Data Privacy Statement
Applicability, Name and Address of the Controller
Operator and controller for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection regulations of the website
SL55 Tower, 17th floor
Samuel Lewis Avenue
Panama City, Panama
How do we collect your data?
On the one hand, your data is collected when you provide it to us. This may be data that you enter in a contact form, for example.
Other data is collected automatically or with your consent by our IT systems when you visit the website. This is mainly technical data (e.g. internet browser, operating system or time of page access). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Some of the data is collected in order to ensure error-free provision of the website. Other data may be used to analyse your user behaviour.
What rights do you have regarding your data?
You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
Third-party analysis tools and tools
When visiting this website, your surfing behaviour may be statistically analysed. This is done primarily with so-called analysis programmes.
Detailed information on these analysis programmes can be found in the following data protection declaration.
Right to object to the collection of data in specific cases and to direct marketing (Art. 21 GDPR)
If the data processing is based on Art. 6 (1) e or f GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this data protection declaration. If you object, we will no longer process your personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims (objection under Article 21(1) of the GDPR).
If your personal data are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object, your personal data will subsequently no longer be used for the purpose of direct advertising (objection pursuant to Art. 21 (2) GDPR).
Right to information, deletion, blocking
You have the right:
- to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;
- to demand the correction of inaccurate or incomplete personal data stored by us without undue delay in accordance with Art. 16 GDPR;
- pursuant to Article 17 of the GDPR, to request the erasure of your personal data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defence of legal claims;
- in accordance with Art. 18 GDPR, to request the restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you object to its erasure and we no longer require the data, but you need it for the assertion, exercise or defence of legal claims or you have objected to the processing in accordance with Art. 21 GDPR;
- pursuant to Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller;
- to revoke your consent at any time in accordance with Art. 7 (3) GDPR. This has the consequence that we may no longer continue the data processing based on this consent in the future; and
- to complain to a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters for this purpose.
Links to other Websites
Our website may contain hyperlinks to third-party websites. We accept no responsibility for the content of these websites, nor do we adopt these websites and their content as our own. The respective provider or operator of the pages is always responsible for the content of the linked pages. The linked pages were checked for possible legal violations at the time of linking. Illegal contents were not identifiable at the time of linking. However, permanent monitoring of the content of the linked pages is not reasonable without concrete indications of a legal violation. If we become aware of any infringements of the law, we will remove such links immediately.
Information is stored in the cookie that is related to the specific end device used. However, this does not mean that we gain direct knowledge of your identity.
In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your end device for a certain fixed period of time. If you visit our site again in order to use our services, it is automatically recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again.
The data processed by cookies is necessary for the aforementioned purposes to protect our legitimate interests as well as those of third parties in accordance with Art. 6 (1) p. 1 lit. f GDPR.
Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a notice always appears before a new cookie is created. However, the complete deactivation of cookies may mean that you cannot use all the functions of our website.
This website uses a Borlabs Cookie, which sets a technically necessary cookie (borlabs-cookie) to store your cookie preferences.
Borlabs Cookie does not collect any personal data.
The borlabs-cookie cookie stores the consent you have given when you entered the website. If you wish to revoke these consents, simply delete the cookie from your browser. If you re-enter/reload the website, you will be asked again for your cookie consent.
Regardless of whether you use our e-mail contact form, the provider of this site automatically collects and stores information in so-called server log files, which your browser automatically transmits to us.The storage period is 30 days.
- The browser used and, if applicable, the operating system of your computer as well as the name of your access provider.
- Website from which the access was made (referrer URL)
- IP address of the requesting computer
- Date and time of the server request
- Name and URL of the retrieved file
The legal basis for data processing is Art. 6 para. 1 p. 1 lit. f GDPR. Our legitimate interest follows from the purposes for data collection listed above. In no case do we use the collected data for the purpose of drawing conclusions about your person.
The aforementioned data is processed by us for the following purposes:
- Ensuring a smooth connection set-up of the website,
- Ensuring a comfortable use of our website,
- evaluating system security and stability, and
- for other administrative purposes.
If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass on this data without your consent.
The processing of this data is based on Art. 6 (1) lit. b GDPRif your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on your consent (Art. 6 para. 1 lit. a GDPR) and / or on our legitimate interests (Art. 6 para. 1 lit. f GDPR), as we have a legitimate interest in effectively processing the enquiries directed to us.
The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. after we have completed processing your enquiry). Mandatory legal provisions – in particular retention periods – remain unaffected.
Please contact us directly regarding the duration of data storage.
SSL or TLS encryption
For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Newsletter, Travel Tips
We offer you to subscribe to our free newsletter on our WebSite. In addition we also offer you to subscribe to receive our travel tips or other information we may offer you free of charge. In this case the data entered by you into the subscription form, which in any case is the e-mail address provided by you, will be transferred to us.
For the subscription to our newsletters we use the so-called double opt-in procedure. This means that immediately after the subscription to our newsletter you will receive a verification e-mail by means of which we will ask you to confirm your subscription. If case the confirmation is granted, we will store your e-mail address as well as any other data provided by you in addition, if any, until you unsubscribe from the newsletter. In order to prevent any misuse, we also save the IP address from which the link provided in the verification e-mail has been accessed as well the time of the access.
Legal basis for the processing of data after subscription to the newsletter is Art. 6 para. 1 lit. a GDPR. The collection of the e-mail address is necessary in order to send the newsletter to the subscribers.
You may revoke your consent to receiving the newsletter at any time with effect for the future and unsubscribe from the newsletter by clicking on the relevant link provided in each newsletter or by sending an e-mail to klaus.happ(at)frapan-invest.com.
Google Tag Manager
Google Tag Manager is a solution that allows marketers to manage website tags through one interface. The Tag Manager tool itself (which implements the tags) is a cookieless domain. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, this will remain in place for all tracking tags implemented with Google Tag Manager.
We may ask you for permission to share some product data (e.g. your account information) with other Google products to enable certain features, such as making it easier to add new conversion tracking tags for AdWords. In addition, our developers review product usage information from time to time to further optimise the product. However, we will never share this type of data with other Google products without your consent.
For more information, see the usage guidelines for this product: https://www.google.com/intl/de/tagmanager/use-policy.html
This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States.
Demographic characteristics with Google Analytics
This website uses the “demographic characteristics” function of Google Analytics. This allows reports to be generated that contain statements about the age, gender and interests of site visitors. This data comes from interest-based advertising from Google as well as visitor data from third-party providers. This data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as shown in the item “Objection to data collection”.
Google Ads and Google Conversion Tracking
This website uses Google Ads. Ads is an online advertising programme of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
Within the framework of Google Ads, we use so-called conversion tracking. When you click on an ad placed by Google, a cookie is set for conversion tracking. Cookies are small text files that the internet browser stores on the user’s computer. These cookies lose their validity after 30 days and are not used to personally identify the user. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognise that the user clicked on the ad and was redirected to this page.
Each Google Ads customer receives a different cookie. The cookies cannot be tracked across Ads customers’ websites. The information obtained using the conversion cookie is used to create conversion statistics for Ads customers who have opted in to conversion tracking. Clients learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that personally identifies users. If you do not wish to participate in the tracking, you can object to this use by easily deactivating the Google conversion tracking cookie via your internet browser under user settings. You will then not be included in the conversion tracking statistics.
The storage of “conversion cookies” and the use of this tracking tool are based on Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited.
Contact data of the Data Protection Officer
All inquiries, requests and declarations as to the use of personal data can be send protection officer via e-mail to
or by post to
SL55 Tower, 17th floor
Samuel Lewis Avenue
Panama City, Panama