General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data includes all data that can personally identify you. Detailed information on data protection can be found in our privacy policy listed below this text.

1. Data Collection on this Website

a) Who is responsible for data collection on this website? The data processing on this website is carried out by the website operator. The operator’s contact details can be found in the section labeled “XXX; with reference to the Responsible Entity; in this privacy policy.”

b) How do we collect your data? Your data is collected when you provide it to us. This can include data entered into a contact form, for example. Other data is automatically collected or with your consent when you visit the website through our IT systems. This primarily includes technical data (e.g., internet browser, operating system, or time of page access). The collection of this data occurs automatically as soon as you enter this website.

c) What do we use your data for? Some of the data is collected to ensure the proper functioning of the website. Other data may be used to analyze your user behavior.

d) What rights do you have regarding your data? You have the right to obtain free information about the origin, recipient, and purpose of your stored personal data at any time. You also have the right to request the correction or deletion of this data. If you have given consent for data processing, you can revoke this consent at any time for the future. Additionally, under certain circumstances, you have the right to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the relevant supervisory authority. For these matters and other questions related to data protection, you can contact us at any time.

e) Analysis Tools and Third-Party Tools When visiting this website, your surfing behavior may be statistically evaluated, primarily through analysis programs. Detailed information about these analysis programs can be found in the following privacy policy.

2. Hosting

a) External Hosting This website is externally hosted. The personal data collected on this website is stored on the servers of the hosting provider. This may include, for example, IP addresses, contact inquiries, meta and communication data, contract data, contact details, names, website access, and other data generated by a website. External hosting is carried out for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 (1) lit. b GDPR) and in the interest of a secure, fast, and efficient provision of our online offering by a professional provider (Art. 6 (1) lit. f GDPR). If consent has been obtained, processing is carried out solely based on Art. 6 (1) lit. a GDPR and § 25 (1) TTDSG, to the extent that the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time. Our hosting provider will process your data only to the extent necessary to fulfill its contractual obligations and will follow our instructions regarding this data.

We use the following hosting provider: 
Domainfactory GmbH, c/o WeWork, Neuturmstrasse 5, 80331 München, Deutschland

b) Data Processing Agreement We have entered into a data processing agreement (DPA) for the use of the aforementioned service. This is a legally required agreement ensuring that the personal data of our website visitors is processed only according to our instructions and in compliance with the GDPR.

3. General Information and Mandatory Information

a) Data Protection The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy. When you use this website, various personal data is collected. Personal data is data that can personally identify you. This privacy policy explains which data we collect and for what purpose. We point out that data transmission over the Internet (e.g., when communicating by e-mail) can have security gaps. A complete protection of the data against access by third parties is not possible.

b) Responsible Party The responsible party for data processing on this website is: Robert Nowikovsky. The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g., names, e-mail addresses, or other data).

c) Storage Period Unless a specific storage period is specified within this privacy policy, your personal data will remain with us until the purpose for data processing ceases to exist. If you make a legitimate deletion request or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial retention periods); in the latter case, the deletion will take place after these reasons cease to exist.

d) General Notes on the Legal Bases of Data Processing on this Website If you have given your consent to data processing, we process your personal data based on Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR if special categories of data are processed under Art. 9 (1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing also takes place based on Art. 49 (1) lit. a GDPR. If you have consented to the storage of cookies or access to information on your device (e.g., via device fingerprinting), the data processing additionally takes place based on § 25 (1) TTDSG. Consent can be revoked at any time. If your data is necessary for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data based on Art. 6 (1) lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation based on Art. 6 (1) lit. c GDPR. Data processing can also be carried out based on our legitimate interest according to Art. 6 (1) lit. f GDPR. The relevant legal bases for data processing in each individual case are provided in the following paragraphs of this privacy policy.

e) Recipients of Personal Data In the course of our business activities, we collaborate with various external entities. In some cases, the transmission of personal data to these external entities is necessary. We only disclose personal data to external entities if this is necessary for the fulfillment of a contract, if we are legally obliged to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure based on Art. 6 (1) lit. f GDPR, or if another legal basis allows data transfer. When using processors, we only disclose personal data of our customers based on a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

f) Revocation of Your Consent to Data Processing Many data processing operations are only possible with your express consent. You can revoke consent that has already been given at any time. The legality of the data processing carried out

g) Right to Object to Data Collection in Special Cases and Against Direct Advertising (Art. 21 GDPR)

If data processing is based on Art. 6(1)(e) or (f) GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation, including objection to profiling based on these provisions. The respective legal basis for processing can be found in this privacy policy. If you object, we will no longer process your affected personal data unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims (objection pursuant to Art. 21(1) GDPR). If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct advertising. If you object, your personal data will subsequently no longer be used for the purpose of direct advertising (objection pursuant to Art. 21(2) GDPR).

h) Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, especially in the member state of their habitual residence, place of work, or the place of the alleged violation. This right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

i) Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to yourself or to a third party in a common, machine-readable format. If you request the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.

j) Information, Correction, and Deletion

Within the scope of the applicable legal provisions, you have the right to free information about your stored personal data, its origin and recipient, the purpose of data processing, and, if necessary, a right to correction or deletion of this data. For this purpose, as well as for other questions regarding personal data, you can contact us at any time.

k) Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. This right exists in the following cases:

• If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the examination, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data is unlawful, but you oppose the deletion of your data and instead request the restriction of the data processing.
• If we no longer need your personal data, but you need it for the exercise, defense, or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
• If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.
• If you have restricted the processing of your personal data, this data—apart from its storage—may only be processed with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a member state.

l) SSL/TLS Encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. Data Collection on this Website

a) Cookies

Our website uses so-called cookies. Cookies are small data packets that do not cause any damage to your end device. They are either temporarily stored for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted after your visit. Permanent cookies remain stored on your end device until you delete them yourself or until automatic deletion by your web browser. Cookies can be from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services). Cookies have various functions. Many cookies are technically necessary because certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies may be used to evaluate user behavior or for advertising purposes. Cookies that are necessary for the performance of the electronic communication process, for the provision of certain functions you requested (e.g., the shopping cart function), or for the optimization of the website (e.g., cookies for measuring the web audience) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and similar recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and § 25(1) TTDSG); consent can be revoked at any time. You can configure your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for specific cases or in general, and activate the automatic deletion of cookies when you close your browser. If cookies are deactivated, the functionality of this website may be limited. Information about the cookies and services used on this website can be found in this privacy policy.

b) Contact Form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent. The processing of this data is based on Art. 6(1)(b) GDPR, insofar as your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this was requested; consent can be revoked at any time. The data you enter in the contact form will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions—especially retention periods—remain unaffected.

c) Inquiry by Email, Telephone, or Fax

If you contact us by email, telephone, or fax, your inquiry, including all resulting personal data (name, inquiry), will be stored and processed by us for the purpose of processing your request. We do not pass on this data without your consent. The processing of this data is based on Art. 6(1)(b) GDPR, insofar as your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this was requested; consent can be revoked at any time. The data you send us via contact requests will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions—especially statutory retention periods—remain unaffected.

Data Controller:

Robert Nowikovsky,
Gral. Mariano Melgarejo N° 349, 2nd floor 
Asuncion,
Paraguay

Email: r.nowikovsky@luga-invest.com