Privacy Policy

Last updated: 15th January 2026

IronMeadow AG ("we", "our", or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our financial planning services.

Data Controller Information

The data controller responsible for your personal information is IronMeadow AG, a company registered in Germany with registration number HRB612386. Our registered office is located at Bahnhofstraße 92, 10515 Berlin, Germany.

Data We Collect

We collect various types of personal data to provide our financial planning services effectively. The data we collect includes information you provide directly to us and information we gather automatically when you use our website.

Information You Provide

• Contact details (name, email address, phone number, postal address)
• Financial information (income, assets, liabilities, investment goals)
• Demographic information (age, occupation, family status)
• Communication preferences and enquiry details
• Documentation required for financial planning services

Information Collected Automatically

• Website usage data (pages visited, time spent, navigation patterns)
• Technical information (IP address, browser type, device information)
• Cookies and tracking technologies data
• Referral source and marketing campaign effectiveness data

How We Use Your Information

We use your personal data for legitimate business purposes in accordance with applicable data protection laws. How we use your information depends on the nature of our relationship and the services you request from us.

Service Provision

• Providing financial planning and advisory services
• Conducting financial assessments and creating personalised strategies
• Managing investment portfolios and monitoring performance
• Communicating with you about your financial plans and market developments

Business Operations

• Processing enquiries and scheduling consultations
• Maintaining accurate client records and documentation
• Complying with regulatory requirements and legal obligations
• Improving our services and developing new offerings

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please refer to our Cookie Policy.

Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Contractual necessity: To provide financial planning services you have requested
• Legitimate interests: To improve our services and communicate relevant information
• Legal compliance: To meet regulatory requirements in the financial services sector
• Consent: For marketing communications and certain cookies (where required)

Data Sharing and Disclosure

We do not sell your personal information to third parties. We may share your data in the following limited circumstances:

• With professional service providers (accountants, legal advisors) when necessary for your financial planning
• With regulatory authorities as required by German financial services law
• With technology service providers who assist in operating our website and systems
• In connection with legal proceedings or to protect our legitimate interests

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected. For financial planning clients, we typically retain records for a minimum of seven years after the end of our relationship, as required by German financial services regulations. Data retention periods may vary based on the type of information and applicable legal requirements.

Your Rights

Under GDPR and German data protection law, you have the following rights regarding your personal data:

• Right of access: Request copies of your personal data
• Right to rectification: Request correction of inaccurate or incomplete data
• Right to erasure: Request deletion of your data in certain circumstances
• Right to restrict processing: Request limitation of how we use your data
• Right to data portability: Request transfer of your data in a structured format
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Withdraw consent for processing where applicable

International Data Transfers

We primarily process your data within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions by the European Commission.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, regular security assessments, and staff training on data protection principles.

Contact Information

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us using the following details:

Complaints

If you believe we have not handled your personal data appropriately, you have the right to lodge a complaint with the relevant supervisory authority. In Germany, this is the Federal Commissioner for Data Protection and Freedom of Information (Bundesbeauftragte für den Datenschutz und die Informationsfreiheit).

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "last updated" date. We encourage you to review this policy periodically to stay informed about how we protect your information.

Additional Information

For more information about our data processing practices, please refer to our related policies:

• Cookie Policy
• Terms of Service

This Privacy Policy is governed by German law and complies with the requirements of the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).