Data protection

Processing of personal data

1. General Information
The protection of your personal data is of utmost importance to Infinigon GmbH. We process personal data exclusively in accordance with applicable data protection regulations, in particular the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and the Telecommunications Digital Services Data Protection Act (TDDDG, formerly TTDSG).

This privacy policy informs you about which personal data is processed when you visit our website, for what purposes this is done, how long the data is stored, to whom the data is transferred and what rights you have as a data subject.

2. Responsible body:
Infinigon GmbH
Am Meerkamp 23
40667 Meerbusch
Germany

Telephone: +49 (0) 211 3105416 0
Email: info@infinigon-capital.com

Infinigon GmbH is responsible within the meaning of the GDPR.

3. Data Protection Officer:
Alexander Lanin

Email: lanin@infinigon-capital.com
You can contact the data protection officer directly at any time with questions or concerns regarding data protection.

4. Definitions
The definitions in the GDPR apply. We refer to the definitions in Article 4 of the GDPR. These include, in particular:

• personal data
• processing
• affected person
• Responsible
• Data processors

5. Provision of the website and log files
When you access our website, the hosting provider automatically collects information and stores it in server log files. This information does not allow us to draw any direct conclusions about…
Your person:

• IP address
• Date and time of access
• Page/file accessed
• amount of data transferred
• Browser type/version and operating system used
• Referrer URL and domain name of your internet provider

Purpose: Technical provision, system security and technical optimization.

Legal basis: Art. 6 para. 1 lit. f GDPR.

Log files are generally only stored for as long as necessary for the aforementioned purposes and are then deleted.

6. Use of cookies
Our website uses cookies and similar technologies.

We use the “Real Cookie Banner” consent tool to manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents.

Details on how “Real Cookie Banner” works can be found at https://devowl.io/de/rcb/datenverarbeitung/ . The legal basis for processing personal data in this context is Article 6(1)(c) GDPR and Article 6(1)(f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

Providing your personal data is neither contractually required nor necessary for entering into a contract. You are not obligated to provide your personal data. If you do not provide your personal data, we will be unable to manage your consent.

a) Technically necessary cookies
These cookies are necessary to ensure basic website functionality.

Legal basis: Art. 6 para. 1 lit. f GDPR in conjunction with § 25 para. 2 TDDDG

b) Optional cookies (analysis / statistics)
Optional cookies are only set if you give your consent via our cookie consent tool.

Purpose: Technical provision, system security and technical optimization.

Legal basis: Art. 6 para. 1 lit. a GDPR in conjunction with § 25 para. 1 TDDDG

You can withdraw your consent at any time via the cookie settings.

• Change privacy settings
• History of privacy settings
• revoke consent

7. Web analytics with Google Analytics
a) Scope of processing
Our website uses Google Analytics, a web analytics service provided by Google Ireland Limited. Google Analytics uses cookies to analyze website usage.

The following data, in particular, is processed:

• Website usage patterns
• Interactions and page views

No IP addresses are logged or stored within the EU, and no precise location data is provided for EU traffic.

b) Data transfer to third countries
A transfer to the USA cannot be ruled out. Google is committed to complying with appropriate safeguards under the Data Privacy Framework (DPF).

Purpose: The use of Google Analytics serves the purpose of statistical evaluation and continuous improvement of our website.

Legal basis: Art. 6 para. 1 lit. a GDPR (consent)

8. Making contact
When you contact us via contact form or email, we process the data you provide (e.g., name, email address, message).

Purpose: To process your request and, if necessary, further communication.

Legal basis: Art. 6 para. 1 lit. b GDPR (pre-contractual measures) or Art. 6 para. 1 lit. f
GDPR (legitimate interest)

The data will be deleted as soon as the request has been fully processed and there are no legal retention obligations.

9th Newsletter
If you subscribe to our newsletter, this will be done using the double opt-in procedure.

a) Handling of the processing
The following data is processed:

• E-mail address
• Time of registration and confirmation

Purpose: To send information about Infinigon and our investment solutions.

Legal basis: Art. 6 para. 1 lit. a GDPR

b) Revocation
You can withdraw your consent at any time via the unsubscribe link in the newsletter. If you have any questions, please contact lanzenstiel@infinigon-capital.com.

10. Integration of services and content Dr. itter
We sometimes embed third-party content (e.g., Google Maps, YouTube videos, graphics). For this to work, it is technically necessary to transmit your IP address to these providers. We strive to use only providers who use the IP address solely for delivering the content.
Use content.

Purpose: Technical provision, system security and technical optimization.

Legal basis: Art. 6 para. 1 lit. f GDPR.

11. Transfer to third countries
Data is only shared with processors bound by instructions (hosting, IT) or where legally required. Transfer to countries outside the EEA only occurs under certain conditions.
Compliance with an appropriate level of data protection (Art. 44 Q. GDPR).

12. Storage period and deletion
In accordance with the principles of data minimization, we only store data for as long as necessary for the purpose or as required by statutory retention periods (e.g., commercial or tax law).
prescribe.

13. Rights of data subjects

Insofar as we process your data based on legitimate interests, you may object at any time for reasons arising from your particular situation.
In the case of direct marketing, you have a general right to object without having to specify a particular situation.

You have the right to:

• Right of access (Art. 15 GDPR)
• Rectification (Art. 16 GDPR)
• Erasure (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Revocation of granted consent

Special note regarding your right to object pursuant to Article 21 GDPR
Case-specific objection:

You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on point (f) of Article 6(1) of the GDPR (balancing of interests). If you object, 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.

Furthermore, there is a right to lodge a complaint with the competent data protection supervisory authority:
State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia

14. Data security
We implement technical and organizational measures to protect your data from unauthorized access, loss or manipulation.

15. Currentness and changes
This privacy policy will be updated as needed to reflect legal or technical changes. The version published on our website is the authoritative version.

As of January 2026