(These documents are available in German only.)
This legal notice applies to our website, our YouTube channel, and our Instagram account.
Gerd Kommer Invest GmbH
Sendlinger Straße 41
80331 Munich
Contact: contact form
Web: https://gerd-kommer.de/en/etf/
Commercial Register: Local Court of Munich, HRB 272214, VAT ID: DE351537657
Managing Director authorised to represent the company: Dr. Gerd Kommer
Responsible for the content pursuant to section 55 (2) RStV:
Gerd Kommer Invest GmbH
Sendlinger Straße 41
80331 Munich
Gerd Kommer Invest GmbH is an authorised securities institution and holds a permit from the German Federal Financial Supervisory Authority (BaFin) to provide, among other services, financial portfolio management, investment advice, investment brokerage and contract brokerage in accordance with section 15 (1) in conjunction with section 2 (2) nos. 3, 4, 5 and 9 of the Securities Institutions Act (WpIG).
Competent supervisory authority: Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) Graurheindorfer Straße 108, 53117 Bonn und Marie-Curie-Str. 24-28, 60439 Frankfurt, Tel. 0228 / 41 08-0, Email: ed.nifab@elletstsop, Internet: www.bafin.de (BaFin-ID: 10160531).
The company is registered as an independent real-estate loan advisor with a permit pursuant to section 34i (1) sentence 1 of the German Trade Regulation Act (GewO) with the Chamber of Industry and Commerce (IHK) for Munich and Upper Bavaria (supervisory authority). Its regulatory status can be verified at any time under registration number D-W-155-36J9-43 in the intermediary register (www.vermittlerregister.info).
The company is registered as an insurance advisor with a permit pursuant to section 34d (2) of the German Trade Regulation Act (GewO) with the Chamber of Industry and Commerce (IHK) for Munich and Upper Bavaria (supervisory authority). Its regulatory status can be verified at any time under registration number D-B47F-3LAKR-23 in the intermediary register (www.vermittlerregister.info).
Competent supervisory authority: Chamber of Industry and Commerce (IHK) for Munich and Upper Bavaria, Max-Joseph-Straße 2, 80333 Munich, www.ihk-muenchen.de.
Statutory compensation scheme:
Entschädigungseinrichtung der Wertpapierhandelsunternehmen (EdW)
10865 Berlin
Tel.: +49 30 203699-0
Email: ed.w-d-e@liam
Internet: www.e-d-w.de
Arbitration body:
For resolving disputes with the securities institution, it is possible to contact the BaFin arbitration body.
Address of the arbitration body:
BaFin Arbitration Board Ref. ZR 3
Graurheindorfer Str. 108
53117 Bonn
Tel.: +49 228 4108-0
Fax: +49 228 4108-62299
Email: ed.nifab@elletssgnuthcilhcs
For clients resident in Switzerland, the competent ombuds office is FINSOM:
FINSOM
Avenue de la Gare 66
1920 Martigny
Switzerland
Tel.: +41 27 552 04 24
Submit an online complaint: https://finsom.ch/startseite/zugang-vermittlung/
Gerd Kommer is a trademark used under licence by Gerd Kommer Invest GmbH.
Gerd Kommer Invest GmbH operates a website for the robo-advisor, while Scalable Capital GmbH operates the apps and manages the assets. Baader Bank AG maintains the custody accounts with settlement accounts.
Gerd Kommer Invest GmbH operates a website as an asset manager and manages its clients’ assets.
The competent supervisory authorities for Gerd Kommer Invest GmbH is the Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) and the Deutsche Bundesbank, Munich Regional Office.
The European Commission has provided an interactive website (OS platform) pursuant to Regulation (EU) No. 524/2013 for the resolution of out-of-court disputes arising from online legal transactions. The EU Commission’s OS platform can be found at the following link: http://ec.europa.eu/consumers/odr/.
Gerd Kommer Invest GmbH does not participate in a dispute resolution procedure before a consumer arbitration board in accordance with the ADR Directive and the German Consumer Dispute Resolution Act (VSBG).
As a service provider, we are responsible under section 5 (1) DDG for our own content on these pages in accordance with general legislation.
Obligations to remove or block the use of information in accordance with general legislation remain unaffected. However, liability in this respect is only possible from the moment we become aware of a specific infringement. If we become aware of any such infringements, we will remove the content concerned without delay.
Our website contains links to external third-party websites over whose content we have no control. Therefore, we cannot assume any liability for such external content or for compliance with data-protection regulations. The respective service provider is always responsible for the content of the linked pages. The linked pages were checked for potential legal violations at the time the link was created. No unlawful content was identifiable at that time.
Permanent monitoring of the content of linked pages is, however, unreasonable without concrete indications of a legal violation. Should we become aware of any legal infringements, Gerd Kommer Invest GmbH will remove such links immediately.
The content and works created by the website operators on these pages are subject to German copyright law. Reproduction, editing, distribution and any kind of use outside the limits of copyright law require the written consent of the respective author or creator. Downloads and copies of this website are permitted only for private, non-commercial use.
Where content on this website was not created by the operator, the copyrights of third parties are respected. Third-party content is specifically identified as such. Should you nevertheless become aware of a copyright infringement, please inform us accordingly. If we become aware of infringements, we will remove such content without delay.
Status: 31 July 2025
1.1 We are pleased that you are visiting our website and are interested in our services. Gerd Kommer Invest GmbH attaches particular importance to data protection and data security. We therefore endeavour, in compliance with the applicable data protection laws, to protect your privacy and to treat your data confidentially. This is done using the best and most up-to-date technologies. Below you can find out which of your personal data we collect and use. Personal data means all information relating to an identified or identifiable natural person. Please note that you can be redirected from our website via hyperlinks to other providers, cooperation partners and, through advertising, to third-party websites, which are in turn subject to their own data protection provisions. We may adapt the provisions of this privacy policy from time to time. For this reason, we recommend that you review the privacy policy regularly.
1.2 Gerd Kommer Invest GmbH, with its registered office at Sendlinger Straße 41, 80331 Munich, is the service provider and controller within the meaning of the EU General Data Protection Regulation (EU-DSGVO), national data protection laws and other data protection provisions.
1.3 The controller’s data protection officer can be contacted at:
Gerd Kommer Invest GmbH
Sendlinger Straße 41
80331 Munich
E-mail: ed.remmok-dreg@ztuhcsnetad
2.1 We only process personal data if:
2.1.1 the data subject has given consent (Art. 6 (1) (a) EU-DSGVO);
2.1.2 it is necessary for the performance of a contract (or for taking steps prior to entering into a contract) to which the data subject is party (Art. 6 (1) (b) EU-DSGVO);
2.1.3 it is necessary for compliance with a legal obligation to which our company is subject (Art. 6 (1) (c) EU-DSGVO); and/or
2.1.4 it is necessary for the purposes of a legitimate interest pursued by our company or by a third party and such interest is not overridden by the interests or fundamental rights and freedoms of the data subject (Art. 6 (1) (f) EU-DSGVO).
2.2 We will pass on your data to affiliated companies, external service providers or other third parties to the extent disclosed in this privacy policy. These third parties are carefully selected by us and, where they act as processors, appropriately instructed with the data processing. The processors are used by us on the basis of appropriate contractual agreements and within the framework of the statutory provisions. In this context, data may also be transferred to a third country outside the EU/EEA (e.g. the USA). Such data transfers are made exclusively subject to an adequacy decision (Art. 45 EU-DSGVO) and/or subject to appropriate safeguards (Art. 46 EU-DSGVO).
2.3 The personal data of the data subject are deleted or blocked at regular intervals once the purpose of storage no longer applies. If retention or recording obligations are stipulated by applicable European or national legislation or other regulations, the personal data will be stored for the prescribed period and then deleted.
You have the following rights vis-à-vis us with regard to personal data concerning you:
You have the right to lodge a complaint in accordance with the provisions of the EU-DSGVO and the German Federal Data Protection Act (BDSG), inter alia with the supervisory authority competent for us:
Bayerisches Landesamt für Datenschutzaufsicht
Promenade 27, 91522 Ansbach
Tel.: +49 981 53 1300
Fax: +49 981 53 98 1300
Internet: https://www.lda.bayern.de/
4.1 Every time our digital offering is accessed, our system automatically collects data and information from the computer system of the accessing device (so-called log files). When using your browser, this includes, among other things, the browser type and version, the operating system, the IP address and the time of the server request. In the case of the app, this includes, among other things, the device identifier, the access provider, the model of the mobile phone used and the version of the app used. The data are stored in our IT systems and transmitted to Google Cloud Services (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).
4.2 The data in the log files are processed in order to ensure the functionality of the website. In addition, the data help us to optimise the website and to ensure the security of our IT systems. The legal basis for the temporary storage of the data and the log files in the client area is Art. 6 (1) (b) EU-DSGVO (performance of a contract or steps prior to entering into a contract); for the use of the digital offering, the legal basis is Art. 6 (1) (f) EU-DSGVO (legitimate interest).
4.3 The collection of the data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. The user therefore has no possibility to object.
4.4 By using the services of Google Cloud Services, your data may be transferred to the USA.
Cookies are very small text files used by websites which your browser stores on your computer and through which certain information is sent to the party that places the cookie (in this case to us). Cookies cannot run programmes or transmit viruses to your computer.
Transient cookies are deleted automatically when you close the browser. These include, in particular, session cookies. These store a so-called session ID which allows different requests from your browser to be assigned to the same session. This means that your computer can be recognised when you return to our website. Session cookies are deleted when you log out or close the browser.
Persistent cookies are deleted automatically after a specified period, which may differ depending on the cookie. The maximum storage period is generally 365 days. Any deviations from this can be found in the information on the individual services (see below). You can delete cookies at any time in your browser’s security settings.
This information helps us to optimise our offering and to provide you with greater comfort when browsing our pages. The legal basis for this data processing is Art. 6 (1) sentence 1 (f) EU-DSGVO.
You can configure your internet browser so that you are informed as soon as a web server wants to send a cookie to you. You can then consent to or reject the cookie. You can configure your browser settings according to your preferences, for example to refuse the acceptance of third-party cookies or of all cookies. However, please note that you may then not be able to use all the functions of this website. You can find further information in your internet browser’s help system.
6.1.1 We use the Borlabs Cookie plugin by Borlabs, Benjamin A. Bornschein, Georg-Wilhelm-Straße 17, 21107 Hamburg, to manage the cookie preferences of our website visitors. Borlabs Cookie uses cookies which record data when our website is visited and used. The following data are stored and transmitted in the cookies, among other things: cookie preferences selected by the user as well as the date and time of selection.
6.1.2 The purpose of using these cookies is to store the cookie settings selected by website visitors in the cookie box when they first visit the website. The legal basis for the transmission of the data is Art. 6 (1) (f) EU-DSGVO.
6.2.1 We use Google Tag Manager from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Tag Manager uses cookies to obtain and technically implement your consent to or rejection of Google Analytics (see 6.4 Google Analytics). The following data are stored and transmitted in the cookies, among other things: consent to or rejection of the use of Google Analytics (see 6.4 Google Analytics for more information).
6.2.2 The purpose of using these cookies is to implement your consent to or rejection of the use of Google Analytics on a technical level. The legal basis for the transmission of the data is Art. 6 (1) (f) EU-DSGVO.
6.3.1 We participate in various affiliate programmes in order to promote our offering. When you click on an affiliate link placed on an external website that leads to our offering, a cookie is set that records data. The following data are stored and transmitted in the cookie, among other things: technical data (e.g. IDs for campaigns, tracking, assignment at user/product level), product specifications (e.g. terms or vehicle data), response data, usage data and usage profiles from web tracking (e.g. usage data recorded in the contractor’s web analytics system, in particular users’ IP addresses).
6.3.2 The purpose of using these cookies is to ensure that our marketing partners receive the agreed remuneration after successfully referring a customer. The legal basis for the transmission of the data is Art. 6 (1) (f) EU-DSGVO.
6.4.1 We use Google Analytics, a web analytics service of Google Inc. (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to analyse the use of our offering. Google Analytics uses cookies that record data when our website is visited and used. The following data are stored and transmitted in the cookies, among other things: IP address, usage data.
6.4.2 The purpose of using these cookies is to analyse the user behaviour in relation to the digital offering and, on the basis of the findings and feedback obtained, to optimise our services and our digital offering. The legal basis for the transmission of the data is Art. 6 (1) (a) EU-DSGVO.
6.5.1 We use functions of the online advertising service Google Ads to promote our offering on our website. Google Ads is a service of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. In this context, we use search and display ads as well as conversion tracking. Google Conversion Tracking is an analytics service. If you click on an ad placed by Google, a cookie for conversion tracking is stored on your device. These cookies have a limited validity period, do not contain any personal data and are therefore not used to personally identify you. If you visit certain pages of our website and the cookie has not yet expired, Google and we can recognise that you have clicked on the ad and have been redirected to this page. Each Google Ads customer receives a different cookie. Therefore, there is no possibility of tracking cookies across the websites of Ads customers. Attribution is done by means of a statistical analysis of non-personal data.
6.5.2 The purpose of using these cookies is to provide you with interest-based advertising. The legal basis for the transmission of the data is Art. 6 (1) (a) EU-DSGVO.
6.6.1 We use “Google reCAPTCHA” (provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to protect our website against spam and abuse. reCAPTCHA analyses the behaviour of website visitors based on various characteristics (e.g. IP address, time spent on the website, mouse movements, device information) in order to distinguish between humans and automated programmes. The data collected in this context are transmitted to Google and may also be processed on servers in the USA.
6.6.2 The legal basis is our legitimate interest in the secure operation of our website (Art. 6 (1) (f) EU-DSGVO). Where you have given your consent via our cookie banner, the legal basis is Art. 6 (1) (a) EU-DSGVO. You may withdraw your consent at any time.
Further information can be found in Google’s privacy policy and terms of use.
6.7.1 We use a pop-up from Mailchimp (The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA). The Mailchimp pop-up uses cookies that record data when our website is visited and used. The following data are stored and transmitted in the cookies, among other things: date and time of the page view.
6.7.2 The purpose of using these cookies is to provide our website visitors with a simple and convenient way to sign up for our newsletter. The legal basis for the transmission of the data is Art. 6 (1) (f) EU-DSGVO.
6.8.1 We use the WordPress plugin Contact Form 7 (provider: Rock Lobster LLC, 812-0011 Fukuoka, Fukuoka-shi, Hakata-ku, Hakata-ekimae 1-chome 15–20, NMF Hakata Ekimae Building 2F, Japan) on our website to provide contact forms. The data you enter (e.g. name, e-mail address, message) are processed solely for the purpose of handling your enquiry and transmitted to us. The data are not passed on to third parties.
6.8.2 The legal basis is Art. 6 (1) (b) EU-DSGVO (steps prior to entering into a contract/contract performance) and Art. 6 (1) (f) EU-DSGVO (legitimate interest in efficient communication).
7.1 We place advertising via various channels. In connection with the use of Google Analytics in combination with Google AdWords and DoubleClick by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”), we place adverts on the internet. Our adverts are shown on websites by third-party providers. Cookies are used for this purpose, which store personal data (IP address and usage data). This enables targeted alignment, optimisation and placement of adverts based on your previous visits to our website. The legal basis for the data processing is Art. 6 (1) sentence 1 (a) EU-DSGVO.
7.2 Retargeting / remarketingIn addition, on the basis of your consent (Art. 6 (1) (a) EU-DSGVO), we use retargeting functions in order to address visitors to our website with interest-based advertising on other websites. For this purpose, we use technologies such as Google Analytics Remarketing Audiences, where cookies or similar technologies are used to analyse and recognise user behaviour. This enables appropriate advertising to be displayed to users who have already visited our website on Google partner pages. You can withdraw your consent at any time via our cookie consent tool or deactivate personalised advertising in the settings of your Google account.
This website uses so-called web fonts provided by Google (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) for the uniform display of fonts. When you access a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly. For this purpose, the browser you use must connect to Google’s servers. In this way, Google becomes aware that our website has been accessed via your IP address. Consequently, personal data are transferred to a third country. The use of Google Web Fonts is in the interest of a uniform and appealing presentation of our online offering. This constitutes a legitimate interest within the meaning of Art. 6 (1) (f) EU-DSGVO. If your browser does not support web fonts, a standard font from your computer will be used. Further information on Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.
9.1 We send newsletters, e-mails and other electronic notifications (hereinafter collectively referred to as “newsletter”) containing information about our services, our company and developments in the financial world. Newsletters are sent only with the recipient’s consent. To register for the newsletter, it is sufficient for the recipient to provide their e-mail address. You can withdraw your consent at any time by unsubscribing from the newsletter. You will find information on this at the end of each newsletter.
9.2 Gerd Kommer Invest GmbH uses the so-called double opt-in procedure for registration, which means that your registration is only complete once you have confirmed your registration by clicking on the link in an e-mail sent to you for this purpose. Your data are stored in our IT systems as part of the registration process and in this context passed on to service providers acting as processors in accordance with Article 28 EU-DSGVO.
9.3 As a processor for sending the newsletters, we use the “Mailchimp” service provided by “The Rocket Science Group, LLC” (675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA). Mailchimp processes the data provided by users for the purpose of sending the newsletter on behalf of Gerd Kommer Invest GmbH. In addition, analytics data (e.g. IP addresses or usage behaviour) are collected in order to continuously improve the newsletter. Gerd Kommer Invest GmbH has concluded a data processing agreement with Mailchimp in accordance with Art. 28 EU-DSGVO, thereby ensuring that the data are processed only in accordance with the instructions of Gerd Kommer Invest GmbH. The legal basis for the data processing is Art. 6 (1) sentence 1 (a) EU-DSGVO.
9.4 Gerd Kommer Capital (GKC) is a brand under which Scalable Capital GmbH offers financial portfolio management. Scalable Capital GmbH is advised by Gerd Kommer Invest GmbH on portfolio management. The custodian bank is Baader Bank AG. When registering for this financial portfolio management, you can consent to receiving the newsletter of Gerd Kommer Invest GmbH. The newsletter is generally sent once a month. If you give your consent at the beginning of the registration process for the financial portfolio management, the e-mail address used is transmitted by Scalable Capital GmbH to Gerd Kommer Invest GmbH and from there to Gerd Kommer Invest GmbH.
9.5 Gerd Kommer Invest GmbH has concluded a data processing agreement with Gerd Kommer Invest GmbH in accordance with Art. 28 EU-DSGVO, thereby ensuring that the data are processed only in accordance with the relevant instructions and in compliance with all statutory provisions. The legal basis for the data processing is Art. 6 (1) sentence 1 (a) EU-DSGVO. You can withdraw your consent at any time by unsubscribing from the newsletter. You will find information on this at the end of each newsletter.
9.6 The legal basis for the transmission of your e-mail address in connection with subscribing to the newsletter is Art. 6 (1) (a) EU-DSGVO (consent of the data subject). The legal basis for the processing of your data in the context of written communication with you is Art. 6 (1) (b) EU-DSGVO (performance of a contract or steps prior to entering into a contract), Art. 6 (1) (c) EU-DSGVO (compliance with a legal obligation) and Art. 6 (1) (f) EU-DSGVO (legitimate interest). The legal basis for the use of cookies is Art. 6 (1) (a) EU-DSGVO (consent of the data subject).
9.7 The data are deleted after the expiry of the statutory retention periods and if the data are no longer required for the establishment, exercise and/or defence of legal claims.
10.1 In addition to the purely informational use of our digital offering, you can make use of a securities service via the financial portfolio management of Scalable Capital GmbH. Scalable Capital GmbH is advised by Gerd Kommer Invest GmbH on portfolio management. For this purpose, you must register and open a user account (“registration”). This requires you to provide data which are also transferred to Gerd Kommer Invest GmbH for this purpose. On the one hand, information about your knowledge and experience with financial instruments and securities services, your investment objectives and your financial circumstances is required so that the securities institution cooperating with us can recommend an appropriate investment strategy to you. On the other hand, information on your person as well as contact details, reference account and tax information is required. Finally, in the course of the identification process, a copy of the identification document as well as a photograph of the client is collected. Where additional voluntary information is possible, this is marked accordingly.
10.2 Gerd Kommer Invest GmbH uses the so-called double opt-in procedure for registration, which means that your registration is only complete once you have confirmed your registration by clicking on the link in an e-mail sent to you for this purpose. Your data are stored in our IT systems as part of the registration process and in this context passed on to service providers acting as processors in accordance with Article 28 EU-DSGVO (e.g. software-as-a-service (SaaS) providers and cloud service providers). Your data are also partly transferred to the securities institution cooperating with us and to the custodian bank.
10.3 Gerd Kommer Invest GmbH deletes your data after the complete termination and settlement of the legal relationship with you, but not before the expiry of statutory, supervisory or other official retention periods. If you do not complete your registration within six months (and therefore do not become a client), Gerd Kommer Invest GmbH will delete your data.
10.4 The purpose of processing the aforementioned data is to identify our clients in accordance with statutory requirements, to carry out the legally required suitability assessment and, in general, to create the conditions for providing our securities service. The legal basis for the processing of the data is Art. 6 (1) (b) EU-DSGVO (performance of a contract or steps prior to entering into a contract) and Art. 6 (1) (c) EU-DSGVO (compliance with a legal obligation).
10.5 The collection of these data is absolutely necessary for our service. The user therefore has no possibility to object.
If you have given us consent, you may withdraw it at any time with effect for the future.
Where we base the processing of your personal data on a balancing of interests, you may object to the processing. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of a justified objection, we will either stop or adapt the data processing or demonstrate our compelling legitimate grounds on the basis of which we will continue the processing.
You can object at any time to the processing of your personal data for the purposes of advertising and data analysis.
You can send your withdrawal of consent or your objection to us using the contact details under “Controller” or to:
Status: 29 September 2025
With this information we inform you about the processing of your personal data in the context of the initiation, conclusion and performance of advisory agreements by Gerd Kommer Invest GmbH, as well as about the rights to which you are entitled under the applicable data protection law.
Gerd Kommer Invest GmbH
Sendlinger Straße 41
80331 Munich
Tel.: +49 (0) 89 1250 1123 10
E-mail: ed.tsevni-remmok-dreg@liam
Represented by: Dr Gerd Kommer, Jonas Schweizer and Felix Großmann
The controller’s data protection officer can be contacted at:
Gerd Kommer Invest GmbH
Sendlinger Straße 41
80331 Munich
E-mail: ed.remmok-dreg@ztuhcsnetad
Personal data within the meaning of data protection law are all data that relate to you personally. This includes, for example, your name, address or information about your profession.
In order to provide the advisory services we offer, we depend on collecting and processing a large amount of personal data from you so that we can support you in the best possible way. The personal data that we process for this purpose include in particular:
For documenting conversations, we use the AI-based transcription service “Bliro” (Bliro GmbH, Munich). In this context, in particular the content of conversations as well as associated basic data (e.g. name, time and duration of the conversation) are processed. The processing is carried out on the basis of our legitimate interest in efficient and legally compliant documentation of our services (Art. 6 (1) (f) GDPR); the data are processed on servers within the EU and stored in accordance with the applicable retention periods. The conversation itself is not recorded or stored. You may object to the use of Bliro for future conversations at any time with effect for the future.
We require the aforementioned data for the performance of the contractual relationship, e.g. for the preparation of the advisory agreement, for correspondence with you and with third parties during the contractual relationship (see below), for invoicing, asset management, etc.
All data provided may also be processed on the basis of statutory requirements (e.g. the German Anti-Money Laundering Act, tax laws, etc.) for identity and age verification, prevention of fraud and money laundering, compliance with tax control and reporting obligations as well as for the assessment and management of our risks.
The conclusion and/or performance of the advisory agreement is not possible without the processing of your personal data.
We may also process your data on the basis of consent obtained from you in individual cases for specific purposes (e.g. sending newsletters, read-only access to custody accounts and bank accounts). You may withdraw such consent at any time. Withdrawal of consent only takes effect for the future and does not affect the lawfulness of data processed prior to the withdrawal.
The processing of your personal data by us is carried out in compliance with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and all other relevant laws.
The legal basis for collecting your personal data for taking steps prior to entering into a contract, carried out at your request, and/or for the performance of the contract with you is Art. 6 (1) sentence 1 (b) GDPR.
In addition, we process your personal data for the purpose of complying with legal obligations (e.g. arising from the German Anti-Money Laundering Act). The legal basis for this is Art. 6 (1) sentence 1 (c) GDPR in conjunction with the relevant legal provisions.
Where and to the extent that you have given us consent, the legal basis for processing on the basis of consent is Art. 6 (1) sentence 1 (a) GDPR.
Should we in future process your data for purposes other than those mentioned above or on a legal basis other than those set out above, we will inform you of this in advance in accordance with the statutory provisions.
We also process your data in order to safeguard legitimate interests of ours or of third parties (Art. 6 (1) (f) GDPR). This may in particular be necessary:
a) Internal units
Recipients of personal data are in particular internal units.
b) External service providers or external parties
For the performance of our contractual and statutory obligations, we use external service providers who process data on our behalf as so-called processors, bound by our instructions and obliged to handle the data carefully. We also use external parties that are not bound by instructions, but are themselves controllers (e.g. auditors, lawyers or other fee-based financial investment advisors). Where we have more than merely temporary business relationships with such parties, you can refer to the following overview for the categories of external parties we use:
| Category | Description |
| Service providers | e.g. cleaning services, reception services, security services, experts, etc. |
| Disposal service providers | Destruction of documents |
| Financial / supervisory authorities | Notifications and levies, audits in accordance with statutory requirements |
| Financial institutions | Payment transactions, custody account management |
| IT companies | Maintenance/servicing and provision of hardware and software; processing of personal data |
| Financial intermediaries/brokers | Brokerage of financial investments or real estate, administration of insurance contracts such as professional indemnity insurance, etc. |
| Tax advisors, auditors | Annual financial statements/audits |
| Lawyers | Legal advice and litigation |
In order to comply with statutory notification obligations, your personal data may be transmitted to additional recipients not mentioned here. This relates in particular to public authorities (tax authorities, social security providers, supervisory authorities, law enforcement authorities, etc.).
As a general rule, your data are only passed on to third parties if you have given us your consent or if this is permitted by law. This is the case, for example, where the recipients are our external service providers whom we have carefully selected and engaged and who are bound by our instructions and subject to regular controls (e.g. web hosting providers), or where transfer is necessary in order to comply with a legal obligation to which we are subject.
If we transfer personal data to service providers outside the European Economic Area (EEA), such transfer will only take place where the European Commission has confirmed that the third country concerned ensures an adequate level of data protection or where other appropriate data protection safeguards (e.g. binding corporate rules or EU standard contractual clauses) are in place.
7.1 Your personal data are deleted or blocked as soon as they are no longer required for processing for the purpose of complying with legal obligations and the purpose of storage no longer applies.
7.2 Please note that, even after termination of a contract, it may still be necessary to store personal data in order to comply with contractual or statutory obligations,
7.3 to comply with commercial or tax law retention obligations (e.g. under the German Commercial Code and the German Fiscal Code) with retention periods of up to ten years from the end of the calendar year, or
7.4 for the establishment or exercise of claims or rights or the defence against claims or rights within the framework of the statutory provisions on limitation periods, which may be up to 30 years from the respective statutory commencement of the limitation period.
You have the following statutory rights vis-à-vis us with regard to the personal data concerning you:
a) Right of access (Art. 15 GDPR): You have the right to obtain confirmation as to whether we are processing personal data concerning you. Where this is the case, you have the right of access to such personal data and to further information, e.g. the purposes of the processing, the recipients and the envisaged storage period or the criteria used to determine that period.
b) Right to rectification and completion (Art. 16 GDPR): You have the right to obtain without undue delay the rectification of inaccurate data. Taking into account the purposes of the processing, you have the right to have incomplete data completed.
c) Right to erasure (“right to be forgotten”) (Art. 17 GDPR): You have the right to obtain erasure where processing is not required. This is the case, for example, where your data are no longer necessary for the original purposes, you have withdrawn your consent under data protection law, or the data have been unlawfully processed.
d) Right to restriction of processing (Art. 18 GDPR): You have the right to obtain restriction of processing, for example if you consider the personal data to be inaccurate.
e) Right to data portability (Art. 20 GDPR): You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format.
f) Right to withdraw your consent under data protection law (Art. 7 (3) GDPR): You may withdraw consent to the processing of your personal data at any time with effect for the future. The lawfulness of processing carried out prior to the withdrawal remains unaffected.
Where personal data are processed for the performance of tasks carried out in the public interest (Art. 6 (1) sentence 1 (e) GDPR) or for the purposes of legitimate interests (Art. 6 (1) sentence 1 (f) GDPR), you have the right to object at any time to the processing of personal data concerning you with effect for the future. In the event of an objection, we must refrain from any further processing of your data for the aforementioned purposes unless
a) there are compelling legitimate grounds for the processing which override your interests, rights and freedoms, or
b) the processing is necessary for the establishment, exercise or defence of legal claims.
If you consider that the processing of data is not in compliance with data protection regulations, you have the option of lodging a complaint with our data protection officer named in section 2. You may also lodge a complaint at any time with a competent data protection supervisory authority. The data protection supervisory authority competent for us is:
Bayerisches Landesamt für Datenschutzaufsicht
Promenade 27
91522 Ansbach
The personal data processed are either collected directly from the data subject or from third parties (e.g. a credit reference agency) and may also originate from publicly accessible sources such as telephone directories, the press or the internet.
The provision of personal data is required for the conclusion and performance of the advisory agreement; both are not possible without the processing of your personal data.
In addition, under anti-money laundering regulations we are obliged, before establishing a business relationship, to identify you on the basis of your identity document and to collect and store your name, place of birth, date of birth, nationality, address and identity document data; you must therefore provide us with the information and documents necessary for this purpose and notify us without delay of any changes arising in the course of the business relationship. If you refuse to provide this information, we may not establish or continue the business relationship with you.
You will not be subject to a decision based solely on automated processing of your data, including profiling (Art. 13 (2) (f) GDPR, Art. 22 (1) to (4) GDPR, Art. 4 no. 4 GDPR in conjunction with section 37 BDSG), which produces legal effects concerning you or similarly significantly affects you.
For further information, requests for access or objections to data processing, please contact the address given in section 1.
In addition, we refer to the full text of the GDPR and the BDSG.
Status: 31 July 2025
Gerd Kommer Invest GmbH
(These documents are available in German only.)
The value of investments and the income derived from them can rise as well as fall, meaning that you may not get back the amount invested. Past performance is not an indicator of future performance. It should be noted that diversification is no guarantee against loss in a falling market. The above information does not constitute a recommendation to buy or sell securities.
The information contained herein is for informational purposes only and does not constitute investment advice, brokerage services or a recommendation to buy or sell any security. The above information is general in nature and does not take into account the investor’s individual circumstances. All views expressed reflect the opinion of Gerd Kommer at the time of publication. The information is not intended for distribution to any person resident in a country where such distribution would be contrary to the laws or regulations in force there.
A summary of investor rights associated with an investment in the fund, in English, is available at:
https://fundcentres.lgim.com/en/de/private-investors/fund-centre/ETF/Gerd-Kommer-Multifactor-Equity/
The risks associated with the individual funds or investment strategies are set out in the key investor information and in the prospectus or the investment management agreement, as applicable. These documents should be reviewed before making any investment decision. A copy of the English version of the prospectus and the key investor information for each fund is available at
https://fundcentres.lgim.com/en/de/private-investors/fund-centre/ETF/Gerd-Kommer-Multifactor-Equity/
and may also be requested from your client advisor.
A decision may be made at any time to terminate the arrangements made for the distribution of the fund in an EEA member state in which it is currently distributed. In such a case, shareholders in the affected EEA member state will be informed of this decision and will be given the opportunity to redeem their units in the fund for at least 30 working days from the date of such notification, without any charges or deductions. Where required under national regulations, the key investor information document will also be made available in the official language of the relevant EEA member state.
Information on the sustainability aspects of the funds can be found at:
https://fundcentres.lgim.com/en/de/private-investors/fund-centre/ETF/Gerd-Kommer-Multifactor-Equity/
When deciding to invest in the funds, all characteristics or objectives of the fund, as described in its prospectus and in the key investor information document, should be taken into account.
Gerd Kommer Invest GmbH
Sendlinger Straße 41
80331 Munich
Germany
If you have any questions, just get in touch with us.
E-mail contact:
Note: For regulatory reasons, we are not permitted to answer inquiries regarding the investment approach of the L&G Gerd Kommer Multifactor Equity UCITS ETF. Please have a look at our Frequently Asked Questions (FAQ) for this information.
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