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Gain Access to Private Equity, Real Estate, and Passive Income with Minimized Risks

We provide investors and entrepreneurs access to off-market investments and guide them on how to minimize risk and the opportunity to outperform traditional markets

Data Management and Privacy Policy

At and Company, we are committed to safeguarding your personal data and ensuring transparency in how we collect, store, and use it. As an entity under German law, we adhere to the EU General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG), and the Telemedia Act (TMG). We have implemented technical and organizational measures to comply with data protection regulations, both internally and through our external service providers.

I. Name and Address of the Controller

The controller, as defined by the General Data Protection Regulation and related data protection laws, is:

Philipp Pagels and Company Philipp Pagels EU Friedensstraße 2 06925 Annaburg Email: hello(@) Website:

II. Provision of the Website and Generation of Log Files

a) Description and Scope of Data Processing

Whenever you visit our website, our system automatically collects data and information from your computer system. The following data is gathered during this process:

  • Information about your browser type and version
  • Your operating system
  • Your Internet Service Provider
  • Your IP address
  • Date and time of access
  • Referrer website(s)
  • Websites accessed from our website

This data is stored in log files on our system but is not combined with any other personal data about you.

b) Legal Grounds for Data Processing

The legal basis for the temporary storage of data and log files is outlined in Article 6, Paragraph 1, Part (f) of the EU General Data Protection Regulation (GDPR).

c) Purpose of Data Processing

The temporary storage of your IP address is necessary for delivering our website's content to your computer. For this purpose, your IP address must be stored for the duration of your session.

Log file storage is crucial for ensuring the functionality of the website, optimizing its performance, and securing our Information Technology systems. Please note that data analysis for marketing purposes does not occur in this context.

Our website,, automatically collects general data and information each time you or an automated system accesses it. This data includes:

  • Browser types and versions
  • The operating system used
  • Referrer website(s)
  • Sub-pages visited
  • Date and time of access
  • IP address
  • Internet service provider
  • Other similar data used for system security

We do not draw any conclusions about your identity based on this data. Instead, it is collected to:

  1. Deliver the website's contents correctly
  2. Optimize and promote the website
  3. Ensure the ongoing functionality of our IT systems
  4. Provide information for law enforcement organizations to investigate cyber-attacks

This anonymous data is analyzed for statistical purposes and to enhance data protection and security at our research center, ensuring the protection of your personal data. This anonymous data in server log files is stored separately from all other personal data.

These purposes align with our legitimate interests in data processing, as per Article 6, Paragraph 1, Part (f) of the GDPR.

At Philipp Pagels and Company, we value your privacy and strive to maintain the highest standards of data protection and transparency. If you have any questions or concerns regarding your data, please don't hesitate to contact us at hello(@) Your trust is important to us, and we are committed to doing the right thing, especially when it comes to protecting your data.

d) Duration of storage
The data is deleted as soon as it is no longer needed for the purpose for which it was collected. In the case of data collection for the provision of this website, this applies at the end of each session. In the case of data stored in log files, this occurs after no longer than seven days. Further storage is possible; in these cases, the users’ IP addresses are deleted or pseudonymised to prevent any association with the accessing client.

e) Right to objection and removal
The collection of data for the provision of our website and the storage of data in log files is crucial to operation of the website. Hence, users are not granted a right to object.

III. Use of Cookies

a) Description and Scope of Data Processing

Our website employs cookies to enhance user experience. Cookies are small text files stored on your computer system by your web browser. They play a crucial role in making websites more user-friendly.

Many websites and servers utilize cookies, which often contain a unique identifier known as a cookie ID. This identifier is a sequence of characters that allows websites and servers to recognize and distinguish your individual browser from others, each containing different cookies. The unique cookie ID helps websites and servers identify a specific Internet browser.

Cookies serve various purposes on our website:

  1. Technically Necessary Cookies: These cookies improve user-friendliness by recognizing your browser when you navigate from one page to another. They optimize the information and services provided on our site, making your visits more seamless. For example, these cookies eliminate the need to re-enter login details during each visit as the website retrieves this information from the cookie on your computer system.

  2. Cookies for Analysis: We also use cookies to analyze how visitors use our website. This analysis includes data such as search terms entered, page access frequency, and the utilization of website functions. We take technical measures to pseudonymize this data, ensuring it cannot be associated with individual users. This data is not combined with other personal data.

Upon accessing our website, an information banner notifies users of our use of cookies for analysis purposes and directs them to this Privacy Notice. We also provide information on how users can adjust their browser settings to prevent cookie storage. When users access our website, we obtain their consent for processing personal data related to these cookies and provide a reference to this Privacy Notice.

b) Legal Basis for Data Processing

i. The legal basis for processing personal data using technically necessary cookies is outlined in Article 6, Paragraph 1, Part (f) of the EU General Data Protection Regulation (GDPR).

ii. For the processing of personal data using cookies for analysis purposes with the user's consent, the legal basis is set out in Article 6, Paragraph 1, Part (a) of the GDPR.

c) Purpose of Data Processing

Technically necessary cookies are employed to enhance the user-friendliness of our website. They are essential for certain website functions and ensure smooth navigation.

User data collected through technically necessary cookies is not used to create user profiles.

As for cookies not required for technical reasons:

Analysis cookies are used to improve our website's quality and content. By analyzing how the website is used, we can continuously optimize our services. For a detailed description, please refer to Section IX of this document.

These purposes align with our legitimate interest in processing personal data, as per Article 6, Paragraph 1, Part (f) of the GDPR.

e) Duration of Storage; Right to Objection and Removal

You have the right to adjust your Internet browser settings to prevent our website from placing cookies and block them permanently. Moreover, standard Internet browsers or other software programs allow you to delete cookies already placed on your computer at any time, either manually or automatically. Please note that disabling cookies may impact your ability to fully utilize our website's functionality.

You can change your Internet browser settings to disable or restrict cookie transfers at any time, and you can delete cookies that have been placed on your computer. Most standard Internet browsers support these actions. Disabling cookies, however, may limit your access to the complete functionality of our website.

Your privacy matters to us, and we are committed to providing you with the best possible user experience while respecting your preferences regarding cookies. If you have any questions or concerns about our cookie usage or data processing, please do not hesitate to contact us at hello(@) We value your trust and are dedicated to doing the right thing, even in matters of data privacy.

IV. E-Mail Newsletter

At Philipp Pagels and Company, we offer an email newsletter service through integrated components of the enterprise Convertkit on our website.

a) Description and Scope of Data Processing

Visitors to our website have the opportunity to subscribe to our free newsletter. When you register for the newsletter, the data entered into the input screen is transmitted to us. This includes:

  • First name
  • Last name
  • Email address

Additionally, the following data is collected during registration and stored in our database:

  • First and last name
  • Email address
  • GDPR consent status
  • Subscription status (Subscribed, Activated, Unsubscribed)
  • Subscription date, subscription place, unsubscribe date

Your consent to data processing is obtained during the registration process, and we refer you to this Privacy Notice. We do not share this data with third parties and use it exclusively for delivering the newsletter.

b) Legal Basis for Data Processing

The newsletter is delivered based on the user's registration on our website. The legal basis for processing this data, once the user has provided consent, is outlined in Article 6, Paragraph 1, Part (a) of the EU General Data Protection Regulation (GDPR).

c) Purpose of Data Processing

We collect the user's email address to deliver our newsletter.

d) Duration of Storage

Data is deleted as soon as it is no longer needed for the purpose it was collected for. Therefore, the user's email address, first and last names, are stored for as long as the newsletter subscription remains active.

e) Right to Objection and Removal

Users have the right to unsubscribe from the newsletter at any time. Each newsletter includes a suitable unsubscribe link.

V. Use of Social Media:

We maintain online presences on the social networks Twitter and LinkedIn to inform and communicate with you through these platforms. You can access our social media channels via the corresponding links on our websites. When you access our social media channels on these networks, the terms and conditions, and data processing information of the respective operators apply.

If you follow a link to our social media profiles, a connection is established with the servers of Twitter or LinkedIn, transmitting the IP address with which you visited our website.

If you are logged in as a member of Twitter or LinkedIn, this information is linked to your personal user accounts on these platforms. To prevent this data transmission, please log out of your Twitter or LinkedIn account before using our websites.

For more information on data collection and use, please refer to the privacy policies of Twitter or LinkedIn.

VI. Rights of the Data Subject

As a data subject under the EU General Data Protection Regulation (GDPR), you have several rights concerning your personal data held by the controller:

a) Right to Information

You have the right to confirmation from the controller regarding whether your personal data is being processed. If so, you have the right to obtain the following information:

  • The purposes for processing your personal data.
  • The categories of personal data processed.
  • Recipients or categories of recipients to whom your personal data has been or will be disclosed.
  • The planned duration of storage or criteria used to determine the storage period if precise information is not available.
  • The existence of the right to correction or deletion of your personal data, the right to restrict processing, or the right to object to processing.
  • The right to lodge a complaint with a supervisory authority.
  • Information about the origins of the data if it was not collected from you.
  • The existence of automated decision-making, including profiling, and meaningful information about the logic and potential consequences involved in such processing.

You also have the right to know if your personal data has been or will be transferred to a third country or international organization. In this regard, you can request information about the appropriate safeguards for this processing under Article 46 of the GDPR.

Upon request, the controller will provide a copy of your processed personal data. If you request additional copies, a reasonable fee may be charged based on administrative costs. If your request is made electronically, the information will be provided in a standard electronic format, unless otherwise specified by you. However, this right to receive a copy must not adversely affect the rights and freedoms of others.

b) Right to Correction

You have the right to request the correction of inaccurate personal data concerning you without undue delay. If your personal data is incomplete, you have the right to have it completed, including by providing a supplementary statement.

c) Right to Limit Processing

Under certain conditions, you have the right to request the controller to restrict the processing of your personal data, including when:

  • The accuracy of your personal data is contested, allowing the controller to verify its accuracy.
  • The processing is unlawful, and you oppose the deletion of your data but request the restriction of its use instead.
  • The controller no longer needs your personal data for processing purposes, but you require it for legal claims or defense.
  • You have objected to processing under Article 21, Paragraph 1 of the GDPR, pending verification of whether the controller's legitimate reasons override your own.

When your personal data processing is restricted, it will only be processed with your consent, for legal claims, for the protection of another person's rights, or for reasons of important public interest.

You will be informed by the controller before the restriction of processing is lifted.

d) Right to Deletion

Obligation to Delete:

You have the right to request the controller to delete your personal data without undue delay if one of the following applies:

  • Your personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
  • You withdraw your consent (if consent was the legal basis) and there is no other legal basis for the processing.
  • You object to processing under Article 21, Paragraph 1 of the GDPR, and there are no overriding legitimate grounds for the processing, or you object under Article 21, Paragraph 2 of the GDPR.
  • Your personal data has been unlawfully processed.
  • Your personal data must be deleted to comply with a legal obligation under EU or Member State law.
  • Your personal data was collected in relation to the offer of information society services to children (Art. 8, Paragraph 1 of the GDPR).

Information to Third Parties:

When the controller has made your personal data public and is obliged to delete it, reasonable steps, including technical measures, will be taken to inform other controllers processing your data of your request for deletion, as well as any links to, copies of, or replications of your personal data.


The right to deletion does not apply in cases where processing is necessary:

  • For exercising the right of freedom of expression and information.
  • For compliance with a legal obligation under EU or Member State law.
  • For reasons of public interest in public health.
  • For archiving purposes in the public interest, for scientific or historical research, or for statistical purposes in accordance with Art. 89, Paragraph 1 of the GDPR.
  • For the establishment, exercise, or defense of legal claims.

e) Right to Notification

If you have exercised your right to correction, deletion, or restriction of processing with the data controller, the controller must notify all recipients to whom your personal data was disclosed about these actions, unless this proves impossible or involves a disproportionate effort. You are also entitled to require that the data controller informs you about these recipients.

f) Right to Data Portability

You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used, and machine-readable format. You also have the right to transfer this data to another controller without hindrance, where:

  • The processing is based on your consent or a contract.
  • The processing is carried out by automated means.

In exercising this right, you have the right to have your personal data transmitted directly from one controller to another, where technically feasible. However, this right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

g) Right to Object

You have the right to object to the processing of your personal data at any time,

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