Legal information/provider identification as per § 18 of The Interstate Treaty on Media (Medienstaatsvertrag – MStV)

Funk Gruppe GmbH
International insurance brokers and risk consultant

Valentinskamp 20
20354 Hamburg

fon +49 40 35914-0
fax +49 40 35914-407
Email welcome[at]

Managing Directors (address as above): Thomas Abel, Christoph Bülk, Yorck Hillegaart, Claudius Jochheim

Commercial register: Hamburg District Court (register no. HRB 20748) 
Berlin-Charlottenburg (register no. HRB 11983)
VAT number: DE118566977

Responsible for journalistic editorial copy as per § 55 RStV: Yorck Hillegaart, Valentinskamp 20, 20354 Hamburg, Germany

Our website provides information, services and products from the offices of Funk Gruppe GmbH. The legally required information for insurance intermediaries (insurance brokers, insurance representatives, insurance consultants) and pension consultants as per § 11 German Insurance Brokerage Ordinance (VersVermV) or § 2 German Service Providers’ Duty to Inform Ordinance (DL-InfoV) can be found on the mandatory information.


Privacy policy

(Last updated: 05/2018)

Below, we have provided you with information about how we collect personal data when you use our website. Personal data is all data which concerns you personally, such as your name, address, email addresses and user behaviour. We have taken extensive technical and operational protective measures to protect your data from accidental or deliberate manipulation, loss, destruction or access by unauthorised individuals. Our security procedures are regularly reviewed and adjusted in line with technological progress.

1 Controller for data processing
The controller according to Art. 4, Para. 7 of the EU General Data Protection Regulation (GDPR) is

Funk Gruppe GmbH
International Insurance Brokers and Risk Consultants
Valentinskamp 20
20354 Hamburg
Tel. +49 40 35914-0
Fax +49 40 35914-407
Email: welcome[at]

2 How to contact the data protection officer
You can contact our data protection officer on datenschutz[at] or by using our postal address with the add-on “FAO Data Protection Officer”.

3 Subject of data protection
The subject of data protection is personal data under the terms of Art. 4, Para. 1 of the GDPR. This is all information which relates to an identified or identifiable natural person. It generally includes all information which could be used to identify a natural person (indirectly at least). This could be, for example, a person’s name or contact details (e.g. telephone number, postal address and email address). The IP address can also represent personal data in this sense.

4 Collection, processing and use of personal data
Funk only collects, processes and uses your personal data insofar as this is permitted or required by the GDPR, the German Federal Data Protection Act or another piece of legislation or insofar as you, as a user of our website, have consented to such collection, processing and use.

5 Your rights
You have the following rights vis-à-vis us with regard to the personal data concerning you: 

5.1 General rights
You have a right of access, correction, deletion, restriction of processing, objection to processing and data portability. Insofar as processing is based on your consent, you have the right to revoke this consent you gave us with effect for the future.

5.2 Rights with regard to data processing according to a legitimate interest
According to Art. 21, Para. 1 of the GDPR, you have the right, on grounds relating to your particular situation, to object at any time to processing of the personal data concerning you based on Art. 6, Para. 1 e) of the GDPR (data processing in the public interest) or based on Art. 6, Para. 1 f) of the GDPR (data processing to protect a legitimate interest); this also applies to profiling based on this regulation. If you object, we shall no longer process your personal data unless we can demonstrate compelling and legitimate grounds for processing which outweigh your interests, rights and freedoms, or if processing serves to establish, exercise or defend legal claims.

5.3 Rights with regard to direct advertising
Insofar as we process your personal data for the purpose of carrying out direct advertising, you have, at any time, the right according to Art. 21, Para. 2 of the GDPR to object to processing of the personal data concerning you for the purposes of such advertising; this also applies to profiling if it is in conjunction with such direct advertising.
If you object to processing for the purposes of direct advertising, we shall no longer use your personal data for these purposes.

5.4 Right to lodge complaints with a supervisory authority
You also have the right to lodge complaints regarding our processing of your personal data with a responsible data protection supervisory authority.

6 Collection of personal data when you visit our website
When you are merely using the website for information purposes, i.e. if you do not register or otherwise transfer information to us, we only collect the personal data which your browser transfers to our server. When you visit our website, we collect the following data, which is technically necessary for us to enable you to view the website and to guarantee stability and security. The legal basis for this is Art. 6, Para. 1 f) of the GDPR: IP address, date and time of the request, time zone difference from Greenwich Mean Time (GMT), content of the request (specific page), access status / HTTP status code, and the amount of data transferred.

7 Contact by email 
If you contact us by email, the data you share (your email address) shall be stored by us for the purpose of answering your questions. We delete the data collected in this regard once storage is no longer necessary, or we restrict processing if legal retention requirements exist.

8 Use of cookies
When you use our website, cookies are stored on your computer. Cookies are small text files that are saved on your hard drive, are assigned to the browser you use and through which the party that sets the cookie receives certain information. Cookies cannot run any programs or transfer viruses to your computer. They are used to make the website more user-friendly and effective on the whole.
This website uses the following types of cookies, the scope and functions of which are explained below:

8.1 Transient cookies 
These cookies are automatically deleted when you close the browser. They particularly include session cookies. These save a ‘session ID’ which can be used to assign various requests from your browser to the same session. Your computer can therefore be recognised if you return to our website. The session cookies are deleted if you log out or close the browser.

8.2 Persistent cookies 
These cookies are automatically deleted after a specified period of time, which can vary depending on the cookie in question. You can delete the cookies at any time in your browser’s security settings.

8.3 Flash cookies
The flash cookies used are not recorded by your browser, but rather by your Flash plugin. We also use HTML5 storage objects, which are stored on your terminal device. These objects store the data required regardless of the browser you use and do not have an automatic expiry date. If you do not want the flash cookies to be processed, you must install a corresponding add-on, such as ‘Better Privacy’ for Mozilla Firefox ( or the Adobe Flash Killer Cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using your browser in Private mode. We also recommend manually deleting your cookies and browser history on a regular basis.

8.4 Preventing cookies
You can configure your browser settings in line with your requirements and refuse to accept third-party cookies or all cookies, for example. Please note that if you do so, you may not be able to use all the functions of this website.

8.5 Legal bases and duration of storage
The legal bases for potential processing of personal data and the data storage durations vary, and are described in the sections below.

9 Website analysis

We use various services for the purposes of analysing and optimising our website; these services are described below. We can use them, for example, to analyse how many users visit our page, what information is desired most or how users discover our offering. We collect data that includes the website from which a data subject has arrived at another (called the ‘referrer’), the pages that are accessed on a website and how often and for how long a page is viewed. This helps us to make our website user-friendly and also to improve it. The data collected in this way is not used to identify individual users personally. Data is collected anonymously or, at most, under pseudonyms. The legal basis for this is GDPR Art 6(1). 

Google Analytics

If you give your consent, this website will use Google Analytics, a Web analytics service from Google LLC. The relevant service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (‘Google’).

Scope of processing

We use the ‘anonymizeIP’ function (i.e. IP masking), enabling IP anonymisation on this website. Accordingly, Google truncates your IP address within member states of the European Union or in other countries party to the Agreement on the European Economic Area. Only in exceptional cases is your full IP address transmitted to a Google server in the United States and truncated there. The IP address transmitted by your browser through Google Analytics is not combined with any other data held by Google.

The following data, among other things, is collected during your visit to this website:

  • the pages you have viewed, i.e. your ‘click path’
  • your usage patterns (e.g. clicks, dwell time and bounce rates)
  • your approximate location (region)
  • your IP address (truncated)
  • technical details about your browser and the devices you use (e.g. language settings, screen resolution)
  • your Internet service provider
  • the referrer URL (the website/advertisement from which you arrive at this website)

Purposes of processing

Google uses this information on behalf of the website operator to analyse how you (under a pseudonym) use the website and to compile reports about the website’s activities. The reports supplied by Google serve the purpose of analysing the performance of our website.

Recipient of the data

  • The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

In this context, the recipient acts as a processor. To this end, we have signed a data processing agreement with Google. Google LLC, based in California in the United States, and potentially American authorities may have access to the data stored at Google.

Length of storage

Data that is sent by us and linked with cookies is automatically deleted after fourteen months. Data for which the storage period has expired is automatically deleted once per month.

Furthermore, you can stop Google from storing and processing the cookie-generated data concerning your use of the website (including your IP address) by:

a. not giving your consent to cookies, or

b. downloading and installing the browser add-on HERE that deactivates Google Analytics

You can also prevent cookies being stored by configuring the relevant settings in your browser. However, if you set your browser to reject all cookies, you may experience restrictions in the functionality of this and other websites.

Legal grounds and option to withdraw consent

Your consent represents the legal grounds for this data processing in accordance with German Telemedia Act (TMG) s 15(3) in conjunction with GDPR Arts 4(11) and 7. You may at any time withdraw your consent with effect for the future by accessing the cookie settings and changing your choices there. You can find the cookie settings under the fingerprint icon at the bottom left of our website. 

Further information about the Google Analytics terms of service and Google’s privacy policy can be found at and

A browser add-on that deactivates Google Analytics has been developed for website visitors who do not want their data to be used in Google Analytics.


10 Advertising
We use cookies for marketing purposes to address our users with interest-based advertising. We also use cookies to restrict the likelihood of ad playback and to measure the effectiveness of our advertising measures. This information may also be shared with third parties, such as ad networks. The legal basis for this is Art. 6, Paras. 1 a) and f) of the GDPR. We have a legitimate interest in direct marketing for the purposes pursued with data processing. You have the right, at any time, to object to processing of your data for the purposes of such advertising. To this end, we provide you with the respective services’ opt-out options below. Alternatively, you can prevent the setting of cookies in your browser settings.

10.1 Google DoubleClick
We use DoubleClick, a service provided by Google Inc. DoubleClick uses cookies to place user-based adverts. The cookies recognise which ads have already been placed in your browser and whether you have called up a website via a placed ad. In doing this, the cookies do not collect any personal information and also cannot be linked with the same. If you do not want to receive any user-based advertising, you can deactivate the placement of ads using Google’s ad setting. Please refer to Google’s privacy policy for further information on how Google uses cookies.

11 Data transfer
Funk discloses personal data within the Group’s companies (as listed on the website in the company profiles found under the section ‘Legal information’) within permissible limits, if such data is required for the purposes listed under Sections 8 to 13. Your personal data is processed on behalf of Funk in these cases as per Art. 28 of the GDPR.
To the extent required, we also disclose personal data to companies outside of the Funk Group in exceptional circumstances if we use these companies to process your data. In these cases, however, the amount of data transferred is restricted to the minimum required. Insofar as recipients outside of the Funk Group come into contact with your personal data, we ensure in the context of processing as per Art. 28 of the GDPR that these parties comply with the regulations set down in data protection legislation in the same way. Please also note the providers’ respective privacy policies. The respective service provider is responsible for the contents of external services, whereby we check, within reasonable limits, that the services comply with the legal requirements.
Insofar as no deviating regulations result from this privacy policy, in principle your data is not transferred to third parties unless we are obligated to this effect by law, or if the data needs to be disclosed to implement the contractual relationship, or you have previously given your express consent to your data being disclosed.
We never transfer any personal data which we collect on this website to countries outside the European Union or the European Economic Area – unless such transmission is expressly stated.

12 Data security
We have taken extensive technical and operational protective measures to protect your data from accidental or deliberate manipulation, loss, destruction or access by unauthorised individuals. Our security procedures are regularly reviewed and adjusted in line with technological progress.

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