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Registration for new clients is open againTwo years of Private Equity NXT: +15.7% since inceptionCash Management: up to 5.5% target return p.a.Wealth Management from €50,000 – three strategiesPrivate Debt NXT: ongoing income from private marketsInfrastructure NXT: real assets in the portfolioRegistration for new clients is open againTwo years of Private Equity NXT: +15.7% since inceptionCash Management: up to 5.5% target return p.a.Wealth Management from €50,000 – three strategiesPrivate Debt NXT: ongoing income from private marketsInfrastructure NXT: real assets in the portfolio
Private Equity & Wealth Management – ZUWAX

This is a convenience translation. The German version is legally binding. Deutsch

Privacy policy

Protecting your personal data is a central part of our self-conception as a digital wealth manager.

Trust, transparency and security form the foundation of every interaction with our offering – whether you visit our website, use our platform or are already a client.

In this privacy notice we therefore inform you transparently about the processing of your data – including the respective legal basis, the purpose and your rights under European data protection law.

Where certain information applies only to particular types of use or target groups – for example webinar participants or clients – this is clearly indicated in the relevant passage.

1. What is personal data?

Personal data are all information that make a person identifiable – either directly or in combination with other data. This includes contact details such as name and address, as well as technical information such as the IP address.

In Europe, personal data enjoy special protection under the EU’s General Data Protection Regulation (DSGVO). It lays down binding framework conditions for their processing – for example for storage, use or transmission by companies such as ZUWAX.

Further fundamental definitions can be found in Article 4 GDPR.

2. Who is responsible for data processing and whom can I contact?

The controller responsible for processing your data is ZUWAX Asset Management GmbH, Kurfürstendamm 177, 10707 Berlin, e-mail [email protected].

You can also find details in our legal notice.

You can reach our data protection officer at our business address and via the e-mail address: [email protected].

Or if you wish to contact our data protection officer on confidential matters:

3. What rights do you have?

You are entitled at any time to the following data protection rights – regardless of the context in which your data are processed:

  • Right of access under Art. 15 DSGVO. Example: You wish to know which data we have stored about you.
  • Right to rectification under Art. 16 DSGVO. Example: Your email address has changed – we are to update it.
  • Right to erasure under Art. 17 DSGVO. Example: You wish us to delete certain data that are no longer required.
  • Right to restriction of processing under Art. 18 DSGVO. Example: Your data should not be deleted, but used only for necessary purposes.
  • Right to data portability under Art. 20 DSGVO. Example: You wish to receive your data in a machine-readable format, e.g. to pass them on to another provider.
  • Right to object under Art. 21 DSGVO. Example: You wish to object to the use of your data for analytics or advertising purposes.
  • Right to lodge a complaint with a data protection supervisory authority (Art. 77 DSGVO). Example: you do not agree with our handling of your data.

An overview of your rights can also be found in Articles 12 ff. of the DSGVO or on the website of your competent data-protection supervisory authority.

4. Which data sources do we use?

We receive personal data from different sources – depending on how you interact with our offering:

When you visit our website, we automatically collect technical information about your devices and browsers (e.g. IP address, operating system, time of page access), the extent of which depends on your consents in our cookie banner. In addition, we receive data when you actively provide it to us – for example via contact forms.

If you create a user account on our platform or express interest in our service, e.g. via newsletters or webinars, we receive the data that you provide to us in the course of registration or communication (e.g. name, e-mail address, telephone number).

When you become a client, we receive additional information:

  • through your active information for initiating or performing the business relationship
  • from service providers engaged in the course of service delivery (e.g. identity verification, contract signing)
  • from partners involved on the basis of your consent (e.g. opinion research)
  • from publicly accessible sources (e.g. commercial register, press), where legally required or necessary to prepare a business relationship

Further information on the specific processing of these data can be found in the following chapters.

5. Which categories of data do we process?

Depending on how you interact with our offering – whether you visit our website, use our platform, take part in a webinar or are a client – we process different categories of personal data:

5.1 When visiting our website

  • Technical access data such as IP address, device type, operating system, browser type, time of access, referrer URL
  • Usage behaviour on the site (e.g. pages viewed, clicks), provided you have consented
  • Data from forms and interactions, e.g. information in contact forms, live chats or when subscribing to newsletters. These include, for example, name, e-mail address and telephone number.
  • Support and communication data when you contact us via chat, email or other channels

The extent of processing depends materially on your consent preferences in the cookie banner.

5.2 When using our platform (with registration)

  • Master data such as name, email address, telephone number
  • Access data (e.g. login times, two-factor authentication)
  • Communication histories, e.g. from Assisted Onboarding or chat support
  • Marketing and CRM data, for example from the use of emails, content or forms (e.g. via Braze or Salesforce)

5.3 When you become or already are a client

  • Contract and transaction data (e.g. deposits and withdrawals, wealth overviews)
  • Identification data (e.g. identity documents, tax information)
  • Financial information such as details of total wealth and origin of funds
  • Product and advice history as well as any scoring or risk data
  • Advertising and communication data, e.g. whether you use a particular channel or have requested particular content
  • Documentation data (e.g. consents, contractual documents, records)

In addition, we process – where permitted – data from publicly accessible sources (e.g. commercial register, press) or from service providers that we use with your consent or for the performance of the contract.

5.4 When you take part in a webinar or online meeting

  • Participant data such as name, email address, telephone number, and where applicable department or profile picture
  • Meeting metadata, e.g. topic, timestamps, IP address, device information
  • Communication content (chat messages, questions, surveys) as well as, where applicable, audio/video data if you actively use a microphone or camera
  • Recordings, if you have consented: video/audio recordings, presentations, chat content
  • Telephone data if you join by dial-in (e.g. phone number, connection duration, location information)

6. For what purpose and on what legal basis do we process your data?

6.1 For entering into and performing contracts (Art. 6 Abs. 1 lit. b DSGVO)

We process personal data where this is necessary for the conclusion or performance of a contract with you – in particular in the context of our digital wealth management. This comprises both pre-contractual measures at your request and all processes necessary for the performance of our services.

These purposes include in particular:

  • registration on our platform and the creation of a client account
  • the assessment of your suitability within the framework of statutory requirements (e.g. risk profile, investment objectives)
  • the execution of transactions, e.g. securities purchases, deposits and withdrawals
  • identity and legitimation checks, e.g. by means of identity documents
  • communication with you via our digital channels, e.g. for queries or to confirm orders
  • the provision of relevant information and documentation, for example on your assets, your contracts or your risk profile
  • the display of your holdings in the ZUWAX dashboard, including transaction and custody-account data, provided you have released us from confidentiality vis-à-vis your custodian bank

The specific processing depends in each case on the product or service you use – e.g. discretionary portfolio management, investment brokerage or account and custody services.

6.2 On the basis of a balancing of interests (Art. 6 Abs. 1 lit. f DSGVO)

We also process personal data where this is necessary to safeguard our legitimate interests or those of third parties – unless your interests or fundamental rights and freedoms prevail. This concerns in particular the following cases:

6.2.1 For all user groups

  • Ensuring information and cybersecurity, e.g. by logging technical access data
  • Error-free provision and optimisation of our digital offerings, e.g. through analysis of server log data.
  • Statistical evaluations and usage analyses in order to further develop our website, products and services
  • Assertion and defence of legal claims, e.g. in disputes or compliance requirements

6.2.2 For platform users and clients

  • Measures for the further development of our products and services, for example through analysis of usage data
  • Direct marketing or client outreach, provided you have not objected
  • Optimisation of our internal processes and business steering
  • Review and improvement of needs-analysis procedures

6.2.3 For webinar participants

  • Processing of your questions or contributions for the follow-up of webinars, where required for content summaries or follow-ups
  • Logging of chat or survey data, where necessary for documentation or to improve our formats
  • Technical implementation, e.g. checking device compatibility and connection quality

6.3 On the basis of statutory requirements (Art. 6 Abs. 1 lit. c DSGVO)

As an investment firm, ZUWAX is subject to various statutory and regulatory obligations. The processing of personal data may therefore also take place where it is necessary to fulfil these legal requirements. These include in particular:

  • Provisions of the Money Laundering Act (GwG), the Securities Trading Act (WpHG) and tax law
  • Requirements of supervisory authorities, such as the Federal Financial Supervisory Authority (BaFin) and Deutsche Bundesbank

Purposes of this data processing include, for example:

  • Performance of identity and age checks
  • Performance of suitability assessments
  • Prevention of fraud and money laundering
  • Fulfilment of tax reporting obligations
  • Risk assessment and risk steering

6.4 On the basis of your consent (Art. 6 Abs. 1 lit. a DSGVO)

In certain cases we process your personal data on the basis of your express consent. This concerns in particular:

  • the use of certain services on our website, for example live chat, contact forms or newsletter forms,
  • analysis and personalisation via cookies or comparable technologies (e.g. in the context of web tracking and remarketing),
  • the recording of webinars or online meetings,
  • and targeted outreach or advertising communication based on your usage behaviour.

Before any processing based on consent, you receive transparent information on the purpose of the processing. You decide yourself whether you wish to consent.

Consent is not required for central functions and offerings of our platform.

Certain optional services (e.g. newsletter, contact via forms, live chat or participation in a webinar) nevertheless require your consent – otherwise we cannot provide these offerings to you. You may withdraw your consent at any time with effect for the future – for example by e-mail to [email protected] or via the corresponding settings in the cookie banner. Data processing that took place up to withdrawal remains unaffected.

6.4.1 Details of consent: analysis of marketing effectiveness

Where you have given your consent in the relevant place, we process certain personal data – for example your e-mail address or telephone number – in pseudonymised form in order to better understand the effectiveness of our marketing measures and to improve them in a targeted way.

This may include transmitting these data in encrypted (hashed) form to selected advertising partners such as Google. In this way, clicks on advertisements can be linked with subsequent interactions (such as registrations or purchases).

Transmission takes place exclusively via secure connections and not in clear text. Processing serves solely the purpose of steering our campaigns more precisely and measuring their success.

Your consent is voluntary and may be withdrawn at any time with effect for the future, for example by email to [email protected].

6.4.2 Details of consent: audience-specific marketing

Where you have consented to this data processing at the relevant point, we use certain personal data – such as your name, email address and age – for target-group-specific marketing. This includes, among other things:

  • the creation of lookalike audiences on social networks,
  • so-called retargeting, in order to display our content to you again,
  • as well as the address-accurate delivery of advertising for ZUWAX offerings.

For this we transmit your data in pseudonymised and encrypted form (e.g. hashed) to selected service providers such as Meta or LinkedIn. The data serve exclusively the purpose of reaching relevant groups of persons as efficiently as possible. Transmission in clear text does not take place.

Consent is voluntary and may be withdrawn at any time with effect for the future, e.g. by e-mail to [email protected]. Your decision has no effect on your business relationship with ZUWAX.

6.4.3 Details of consent: analysis of your usage behaviour

Where you have given consent at the relevant point, we analyse your usage behaviour in connection with our digital offerings in order to provide you with as individual and needs-based a user experience as possible. Specifically this includes:

  • the evaluation of open and click rates of our e-mails,
  • the analysis of your use of our website or web app,
  • the evaluation of interactions with chat messages,
  • as well as the derivation of interests in order to improve our communication and product experience.

These personalised analyses enable us to tailor content to your wishes and needs – e.g. on your dashboard or in personal contact.

Consent is voluntary and may be withdrawn at any time with effect for the future, e.g. by e-mail to [email protected]. Your decision has no effect on your business relationship with ZUWAX.

6.4.4 Details of consent: use of chat services, AI systems and Assisted Onboarding

When you use our interactive support offerings – for example live chat, assisted onboarding or AI-supported systems for answering questions – we process certain personal data.

This includes in particular:

  • Your messages in the chat (e.g. questions, answers, free text),
  • Usage information (e.g. times, interactions, read receipts),
  • where applicable, technical information such as browser or device type.

The underlying systems may be based in whole or in part on artificial intelligence (AI). Corresponding functions are clearly labelled. They are used responsibly and in line with the principles of the EU AI Act – in particular with regard to transparency, safety and non-discrimination.

Important: please do not transmit sensitive information such as account details or personal documents in the chat.

Use of these offerings is voluntary. If you use them, you consent to the associated data processing. You may withdraw your consent at any time with effect for the future – e.g. to [email protected] – or discontinue use of the offerings.

7. Who receives your data?

We share personal data only with bodies that are required to fulfil the purposes described. These include in particular:

  • Our employees, insofar as they require access to fulfil their tasks,
  • Processors pursuant to Art. 28 DSGVO who support us in areas such as IT services, hosting, communications, sales, analytics or marketing. They are contractually obliged to process your data only on our instructions and in accordance with applicable data-protection law.
  • Public authorities and supervisory bodies (e.g. BaFin, Deutsche Bundesbank, tax authorities), where a statutory obligation exists.
  • Authorities or third parties legally entitled, where a corresponding obligation exists,
  • Credit and financial institutions or comparable bodies, where this is necessary in the context of the business relationship with you (e.g. for custody, payment processing or transactions).

An overview of the services currently used – for example for web analytics and conversion tracking – can be found in the section on cookies and similar technologies and in our cookie banner.

8. Are data transferred to a third country or an international organisation?

ZUWAX works primarily with processors that operate the data centre relevant for data processing in the EU and are therefore subject to European (EU) data protection law.

If this is not possible, a transfer of data to third countries takes place in principle only if a level of data protection equivalent to European data protection law can be guaranteed by the fact that:

  • an adequacy decision of the European Commission exists for the third country,
  • or suitable safeguards have been contractually agreed in advance of the business relationship, for example the EU standard contractual clauses for the transfer of personal data to third countries.

A copy of the appropriate safeguards will be provided on request.

9. How long are your data stored?

We generally store your personal data only for as long as is necessary to fulfil the respective purposes – for example to perform a contract, to answer your enquiry or to provide our services.

The specific storage duration is determined in particular by the following criteria:

  • the purpose for which the data were collected (e.g. contract processing, communication, analysis),
  • the continuation of a business relationship or a statutory obligation,
  • your consent (e.g. for marketing data),
  • as well as any ongoing retention periods (e.g. under commercial, tax or anti-money-laundering laws).

We delete data that must be stored to fulfil statutory obligations after the corresponding periods expire. These are as a rule between 2 and 10 years, but can – for example in legal disputes or under specialised statutory requirements – also amount to up to 30 years.

If there is no statutory retention obligation, we delete your data as soon as the purpose of processing ceases. Alternatively, you may actively request deletion if no other legal basis for storage exists.

Note: Concrete details on the storage duration of cookies and similar technologies can be found at any time in our cookie banner or in the detailed information deposited there.

10. Do we use automated decisions or profiling?

10.1 Automated decision-making

We do not use exclusively automated decision-making processes pursuant to Art. 22 GDPR. Should this be required in exceptional cases, we will inform you separately in advance where provided by law.

10.2 Profiling (scoring)

For needs-based support, fulfilment of statutory duties and the further development of our services, we in some cases analyse certain usage data. This is done, for example, to prevent financial crime (e.g. in the context of statutory anti-money-laundering checks) or for targeted outreach with suitable product information.

These analyses are never based solely on individual personal characteristics, but always on several pieces of information in context.

11. Is there an obligation to provide data?

In the context of our platform offerings, the provision of personal data is in some cases required by law (e.g. due to anti-money-laundering rules) or necessary for the conclusion and performance of a contract. For example, we are obliged to collect certain information for identity verification before we may enter into a business relationship.

If you do not provide us with the data required for this purpose, we may be unable to provide certain services or offerings, or a desired business relationship may not come about.

In all other cases, the provision of personal data is voluntary. If, for example, you choose not to use optional services or do not wish to give consent, this will not result in any disadvantages for you in the general use of our platform or website.

12. Cookies and similar technologies

12.1 What are cookies?

Cookies and similar technologies are small files or code elements that are stored on your device in order to collect or temporarily store information. They enable basic website functions, improve the user experience, help analyse usage behaviour or serve to display personalised content and advertising.

12.2 How do we use cookies?

We use cookies in order to:

  • to ensure the technical provision of our website,
  • to improve your user experience (e.g. through language or login preferences),
  • to analyse user behaviour and further develop our offerings,
  • and – provided you have consented – to provide personalised content and advertising.

The legal basis is, depending on the category, either our legitimate interest (Art. 6(1)(f) DSGVO) or your voluntary consent (Art. 6(1)(a) DSGVO). You can manage or withdraw your consent at any time via our cookie banner.

12.3 What types of cookies do we use?

  • Necessary cookies. Essential for the operation of the website (e.g. to store logins or privacy preferences).
  • Statistics & analytics cookies. Help us understand how users use our website – for example which pages are particularly popular.
  • Functional cookies. Enable additional functions such as videos, live chats or interaction with social media.
  • Marketing & tracking cookies. Serve to display content and advertising tailored to you – including on other websites.

12.4 Recipients and services used

For analysis and advertising control we use – provided you have consented – selected third-party providers. Processing is based on data-processing agreements and, where applicable, additional safeguards such as standard contractual clauses for transfers outside the EU.

Examples of services and providers used in this area include, among others:

  • Google Analytics / Ads (Google Ireland Ltd.)
  • Meta Pixel / Meta Plugins (Meta Platforms Ireland Ltd.)
  • LinkedIn Conversion Tracking (LinkedIn Ireland)
  • Outbrain, Taboola (recommendation services)
  • Microsoft Clarity (Microsoft Corporation)

Please note: the services used may change. A complete and always up-to-date overview – including storage duration and purpose of processing – can be found at any time in the cookie banner.

13. Use of social networks

13.1 Data processing by social networks

We operate publicly accessible profiles on social networks. When you visit our pages or interact with embedded social-media content (e.g. “Like” buttons), your user behaviour may be analysed by the respective operators. They record, for example, which content you view or how you interact with our profile, in order to create user profiles and interest clusters. On this basis, interest-based advertising can be displayed within and outside the network.

13.2 Responsibility and rights

For data processing when you visit our social-media presence, we are jointly responsible with the respective platform provider (Art. 26 DSGVO). You can in principle assert your rights (e.g. to information or erasure) both vis-à-vis us and directly vis-à-vis the provider. Please note: our influence on the specific processing by the platforms is limited – it is governed by their respective business models and privacy policies.

13.3 Legal basis

Our presence on social networks serves public relations, dialogue with interested parties and clients, and the visibility of our offerings. This use is based on legitimate interests (Art. 6(1)(f) GDPR). For further processing, such as personalised advertising, the platform operators themselves are responsible. Please refer to the providers’ privacy notices for the legal bases.

13.4 Retention period

We delete data that we collect in the context of social networks as soon as the purpose ceases or you withdraw your consent. Please refer to the privacy notices of the network operators themselves for the storage duration of data by those operators. You can delete stored cookies at any time via your browser settings.

13.5 Information from the providers

Further information on data processing can be found in the respective privacy policies and terms of use of the platforms:

  • Facebook: https://www.facebook.com/privacy/policy
  • Instagram: https://privacycenter.instagram.com/policy
  • LinkedIn: https://www.linkedin.com/legal/privacy-policy
  • XING: https://privacy.xing.com/de/datenschutzerklaerung
  • X (formerly Twitter): https://x.com/privacy

14. Applications at ZUWAX

You have the option of applying to us via an online application form. We then collect and process your personal data for the purpose of conducting the application process and taking pre-contractual measures. By submitting an application on our recruiting page, you express your interest in taking up employment with us. In this context you transmit personal data to us, which we use and store exclusively for the purpose of your job search / application.

In particular, the following data are collected:

  • Name (first and last name)
  • Email address
  • Telephone number
  • Channel through which you became aware of us

The data submitted in the course of your application are transmitted with TLS encryption and stored in a database. This database is operated by Ashby, Inc., which offers an Applicant Tracking System (ATS) (https://www.ashbyhq.com/). Ashby, Inc. is in this connection our processor pursuant to Art. 28 DSGVO. The basis for processing is a data-processing agreement between us as the controller and Ashby, Inc. Your data are thereby transmitted to servers of Ashby, Inc. in the USA. To ensure appropriate safeguards, standard contractual clauses pursuant to Art. 46(2)(c) DSGVO have been agreed. Further information on data processing by Ashby, Inc. can be found at: https://www.ashbyhq.com/resources/privacy.

In the course of the application process we may process publicly available information about you (e.g. from professional networks or search engines) insofar as this is necessary to assess your suitability for the advertised position. In doing so, we take care to consider only such data as have a factual connection to the intended activity.

Furthermore, it is possible that we receive data from recruitment agencies to which you have entrusted your application documents and which propose you to us as a candidate for a position. If references from previous employers are to be requested, this will be discussed separately with the applicant.

14.1 Purpose and legal basis of processing

In the course of your application we process your personal data – including, for example, contact details such as name and address, your educational and professional background, certificates and credentials, or notes from interviews – in order to decide on the establishment of an employment relationship.

Processing is based on:

  • Art. 6(1)(a) DSGVO, where you give us voluntary consent (e.g. for inclusion in an applicant pool),
  • Art. 6(1)(b) DSGVO (pre-contractual measures),
  • Art. 6(1)(c) DSGVO, on the basis of statutory requirements (e.g. feedback to the Federal Employment Agency as well as information to offices, authorities and courts where we are obliged to provide it), and
  • Art. 6(1)(f) DSGVO (legitimate interests, e.g. compliance checks, improvement of the application process and defence against or assertion of legal claims).
  • § 26 BDSG (where applicable).

Within our company, your data are disclosed only to persons who are directly involved in the application process. These are typically employees of the human resources department and of the specialist department in which the position is to be filled, for example the manager in whose team the role sits.

With regard to the disclosure of data to recipients outside our company, it should be noted that we pass on information about you only where statutory provisions require it, you have consented, or we are authorised to provide information. Under these conditions, recipients of personal data may include, for example, public bodies and institutions (e.g. authorities) where a statutory or official obligation exists.

In addition we work with service providers who support us. We transmit your personal data to our service providers and cooperation partners only where a legal basis exists. These are service providers in the following areas:

  • Recruitment consultants and agencies
  • Headhunter
  • Service providers for assessing applicant qualifications

Further data recipients may include those bodies for which you have given us your consent to data transmission, or to which we are authorised, following a balancing of interests, to transmit personal data.

If an employment relationship is established, your application data will continue to be used for the performance of the employment relationship.

Regarding the use of automated decision-making and profiling (scoring), you will find more information in section 10 of this privacy policy.

14.2 Retention period

If no employment results, we retain your data for up to 6 months after conclusion of the application process. This period serves in particular as evidence under the Allgemeines Gleichbehandlungsgesetz (AGG). After expiry of the period we delete your data, unless statutory retention obligations or other legal grounds exist for longer storage (e.g. in ongoing legal proceedings).

If an employment contract is concluded between you and us, your application documents will be included in the personnel file and stored at least for the duration of the employment relationship and any subsequent retention obligations.

If you give us a separate consent (e.g. for inclusion in our talent pool), storage takes place on that basis and until you withdraw it, or the storage period is also determined by the statutory limitation periods, which, for example under §§ 195 ff. of the Bürgerliches Gesetzbuch (BGB), can as a rule be three years. You may withdraw your consent at any time with effect for the future – by email to [email protected].

14.3 Data protection rights & enquiries

An application to our firm is voluntary. However, providing your personal data regarding your previous professional and/or educational background, your qualifications, your skills and information about yourself as well as your contact details is necessary so that we can determine whether you as an applicant fit the position to be filled and so that we can make a corresponding personnel selection. Without you as an applicant providing these data, no personnel selection can take place in the application process. Consequently, a failure to provide personal data means that you cannot be considered as a candidate for the vacancy.

Information on your right to object pursuant to Article 21 DSGVO

You have the right, on grounds relating to your particular situation, to object at any time to processing of personal data concerning you which is based on Art. 6 Abs. 1 lit. e DSGVO (processing in the public interest) and Art. 6 Abs. 1 lit. f DSGVO (processing on the basis of a balancing of interests).

If you object, we will no longer process your personal data for these purposes, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

You have an unrestricted right to object pursuant to Art. 21 Abs. 2 and 3 DSGVO to any form of processing for the purposes of direct marketing. If you object to processing for direct-marketing purposes, we will no longer process your personal data for these purposes.

If you have questions about the processing of your application data or wish to exercise your rights, please contact [email protected] at any time. Further information on responsibility and your rights can be found further above in this privacy notice.