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Table of Contents

1 General Details
1.1 Purpose and Accountability
1.2 Legal Bases
1.3 Data Subject Rights
1.4 Data Erasure and Duration of Retention
1.5 Data Processing Security
1.6 Data Transfer to Third Parties, Subcontractors and Third-Party Providers
2 Processing Within the Scope of our Online Offer
2.1 Collection of information from use of the online offer
2.2 DoubleClick
2.3 Facebook Pixel (Facebook Custom Audience)
2.4 Google AdServices
2.5 Google AdWords Conversion
2.6 Google Analytics
2.7 Google Fonts
2.8 Google Tag Manager
2.9 Links to Other Websites
3 Processing for the Purpose of Conducting our Business Processes
3.1 Contact Form and Contact by Email
3.2 Direct Marketing
3.3 Existing Customer Advertising
3.4 Answering Project Enquiries
4 Cookies Policy
4.1 General Information
4.2 Cookies Summary
4.3 Option to Object
5 Changes to the Privacy Policy

1 General Details

1.1 Purpose and Accountability

1. This Privacy Policy provides information about the type, scope, and purpose of the processing of personal data in relation to our online offer and the associated websites, functions, and content (hereinafter jointly referred to as “online offer” or “website”).

2. The provider of the online offer and data controller is adVenture GmbH - hereinafter referred to as the “Provider”, “We” or “Us”.

3. Our Data Protection Officer is "information not available yet"

4. The term “user” includes all customers of and visitors to the online offer.

1.2 Legal Bases

We collect and process personal data based on the following legal bases:

1. Consent gin accordance with Article 6 Paragraph 1 lit. a General Data Protection Regulation (GDPR). Consent is any voluntary, informed, and unequivocal expression of will for a specific case in the form of a declaration or other clear confirmatory action with which the data subject indicates that they agree to the processing of their personal data.

2. Necessity for contract fulfilment or to carry out preparatory measures in accordance with Article 6 Paragraph 1 lit. b GDPR, i.e. the data is required so that We can fulfil our contractual obligations towards you or We need the data to prepare a contract with you.

3. Processing to fulfil a legal obligation in accordance with Article 6 Paragraph 1 lit. c GDPR, i.e. for example, processing of the data is required by law or other regulations.

4. Processing to protect legitimate interests in accordance with Article 6 Paragraph 1 lit. f GDPR, i.e. processing is necessary to protect legitimate interests on our part or on the part of third parties, unless your interests or fundamental rights and freedoms, which require the protection of personal data, prevail.

1.3 Data Subject Rights

You have the following rights about data processing by Us:
1. Right to lodge a complaint with a supervisory authority in accordance with Article 13 Paragraph 2 lit. d GDPR and Article 14 Paragraph 2 lit. e GDPR.
2. Right of access in accordance with Article 15 GDPR
3. Right to rectification in accordance with Article 16 GDPR
4. Right to erasure (“right to be forgotten”) in accordance with Article 17 GDPR
5. Right to restriction of processing in accordance with Article 18 GDPR
6. Right to data portability in accordance with Article 20 GDPR
7. Right to object in accordance with Article 21 GDPR

Notice: Users can object to the processing of their personal data, non-retroactively, in accordance with legal requirements at any time. The objection can be made in particular against processing for direct advertising purposes.

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your place of residence, your place of work or the place of the alleged infringement, if you believe that the processing of your personal data is contrary to the GDPR.

1.4 Data Erasure and Duration of Retention

The personal data of the data subject will be erased or blocked as soon as the purpose of retention no longer applies. Retention may also b required if this has been stipulated by the European or national legislator in EU regulations, laws or other regulations to which the data controller is subject. The data will also be blocked or erased if a retention period stipulated by the standards mentioned expires unless there is a need for further data retention for the conclusion or fulfilment of a contract.

1.5 Data Processing Security

1. We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). This protects the data We process from accidental or intentional manipulation, loss, destruction, and unauthorised access.

2. The security measures include, in particular, encrypted transmission of data between your browser and our server.

1.6 Data Transfer to Third Parties, Subcontractors and Third-Party Providers

1. Our online offer is provided by Amazon Web Services EMEA SARL, Germany (Marcel-Breuer-Straße 12, 80807 Munich, Germany). The location of the AWS server is Germany.

2. When using the online offer, information is automatically transmitted to Us from the user's browser; this includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

3. This information is processed on the basis of legitimate interests in accordance with Article 6 Paragraph 1 lit. f GDPR (e.g. optimisation of the online offer) and to ensure the security of processing in accordance with Article 5 Paragraph 1 lit. f GDPR (e.g. prevention and investigation of cyber attacks).

2 Processing Within the Scope of our Online Offer

2.1 Collection of information from use of the online offer

1. Our online offer is provided by Amazon Web Services EMEA SARL, Germany (Marcel-Breuer-Straße 12, 80807 Munich, Germany). The location of the AWS server is Germany.

4. The information is automatically erased 7 days after the end of the connection - i.e. use of the online offer - provided there are no other retention periods to the contrary.

5. The collection of the data and its retention in log files is absolutely necessary for the provision of the online offer. The user is therefore not entitled to any option of erasure, objection, or rectification.

2.2 DoubleClick

1. DoubleClick by Google is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

2. DoubleClick by Google uses cookies to show you advertisements that are relevant to you. A pseudonymous identification number (ID) is assigned to your browser to check which adverts were displayed in your browser and which adverts were viewed. The cookies do not contain any personal information. The use of DoubleClick cookies only enables Google and its partner websites to place adverts based on previous visits to our or other online websites. The information generated by the cookies is transmitted by Google to a server in the USA for analysis and is stored there. Under no circumstances will Google combine your data with other data collected by Google.

3. More information about DoubleClick by Google and data protection is available here: https://policies.google.com/technologies/ads?hl=de

4. The legal basis for using Doubleclick is your consent in accordance with Article 6 Paragraph 1 lit. a GDPR. You consent to the processing of data about you by Google in the manner described above and for the stated purpose.

2.3 Facebook Pixel (Facebook Custom Audience)

1. We use Facebook Website Custom Audiences on our website and have integrated the so-called Facebook Pixel.

2. This Pixel is used to collect pseudonymous information about the use of this website (e.g. information about the content viewed). The data transmitted by the Pixel can be used to address you with customised advertising on Facebook, provided you have a Facebook account.

3. Further information on the scope and purpose of data collection can be found in Facebook's data protection information at https://de-de.facebook.com/privacy/explanation. You can deactivate data collection at any time under the following link: https://de-de.facebook.com/help/769828729705201/.

4. The legal basis for the processing is your consent in accordance with Article 6 Paragraph 1 lit. a GDPR.

2.4 Google AdServices

1. This website uses the remarketing or “Similar Target Groups” function of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

2. You may be targeted with advertising by placing personalised and interest-based adverts when you visit other websites within the so-called “Google Display Network”. “Google Remarketing” or the “Similar Target Groups” function uses so-called “cookies”, text files which are stored on your computer, and which enable analysis of your use of the website. These text files are used to record your visits and anonymous data about the use of the website. Personal data will not be saved. If you visit another website in the so-called “Google Display Network”, you may be shown advertisements relating to the product and information areas previously accessed on our website.

3. Google's privacy policy for remarketing, including further information, is available here: http://www.google.com/privacy/ads/.

4. The legal basis for the processing is your consent in accordance with Article 6 Paragraph 1 lit. a GDPR.

2.5 Google AdWords Conversion

1. This website uses the “Google AdWords Conversion Tracking” function of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

2. Google AdWords Conversion Tracking uses so-called “cookies”, text files that are stored on your computer and that enable an analysis of your use of the website when you click on a Google advert. Personal data will not be saved. As long as the cookie is valid, Google and We, as the website operator, can recognise that you have clicked on an advert and accessed a specific target page (e.g. order confirmation page, newsletter registration). These cookies cannot be tracked across websites from different AdWords participants. The cookie creates conversion statistics in “Google AdWords”. These statistics record the number of users who have clicked on one of our adverts. It also counts how many users have reached a target page that has been tagged with a “conversion tag”. However, the statistics do not contain any data that could be used to identify you.

3. For more information about how Google uses conversion data and about Google's privacy policy, see: https://support.google.com/adwords/answer/93148?ctx=tltp http://www.google.de/policies/privacy/

4. The legal basis for the processing is your consent in accordance with Article 6 Paragraph 1 lit. a GDPR.

2.6 Google Analytics

1. We use Google Analytics, a web analytics service provided by Google Ireland Limited (Gordon House Barclays Dublin Ireland - hereinafter “Google”), based on your consent for the analysis, optimisation, and economic operation of our online offer in accordance with Article 6 Paragraph 1 lit. a GDPR. Google uses cookies and other technologies. The information generated by the service about the use of the online offer by users is transmitted to a Google server in the USA and processed there.

2. Google acts on our behalf within the framework of order processing in accordance with Article 28 GDPR. We have entered into a data protection agreement with Google that contains the EU standard data protection clauses.

3. We use Google Analytics with activated IP anonymization.

4. Google Analytics stores cookies in your web browser for a period of two years after your last visit. These cookies contain a randomly generated user ID that can be used to recognise you on future visits to the website. Users can prevent the storage of cookies by setting their browser software; accordingly, In addition, users can prevent the data generated by the cookie and related to their use of the online offer from being collected and processed by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/¬dlpage/gaoptout?hl=de.

5. The recorded data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically erased after 26 months. Other data is stored in aggregate form indefinitely.

6. Further information on data use by Google, settings and revocation options can be found on the Google websites: https://policies.google.com/technologies/partner-sites?hl=de (“Data use by Google when you use our partners' websites or apps”). https://policies.google.com/technologies/ads (“Use of data for advertising purposes”) https://adssettings.google.com/¬authenticated (“Managing Information Google Uses to Serve Advertising to You”).

2.7 Google Fonts

1. In order to make visiting our website attractive, We use fonts from Google, so-called Google Fonts.

2. We have integrated the Google Fonts locally, i.e. on our web server. This means that there is no connection to Google servers and therefore no transmission of your data to Google.

2.8 Google Tag Manager

1. This website uses the Google Tag Manager. This service allows website tags to be managed through an interface. The Google Tool Manager only implements tags, does not set cookies and does not collect any personal data. Google Tag Manager triggers other tags that can collect personal information. However, the Google Tag Manager does not access this data.

2. If the deactivation is done at domain or cookie level, it remains valid for all tracking tags implemented with Google Tag Manager.

3. The Google Tag Manager is used based on our legitimate interests in accordance with Article 6 Paragraph 1 lit. f GDPR. We are interested in an efficient and simple provision of our services.

2.9 Links to Other Websites

1. While using some of our services (e.g. in the “Projects” area), you will also be automatically forwarded to other websites.

2. Please note that this Privacy Policy is not valid there. The privacy policy of the linked website may differ significantly from this one.

3 Processing for the Purpose of Conducting our Business Processes

3.1 Contact Form and Contact by Email

1. When contacting Us (via online form or email), the data provided by the user will only be used to process the request and carry out all associated procedures.

2. Any other use of the data takes place only based on the consent of the user.

3. User data is stored in our customer relationship management system (“CRM system”). The statutory retention periods for business letters apply.

3.2 Direct Marketing

1. If you have given Us your consent, We will inform you regularly by email, telephone, or SMS about Us, as well as new adVenture Home offers and construction projects that We market for various property developers. We use your name, email address and telephone number for this purpose. The legal basis for data processing is Article 6 Paragraph 1 lit. a GDPR. You can revoke your consent at any time with effect for the future.

2. Our newsletter will only be sent by e-mail with your prior express consent according to the double opt-in principle: After registering for the newsletter on our website, you will receive an email asking you to confirm your subscription to the newsletter. This ensures that no third party has misused your data. If there is no confirmation within 48 hours after receipt of the confirmation email, We will erase your contact details. If you revoke your consent, your email address will be erased from our newsletter distribution list.

3. By registering for the newsletter, you also agree to our newsletter tracking for the purpose of personalised advertising and market research. With the help of so-called tracking pixels or web beacons and links, each of which is linked to an individual ID, We collect the following personal tracking information in connection with the use of our newsletter:

• Opening the newsletter, clicking on the links contained therein, submitting a form on our website after clicking on a link contained in the newsletter (including the time of these actions)

• Type of end device used when you retrieve images in the newsletter or click on links

• Behaviour on our website when you access it via a link from our newsletter (including the time of these actions)

• Location of retrieval when you retrieve images in the newsletter or click on links (by assigning your IP address, which We do not save)

We retain this data for your user profile, which is assigned to the data entered when you registered for the newsletter. We use this data to evaluate and optimise our email marketing and for personalised advertising and market research purposes. This enables Us to send you personalised information regarding products, services and other offers that is of particular interest to you as part of our newsletter. You can revoke your consent to this data processing at any time, non-retroactively, by unsubscribing from the newsletter. We erase the tracking data when you unsubscribe from our newsletter. Data retained by Us for other purposes remain unaffected.

4. We use MailChimp, a service provided by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (“MailChimp”), to send and analyse emails. The data processed when sending and analysing the emails is retained on the MailChimp servers in the USA. MailChimp works for Us as a processor within the meaning of Article 4 Number 8 GDPR.

If you unsubscribe from our newsletter, your data (including the tracking data) will be erased from the MailChimp servers.

For more information, see MailChimp’s privacy policy (https://mailchimp.com/legal/privacy/).

3.3 Existing Customer Advertising

1. If you have already used paid (brokerage) services from Us, We can inform you from time to time by email or letter about similar services from Us (new construction projects that We market as brokers for various property developers), if you have not already objected to this.

2. The legal basis for data processing is Article 6 Paragraph 1 lit. f GDPR. Our legitimate interest lies in direct advertising (Recital 47 GDPR). You can object to the use of your email address and postal address for advertising purposes, non-retroactively, at any time without additional costs.

3.4 Answering Project Enquiries

In the case of enquiries about projects from developers, We pass on the data provided in your enquiry to the developer or broker of the respective project, insofar as this is necessary or helpful in answering your enquiry and/or to carry out contractual or pre-contractual measures.

4 Cookies Policy

4.1 General Information

1. Cookies are pieces of information that are transmitted from our web server or web servers of third parties to the web browser of the user and stored there for later retrieval. Cookies may be small files or other types of information storage.

2. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies may restrict the functionality associated with this online offer.

4.2 Cookies Summary

Our Cookies Policy contains a summary of the cookies We use.

4.3 Option to Object

You can manage your cookies settings via our Cookies Policy.

5 Changes to the Privacy Policy

1. We reserve the right to change this Privacy Policy regarding data processing to adapt it to the changing legal situation, changes to the online offer or to data processing.

2. If user consent is required or parts of the Privacy Policy contain provisions of the contractual relationship with the user, the changes will only be made with the consent of the user.

3. Users are asked to inform themselves regularly about the contents of this Privacy Policy.

Version: January 2023