Privacy Policy

1) Introduction and contact details of the data controller

1.1 We are pleased that you are visiting our website and thank you for your interest. Below we inform you about the handling of your personal data when using our website. Personal data means any data by which you can be personally identified.

1.2 The data controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is FinEase Financial Service GmbH, Karlstraße 13, 35641 Schöffengrund, Germany, Email: info@finease-fs.de. The data controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) Data collection when visiting our website

2.1 When using our website for informational purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect the data that your browser sends to our server (so-called "server log files"). When you access our website, we collect the following data, which is technically necessary for us to display the website to you:

The website of ours that you visited
Date and time of access
Amount of data sent in bytes
Source/referrer from which you reached the page
Browser used
Operating system used
IP address used (if applicable: in anonymised form)

Processing is carried out in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or used in any other way. However, we reserve the right to check the server log files subsequently if there is concrete evidence of unlawful use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or enquiries to the controller). You can recognise an encrypted connection by the string "https://" and the lock symbol in your browser bar.

3) Hosting & Content Delivery Network

We use a provider for hosting our website and displaying its content that provides its services exclusively on servers within the European Union, either itself or through selected sub-contractors.

All data collected on our website is processed on these servers.

We have concluded a data processing agreement with the provider that ensures the protection of our site visitors' data and prohibits unauthorised disclosure to third parties.

4) Cookies

To make visiting our website attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your device. Some of these cookies are automatically deleted again when you close your browser (so-called "session cookies"), while others remain on your device for a longer period and allow us to save page settings (so-called "persistent cookies"). In the latter case, you can find out the storage period from the overview in your web browser's cookie settings.

If personal data is also processed by individual cookies we use, processing is carried out in accordance with Art. 6(1)(b) GDPR for the performance of the contract, in accordance with Art. 6(1)(a) GDPR in the case of consent given, or in accordance with Art. 6(1)(f) GDPR to safeguard our legitimate interests in the best possible functionality of the website and a user-friendly and effective design of your visit.

You can set your browser so that you are informed when cookies are set and can decide individually whether to accept them or to exclude the acceptance of cookies in certain cases or in general.

Please note that if you do not accept cookies, the functionality of our website may be limited.

First-party registration attribution (URL parameters and browser storage)

If you open our registration page with certain URL parameters or sign up through it, we process the following information to attribute your sign-up to marketing and acquisition channels and to our own-platform referral and partner programmes (this is separate from the external third-party affiliate networks in section 8):

entry – indicates the product entry/funnel (e.g. quiz, how-to-study, newsletter signup). The value is stored in localStorage under the key gfs_entry_source (limited retention, currently up to 30 days).
ref – referral code under our student referral programme. parref – identifier of a referral or affiliate partner on our platform. Whichever value is present (ref and/or parref) is stored in the gfs_referral cookie and additionally in localStorage under gfs_referral_code.
gfs_origin – internal source from email campaigns or CTAs (e.g. nurture email, study-guide link) to document the internal touchpoint.
utm_source, utm_medium, utm_campaign, utm_term, utm_content – campaign parameters. They are only stored persistently in the gfs_referral cookie if you consent to Statistics or Marketing in the cookie settings. If you give consent, they may also be stored together with gfs_origin in sessionStorage (key gfs_attribution_session) for up to the current browser session; with immediate sign-up, typically until registration.

The legal basis for processing ref, parref and entry in connection with registration and use of the platform (referral/partner attribution, entry funnel) is Art. 6(1)(b) GDPR (contract / pre-contract). UTM parameters and gfs_origin are only processed in cookies, localStorage or sessionStorage as described above if they are not strictly required for performance of the contract – in that case only if you consent to Statistics or Marketing; the legal basis is then Art. 6(1)(a) GDPR. Further details are shown in the cookie banner and in section 4 above.

5) Contact

When you contact us (e.g. via contact form or email), personal data is processed – solely for the purpose of handling and responding to your request and only to the extent necessary for that purpose.

The legal basis for processing this data is our legitimate interest in responding to your request in accordance with Art. 6(1)(f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6(1)(b) GDPR. Your data will be deleted when it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations.

6) Data processing when opening a customer account

6.1 In accordance with Art. 6(1)(b) GDPR, personal data will continue to be collected and processed to the extent necessary if you provide it to us when opening a customer account. You can see which data is required for opening an account from the input mask of the relevant form on our website.

Deletion of your customer account is possible at any time and can be done by sending a message to the controller's address given above. After deletion of your customer account, your data will be deleted unless all contracts concluded have been fully executed, no statutory retention periods apply and we have no legitimate interest in further storage.

6.2 Data transfer to our product partners

For the purpose of contract mediation, your data is transferred to the respective product partner whose offer you have selected via the relevant product page of our platform and whose identity is evident from the respective offer, in accordance with Art. 6(1)(b) GDPR. The product partner processes the transmitted data for the purpose of handling your application. After the transfer, the product partner is responsible for the further processing of your data.

7) Use of customer data for direct marketing

7.1 Subscription to our email newsletter

When you subscribe to our email newsletter, we send you regular information about our offers. The only mandatory information for sending the newsletter is your email address. Providing further data is voluntary and is used to address you personally. For sending the newsletter we use the double opt-in procedure, which ensures that you only receive newsletters once you have expressly confirmed your consent to receive them by clicking on a verification link sent to the email address provided.

By activating the confirmation link, you give us your consent for the use of your personal data in accordance with Art. 6(1)(a) GDPR. We store the IP address entered by your internet service provider (ISP) as well as the date and time of registration in order to be able to trace any misuse of your email address at a later date. The data collected when you subscribe to the newsletter is used strictly for the intended purpose.

You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a message to the controller mentioned above. After unsubscribing, your email address will be deleted from our newsletter distribution list without delay, unless you have expressly consented to further use of your data or we reserve the right to use your data for other purposes that are permitted by law and about which we inform you in this statement.

7.2 Sending the email newsletter to existing customers

If you have provided us with your email address when purchasing goods or services, we reserve the right to send you regular offers by email for similar goods or services to those already purchased from our range. We do not need to obtain separate consent from you for this in accordance with § 7(3) of the German Unfair Competition Act (UWG). Data processing is carried out solely on the basis of our legitimate interest in personalised direct marketing in accordance with Art. 6(1)(f) GDPR. If you initially objected to the use of your email address for this purpose, we will not send you any emails.

You are entitled to object to the use of your email address for the aforementioned advertising purpose at any time with effect for the future by notifying the controller mentioned at the beginning. You will only incur the transmission costs according to the basic rates. After we receive your objection, the use of your email address for advertising purposes will be discontinued without delay.

7.3 ActiveCampaign

Our email newsletter is sent via this provider: ActiveCampaign, LLC, 150 N. Michigan Ave Suite 1230, Chicago, IL, USA

On the basis of our legitimate interest in effective and user-friendly newsletter marketing, we pass on the data you provided when registering for the newsletter to this provider in accordance with Art. 6(1)(f) GDPR so that it can send the newsletter on our behalf.

Subject to your express consent in accordance with Art. 6(1)(a) GDPR, the provider also carries out a statistical analysis of the success of newsletter campaigns by means of web beacons or tracking pixels in the emails sent, which can measure opening rates and specific interactions with the newsletter content. Device information (e.g. time of access, IP address, browser type and operating system) is also collected and evaluated, but not merged with other data.

You can revoke your consent to newsletter tracking at any time with effect for the future.

We have concluded a data processing agreement with the provider that protects our site visitors' data and prohibits disclosure to third parties.

For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with European data protection standards on the basis of an adequacy decision by the European Commission.

8) Online marketing

8.1 ADCELL partner programme (affiliate)

We participate in the affiliate programme of the following provider: Firstlead GmbH, Rosenfelder St. 15-16, 10315 Berlin, Germany