Privacy Policy

Introduction

genvio GmbH ("we", "our", or "us") is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website and asset management services. We are committed to transparency about our data collection and use of your information.

This policy applies to all personal data we collect through our website, services, and any other interactions you may have with genvio. By using our services, you consent to the data collection and use practices described in this Privacy Policy.

Data Controller Information

The data controller for your personal data is:

Data Collection

We collect personal data that you provide to us directly and information that is automatically collected when you use our website and services. The data we collect includes information necessary to provide our asset management services and improve your experience with our company.

Information You Provide Directly

• Contact information (name, email address, phone number, postal address)
• Financial information relevant to our asset management services
• Investment objectives, risk tolerance, and financial goals
• Communication preferences and correspondence with us
• Information provided through our contact forms and enquiries
• Documentation required for regulatory compliance and client onboarding

Automatically Collected Information

• Website usage data, including pages visited and time spent on our site
• Technical information such as IP address, browser type, and device information
• Cookies and similar tracking technologies (as detailed in our Cookie Policy)
• Referral sources and website navigation patterns

How We Use Your Information

We use your personal data for legitimate business purposes related to providing our asset management services and maintaining our relationship with you. How we use your information depends on the services you use and your relationship with genvio.

Primary Uses

• Providing asset management and investment advisory services
• Processing and responding to your enquiries and service requests
• Maintaining client accounts and providing portfolio management services
• Conducting risk assessments and ensuring suitable investment recommendations
• Complying with legal and regulatory obligations in the financial services industry
• Communicating with you about your investments and market developments
• Improving our services and developing new investment solutions

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contractual necessity: To perform our asset management services and fulfil our contractual obligations
• Legitimate interests: To improve our services, conduct business operations, and maintain client relationships
• Legal compliance: To meet regulatory requirements in the financial services sector
• Consent: For marketing communications and certain data processing activities where required

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use and how to manage them, please refer to our Cookie Policy.

Data Sharing and Disclosure

We do not sell, rent, or trade your personal data to third parties for their marketing purposes. We may share your information in the following circumstances:

• With service providers who assist us in delivering our services (under strict confidentiality agreements)
• With regulatory authorities and financial institutions as required by law
• With professional advisers such as lawyers, auditors, and consultants
• In connection with a business transaction such as a merger or acquisition
• To protect our rights, property, or safety, or that of our clients or others

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include encryption, secure data transmission, access controls, and regular security assessments.

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to maintaining the highest standards of data protection.

Data Retention

We retain your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. Data retention periods vary depending on the type of information and the purpose for which it was collected.

For client data related to our asset management services, we typically retain records for a minimum of seven years after the end of our business relationship, or as required by applicable financial services regulations. Some information may be retained for longer periods where required by law or for legitimate business purposes.

Your Rights

Under GDPR and Austrian data protection law, you have several rights regarding your personal data. Your rights include the ability to control how your personal information is used and to ensure its accuracy and completeness.

Your Data Protection Rights

• Right of access: You can request a copy of the personal data we hold about you
• Right to rectification: You can request correction of inaccurate or incomplete personal data
• Right to erasure: You can request deletion of your personal data in certain circumstances
• Right to restrict processing: You can request limitation of how we process your data
• Right to data portability: You can request transfer of your data to another service provider
• Right to object: You can object to certain types of data processing
• Right to withdraw consent: You can withdraw consent for processing based on consent

To exercise any of these rights, please contact us using the contact information provided below. We will respond to your request within one month of receipt.

International Data Transfers

Your personal data is primarily processed within the European Economic Area (EEA). If we transfer your data outside the EEA, we ensure appropriate safeguards are in place, such as adequacy decisions by the European Commission or standard contractual clauses approved by the European Commission.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. We encourage you to review this policy periodically.

Contact Information

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

You also have the right to lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde) if you believe we have not handled your personal data in accordance with applicable data protection laws.