Privacy Statement

Privacy Statement

Commerz Real Investmentgesellschaft mbH takes the protection of your personal data very serious, and abides strictly by the applicable privacy regulations. Personal data is collected on these internet pages only to the extent technically necessary. In no case will the data collected be disseminated to any third party without your consent. The statement below gives you an overview of the type of data that Commerz Real Investmentgesellschaft mbH collects during your visit of its Internet pages, also stating the purpose for which they are collected, and defining the ways in which they are used.

Data Processing on these Internet Pages

Each time you access the internet pages of Commerz Real Investmentgesellschaft mbH, information that your browser communicates is automatically and temporarily retained. The information saved in the log file that is created to this end includes browser type and version, operating system used, name and URL of the retrieved file, referrer URL (the web page from which the user was redirected to these internet pages), the data quantity transmitted, the host name of the accessing computer (IP address), as well as date and time of the server query. The information logged does not permit inference of a specific individual. The data are not pooled with other data sources, and the data will moreover be deleted after their statistic evaluation. Saving and processing these data serves exclusively the purposes of system security and optimisation of the internet presentation.


In several instances, these internet pages use so-called cookies. Cookies are small text files placed on your computer, and saved by your browser. Their purpose is to determine the usage frequency of, and number of visitors to, these internet pages. By doing so they help to enhance the user-friendliness and efficiency of this internet presentation. Temporary so-called “session cookies” are saved exclusively for the duration of your visit of these internet pages, and are automatically deleted thereafter, though “permanent cookies” may also be used. The content of a permanent cookie is limited to an identification number designed to capture information about users who keep returning to a given internet page, and thus to recognise those users and offer them an optimised user guidance, where applicable. Cookies cause no harm to your computer, and contain no viruses. You may refuse the retention of cookies by selecting the appropriate settings on your browser. If you decide not to accept cookies, this may limit the functionality of these internet pages.

Submission of Personal Data / Newsletter

Entering personal or commercial data (name, address, e-mail address), for instance in the context of contact forms or registrations, is entirely voluntary on the part of the user. Commerz Real Investmentgesellschaft mbH saves, processes, and uses data only to the extent necessary to provide the offered service. Afterwards, the data are deleted. Inasmuch as your query regards the activities of Commerz Real Investmentgesellschaft mbH or one of its member companies or equity investment companies or a company it runs under an agency contract, and inasmuch as these data are required for an efficient processing of your query, your data may be forwarded to the respective company. If you wish to receive a newsletter that may be offered on these internet pages, we need your e-mail address at the least. Additional data are voluntary, and where provided will be used to address you in person. You may revoke your consent to the retention of your data and their use to send you our newsletter any time by unsubscribing the newsletter. Once you have done so, your data will be deleted. The use of your data for advertising purposes is ruled out. The offered services may, wherever technically feasible and reasonable, be used even without the submission of such data or by submitting an alias or anonymous data. By entering your data you consent to the storage and use of that data in accordance with this data protection statement.

Responsible Entity

The responsible entity within the meaning of the German Federal Data Protection Act (BDSG) is:

Commerz Real Investmentgesellschaft mbH

Friedrichstraße 25
65185 Wiesbaden, Germany

Right of Access

You have the right to access your personal data that we save, as well as the right to know the data's origin and recipient and the purpose of the data retention. You may demand at any time that your data be corrected, blocked, or deleted. For information on stored data, and in order to have your data corrected, blocked or deleted, please contact the Data Protection Officer of Commerz Real Investmentgesellschaft mbH: 


Commerz Real Investmentgesellschaft mbH offers no warranty regarding the security of the data transmission via the Internet. E-mail messages are not encrypted. Therefore, interception by third parties cannot be ruled out. We therefore recommend sending confidential information exclusively via postal mail.

Web Tracking

Our internet pages use web controlling technologies to collect and store data in anonymised form for the exclusive purpose of website optimisation. These data will be used to compile a use profile under a pseudonym. To this end, cookies may also be used, which collect and save data in pseudonymised form only. The data will not be used to identify website visitors personally, and the data will not be merged with data on the bearer of the pseudonym. You may configure your browser in such a way that it will notify you whenever a cookie is to be placed, giving you the option to allow or block the cookie as you see fit. Moreover, you may prevent the placement of cookies by adjusting the relevant settings in your browser. In this case, however, you may not have the full use of all features of this website. No personal data are saved in the process. The IP address of a given user is rendered unrecognisable, and permits no inferences regarding the visitors of this website.

Disable tracking services

At the moment, the following tracking services are employed:

Webtrekk for on-site tracking

Disable Webtrekk

Adform for off-site and campaign tracking

Disable Adform

On-site Tracking using Webtrekk

Webtrekk is used for on-site tracking. For more details about Webtrekk, go to:

About Webtrekk

In Germany, where Webtrekk has its principal place of business, personal data must not be processed without the user's consent (Article 2, German Information and Communication Services Act (IuKDG). The protection of internet user data has chief priority for Webtrekk. The company therefore adheres strictly to the data protection laws of the European Union and Germany. Internet user data are captured through a pixel that it built into all pages of our website.

No Data to Third Parties

Webtrekk does not forward any data to third parties.

IP Addresses

Every internet query is accompanied by the respective IP address to tell the server where to send replies. Internet users are given an internet address by their internet service provider (ISP) as soon as they access the internet. The ISP knows which IP address was used when and by which internet user. The ISP is legally obliged to save this information. Webtrekk does not save IP addresses. Webtrekk immediately truncates the IP address for the purpose of session detection and the geographic analysis by the Webtrekk tool. Afterwards, Webtrekk deletes the IP address. It is impossible to match the data with individual persons and to identify these individuals. Geographic analyses use a database that contains the IP address information of various ISPs sharing the geographic location of the IP address down to the city level. The addresses of the individual internet users are not known. 


Cookies are small text files that the browser of an internet user saves on the hard disk of an internet user whenever the user visits a new website. Most Webtrekk cookies represent so-called “session cookies.” These cookies will not harm the hard disk of the internet user, and contain no viruses. The data cannot be matched with any single user. Webtrekk uses the following cookies:

  • Last click (used for the session timeout; expires after session)
  • Session cookie (used for session detection; expires after session)
  • Ever cookie (used for the recognition of new and returning visitors; expires after 6 months)

Use your browser setting to define which cookies to allow or block, as the case may be.

Data Retention Disclaimer

Pursuant to Art. 15, German Telemedia Act (TMG), internet users may prohibit the future tracking and retention of data of their internet visits. If you wish to disable the tracking function while visiting the hausInvest website, you may place a cookie called webtrekkOptOut available from the domain Tracking will be disabled until the Webtrekk-OptOut cookie is deleted again.

If you wish to disable future tracking of your activities on this website, please click here:

Disable tracking

The following data will be captured:

  • Query (file name of the requested file)
  • Browser type and version (e.g. Mozilla Firefox 33.0, Internet Explorer 10, etc.)
  • Browser language (e.g. English)
  • Operating system
  • Browser resolution
  • Screen resolution
  • JavaScript enabled: “yes” or “no”
  • Java: “on” or “off”
  • Cookies: “on” or “off”
  • Colour depth
  • Referrer URL
  • Truncated IP address for geographic analyses down to the city level
  • Timestamp
  • Clicks
  • E-commerce data such as order value, products, quantity, etc.
  • Contents of forms: text boxes for name, e-mail address, account number, and phone number are captured as “populated” or “blank.” The actual entries are not captured

Off-site and Campaign Tracking using Adform

Adform is used for off-site tracking and campaign tracking. For more details on Adform, please go to their website at

Adform Data Protection Statement

To identify the end customer, Adform creates a random pseudonym that is filed in a cookie on the computer of the end customer (= the internet user).

This cookie does not contain IP addresses. 

A cookie always relates to a given campaign, and is structured in such a way as to have the cookie expire by the end of the campaign – with data protection supervisory authorities generally tolerating lifetimes of up to 6 months. 

Adform makes a global opt-out cookie available to each user that may be directly downloaded by the internet user using the URL Whenever the opt-out cookie is detected on a computer, no data from it is captured and evaluated for the campaign. Placing the opt-out cookie will delete all legacy Adform cookies. 

Retrieving information on individual customers is generally impossible because the instant pseudonymisation (cookie ID) keeps Adform from accessing personal data. Using the URL the customer may autonomously read out the status of the cookie.

For a detailed description, see the “Adform - Data Collection and Privacy Policy” below.

Adform - Data Collection and Privacy Policy

About Adform

Adform is a privately owned Scandinavian company which since 2002 has provided a digital marketing platform for most Nordic media agencies and large advertisers. Adform has clients in all major industries worldwide and is serving campaigns for thousands of clients across over twenty thousand web publishers all over the globe.

Adform is used mainly as a leading and comprehensive end-to-end solution for media planning, ad serving, real time ad buying, rich media execution, search tracking, web analytics and reporting. By using Adform’s platform for execution and tracking online marketing activities, agencies and advertisers achieve a number of significant advantages, such as:

  • Ad-serving with real-time control, rotation, targeting, customization and optimization of ads to each individual user providing significant lifts in campaign performance;
  • Ad-buying using real-time control and pricing of each ad impression according to each individual user/browser;
  • Consistent control and comparison of purchased delivery from media partners on an “apples to apples” basis, including de-duplication of CPA and affiliate leads;
  • State-of-the art reporting showing the complete paths for each customer’s interaction with all online marketing activities, such as search, ads, email and site visits.

This document describes what data Adform collects, what purposes it serves, who has access to the data and what policies Adform has.

Collected Data and Usage

The following data is collected in the Adform ad-serving and web analytics platform.

User Identification

  1. User identification number
    In order to link each single interaction to an individual user, Adform generates a unique user ID for every new user that interacts with any form of Adform tracking. The User ID is fully anonymized and is stored locally by using a cookie in the user’s browser. The cookie expires 30 days after the last interaction. The user ID is either generated as a truly random number or in some cases based on a device recognition technology invented by a partner company called Adtruth. The Adtruth ID is fully anonymized, but not random. Instead, it is based on a set of variables that are related to the browser and device, such as operating system, screen format and similar. It does not contain any unique IDs such as UDID, Apple ID, the IP number or any sort of personally identifiable information (PII).
  2. User Choice
    Adform provide internet users with the choice to opt-out from all device recognition based activities, including targeted advertisements, and tracking of visits across media sites, including that of third-parties technologies deployed through Adform. The opt-out choice erases all previously collected data and places an Adform cookie into the internet user’s browser with special indication of “opt-out” choice. Due to the nature of cookies, it will apply to the specific computer and browser only; if users wish to opt-out for other browsers or computers, they must repeat the same process using these browsers or computers. If users erase all cookies, they will inherently also erase the opt-out cookie and will need to repeat the process again.
  3. Adform Partner ID Exchange
    Adform is connected to a large number of partners such as Google, AppNexus, Adobe and many others. Adform automatically exchange anonymous user IDs with these partners as a vital part of the infrastructure to how tracking and buying of online advertising works. The exchange of IDs is mainly initiated by the partners when they register a user for which they do not hold an Adform ID, but the reverse exchange is also quite common with partners such as AppNexus, who currently do not support initiation on their side.

Interaction Types

Adform stores each interaction that users have with ads and site-tracking scripts. These include impressions, clicks or interactions with ads and visits to the advertiser website. The interactions stored in the user’s profile can subsequently be used to deliver targeted and personalized ads as well as to generate advanced user-behavior statistics.

1. Historical Ad Impressions, Ad Interactions and Frequencies

Historical ad impressions and interactions are stored per user, making it possible to:

  • Report the number of times a user has seen a specific ad and in what context;
  • Mark users’ conversion paths;
  • Fire post-impression publisher pixels from Adform container tags, also known as
  • piggy-backing/Floodlight tags;
  • Optimize Ad buying based on correlation between sales conversions and site visits; o Target a user with different ads.

The rotation based frequency is stored per user, making it possible to:

  • Rotate ads for a user, based on, for example, how many times the ads was shown to the user;
  • Target or stop targeting a user, based on the total frequency.

2. Historical Clicks

Historical ad clicks are stored per user, making it possible to:

  • Report the number of times a user has clicked on a specific ad;
  • Mark users’ conversion paths;
  • Target a user with different ads based on click activity;
  • Fire post-click publisher pixels from Adform container tags, also known as piggy-backing/Floodlight tags.

Historical keywords are stored per user: if a click was made on a search engine, keywords are retrieved.

3. Site Visits

Historical site visits are stored per user, making it possible to:

  • Report the number of times a user has visited certain pages or sections;
  • Perform real-time retargeting;
  • Mark users’ conversion paths and analyze as well as report on any interesting aspect of users’ behaviors leading to visits or specific site action.

Historical keywords are stored per user: if the user was redirected from a search engine, keywords are retrieved.

Interaction Attributes

Each stored interaction has several attributes that are stored alongside the transaction data of whenever a user is clicking through an ad, visiting a web page containing an ad, or web analytics tracking tag.

  1. Time of the interaction
    The exact time of user’s interaction is stored.
  2. URLs of the interaction
    The URL of the page where the interaction occurred and the referring URL are stored. For search engines, this can include the searched keywords. The URL can be applied for brand safety filtering – in this case, non-desirable URLs can result in a blank ad being displayed instead of the intended brand advertisement. The URL can also be translated into contextual classifications – this can be used for reporting the context of the displayed ads or creating user profile groups for subsequent targeting.
  3. IP number
    The user’s IP number is stored depending on account configurations. In many cases, the received IP is truncated by the last three digits before storing in order to comply with local privacy laws, such as Germany’s, where IP numbers are PII (Personal Identifiable Information).
  4. Location data
    Adform use an internally hosted database for predicting the estimated geographical location (city, region and country) based on the transmitted IP number. This happens before IP numbers are truncated and stored, so it does not affect the storage or privacy issues related to IP numbers.
  5. Terminal data
    Terminal data, such as operating system’s type and version, browser’s type and version, screen-size, and such, is stored.
  6. Sales transaction data
    Transaction data variables (e.g. order id, product name or sales value) can be passed from advertiser’s CRM and CMS systems through tracking pixels to Adform. Passing user identifiable data to Adform (e.g. phone or e-mail) is not restricted, but must always comply with the Adform privacy policy and any local applicable privacy laws. Once the implementation of transaction data variable passing is done on the advertiser’s site, it is up to the advertisers’ web masters to enforce these restrictions. Passing sensitive user identifiable data to Adform (e.g. credit card numbers or social security number) is not allowed under any circumstances. Should this be breached, Adform will delete such data immediately after notifying all involved parties.
  7. Transaction details
    On certain transactions, such as ad impression, Adform will measure the number of mouse-overs, visibility % of the ad, and the total visibility time. In the event of clicks, Adform will detect and store the coordinates of where the click happened on the ad.

Web Analytics Disclaimer

Inserting Adform web analytics scripts and redirect links on the advertiser’s web pages may influence page rendering. It is recommended to always verify the implementation before publishing any of the Adform web analytics tags.

Ad-serving Disclaimer

Adform ad-serving tags load creative content from Adform’s ad-serving cluster. However, in some cases the load can happen from other external sources, such as ad-servers, streaming providers, data-sources or tracking systems, for which Adform cannot be held liable. It is publisher‘s responsibility to check that the content in these tags is in accordance with the agreement between the publisher and the Advertiser, agency or other third party using the Adform‘s system. Adform do not control or accept any responsibility if ads or other content contains libelous, indecent or defamatory messages.

Prohibited Usage

Adform has certain restrictions regarding how advertisers and agencies can utilize the platform.

  • All usage must comply with all corresponding laws.
  • Adform does not allow the system to be used for certain profiling or tracking which can be
  • considered as sensitive personal information, e.g. information of racial, sexual preference, political or similar nature, or any information defined in national, US or EU level as being of personal sensitive character.
  • Tracking of personal identifiable information (PII) is not permitted without explicit consent from Adform. This especially applies to directly identifiable information, such as addresses, emails or phone numbers.
  • Targeting/profiling children under the age of 12 is forbidden (as required by EDAA/IAB). No advertisements specifically targeted for age 12 and under will be delivered to this category.

Data Protection

The Adform ad-serving system conforms to the Scandinavian data protection laws as well as the regulations of the Privacy Preferences Projects (P3P) (originating from the World Wide Web group). Data is currently stored in three locations in Denmark:

  1. Data-warehouse platform *
  2. Data-warehouse backup system *
  3. Sandbox test environment **

* Data-warehouse platform is a part of the Adform’s online platform, which is protected according to some of the recommendations and standards set by the Payment Card Industry for securing Credit Card storage, including firewalls, monitoring, scans and physical access restrictions protected by eye-scanners and security guards day and night.

** Located in Adform’s development center and contains only old statistical data. It is stored behind similar layers of firewalls and in a constantly locked location, with 24 hour security personnel protection.

No data is stored or routed outside Europe.

Access to Data

The media agency and advertiser can be given access to all the data mentioned in this document through Adform’s reporting modules, API and manual data extraction requests.

Access to the reporting module can be given to support staff at Adform, the media agency and the advertiser. Non-Adform employees, including partner companies will never be granted access unless written instructions are received by the advertiser or the media agency.

Access to the data-warehouse data is only given to a part of Adform’s development team and IT system administrators.

Access to the physical servers is only granted to Adform IT system administrators with clearance.

The Adform ad serving and web analytics platform allows using third party pixels. An example is adding affiliate network 1x1 pixels in Adform web analytics container tags, which can be triggered based on certain rules. In various cases this can also be used by internal media agency performance departments, external tools and partners. Media agencies or Adform can implement such usage through the system when instructed by either the media agencies or the advertiser.

Adform will never share, sell, rent or otherwise disclose any online campaign statistics to third party companies without explicit consent from the advertiser or agency, unless in aggregate form not revealing data about individual advertisers.

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