Privacy Policy

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting

We are hosting the content of our website at the following provider:

Mittwald

The provider is the Mittwald CM Service GmbH & Co. KG, Königsberger Straße 4-6, 32339 Espelkamp, Germany (hereinafter referred to as Mittwald).

For details, please view the data privacy policy of Mittwald: https://www.mittwald.de/datenschutz.

We use Mittwald on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable depiction of our website possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

7orca Asset Managenent
Jochen Runze
Am Sandtorkai 77
20457 Hamburg

Phone: +49 (0) 40 33 460 460
E-mail: info@7orca.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion 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 law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TTDSG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Information on data transfer to the USA and other non-EU countries

Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions, or for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TTDSG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Consent with Cookiebot

Our website uses consent technology from Cookiebot to obtain your consent to the storage of certain cookies on your end device or for the use of certain technologies and to document this in a data protection-compliant manner. The provider of this technology is Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter “Cookiebot”).

When you enter our website, a connection is established with the Cookiebot servers to obtain your consent and provide you with other explanations regarding the use of cookies. Cookiebot will then store a cookie in your browser to identify the consent you have given or its revocation. The data collected in this way is stored until you request us to delete it, delete the Cookiebot cookie itself or the purpose for which the data is stored no longer applies. Mandatory legal storage obligations remain unaffected.

Cookiebot is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

5. Social media

LinkedIn

This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Any time you access a page of this website that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn.

If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6 (1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/help/linkedin/answer/62538/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=en.

For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.

XING

This website uses elements of the XING network. The provider is the New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany.

Any time one of our sites/pages that contains elements of XING is accessed, a connection with XING’s servers is established. As far as we know, this does not result in the archiving of any personal data. In particular, the service does not store any IP addresses or analyze user patterns.

If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6 (1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.

For more information on data protection and the XING share button please consult the Data Protection Declaration of Xing at: https://www.xing.com/app/share?op=data_protection.

6. Analysis tools and advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymization

On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.


7. Plug-ins and Tools

YouTube with expanded data protection integration

Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.

Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

Google Fonts (local embedding)

This website uses so-called Google Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application.

For more information on Google Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

Google Maps

This website uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer. In case Google Maps has been activated, Google has the option to use Google Fonts for the purpose of the uniform depiction of fonts. When you access Google Maps, your browser will load the required web fonts into your browser cache, to correctly display text and fonts.

We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6(1)(f) GDPR. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

8. Custom Services

Handling applicant data

We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 BDSG according to German Law (Negotiation of an Employment Relationship), Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.


Principles for dealing with conflicts of interest
(Version October 2017) 

As a securities service company we are required to act exclusively in the interests of our investors and carry out our activities honestly, with the required care, conscientiousness and probity, and for this purpose act in the best interests of our clients and the integrity of the market. 

In view of our focused business model with a limited number of services, conflicts of interest when carrying out our activities are manageable, but cannot always be ruled out in individual cases.


Services

The focal point of the services we provide is individual financial portfolio management and investment advice for institutional investors, primarily within the scope of insourcing portfolio management of capital management companies for investment funds. In addition, 7orca Asset Management AG can also broker investments and acquisitions. Private investors are usually only indirect recipients of our services, such as through acquiring shares in investment funds for whose portfolio management we are responsible.

We have specialised in rules-based portfolio management and focus on overlay management, currency and value guarantee management, and short-vola strategies. Within this framework, we use in particular exchange-traded derivatives (such as futures and options) and off-exchange-traded (“OTC”) derivatives, such as forward exchange transactions.

We commission the following important services from third parties: internal audit, external audit, legal advice, tax consulting, insurance services, data supply and IT services.


Shareholders

In addition to the founders, a pension fund and a financial services provider that also specialise in institutional investors hold minority shareholdings in the company. 7ORCA Asset Management does not hold any investments in other companies.

In accordance with the guidelines of the German Securities Trading Act, we will inform you below about our precautions when dealing with conflicts of interest.


Possible conflicts of interest

Interests of our clients or investors could collide with the following interests:

  • the interests of 7orca Asset Management or its affiliates;
  • the interests of our employees;
  • the interests of other clients or investors.

Conflicts of interest between our company, capital management companies and the custodians of our insourcing mandates are also conceivable. 

Conflicts of interest can result from, for example

  • when receiving or granting gratuities (such as when selecting brokers/counterparties or financial instruments)
  • from incentive systems for managers or employees of the company
  • personal transactions with assets that are held in investment funds whose portfolio we manage
  • reallocations in investment funds;
  • transactions between investment funds administered by our company and/or individual portfolios;
  • consolidating several orders (“block trades”);
  • commissioning closely affiliated companies and people,
  • individual investments of considerable extent;
  • frequent trading;
  • exploiting insider information

Measures to prevent, control and monitor these possible conflicts of interest

7orca Asset Management AG has taken organisational and administrative precautions to identify, prevent, settle, control and observe/monitor conflicts of interest in order to prevent conflicts of interest from causing considerable damage to the interests of investment funds or investors.

In particular, we have set up a compliance organisation that monitors our precautions against conflicts of interest regardless of the business field and regularly train all employees concerning legal requirements and internal company directives. 

If it is possible in a company of our size, we create confidentiality areas and information barriers between individual business areas and in relationship to the third parties we commission. Our risk controlling system is subject to special protective precautions against conflicts of interest.

If the organisational precautions taken by us to identify, prevent, settle and observe conflicts of interest to avoid an impairment of investor interests are not sufficient, we will inform investors in advance and develop countermeasures.

We have also taken the following measures in detail:

  • our remuneration system does not create any incentive to place personal interests above those of our investors and clients;
  • we have set up rules for personal transactions that are continuously monitored by the Compliance department and lead to a blocked list, which prohibits personal transactions with certain asset items (depending on the investment strategy we offer), in order to counter possible conflicts of interest;
  • we have ruled out the acceptance of third party payments (trailer fees, reimbursements, other payments). One exception is low-value, non-monetary gratuities, which we may accept under certain conditions and that are documented in a directory of gratuities;
  • we continuously monitor the transaction frequency in the investment funds we manage in order to prevent investors from experiencing disadvantageous reallocations in the individual portfolios or insourcing mandates;
  • we have published our Execution Principles;
  • we do not do any own-account business whatsoever – especially not with the investment funds or individual portfolios we manage – and only carry out securities transactions between different clients of ours at their wish;
  • the consolidation of several orders (“block trades”) is done on the basis of a standard assignment principle;
  • if we commission closely affiliated companies or people (in particular our shareholders), (e.g. with the role of an asset manager, investment advisor, broker or custodian), we will disclose this to investors;
  • we only use our own financial instruments or those from shareholder companies within the scope of investment advice or financial portfolio management at the explicit wish of the client;

If our company cannot avoid conflicts of interests, we will advise you of the type of conflict and its cause.


Disclosure report according to the Institutsvergütungsverordnung and in conjunction with Article 450 of the EU-Capital Requirements Regulation 575/2013
(Last updated 15/03/2018 )

7orca Asset Management AG is not a prominent institution within the meaning of the Institutsvergütungsverordnung (InstVergVO), meaning that the presentation and scope of information relating to our remuneration policy conform to article 450 of the EU CRR no. 575/2013 without having to fulfil the additional provisions of paragraph 16 I and II of the InstVergVO. Although the company does not qualify as a CRR investment firm and hence not as an institute within the meaning of EU CRR no. 575/2013, the analogous application of article 450 comes into effect in accordance with paragraph 1a II of the German Banking Act (Kreditwesengesetz – KWG). 

7orca Asset Management AG specialises in financial portfolio management for institutional clients and generally provides its services to capital management companies for the account of investment funds. In so doing, we predominantly pursue systematically and quantitatively oriented investment strategies. 

The company´s remuneration principles meet the requirements of the German Banking Act (KWG) and those of MaComp (Mindestanforderungen Compliance) – minimum requirements for compliance – which were communicated to each employee at the end of his/her employment contract. Presently, the company employs another nine workers in addition to the three members of the executive board. All members of the executive board as well as the persons involved in portfolio management are relevant persons according to the (MaComp). 

The executive board is responsible for the appropriate design and implementation of the remuneration system as well as the avoidance of remuneration-related risks, in as far as the remuneration of the the other employees is concerned. In contrast the supervisory board of the company is responsible for the remuneration principles of the executive board in a corresponding manner. 

The remuneration principles are reviewed at least once a year with the participation of the compliance officer, and they currently contain a fixed and a variable component.Bonus regulations for all employees starting from a low threshold value are subject to the approval by the supervisory board. 

The remuneration structure and implementation plan must be aligned with our business and risk policy, and hence be of benefit to the sustainable development of the company. Consequently, the payment of a variable remuneration is always subject to the company havingadequate capital and liquidity. 

A variable remuneration scheme did not take effect in 2017 due to the fact that the company was at an early stage of development. Even beyond 2017, the essential remuneration component for all employees is fixed and no significant dependencies on bonus payments arise. In general the variable remuneration depends on the overall success of the company as a whole and does not lead to disproportionate risks. This is also accommodated by the fact that the strategies we pursue are strongly rule-based and are not dependent on individual portfolio managers for their implementation. 

The fixed remuneration of employees is paid in twelve monthly payments per year and is calculated in such a manner that no incentives for disproportionately risky transactions are created. The variable remuneration is paid annually, where payment is applicable, and is capped in accordance with the provisions of the German Banking Act (KWG).


Execution Venues

The files that can be downloaded below contain information in German on the identity of the most important trading venues and on the quality of execution.

Meldung Ausführungsplätze 2017.pdf
Informationen zu Handelsplätzen.pdf
Ausführungsplätze 2018.pdf
Informationen zu Handelsplätzen 2018.pdf


Complaint Management

We aim to meet the requirements and standards of our customers and investors with our services and products at any time. If there is nevertheless cause for complaint, you can contact us free of charge electronically, in writing or verbally.

We have established effective and transparent complaint management procedures. This includes confirming receipt of a complaint without delay and providing you with information on how the complaint is handled. All complaints are immediately brought to the attention of the board.

 

Disclaimer

The content of our website is exclusively directed at professional investors in accordance with section 31a (2) WpHG. Therefore, we do not take the guidelines of section 4 WpDVerOV into account for the presentation of information for private clients. Thus, the contents detailed on our website are not suitable for private investors.

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