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Data protection

Your rights according to Art. 12ff. DSGVO

You should know what data we collect, process and use about you and for what purpose. This is your right and complies with the requirements of the EU General Data Protection Regulation (EU-DSGVO) of 27.04.2016, applicable from 25.05.2018, as well as the Federal Data Protection Act (BDSG-2018). Therefore, we provide you here with an overview of both the type of personal data stored by you and the data protection organisation of CW Wine GmbH & Co. KG. In this way, we would like to enable you to exercise your “fundamental right to informational self-determination”.


Responsible office

CW Wine GmbH & Co. KG
Tel.: +49 40 – 37503783
Fax: +49 40 – 303 86690


Data protection officer

A data protection officer has not been appointed because the legal requirements for this are not met.

Responsible supervisory authority for data protection

The Hamburg Commissioner for Data Protection and Freedom of Information

Prof. Dr. Johannes Caspar

Klosterwall 6
(Block C)
20095 Hamburg
Telefon: 040/428 54-40 40
Telefax: 040/428 54-40 00


General statements

1. origin and categories of data

CW Wine GmbH receives personal data from clients and other business partners in the course of initiating and fulfilling contracts. In the course of our administrative activities, we also receive data from the custodian banks selected by you. Furthermore, we process personal data from publicly accessible sources, e.g. telephone directories, Internet.

Possible categories of data

  • Names/contact data
  • Identity card data
  • Bank data
  • Creditworthiness data
  • Asset data
  • Order data
  • Invoice data
  • Payment data
  • Tax data
  • Curriculum vitae
  • Qualification data
  • Insurance data
  • Marital status and situation
  • Interests/preferences/special circumstances
  • Plans and goals for personal and professional future
  • Company contact data

2. Processing purposes

We process your personal data in accordance with the EU-DSGVO for a specific purpose and limited to what is necessary.

Conceivable processing purposes

  • Contract initiation and conclusion
  • General contract fulfilment
  • Master data maintenance
  • Creation of an investment strategy
  • Creation of a suitability concept
  • Or processing
  • Payment transactions on behalf of customers
  • Order processing
  • Telephone recording
  • Handling electronic communication
  • Strengthening customer loyalty
  • Sending a newsletter
  • Accounting/collection
  • Prevention of criminal offences
  • Fulfilment of superordinate legal regulations, in particular those for financial services institutions (e.g. KWG, WpHG, various EU regulations and directives)
  • Protection of legal claims
  • Translated with (free version)

3. Legal basis of processing

Based on the conditions of the EU-DSGVO, the processing of personal data by CW Wine is lawful.

Accepted legal basis

  • Consent
  • Initiation of a contract
  • Contract, relationship of trust similar to a contract
  • Legal obligation, overriding legal provisions, public interest
  • Weighing of interests

4. Recipients of data

CW Wine GmbH employees process the relevant personal data to fulfil contractual and legal obligations. This takes place within the employment relationship – the data does not leave our catchment area. In addition, bodies outside HWA Hanseatische (third parties) receive personal data on the basis of a defined legal basis. These bodies only receive the data they need for the respective task.

Possible data recipients

  • Public authorities (BaFin, Bundesbank, tax authorities, etc.)
  • Custodian bank/account-holding institution, financial services institution, comparable institutions and order processors
  • External accounting
  • Shipping service provider
  • Further, contractually bound vicarious agents
  • Other bodies for which you have given us your consent to the transfer of data.

5. Transfer to third countries

Data is only transferred to countries outside the EU or the EEA (so-called third countries) if this is necessary to execute your orders (e.g. payment or securities orders), if it is required by law (e.g. tax reporting obligations) or if you have given us your consent. If service providers are used in a third country, in addition to written instructions, they are obliged to comply with the level of data protection in Europe by agreeing to the EU standard contractual clauses.

6. Deletion periods

We process (and store) your personal data to fulfil our contractual and legal obligations or for the purpose for which you provided us with the data. As soon as the purpose of processing ceases to apply, this data is regularly deleted, unless its further processing for a limited period is necessary for the following purposes.

Compliance with retention periods under commercial and tax law: These include the German Commercial Code (HGB), the German Fiscal Code (AO), the German Banking Act (KWG), the German Money Laundering Act (GwG) and the German Securities Trading Act (WpHG). The periods specified there for retention or documentation are two to ten years.

Preservation of evidence under the statute of limitations. According to §§ 195ff of the German Civil Code (BGB), these limitation periods can be up to 30 years, whereby the regular limitation period is three years.

7. Your rights under the EU General Data Protection Regulation

(Preliminary) Information

You can read this at this moment.

Upon request, we will provide you with a summary of the personal data we have stored about you.

You have the right to demand that we correct incorrectly recorded data without delay.

We delete your data as soon as its processing is no longer necessary. However, there are exceptions to this, see the following section.

Einschränkung der Verarbeitung
Ihre Daten werden von uns nicht mehr genutzt, wenn der Verarbei­tungszweck wegfällt, wir sie aber aufgrund übergeordneter Rechts­vorschriften noch nicht löschen dürfen.


Restriction of processing
Your data will no longer be used by us if the purpose of processing no longer applies but we are not yet allowed to delete it due to overriding legal provisions.

Data portability
Upon request, we will provide you with your data in a suitable form so that it can be transferred to a third party.


If you have given us consent to process your personal data for certain processing purposes, you may revoke this consent at any time without giving reasons.

If the data processing is in the public interest or has been justified on the basis of a balancing of interests (“overriding legitimate interest”), you may object to the processing of your personal data for contractual purposes.

If you believe that the processing of your personal data by CW Wine GmbH & Co. KG is unlawful, you have the right to complain to the supervisory authority of your place of residence.

8. are there obligations to provide and process data?

In particular, we are obliged under money laundering regulations to identify you before the establishment of the business relationship, for example by means of your identity card, and to collect and record your name, place of birth, date of birth, nationality and residential address. In order for us to comply with this legal obligation, you must provide us with the necessary information and documents in accordance with the Money Laundering Act and notify us immediately of any changes that arise in the course of the business relationship. We are legally obliged to process certain data when providing financial services (e.g. investment advice, investment and acquisition brokerage).

Within the scope of our business relationship, you must therefore provide those personal data that are necessary for the establishment and performance of a business relationship and the fulfilment of the associated contractual obligations or which we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or execute the order or will no longer be able to perform an existing contract and may have to terminate it. If you do not provide us with the necessary information and documents, we may not enter into or continue the business relationship requested by you.

9. is there automatic decision-making (including profiling)?

As a matter of principle, we do not use fully automated decision-making pursuant to Article 22 DSVO to establish and implement the business relationship. Should we use these procedures in individual cases, we will inform you of this separately if this is required by law.

10 Electronic communication

If you send us a message by e-mail, the processing is usually necessary as a pre-contractual or contractual measure. In addition, for the purpose of contacting us, you give us your voluntary consent to process your required personal data. This requires the provision of a valid e-mail address, which is used to allocate your enquiry and respond to it. The information you provide will be stored for the purpose of processing the enquiry and for possible follow-up questions.

11. consequences of revocation of consent and objection

If you revoke a necessary and already granted consent, we will no longer process your personal data. If you object to data processing in the public interest or on the basis of a balance of interests, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If you object to processing for direct marketing purposes, we will no longer process your personal data for these purposes.

Information relevant to the website

1. collection of general information when you visit our website

When you view our website, general information is automatically collected by means of a cookie. This information (log files or server log files) describes, for example, the type of web browser, the operating system used, the domain name of your Internet service provider and the like. This data is collected by the Internet service that hosts our website. They are technically necessary in order to display the contents of the website correctly and are always collected when you move around the internet. In particular, they are processed for the following purposes:

Ensuring a smooth connection setup of the website.
Ensuring the smooth use of our website.
Evaluating system security and stability.
According to the Internet host, the data in the log files are anonymised after 7 days and stored for a maximum of 8 weeks. Anonymous information of this kind can also be statistically evaluated by us in order to optimise our website and the technology behind it.

Due to our legitimate interest, this processing of your personal data is permitted. We do not use your data to draw conclusions about your person. The only recipients of the data are CW Wine GmbH as the responsible party and the Internet host.

2. Use of website analysis services

We do not use tracking tools such as Google Analytics, Matamo and others!

3. Electronic communication

If you send us a message via contact form, you give us your voluntary consent to process your required personal data for the purpose of contacting you. In order to do this, you must provide a valid e-mail address, which is used to allocate your enquiry and reply to it. The information you provide will be stored for the purpose of processing the enquiry and for possible follow-up questions.

4. Validity of this data protection declaration

Our data protection declaration should always comply with the current legal requirements and reflect changes to our services, e.g. when new services are introduced. Therefore, the latest data protection declaration will apply to your next visit.

Status of the data protection declaration: 25. 5. 2018

5. Questions about data protection

If you have any questions about data protection at CW Wine GmbH & Co. KG, we can help you:

CW Wine GmbH & Co. KG

Tel.: 040 – 375033783
Fax: 040 – 303 866 91