatically deleted from our database.
Following subscription to our Newsletter, your email address will be used for promotional purposes until you unsubscribe. To unsubscribe, you can either send an informal email to unsubscribe(at) or use the link at the bottom of the newsletter. 

b)     Contact form 
If you direct inquiries to us via our contact form, we will ask you for your first and last name, and your email address. You can then direct individual inquiries to us via the message field.
You are free to decide whether to provide these data. However, without this information, we will not be able to fulfill your contact request.

§ 5   User profiles / Use of cookies 

Except in the cases mentioned above, we do not create personal user profiles. In connection with the retrieval of information requested by you, exclusively anonymous data for the provision of our various services, or for evaluation purposes, will be stored on our servers. In doing so, general information will be recorded, such as which specific content from our range of services is being requested when, or which pages are visited most frequently.
Our website uses "cookies" (small text files containing configuration information). Cookies are small text files that are sent from our web server to your browser during your visit to our website, and they are retained on your computer for later retrieval.  We exclusively use so-called session-cookies (also known as temporary cookies), which are stored only for the time that you use one of our websites.  
The cookies are used in particular to determine the frequency and number of users of our websites, and to identify your computer during a visit to our website when changing from one of our websites to another, as well as determining when your visit has ended. In this way, we can determine which area of our websites as well as which other websites our users have visited. However, these usage data does not enable conclusions to be drawn about the user. In accordance with §3 of this Privacy Policy, none of these anonymously collected usage data will be merged with your personal data. Moreover, they will be deleted immediately following statistical analysis. After the session, these cookies are deleted as soon as you have finished your browser session.
Most browsers are pre-set to accept cookies automatically. However, you can deactivate the storage of cookies or set your browser to notify you before accepting cookies. Users who do not allow cookies may not be able to access certain areas of our websites. 

§ 6   Integration of the Xing plugin 

We would like to take this opportunity to inform you about the processing of personal data via the function of the "XING button" that is used on this website. Calling up this website briefly connects your browser with the servers of XING AG (hereafter "XING") that deliver the functions for the XING button. XING stores no personal information about you when you connect to this website. In particular, XING does not store your IP address. There is also no evaluation of your user behaviour through the use of cookies in connection with the "XING share button". The current data protection information concerning the "XING share button", together with additional information, is available on the following website: and

§ 7    Integration of the LinkedIn plugin 

Also integrated into our website are plugins of the social network LinkedIn, of LinkedIn Corporation (hereafter: "LinkedIn"). The LinkedIn plugin is indicated on our website by the LinkedIn logo. When you visit our pages, the plugin establishes a direct connection between your browser and the LinkedIn server. In this way, LinkedIn is informed of your visit to our website and receives your IP address. If you click on the LinkedIn "Recommend" button while logged into your LinkedIn account, you can link to the contents of our pages on your LinkedIn profile. Thereby, LinkedIn is able to assign your visit to our website to your user account. Please note that we, as provider of the website, do not receive any information through LinkedIn about the content of submitted data, nor their use.
Further details of data retention (purpose, scope, further processing, use), as well as details of your rights and ability to set preferences, can be derived from the details regarding the data privacy of LinkedIn, available at: 

§ 8   Google Analytics 

This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies", text files that are stored on your computer to assist in the analysis of how users use the website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. 
In the case of activation of IP anonymisation on this website, your IP address will be truncated by Google within the area of Member States of the European Union or in other countries which are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the United States and truncated there.  Please note that on this website, Google Analytics has been supplemented by the code "gat._anonymizeIp();" in order to ensure anonymised collection of IP addresses (so-called "IP masking").
On behalf of the website operator, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and Internet usage. The IP address used by your browser within the scope of Google Analytics will not be associated with any other data held by Google.
You may refuse the use of cookies by selecting the appropriate settings in your browser software. However, please note that if you do this, you may not be able to use the full functionality of this website.
Furthermore, you can prevent the collection of data generated by the cookie and related to the use of the website and the processing of these data by Google by downloading and installing the browser plugin, which is available under the following link: 
As an alternative to this browser plugin, or within browsers on mobile devices, you can also opt out from being tracked by Google Analytics by clicking the following link: deactivate Google Analytics
An opt-out cookie will then be set that will prevent your data from being collected in future when you visit this website. 
For more information, please see or (general information on Google Analytics and data protection).

§ 9    Use of YouTube videos 

We use embedded YouTube videos in extended data protection mode. YouTube is a service provided by Google Inc. 

YouTube provides this extended data protection mode and thus assures that cookies containing personal data will not be stored on your computer. The IP address is transferred when the website is called up and is used for embedding the videos. Provided you have not logged in with YouTube or another Google service prior to calling up the website, or are not permanently logged in, this IP address cannot be assigned.
As soon as you watch an embedded video by clicking Play, YouTube, by means of the extended data protection mode, will only store cookies that do not contain any personal data on your computer. These cookies can be prevented by corresponding browser settings and add-ons. (Source: YouTube "Enabling privacy-enhanced mode for embedded videos").
Additional information on including YouTube videos can be found on YouTube’s information page. 

§ 10  Using Google Ads (Remarketing/Similar Audiences) 

Our website uses the Google Ads service. Google Ads is an online advertising program of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). By using it we use the remarketing feature within the Google Ads service. The remarketing feature allows us to show users of our website ads that are based on their interests while they are browsing on other sites within the Google Display Network (on Google itself, so-called “Google Ads”, or on other websites). For this purpose, the interaction of the users on our website is analysed in order to be able to show users targeted advertising on other sites, even after they have visited our website. Google stores a number in the browsers of users who visit certain Google services or websites on the Google Display Network. This number, referred to as a “cookie”, records the visits of these users. This number acts as a unique identification of a web browser on a particular computer and not as a means to identify a person. Personal data is not stored. Cookies are stored for 14 months. You may disable the use of cookies by Google by following the link below and downloading and installing the plug-in provided there: More information about Google Remarketing and Google's Privacy Policy can be found here:

§ 11   Hyperlinks to external websites  

Included in our website are so-called hyperlinks to other websites. When activating these links, you are forwarded directly from our website to the website of the other provider. You can recognise this, for instance, when there is a change of the URL. We cannot take responsibility for the strictly confidential handling of your data on these external websites, as we have no control over whether these companies comply with data protection regulations. Please obtain information on the handling of your personal data by these companies on their websites directly.

§ 12 Rights of the parties concerned

The DSGVO gives rise to the following rights for you as a person affected by the processing of personal data:

- In accordance with Article 15 DSGVO you may request information about your personal data we have processed. In particular you may request information about the reasons for it being processed, the categories of personal data processed, the categories of recipients to whom your data has been, or will be, disclosed, the intended length of time over which it is intended to save your data, the existence of your right to have personal data held by us about you corrected or deleted, the scope of processing restricted or your right to object to your personal data being processed, about the existence of a right to lodge a complaint, about where your data was sourced insofar as it was not collected by us, about the transmission of your personal data to third countries or to international organisations as well as about the existence of an automated decision-making process including profiling system and meaningful information, if there is any, about the details of such systems.

- In accordance with Article 16 DSGVO you may request that your personal data stored by us which is incorrect or incomplete is corrected straight away.

- In accordance with Article 17 DSGVO you may request that your personal data stored by us is deleted, provided that it does not have to be processed for you to exercise your right to freedom of expression and information to fulfil a legal obligation, for public interest reasons or to assert, exercise, or mount a defence against, legal claims.

- In accordance with Article 18 DSGVO you may request that the processing of your personal data stored by us is restricted, insofar as the accuracy of the data is contested by you, processing is unlawful, we no longer need the data and you refuse to allow it to be deleted since you need to have this data to assert, exercise, or mount a defence against, legal claims. You will also be entitled to the right under Article 18 DSGVO if, in accordance with Article 21 DSGVO you have lodged an objection to your personal data being processed. 

- In accordance with Article 20 DSGVO you may request that your personal data which you have passed over to us is returned to you in a structured, common format which can be read by a computer or you may request that such data is sent to another responsible body.

- In accordance with Article 7 Para 3 DSGVO you may revoke the consent you have already granted to us at any time. The consequence of this will be that we shall no longer be allowed to continue processing data based upon this consent in the future.

- In accordance with Article 77 DSGVO you will be entitled to lodge a complaint with a supervisory authority. As a rule you may wish to contact the supervisory authority responsible for your normal place of residence, place of work, or for our Company’s principal place of business.

§ 13   Withdrawal / Objection 

You may have given your explicit consent to the following text. We would like to point out that you have the right to withdraw your consent with effect for the future, and may object to the processing and use of your data for advertising purposes at any time: Please contact unsubscribe(at)  

a)     Authorisation to send the Newsletter / Factsheet 
( ) Yes, I would like to regularly receive the selected information from MainFirst, which will be sent to my email address. I can unsubscribe from the service at any time by clicking the "Unsubscribe" link at the bottom of the Newsletter, or via unsubscribe(at)

§ 14   Information about your personal data we store / Storage duration / Deletion 

We only store your personal details with us inasmuch as this is permitted by law. The deletion of stored personal data will follow if you revoke your consent to the storage, if the knowledge of the data is no longer required in order to fulfill the intended purpose, or if the storage is inadmissible for other legal reasons.
At your request, we will be happy to inform you of which of your personal data is stored in our system. If incorrect data has been stored despite our efforts to ensure that it is correct and up to date, we will rectify the data immediately at your request. 
You have the opportunity at any time to review, modify or delete the personal data available to us by sending an email to unsubscribe(at) Should you request the deletion of stored data, this deletion at your request will likewise take place immediately. If the deletion is not possible for legal reasons, the respective data will be blocked instead of deleted. However, please note that in the case of the deletion of your data, we will be unable to provide you with the respective services.

§ 15   Safeguards to protect the data stored with us

We commit ourselves to protecting your privacy and treating your personal data with confidence. To avoid any loss or misuse of data stored with us, we take extensive technical and internal security precautions, which are reviewed on a regular basis and updated in line with technical progress. However we wish to point out that, due to the structure of the Internet, the rules of data protection and the above mentioned security measures may be violated by persons or institutions beyond the scope of our responsibility. In particular, data which is sent unencrypted – including via email – can be read by third parties. We do not have any technical influence in this regard. The user is responsible for protecting any data provided against misuse by means of encryption or any other method. 

As per 15 April 2019