License No.:CN-1100434 | Brokerage No.:202100982107
The regulation of cookies is primarily outlined in the ePrivacy Directive (2002/58/EC), also referred to as the “Cookie Law”. More specifically, Article 5(3) of the ePrivacy Directive requires that users are informed about the use of cookies and must give consent for their use, except where they are strictly necessary for the provision of an information society service requested by the user. In addition, the General Data Protection Regulation (GDPR) governs the processing of personal data, which can often include data gathered via cookies. Specifically, GDPR's Articles regarding consent (Article 7) and transparency (Articles 12, 13, and 14) are pertinent. These articles require that consent be freely given, specific, informed, and unambiguous, and that individuals be transparently informed about how their data is being used.
Cookie Policy of Property Shop Investment LLC (hereinafter "Property Shop Investment", “PSI”,"us" or "we") for the website https://psinv.net and all its subpages (hereinafter collectively referred to as the "Website") valid as of 7TH July 2023.
An important piece of information to note initially:
The right to withdraw consent at any time is a fundamental part of EU data protection law, outlined in Article 7(3) of the General Data Protection Regulation (GDPR). This stipulates that the data subject shall have the right to withdraw his or her consent at any time, and it shall be as easy to withdraw as to give consent. ePrivacy Directive (2002/58/EC) applies specifically to the use of cookies. Article 5(3) of this directive states that the use of cookies requires informed consent from the user, except for certain exemptions. Our website uses cookies to ensure that we give you the best experience, optimize our services. In line with the General Data Protection Regulation (GDPR) and other relevant legislation, we seek your explicit consent for such use. To ensure transparency and grant you control over your personal data, we use a cookie Consent Management Platform of CookieYes (hereinafter referred to as the "CMP Tool"). When you first visit our site. Upon arrival at our website: If you click on "I accept", you are giving us your explicit consent to use cookies as described in this policy.
If you click on “I don't accept”, no non-essential cookies will be placed on your device, and you can still navigate through our site. However, please note that certain functionalities may be limited without the aid of cookies.
Withdrawing Your Consent:
Should you wish to change your cookie preferences at any point, you can adjust your browser settings to delete or prevent certain cookies from being stored. If you want to revisit your decision, a link will be available on our site to bring up the Consent Management Platform again.
Articles 13 and 14 of the GDPR require the data controller to provide information to the data subject about what data is being collected and processed. This would include information about what data is being processed when a user interacts with the Property Shop Investment website.
You may use the website https://psinv.net and all its associated subpages (hereinafter referred to as the “Website”) without registering or actively providing personal data. if a website visitor is not required to actively provide personal data, the processing of personal data that does occur (such as cookies) is regulated by Article 4(1) of GDPR, defining personal data, Article 5, outlining the principles of data processing, and Article 6, defining the lawfulness of processing. Please refer to our data protection policy, which you can find here, or the data protection policies of the company web presences of our respective licence partners for further information. You will find the data protection notices of our licence partners at the bottom of each respective company's web presence, which can be reached via PSI Website. Additionally, the reference to the data protection policies of the respective license partners implies a data sharing or processing arrangement, which would be regulated under Article 26, which deals with joint controllership of two or more entities, and Article 28, which addresses the relationship between controllers and processors.
In the event of a visit to the Website, we or our license partners collect data about the end device you are using and your usage behavior on our online services. This data is limited and cannot be assigned to an individual by us or our license partners. This is to adhere to Article 5(1)(b) of GDPR which denotes that personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is collected. This includes the following data when calling up a website:
1. What are Cookies?
Like all other commercial websites, our Website also uses so-called cookies and other tracking technologies (hereinafter collectively referred to as "Cookies").
Cookies are small text files that are stored locally in the memory or on the hard drive of your computer or mobile device (hereinafter referred to as “end device”). Cookies fulfil various functions and can process data for many different purposes. Once the Cookies have been saved and the corresponding website is called up again, the user's browser sends back the content of the cookies and thus enables the recognition of the user on that particular website. Third-party technologies such as scripts, pixels and tags integrated by PSI for advertising purposes may also set cookies on your end device. Certain cookies are automatically deleted at the end of the browser session (so-called session cookies), others are stored in the user's browser for a specified period of time and then delete themselves automatically (so-called temporary cookies). Others may be stored cookies permanently on the end device (permanent cookies). Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie by which internet pages and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the visited Internet pages to distinguish the user's browser from other Internet browsers. Cookies cannot, in principle, identify you individually but rather enables the identification of your end device.
In accordance with the General Data Protection Regulation (GDPR), we aim to inform our users about the tracking technologies we utilize on our website. This section provides details on various tracking pixels and analytics tools implemented on our platform.
Google Analytics: We use Google Analytics to gain insights into how our visitors interact with our website. Google Analytics may set cookies on your browser or mobile device to collect data about your user behavior. No personally identifiable information is collected without your explicit consent.
Facebook Pixel: This is a tool that allows us to understand and measure the effectiveness of our advertising on Facebook. It might collect cookie data on actions taken on our website as a result of the ads we place on Facebook.
Snapchat Pixel: We utilize the Snapchat Pixel to measure the impact of our advertisements on Snapchat. This helps us monitor user interactions on our website that result from Snapchat ads.
Google Ads Pixel: This tool helps us optimize and understand the performance of our advertising campaigns on the Google Ads platform. It may collect data on your interactions with our ads and our website.
TikTok Pixel: Implemented to evaluate the success of our TikTok advertisements. The pixel allows us to understand how users engage with our website after seeing a TikTok ad.
Yandex Metrica: Yandex Metrica is an analytics tool that provides insights about our website's traffic and user behavior. It may employ cookies to gather data, although no personally identifiable information is captured without your express agreement.
VK Pixel: We use the VK Pixel to monitor the effectiveness of our ads on the VK platform. This tracking pixel assists in understanding how VK users interact with our website post-engagement with our ads.
Microsoft Clarity: Microsoft Clarity provides us with user behavior insights, helping improve user experience on our website. It collects data on how visitors interact with our site, focusing on aspects like mouse movements, clicks, and scrolling patterns.
Your Choices and Consent
We respect your privacy. By using our website, you consent to the use of these tracking pixels and analytics tools as described above. If you wish to opt out or learn more about the cookies set by these tools, please visit their respective privacy policies
However, in the legal context Cookies are defined in Recital 30 of the EU General Data Protection Regulation (GDPR). They are considered “online identifiers”, which are described as capable of creating profiles about individuals and potentially identifying them. Article 4(1) of the GDPR includes cookies in its definition of personal data, if they can be or are used to identify individuals. Article 6 outlines the lawfulness of processing personal data, which would apply to the use of cookies if they collect personal data. The principles laid out in Article 5, such as data minimization, accuracy, storage limitation, also apply. Likewise, article 5(3) of the ePrivacy Directive (Directive 2002/58/EC) states that the storing of information, such as cookies, on a user's device, is only allowed if the user has given their informed consent after being provided with clear and comprehensive information about the purposes of the processing which PSI thus adheres to.
a. Types of Cookies
This section shall outline types of cookies utilized as per GDPR, Article 13 which requires organizations to provide users with information about the cookies they are using, including the purpose of the cookies and the duration of their storage.
We make use of several different types of Cookies:
(i) So-called technically essential Cookies
Firstly, we use technically essential cookies to operate the Website. In accordance with the GDPR, where Article 6(1)(f) is cited as the pre-requisite legal basis for processing personal data in this context. This article permits data processing necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, unless these interests are overridden by the data subject's. Technically essential Cookies are necessary for the functionality of the Website, without them the Website would not be operable or would only be operable to a limited extent. The user data collected through technically essential cookies are not used to create user profiles. This also includes temporary cookies (session cookies). These cookies do not collect any data from your computer and are automatically deleted as soon as you close your browser. Functionality of the website is thus to be cited as a compulsory legitimate purpose for utilization as per Article 6(1)(f) of the GDPR.
Technically essential cookies are “essential” cookies in the context of the ePrivacy Directive 2002/58 EC and do not require consent. For the scope of application of the Federal Republic of Germany, the legal basis for their use is § 25 II TTDSG. If personal data is processed in this context, the legal basis is Art. 6 para. 1 p. 1 lit. f GDPR (legitimate interest).
(ii) So-called non-essential Cookies
Furthermore, some cookies have no technical necessity. Such cookies serve very different purposes, such as optimising the Website, creating user profiles and displaying interest-based advertising. As a general rule, it can be said that they are for analysis or marketing purposes.
If we use any of these cookies for analysis or marketing purposes, we process your data based on your consent pursuant to Art. 6 (1) sentence 1 lit. a) GDPR. This consent is given by you through the Consent Management Platform . Alternatively, Art. 6(1) sentence 1 lit. f) GDPR (legitimate interest) may also be the legal basis for such cookies for analysis or marketing purposes. Please refer to our Consent Management Platform for further details (accessible via the menu item “Manage Cookie settings” at the bottom of the Website). Here we have listed in detail for which purposes we use Cookies for analysis or marketing purposes and the legal basis thereof. Further clarification can also be found below.
b. Managing Cookies in our Consent Management Platform
What Cookies are used when using the Website, if applicable by which service provider/partner (“vendors”) they are supplied, which of your data is processed in the process and whether you wish to consent to this, can be determined through the Consent Management Platform. The Consent Management Platform also includes further information about the cookies and tracking technologies used. This is to further adhere to article Article 6(1)(a) of the GDPR pertaining to informed consent through means of CMP. Likewise, Article 7 of the GDPR stipulates conditions for consent, which include the necessity to keep records demonstrating that the user has given their consent to the processing of their personal data.
To enable you to make an informed decision, we use a cookie consent management procedure (the Consent Management Platform described above), which obtains your consent to the use of cookies, associated processing as disclosed within the procedure and respective vendors. This consent can be managed by you and if you wish, can also be revoked. This is to follow Article 7(3) of the GDPR states that “The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.” This likewise adheres to ePrivacy Directive (2002/58/EC), which requires that users be given the ability to refuse the use of cookies that are not strictly necessary. The declaration of consent is stored to avoid a repeat request for consent and to be able to prove your consent in accordance with the obligatory legal requirements. The storage of consent obeys Article 7(1) of GDPR where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. This implies that consent must be stored and documented. The storage can take place on the associated server and/or in the form of a cookie (“opt-in cookie”) or with the help of comparable technologies, to be able to assign the consent to a user or their end device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to 12 months. The compulsory duration period of consent storage is not directly specified within GDPR, however it does emphasize that personal data may only be stored for as long as necessary to fulfill the purpose for which it was collected as per Article 5(1)(e), known as the “storage limitation” principle. This implies that storage of consent may therefore vary depending on individually given circumstances. A pseudonymous identifier of the user is created and together with the time of consent and information on the scope of consent (e.g. which categories of cookies and/or service providers) saved. As defined within Article 4(5) of the GDPR 'pseudonymisation' means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person; In addition, Recital 26 of GDPR states that Personal data which have undergone pseudonymisation, which could be attributed to a natural person by the use of additional information, should be considered to be information on an identifiable natural person.
It may be vital to note that according to Recital 28 of GDPR, the application of pseudonymisation to personal data can reduce the risks to the data subjects concerned and help controllers and processors to meet their data-protection obligations.
The Consent Management Platform enables you to filter and provide an overview of the various cookies, trackers and analysis tools and, if applicable, the vendors used by us. Furthermore, it enables you to select them according to their processing purpose and, if desired, to deactivate them generally or individually. However, you cannot deactivate technically essential cookies, trackers and analysis tools for the reasons described above. This in turn adheres to the aforementioned Articles 4(11), 7, and 8 of the GDPR pertaining to nuances of consent. It likewise follows Privacy Directive (Directive 2002/58/EC): Article 5(3) which specifically deals with the storing of information, or the gaining of access to information already stored, in the terminal equipment of a subscriber or user.
To access this Consent Management Platform , please click on “Manage cookie settings” (accessible via the menu item at the bottom of the Website). Easy mode of access to consent and data management tools follows Article 15 of the GDPR states that: “The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact the controller.” CMP tool is thus to serve as a mode of transparent and accessible management.
As previously stated, you can use the Website free of cookies and other tracking mechanisms that are not technically essential, both from the outset and also subsequently. In this case, only the technically essential cookies, trackers and analysis tools that are necessary for the operability of the Website will remain.
Note on consent: Some of the services listed in the Consent Management Platform are set by our vendors or we transmit your data to these vendors. You can find more details in our Consent Management Platform .
Note on consent: Some of the services listed in the Consent Management Platform transmit data to the USA. The data processing and the protection of your data in the USA do not meet GDPR standards. The services/vendors are subject to US law and may therefore be required to hand over data to US authorities or US secret services. In particular, risks for you include the difficulty of asserting your rights, the lack of control over the further processing or transfer of your data and the aforementioned access by state authorities. You can also find more details in our Consent Management Platform . Article 45 of the GDPR provides that a transfer of personal data may take place where the Commission has decided that the third country ensures an adequate level of protection. In the absence of such a decision, Article 46 outlines the conditions for data transfers subject to appropriate safeguards, such as standard data protection clauses adopted by the Commission. However, the US does not have an adequacy decision from the European Commission, which means that the level of protection for personal data in the US is not considered to be adequate by the EU. This would therefore serve as a standard contractual clause (SCC) as per Article 46 of the GDPR for data transfer allowance. (*For reference only - CJEU made clear that reliance on SCCs requires a case-by-case assessment of the level of data protection that can be ensured in the recipient country, taking into account both the SCCs and, where necessary, supplementary measures.)
To manage your cookie settings/opposition in this regard, please click on “Manage Cookie Settings” (accessible via the menu item at the bottom of the Website).
c. Management of Cookies via your browser
You can also deactivate the storage of cookies via your browser settings and delete already stored cookies in your browser at any time. However, please note that the Website or the online features may not function or may only function to a limited extent without cookies. We also recommend that you visit the website of www.YourOnlineChoices.com, where you can obtain information and assistance in connection with web tracking mechanisms. A central objection option for various tools, in particular from US providers, is also available under the following link: optout.networkadvertising.org. This may be interpreted as further means of consent and cookie management which thus likewise adheres to Article 7 of the GDPR and Article 21 of the GDPR pertaining to consent management.
Summary of the purposes for which we set Cookies or also process personal data in the context of web tracking as per Article 5(1)(b) which states that personal data must be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. If cookies collect personal data, they must adhere to this principle.
a. For the provision of individual offers of our services or the services of our licence partners
If you have consented in accordance with Art. 6 (1) a of the GDPR, we may set cookies and/or process personal data such as your IP address or we may use unique identifiers (a unique identifier, or UID for short, is a unique identifier consisting of codes in the form of strings of numbers and letters) to inform you about our services. In doing so, we also take into account your preferences resulting from your usage behaviour on our Website. This denotes that optimization of marketing and/or general act of informing is to be construed as a legitimate purpose as per Art. 6(1) of the GDPR.
b. Usage profiles based on statistical analysis for the needs-based design of the Website
We need statistical information about the use of the online services on the Website to make the Website or its contents more user-friendly and to conduct market research or a reach analysis. The legal basis for data utilization as per Article 6 of the GDPR is the legitimate purpose of website optimization. For this purpose, we use web analysis tools (“Tools”). Usage profiles are created with the help of analysis cookies or by evaluating your log files. The providers of these Tools process your data as processors in accordance with our instructions and not for their own purposes. The obligations of data processors, including how they should handle personal data, are outlined in Articles 28-30 of the GDPR. These articles stipulate that processors should only process personal data according to the controller's instructions, unless required by law. The Tools either do not use the IP addresses of users at all or shorten them immediately after collection. The shortening of an IP address could be considered a form of pseudonymization as per the definition provided by Article 4(5) of the GDPR. By removing a part of the IP address, the remaining data is less identifiable and harder to link to a specific individual without additional information.
The legal basis may be your consent (if we process your personal data, the legal basis is Art. 6 para. 1 a) GDPR; if we use Cookies and do not process personal data, the legal basis is the ePrivacy Directive 2002/58 EC or, in the area of application of the Federal Republic of Germany, Section 25 II TTDSG). In addition, PSI may also have an overriding legitimate interest in the design of the Website in line with demand and user habits and the statistical evaluation of the Website. The legal basis for data processing is then Art. 6 para. 1 f) GDPR.
For the aforementioned purposes, we use both our Cookies as well as Cookies of third-party providers on our Website and associated subpages, which are transmitted to your computer via your web browser. They enable our systems to distinguish your browser from others. On the one hand, we send so-called persistent cookies and on the other hand, we use so-called session cookies, with the help of which you receive a session ID for the duration of a visit to our pages, which enables us to distinguish you from other visitors to the Website. The following list of cookie categories adheres to Articles 12-14 of the GDPR, which state that an organization is ought to inform data subjects about processing activities in a transparent manner. If cookies are used, clarification of what cookies are used, what data they collect, how long they last, and what they're used for is thus mandatory.
In our Consent Management Platform, you will find these Cookies under the following headings:
This is largely governed by the ePrivacy Directive (2002/58/EC), particularly Article 5(3). For the GDPR aspect, Article 6 may be applied (lawfulness of processing). Article 9 of the GDPR categorizes geolocation data as a special category of personal data. Its processing generally requires explicit consent, unless certain exceptions apply. Article 22 is likewise (regarding automated individual decision-making, including profiling) is relevant. Additionally, Articles 12-14 emphasize the requirement for transparency under scenarios of active profiling as per Article 22 pertaining to device scanning for identification purposes. PSI thus adheres to transparency under Article 22.
Some of the services listed in the Consent Management Platform transmit data to the USA. The data processing and the protection of your data in the USA do not meet GDPR standards. The services are subject to US law and may therefore be required to hand over data to US authorities or US secret services. In particular, risks for you include the difficulty of asserting your rights, the lack of control over the further processing or transfer of your data and the aforementioned access by government agencies. Some providers, such as Google, may also process data for their own purposes. In these cases, data processing is based on your consent, cf. Art. 6 I lit. a GDPR. This would therefore serve as a standard contractual clause (SCC) as per Article 46 of the GDPR for data transfer allowance
You can also find more details in our Consent Management Platform (accessible via the menu item “Manage cookie settings” at the bottom of the Website).
3. Linking to social media pages
Our Website partly contains links to the most frequently used social media network sites (e.g. Facebook and Twitter). In this respect, it is not a matter of embedding social media plug-ins, but rather a linking in which personal data is not transmitted to the social media operators.
Please refer to the information within our Consent Management Platform to see to what extent we share personal data with our partners and whether these partners are based in non-EU countries.
Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to adequate safeguards (e.g. standard contractual clauses) as agreed by the European Union and the recipient of the data (Art. 46 GDPR) unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree to additional measures with recipients to ensure an adequate level of data protection.
Copies of the adequate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted to the necessary extent to protect trade secrets or other confidential information.
Property Shop Investment will retain your personal data for the time necessary to achieve the purposes for which data is collected, including any retention period required by the applicable law (e.g. retention of accounting records). Please refer to our Consent Management Platform for further details on the storage period. The handling of data retention periods in GDPR is covered by Article 5(1)(e) which states that personal data shall be: kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject ('storage limitation').
Our data protection information includes details of our responsibilities, our contact details and your rights within the scope of data processing.
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