Privacy Policy (GDPR)

Last updated: 20 September 2025

1. Controller

Portfolio DOC UG (haftungsbeschränkt) Rissener Landstraße 40B, 22587 Hamburg, Germany Email: contact@portfoliodoc.de

2. What We Process, Why, and the Legal Basis

Site visit / server logs: IP address, date/time, URL, referrer, user-agent, device/OS; to ensure connection, security, and stability. Legal basis: Art. 6(1)(f) GDPR (legitimate interests).

Contact via email: your email address and the information you send us; to handle enquiries and pre-contract steps. Legal basis: Art. 6(1)(b) GDPR.

Using our services: data necessary to provide our services (e.g., personalised portfolio analyses) and to fulfil a contract. Legal basis: Art. 6(1)(b) GDPR.

Cookies/analytics/marketing (optional): set only with your consent. Legal basis: Art. 6(1)(a) GDPR. See the Cookie Policy.

3. Recipients and Processors

We may use carefully selected service providers (e.g., hosting, analytics, email, security) acting as processors pursuant to Art. 28 GDPR under appropriate data processing agreements. We disclose data only with consent, for contract fulfilment, or where required by law (Art. 6(1)(a)–(c) GDPR).

4. International Transfers

Where data is transferred outside the EEA, we implement appropriate safeguards (such as EU Standard Contractual Clauses) and, where required, conduct transfer impact assessments.

5. Retention

We retain personal data only as long as necessary for the purposes described or to comply with statutory retention periods. Examples include:

  • Server logs: typically 30–90 days for security/abuse detection.
  • Contract/account data: for the term of the contract plus statutory retention periods.
  • Support enquiries: typically 6–24 months after closure.

Actual periods may vary depending on the context and legal requirements.

6. Your Rights

You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), and objection (Art. 21) to processing based on legitimate interests, as well as the right to withdraw consent at any time without affecting the lawfulness of processing before withdrawal. You may also lodge a complaint with a supervisory authority, e.g., the Hamburg Commissioner for Data Protection and Freedom of Information.

Contact for requests: contact@portfoliodoc.de

7. Security

We maintain appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, and regular backups.

8. Children's Data

Our services are not directed to children. We do not knowingly process children's data without parental consent where required.

9. Automated Decision-Making

We do not use automated decision-making that produces legal or similarly significant effects unless clearly disclosed, with meaningful information about the logic and consequences.

10. Changes to This Policy

We may update this Privacy Policy and will indicate the 'Last updated' date. Material changes will be highlighted where appropriate.

Cookie Policy

Last updated: 20 September 2025

1. What Are Cookies?

Cookies and similar technologies (such as local storage and pixels) help us operate the site and, with your consent, understand usage and improve marketing.

2. Types of Cookies We Use

  • Strictly necessary: required for core site functions (e.g., page navigation, security). These do not require consent.
  • Analytics: help us understand performance and usage. These are set only with your consent.
  • Marketing: help measure campaigns or tailor content. These are set only with your consent.

3. Your Consent and Controls

We do not set non-essential cookies until you opt in. Our cookie banner provides Accept, Reject, and Settings with equal prominence. You can change or withdraw your consent at any time via the Cookie settings link in the site footer. We maintain a record of your consent in accordance with applicable EU requirements.

4. Cookie Details

Our consent management platform displays an up-to-date list of cookies and similar technologies in the Cookie settings panel, including provider, purpose, duration, and whether they are first- or third-party.

Impressum / Legal Notice (Germany)

Provider (Anbieterkennzeichnung) pursuant to § 5 DDG and, where applicable, § 18(2) MStV

Portfolio DOC UG (haftungsbeschränkt) Rissener Landstraße 40B, 22587 Hamburg, Germany Represented by: Managing Director Adnan Bilgin Commercial Register: Amtsgericht Hamburg, HRB 187569 Email: contact@portfoliodoc.de Website: www.portfoliodoc.de

Responsible for content pursuant to § 18(2) MStV

Adnan Bilgin, address as above.

Dispute Resolution

The EU Online Dispute Resolution (ODR) platform has been discontinued. We therefore do not link to it. We are not willing or obliged to participate in dispute resolution proceedings before a consumer arbitration board. Please contact us directly at contact@portfoliodoc.de with any complaints.

Liability for Content

As a service provider, we are responsible for our own content on these pages according to general laws and the applicable provisions of the Digital Services Act Implementation Act (Digitale-Dienste-Gesetz, DDG). Obligations to remove or block the use of information under general laws remain unaffected. Content will be removed promptly upon knowledge of a specific infringement.

Liability for Links

Our website contains links to third-party websites. We have no influence over their content and therefore cannot assume liability for these external contents. The respective provider or operator is responsible for the content of linked pages. Unlawful links will be removed promptly upon knowledge.

Trademark Notice

'Portfolio DOC' is a registered trademark protected under the regulations of the European Union Intellectual Property Office (EUIPO). Any unauthorised use is prohibited.

Copyright

Content and works created by us on these pages are subject to German copyright law. Third-party contributions are marked as such. Any reproduction, editing, distribution, or any kind of utilisation outside the limits of copyright requires prior written consent.

Website Terms of Use

Last updated: 20 September 2025

1. Scope and Acceptance

These Terms govern your use of our website and any services provided through it. By accessing or using the site, you agree to these Terms.

2. Use of the Site

You must not misuse the site, attempt to disrupt it, introduce malicious code, or infringe our or others' rights. If you create an account, you are responsible for safeguarding your credentials and ensuring the information you provide is accurate and up to date.

3. Intellectual Property

All content on the site is owned by or licensed to Portfolio DOC UG and is protected by applicable copyright and other intellectual property laws. You may view and make personal, non-commercial copies. Any other use requires our prior written consent.

4. No Financial or Investment Advice

Information on this site, including analytics and tools, is provided for general information only and does not constitute investment advice, recommendation, or solicitation. Past performance is not a reliable indicator of future results. You remain solely responsible for your investment decisions and should seek professional advice where appropriate.

5. Availability and Changes

We may change, suspend, or discontinue the site or any feature at any time. We may also update these Terms; the 'Last updated' date will reflect the latest version.

6. Liability

We are liable without limitation for intent and gross negligence and for injury to life, limb, or health. Otherwise, our liability is limited to typical, foreseeable damages as permitted by law. Mandatory consumer rights remain unaffected.

7. Governing Law and Jurisdiction

German law applies. If you are a consumer resident in the EU, you may also benefit from mandatory provisions of your country of residence. The place of jurisdiction is determined by the applicable statutory rules.

8. Contact

For questions regarding these Terms, please contact contact@portfoliodoc.de.

Last updated: 20 September 2025