Advising a robo-advisor / digital asset manager on data protection

Client

My client is an award-winning startup in the field of digital asset management (so-called robo-advisor). Via the website or native app, customers are first asked questions about risk aversion, goals, monthly savings rates, financial circumstances, and their investment horizon. Based on the answers, an individual investment portfolio is automatically suggested. Portfolios can be monitored or the customer can open a custody account directly via the platform and buy the suggested portfolio.

Consultancy

• Draft privacy notices / privacy policy for the website, online platform and native app.
• Advice on data protection-compliant design, including video legitimation (in accordance with the Money Laundering Act - GWG) and optional consents for data analysis and marketing
• Contract drafting under data protection law in the context of business partners (including white label models, technical service providers / platform operators, contracts with account information service providers, data analytics service providers)
• Advice on data protection and cookies in the field of analytics and online marketing (remarketing / retargeting)

Expertise Gained

• Insight into the functioning of digital asset management / robo-advisors
• Legal advice in the context of the highly regulated financial industry (e.g. money laundering, KWG, ZAG, WpHG)
• Close cooperation with lawyers from adjacent disciplines