Privacy notice for the FinWell Score in cooperation with Smartbroker

Controller

House of Finance and Tech Berlin GmbH, Saarbrücker Straße 36, 10405 Berlin, Germany. Phone: +49 (0)30 43974287-0, email: info@hoft.berlin

Smartbroker AG is not responsible for the processing on this site. It receives no information from us that could be linked to you (see “Recipients”).

Hosting and server logs

The site is hosted by Netlify, Inc., 101 2nd Street, San Francisco, CA 94105, USA. Netlify processes data on our behalf under a data processing agreement (Art. 28 GDPR) and uses sub-processors for this, including Amazon Web Services.

When you visit the pages, Netlify processes technically necessary data, in particular your IP address, date and time, the page requested, and browser and device information. The purpose is to deliver the pages and keep them secure. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR). According to Netlify, these logs are kept online for 90 days and archived for up to one year.

Taking part

The link in the Smartbroker mailing only contains a group code (segment), for example whether an account opening was not completed or whether an account has not been funded yet. It contains no customer number and no other information about you. The group code follows the “#” sign in the address; it is not sent to any server but read by the page and removed from the address bar straight away.

During and after your participation we store:

• your answers to the 10 questions, and the calculated score, its range and the sub-scores
• your age group (not your exact age) and your gender
• your answers to the optional additional questions after the result, if you answer them
• the segment from the link, the progress of your participation (opened, started, completed) and the last question answered
• a random technical session ID, the language and the times of opening, starting and completing

We do not store your name, email address, customer number or IP address with this data. Answers are saved while you fill in the questionnaire so we can see where participants stop. The data is stored with Netlify in Frankfurt am Main (EU). It is transmitted via Netlify servers, including in the USA.

We use this data to show you your score and the comparison with our study, analyse it for research on financial health, and provide Smartbroker with analyses. The legal basis is our legitimate interest in this research and in the cooperation with Smartbroker (Art. 6(1)(f) GDPR). The additional questions are optional and can be skipped one by one.

Taking part is voluntary. Because we cannot link stored records to a person, we generally cannot find, correct or delete an individual record on request (Art. 11 GDPR). If you give us details that let us identify your record unambiguously, we will act on your request.

Recipients

Netlify as our processor, together with its sub-processors.

Smartbroker AG receives aggregated analyses and records without any identifier: no name, customer number, email address or IP address, and with dates but no time of day. Smartbroker therefore cannot link these records to individual customers. We publish results only in aggregated form and never for groups small enough to allow conclusions about individuals.

We do not sell the data and do not pass it on to anyone else.

Retention

The survey runs until 31 December 2026. We delete incomplete participations no later than 30 days after that date and all other individual records by 31 December 2027. Aggregated results that allow no conclusions about individuals are kept without a time limit.

Transfer to the USA

Netlify, Inc. is certified under the EU-U.S. Data Privacy Framework. Transfers are based on the European Commission's adequacy decision (Art. 45 GDPR). Should the Data Privacy Framework cease to apply, EU standard contractual clauses apply instead (Art. 46(2)(c) GDPR).

No cookies, no tracking

The site sets no cookies and uses no analytics or tracking services. It loads no third-party content; fonts are served from our own server.

So that your answers are not lost if you reload the page, the site keeps your progress in your browser's session storage (sessionStorage). It is deleted when you close the tab. This is technically necessary for the use you requested (Section 25(2) no. 2 TDDDG).

Only the password-protected admin area sets a technically necessary session cookie after login (Section 25(2) TDDDG).

Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20). You can object at any time to processing based on legitimate interests (Art. 21 GDPR). To do so, contact info@hoft.berlin.

You can also lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59–61, 10555 Berlin, Germany.