Privacy Policy
Effective Date: 17 April 2025
Protecting your personal data is of utmost importance to Flynance Expat. This Privacy Policy explains the nature, scope and purpose of the processing of personal data in accordance with the General Data Protection Regulation (GDPR) and applicable German data protection laws.
1. Controller
Flynance Expat
Wilhelminenstr. 11
04129 Leipzig
Germany
Email: info@flynanceexpat.com
Phone: +49 176 41081846
For certain financial advisory services (see Section 10), processing may take place jointly with HORBACH Wirtschaftsberatung GmbH.
PART A – WEBSITE & MARKETING PROCESSING
(Flynance Expat as Sole Controller)
2. Data Collected When Visiting Our Website
When you access our website, the following data may be processed:
– IP address (anonymized where applicable)
– Date and time of access
– Browser type and version
– Operating system
– Referrer URL
– Pages visited
Processing is based on Art. 6(1)(f) GDPR (legitimate interest in website security and optimization).
3. Contact Form & Direct Communication
If you contact us via email or contact form, we process:
– Name
– Email address
– Phone number
– Message content
Legal basis:
Art. 6(1)(b) GDPR (pre-contractual measures)
Art. 6(1)(a) GDPR (if consent-based)
Data is stored only as long as necessary to process your request.
4. Newsletter
If you subscribe to our newsletter:
If you sign up for our newsletter, we will use your email address to send you regular updates, news, and offers related to our services.
We use a double opt-in process to ensure that the subscription is truly intended by you. Your data is stored securely and will not be shared with third parties for advertising purposes. Processing is based on Art. 6(1)(a) GDPR
You can unsubscribe at any time via the unsubscribe link in each newsletter or by emailing us at info@flynanceexpat.com
5. Cookies & Tracking Technologies
We use cookies to make navigation and use of our website as user-friendly as possible. Cookies are small text files that are deposited on your hard drive when you access our services.
Cookies also serve, for example, to recognize the users of our website and not have to ask them again for their access data each time they visit the website. Cookies are also used to track visitor preferences, which can help to optimize the layout of our website. This enables us to make targeted adjustments of the content of our website to meet your needs and improve our offer to you. Cookies used by us do not store any personal data and do not enable you to be personally identified.
You can deactivate storage of these cookies and delete existing cookies in the system settings of your browser at any time. Any user can view our services without non-essential cookies. However, if you do not accept cookies, this can restrict the available functionality.
5.1 Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Inc. (‘Google’). Google Analytics uses cookies, which enable analysis of your use of the website. Information generated by cookies about your use of this website is normally transmitted to a Google server in the USA and stored there.
However, if IP anonymisation is activated on this website, your IP address will first be shortened by Google within member states of the European Union or in other countries that are signatories of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. Google will use this information on behalf of the provider of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website usage and internet usage for the website provider.
The IP address transmitted by your browser for Google Analytics will not be associated with any other data held by Google. You can prevent these cookies being stored by selecting the appropriate settings in your browser; however, please note that doing so may make you unable to use the full functionality of this website.
You can also prevent the data generated by the cookies about your use of the website (including your IP address) being sent to and processed by Google by downloading and installing the browser plugin available from the following link:
http://tools.google.com/dlpage/gaoptout?hl=en
Please note that we also use the extended Google Analytics remarketing and advertising functions, alongside the standard Google Analytics functions. Based on a user’s previous visits to our website, the remarketing and advertising functions enable analysis and placement of optimised, interest-based advertising on other websites within the Google Display Network (on Google itself, on Google Ads, or on other websites). Google Analytics uses a third-party cookie from DoubleClick to evaluate data on user browsing habits on various websites. These data can provide information on topics such as demographics and the interests of website users.
DoubleClick cookies do not contain or store any personal user data; this means you cannot be personally identified at any time.
You can prevent these cookies being stored by selecting the appropriate settings in the cookie settings or in your browser. You can also deactivate interest-based advertising on Google and interest-based Google ads (within the Google Display Network) in your browser by going to https://adssettings.google.com or http://www.google.com/settings/ads/onweb/?hl=en and switching the button to ‘off’, or deactivate ads on http://www.aboutads.info/choices. You can find further information on available settings and Google data protection on https://www.google.com/intl/en/policies/privacy/?fg=1.
Google Remarketing: In addition, this website uses the Google program for interest-based advertising – the so-called Google Remarketing. Third-party providers, including Google, place ads on websites on the Internet and use stored cookies for this on the basis of a user’s previous visits to this website. You can also disable Google’s use of cookies for these purposes by visiting the Google advertising opt-out page.
Please note that Google has its own privacy policies, of which Flynance Expat is independent. We do not take any responsibility or liability for these policies and procedures.
Processing is based on your consent (Art. 6(1)(a) GDPR).
5.2 Google Ads & Remarketing
We use Google Ads conversion tracking to measure campaign effectiveness and display relevant advertising.
Processing occurs only after consent.
5.3 Meta Pixel (Facebook & Instagram)
a. Use of Facebook Pixel
We use Facebook’s Pixel service, provided by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, for online advertising. Here anonymised data on browsing habits is collected. The data collected is only general and technical information of the page visited. These are not linked to or evaluated together with the user’s personal data. You can deactivate this type of data processing by opting out on the following link: http://www.youronlinechoices.com/uk/your-ad-choices. Facebook users can also deactivate this type of data processing on the following link: https://www.facebook.com/settings?tab=ads.
b. Facebook Custom Audiences Pixel
On our website, the pixel variant of Facebook Custom Audiences (without the so-called advanced matching function) is used. This tool is provided by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA. With the help of Facebook Pixel, technical data about your use of our website can be sent to Facebook. If you are registered with Facebook, Facebook can assign the sent data to you based on an automated matching of hash values and show you interest-based advertising on your home page. Such advertising may, for example, be special offers. Facebook assures in the Custom Audience Terms of Use that it will process the collected data exclusively for this advertising purpose in our Custom Audience.
You can find out more about the advertising by Facebook and how you can influence it here under Facebook – Settings for advertisements. As a user of Facebook, you can deactivate the data processing described under the following link https://www.facebook.com/settings?tab=ads.
5.4 TikTok Pixel
We use TikTok Pixel on our website. TikTok Pixel is an advertisement tool provided by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, WeWork, 125 Kingsway, London, WC2B 6NH, United Kingdom (“TikTok”). This is a code that allows us to understand and track your behavior on our website. TikTok uses login or device information to identify users of this website and associate it with a TikTok user account. This data is then used by TikTok to display tailored advertisements and content of interest to its users. The collected data is anonymous and not visible to us and is only used for the purpose of measuring the effectiveness of ad placements. Your data will generally be processed within the EU or the EEA. In the event that a data transfer takes place outside the EU or the EEA, this will take place within the framework of standard contractual clauses in accordance with Art. 46 GDPR. TikTok’s privacy policy can be found here: https://www.tiktok.com/legal/new-privacy-policy?lang=de-DEf.
5.5 Google reCaptcha
On the basis of Art. 6 para. 1 sentence 1 lit. f GDPR, we use the reCAPTCHA service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter “Google”, to protect your inquiries via the Internet form. The query is used to distinguish whether the input is made by a human or abusively by automated, machine processing. The query includes sending the IP address and any other data required by Google for the reCAPTCHA service to Google. For this purpose, your input is transmitted to Google and used there. However, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of this service. The IP address transmitted by your browser as part of reCaptcha will not be merged with other Google data. The deviating data protection provisions of Google apply to this data. You can find more information about Google’s privacy policy at: https://www.google.com/intl/de/policies/privacy/
On our Internet pages you will find links that refer to Internet pages of third parties. We therefore expressly point out that we have no influence on the content and design of the linked pages. Flynance Expat assumes no responsibility or liability for their policies and procedures. On the servers, to which the external links lead, there can be other privacy policies.
6. International Data Transfers
Where data is transferred outside the EU/EEA (e.g. to the United States), this occurs on the basis of:
EU Standard Contractual Clauses
EU–US Data Privacy Framework (if applicable)
7. Data Retention
Data is stored only as long as required for:
– Contract performance
– Legal obligations
– Legitimate business interests
After expiration of statutory retention periods, data is securely deleted.
PART B – FINANCIAL ADVISORY & INSURANCE MEDIATION
8. Scope of Advisory Services
Flynance Expat operates as a registered insurance intermediary pursuant to §34d GewO within the advisory structure of HORBACH Wirtschaftsberatung GmbH.
For the purpose of providing holistic financial advisory and insurance mediation services, personal data may be processed jointly with HORBACH Wirtschaftsberatung GmbH and affiliated entities within the Swiss Life Group.
9. Categories of Advisory Data Processed
Depending on the advisory case, this may include:
– Identity data
– Contact details
– Tax identification numbers
– Income information
– Insurance data
– Contract data
– Bank details
– Documentation relevant to insurance mediation
10. Joint Processing (Art. 26 GDPR)
In the context of financial advisory and insurance mediation services, personal data is processed jointly with:
HORBACH Wirtschaftsberatung GmbH
Swiss-Life-Platz 1
30659 Hannover
Germany
HORBACH provides:
– CRM systems
– Documentation platforms
Regulatory infrastructure
– Administrative processing
– Contract management support
The allocation of responsibilities between Flynance Expat and HORBACH Wirtschaftsberatung GmbH is governed by a Joint Controller Agreement in accordance with Art. 26 GDPR.
The essential content of this agreement can be made available upon request.
11. Data Recipients in Advisory Processing
Data may be transferred to:
– Insurance companies
– Product providers
– Financial institutions
– Public authorities
– IT service providers within the HORBACH infrastructure
Processing is based on:
Art. 6(1)(b) GDPR (contract performance)
Art. 6(1)(c) GDPR (legal obligations)
12. Your Rights Under GDPR
You have the right to:
– Access (Art. 15 GDPR)
– Rectification (Art. 16 GDPR)
– Erasure (Art. 17 GDPR)
– Restriction (Art. 18 GDPR)
– Data portability (Art. 20 GDPR)
– Objection (Art. 21 GDPR)
– Withdrawal of consent (Art. 7(3) GDPR)
Requests can be directed to:
info@flynanceexpat.com
13. Supervisory Authority
You have the right to lodge a complaint with the competent supervisory authority in your federal state.
For Saxony, this is:
Sächsischer Datenschutz- und Transparenzbeauftragter
Devrientstraße 5
01067 Dresden
Germany
14. Data Security
We implement appropriate technical and organizational measures to protect personal data against:
– Unauthorized access
– Loss
– Manipulation
– Destruction