With the following data protection information, we would like to give you an overview of the processing of your personal data when you visit our website and in general at our company. We would also like to explain to you for which purposes we collect which data and which rights you are entitled to in this context. The data protection information applies to our websites and our profiles on social media platforms.
1. contact details of the person responsible and the contact person for data protection concerns
The controller within the meaning of the EU General Data Protection Regulation (hereinafter "GDPR"), the Federal Data Protection Act, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is the:
TRADIUM GmbH
Kennedyallee 123
60596 Frankfurt am Main
Germany
Phone: +49 (0) 69 50 50 250- 0
Fax: +49 (0) 69 50 50 250- 11
Mail: info@tradium.com
Managing Partner: Matthias Rüth
Data Protection Officer: Kimia Rüth
Phone: +49 (0) 69 50 50 25 0- 203
Fax: +49 (0) 69 5050250- 11
E-mail: info@tradium.com
2. provision of the websites
Our system automatically collects data and information that your Internet browser transmits to us when you visit one of our websites. The following data is processed:
- the current IP address of the Internet connection you are using,
- if you visit our website via a link, the page from which you visit us,
- the pages visited,
- Date and time of your visit,
- the operating system you are using, the browser name and the browser version,
- the name of your Internet access provider,
- the amount of data transferred.
The collection of data for the provision of the websites and the storage of data in so-called log files is absolutely necessary for the operation of the websites.
The legal basis for data processing is Art. 6 para. 1 lit. f GDPR.
The temporary storage of the IP address by the system is necessary to enable the website to be delivered to your computer. The purpose of storage in log files is to ensure the functionality and stability of the website. These purposes also constitute our legitimate interest in data processing in accordance with Art. 6 para. 1 lit. f GDPR. The data is neither passed on to third parties nor merged with other data.
The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected, unless contractual or legal obligations prevent deletion. The deletion takes place at the latest seven days after the end of the respective session and closing of the browser.
3. contact via contact form, chat, e-mail or telephone
On some websites, we provide a contact form that you can use to send us your contact details and concerns. When you send the contact form, the data you provide (contact details such as name, e-mail address, address, telephone number, your desired investment volume, your request) will be transmitted to us and processed by us for the purpose of processing your request and contacting you. As part of the sending process, the date and time of sending the contact form and your IP address are automatically saved by the system.
Alternatively, you can contact us via the e-mail addresses and telephone numbers provided. In these cases, we will process your personal data transmitted by e-mail or telephone.
If it makes sense and you have given your consent, we will transfer your data to one of our sales partners abroad for the purpose of further communication in your native language.
The provision of your data is voluntary. Failure to provide personal data, insofar as it concerns mandatory information in our contact form or our chat function, means that it is not possible for us to process your request.
The legal basis for the processing of your data transmitted via a contact form, e-mail or telephone is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in processing your request. If the date and time of the sending process and your IP address are automatically collected when you send a contact form or chat input, this serves to ensure the security of our systems and to protect against misuse. This is also our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. We obtain your consent for data processing when using our chat function, Art. 6 para. a GDPR. We will also obtain your consent if we transfer your data to one of our sales partners abroad for the purpose of further communication. If the contact is aimed at establishing a contractual relationship with us or takes place within the framework of an existing contractual relationship, Art. 6 para. 1 lit. b GDPR is a further legal basis for data processing.
Your data will be deleted as soon as the respective conversation with you has ended, unless the deletion conflicts with contractual or statutory retention obligations. The conversation is deemed to have ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified. As a rule, the data is deleted three years after the end of the conversation. If we establish a business relationship with you or are in a contractual relationship, your data required for the implementation of pre-contractual measures and/or a contract will be stored for the duration of the contractual relationship and, in addition, for the duration of the retention periods under commercial or tax law.
4. establishment, existence and handling of a business relationship
For the purpose of establishing or implementing a future or existing business relationship, we process your personal data required for this, such as your name, address, email address, telephone number, data for identification purposes (e.g. ID card or passport data) and data from the fulfilment of our contractual obligations (contractual documents, declarations, communication, bank details). We receive this data as part of our business relationship and its initiation from you (e.g. via a contact form) or from sales partners or intermediaries cooperating with us. In addition, we may process data that we have legitimately collected from publicly accessible sources (e.g. debtor directories, commercial and association registers, land registers, etc.) if this is necessary in the context of our service.
If we work together with a sales partner or intermediary to establish a business relationship, we may exchange information with this sales partner or intermediary about the conclusion of a contract in order to be able to calculate any commission payments.
As part of the contractual relationship, you only need to provide the personal data that is required for the establishment, execution and termination of the contractual relationship or that we are legally obliged to collect (e.g. due to tax regulations). Without this data, we will generally have to refuse to establish a business relationship.
The legal basis for data processing is the establishment and fulfilment of a contract or the implementation of pre-contractual measures, Art. 6 para. 1 lit. b GDPR. For individual processing operations, such as the exchange of data with a sales partner or agent of ours, we obtain your consent, Art. 6 para. 1 lit. a GDPR.
Your data will only be processed and stored for as long as is necessary for the purpose for which it was collected, in particular for the fulfilment of our contractual obligations and any additional statutory retention periods, e.g. from the German Commercial Code or the German Fiscal Code. These are usually six or ten years. In addition, data may be stored for the assertion and enforcement of legal claims within the statutory limitation periods, e.g. for the preservation of evidence.
5. use of Matomo
We use the "Matomo" programme in the cloud version for web analysis, a service provided by InnoCraft Ltd, a New Zealand company (NZBN 6106769) based at: 7 Waterloo Quay PO625, 6140 Wellington, New Zealand.
We use Matomo without cookies. In addition, we have configured Matomo so that your IP address is only recorded in abbreviated form. We therefore process your personal usage data in anonymised form. It is not possible for us or Matomo to identify you personally. Due to this particularly data-saving configuration of Matomo, you do not have to consent to its use in advance. We store the anonymised visitor data for 2 years.
Further information on Matomo's terms of use and data protection regulations can be found at: https://matomo.org/matomo-cloud-privacy-policy.
6. use of cookies on the websites
Cookies are used on our websites. Cookies are small text files that are stored on your end device. Technically necessary cookies are used to provide certain functions on our websites, e.g. language settings.
In addition to technically necessary cookies, third-party cookies may also be used to analyse your usage behaviour on our websites and to optimise our marketing activities. We obtain your express consent in advance for the use of such cookies.
To obtain and document your consent to the use of third-party cookies, we use the Borlabs function, a plug-in solution from Borlabs (Rübenkamp 32, 22305 Hamburg, Germany, hereinafter "Borlabs"). You can use the Borlabs cookie box to manage your cookie settings and call up further details on the cookies used (name, purpose, duration of function) on our websites. The Borlabs plugin stores the status of your consent. The legal basis for this data processing is our legal obligation to obtain and document your consent, Art. 6 para. 1 lit. c GDPR.
You can generally set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If you do not accept technically necessary cookies, the functionality of our websites may be restricted.
If personal data is processed using technically necessary cookies, the legal basis for this is our legitimate interest in maintaining the functionality of our websites, Art. 6 para. 1 lit. f GDPR.
The data collected by technically necessary cookies is not used to create user profiles.
Use of Google Analytics
Subject to your consent, we may use Google Analytics on our websites, a web analytics service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Analytics uses cookies, which are stored on your computer and enable your use of the website to be analysed.
The information generated by these cookies, such as the time, place and frequency of your website visit, including your IP address, is transmitted to Google in the USA and stored there. We use Google Analytics with the addition "_gat._anonymiseIp" on our website. In this case, your IP address will already be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and thereby anonymised.
Google will use this information on our behalf to analyse your use of our website, to compile reports on website activity for us and to provide other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
Google states that it will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website.
Google is a subsidiary of Google Inc. based in the USA. We cannot rule out the possibility that, even if providers are based in the EU, data may also be transferred to group companies in the USA or another third country. Some of these third countries do not have an adequate level of data protection. In some third countries, for example in the USA, government agencies have far-reaching access rights to data from companies based in these third countries. We have concluded an agreement with Google regarding order processing. We also use the standard contractual clause for the transfer of personal data from the European Union to third countries.
Google offers a deactivation add-on for the most common browsers, which gives you more control over what data Google collects about the website you visit. The add-on informs the JavaScript (ga.js) of Google Analytics that no information about the website visit should be transmitted to Google Analytics. However, the deactivation add-on for browsers from Google Analytics does not prevent information from being transmitted to us or to other web analysis services that we may use. For more information on installing the browser add-on, please click on the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
If you visit our websites via a mobile device (smartphone or tablet), you must click this link instead to prevent tracking by Google Analytics in the future. This is also possible as an alternative to the above browser add-on. Clicking the link will set an opt-out cookie in your browser that is only valid for this browser and this domain. If you delete the cookies in this browser, the opt-out cookie will also be deleted, so you will have to click the link again.
The legal basis for the use of the cookies used for Google Analytics is your consent (Art. 6 para. 1 lit. a) GDPR).
The data sent by us and linked to cookies, user identifiers (e.g. user ID) or advertising IDs are automatically deleted after 14 months. Data that has reached the end of its retention period is automatically deleted once a month. Further information on terms of use and data protection can be found at https://policies.google.com/?hl=de.
Use of Google Ads
Subject to your consent, we use functions of Google Ads and Google Conversion Tracking, a service of Google Ireland Ltd, Google Building Gordon House, Barrow St., Dublin 4, Ireland (hereinafter "Google").
Google Ads enables us to draw attention to our attractive offers with the help of advertising material on external websites and to determine how successful individual advertising measures are. These adverts are delivered by Google via so-called "AdServers". We use so-called AdServer cookies for this purpose, through which certain parameters for measuring success, such as the display of adverts or clicks by users, can be measured. If you access our websites via a Google advert, Google Ads will store a cookie on your end device. The cookie is not intended to identify you personally. The following information is usually stored as analysis values for the cookie: unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions), opt-out information (marking that the user no longer wishes to be addressed). These cookies enable Google to recognise your web browser. If you visit certain pages of a website and the cookie stored on your end device has not yet expired, Google can recognise that you clicked on the ad and were redirected to the website. A different cookie is assigned to each Ads customer. According to Google, cookies can therefore not be tracked via the websites of Ads customers.
We ourselves do not collect and process any personal data in the aforementioned advertising measures. We only receive statistical analyses from Google. These analyses allow us to recognise which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify individual users on the basis of this information.
Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of Google Ads. To the best of our knowledge, Google receives the information that you have accessed the relevant part of our website or clicked on one of our adverts. If you have a user account with Google and are registered, Google can assign the visit to your user account. Even if you are not registered with Google or have not logged in, there is a possibility that Google will find out your IP address and store it.
The legal basis for data processing is your consent, Art. 6 para. 1 lit. a GDPR.
The cookies have a functional life of up to 180 days.
Google is a subsidiary of Google Inc. based in the USA. We cannot rule out the possibility that, even if providers are based in the EU, data may also be transferred to group companies in the USA or another third country. Some of these third countries do not have an adequate level of data protection. In some third countries, for example in the USA, government agencies have far-reaching access rights to data from companies based in these third countries. We are jointly responsible with Google for the data processing processes for the purpose of the aforementioned statistical analyses and have agreed the corresponding standard contractual clauses.
Further information on data processing by Google, setting options and data protection can be found in Google's privacy policy at https://policies.google.com/privacy?hl=de&gl=de take.
Use of GetResponse
We use GetResponse on our website, a service for our email marketing and marketing automation. The service provider is the Polish company GetResponse Sp. z o.o., Arkonska 6/A3, 80-387 Gdansk, Poland.
What is GetResponse?
In addition to the classic newsletter service, the company also offers marketing automation. This refers to a technical method that automates and individualises certain marketing or sales processes. This enables us to better adapt our communication to your needs based on your user behaviour and to tailor and automate possible advertising campaigns to you and our other customers. Personal data (e.g. name, address, IP address) and technical data such as your click behaviour or how long you stay on one of our pages are stored and processed for this purpose. This data is only stored if you have consented to the data processing.
Why do we use GetResponse?
Of course, we don't want to withhold any news from our company from you. At the same time, however, we also want you to receive only the news that may be relevant to you. With a clever marketing and newsletter tool, we have the opportunity to reconcile both.
Your data will be stored for the purpose of sending the newsletter until you revoke your consent or unsubscribe. You can unsubscribe from receiving our newsletters at any time using the corresponding function in our newsletters. After receipt of a cancellation/unsubscription, we will block your e-mail address to document that you no longer wish to receive newsletters from us in future. The blocking notice and your e-mail address will be deleted three years after the end of the calendar year in which the blocking notice was set, unless an active business relationship still exists at this time and the storage of your e-mail address is necessary for the fulfilment of the contract with you. If you do not respond to our e-mail as part of the double opt-in procedure, we will delete your data three months after your registration for the newsletter, provided that this does not conflict with statutory retention obligations.
You can find out more about the data processed through the use of GetResponse in the privacy policy at https://www.getresponse.com/legal/privacy. If you have specific questions about data processing at GetResponse, you can also send an e-mail to privacy@getresponse.
7 Our profiles on social media platforms
We maintain a company profile on several social media channels. When you visit our profile on one of the social media platforms, the respective provider of the social media platform processes your data in order to create user profiles and to operate and improve its own services. Furthermore, some social media platform providers provide us with anonymised evaluations of the use of our company profile. Some of the data processing takes place regardless of whether you are registered on the social media platform or not. The analyses usually contain the following information:
Reach measurements relating to profile, posts and other functions, i.e. total number of people who have visited/used the profile, posts and other functions;
Aggregated data on age, gender, occupational field, household income and place of residence (country, region/city) of the people who visit Profil;
Usage time for videos and other functions;
Time and location of utilisation;
Devices, operating systems and software used;
Interactions in connection with posts, e.g. click rates, shares, comments.
With regard to the data processing operations for the purposes of the aforementioned analyses, we are jointly responsible with the respective providers of the social media platforms within the meaning of the GDPR and have concluded corresponding agreements on joint responsibility.
To optimise our marketing activities, we use the functions of social media platforms to display advertising and promote posts and content. For this purpose, we define target groups according to certain criteria (such as location, gender, age, interests) that participate in a campaign. It is not possible to assign them to specific individuals. We receive the statistical analyses described above from the social media providers about the campaigns.
We have no influence on whether and to what extent the providers collect personal data on their social media platforms. We are also unaware of the scope, purpose and storage period of data collection. It must be assumed that at least the IP address and device-related information is collected and used. It is also possible that the providers use cookies and similar technologies on their platforms with which the usage behaviour on the platforms and other services of the providers can be tracked and evaluated.
Some of the providers of the social media platforms are based outside the territory of the EU and the European Economic Area (EEA) (so-called "third countries"), in particular in the USA. Some of these third countries do not have an adequate level of data protection. In some third countries, for example in the USA, government agencies have far-reaching access rights to data from companies headquartered in these third countries. We cannot rule out the possibility that, even if the providers are based in the EU, data may also be stored at Group companies in the USA or in another third country. The standard contractual clauses apply to the transfer of data.
Further information on the individual providers of the social media platforms:
Facebook and Instagram:
The service provider is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland. Further information on the collection and use of personal data on Facebook can be found at https://www.facebook.com/policy.php and on Instagram at https.//help.instagram.com/519522125107875. When you use our Facebook page and our Instagram profile, Facebook stores cookies on your computer or smartphone. You can find information on this at https://www.facebook.com/policies/cookies. We have concluded an additional agreement on joint responsibility with Facebook, which specifies which data processing operations we or Facebook are responsible for when you visit our Instagram profile and which you can view at the following link: https://www.facebook.com/legal/controller_addendum.
LinkedIn:
The service provider is LinkedIn Ireland Unlimited Company (Wilton Place, Dublin 2, Ireland). Further information on data protection can be found in LinkedIn's privacy policy at https://www.linkedin.com/legal/privacy-policy and in the cookie policy at https://www.linkedin.com/legal/cookie-policy?. The following joint responsibility agreement applies to the processing operations for which we are jointly responsible with LinkedIn: https://legal.linkedin.com/pages-joint-controller-addendum.
8. integration of YouTube videos
On some websites, we have integrated YouTube videos that are stored on the website of YouTube LLC (901 Cherry Avenue, San Bruno, CA 94066, USA), a subsidiary of Google, and can be played directly from the respective website. The videos are all integrated in the so-called "extended data protection mode", i.e. according to the provider, no data about you as a user is transferred to YouTube if you do not play the videos. Only when you play the videos will the data mentioned in paragraph 2 be transmitted. We have no influence on this data transfer.
If you click on "Load video" for a video, YouTube receives the information that you have accessed the corresponding subpage of a website. The data is also transmitted. This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be assigned directly to your account. If you do not wish your data to be associated with your YouTube profile, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or customising its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide customised advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.
The data protection provisions published by YouTube, which can be accessed at https://policies.google.com/privacy?hl=de?gl=de, provide information about data processing by YouTube and Google.
9. automated decision-making including profiling
No automated decision-making, including profiling, takes place.
10. your rights
Every data subject has the right of access (Art. 15 GDPR), the right to rectification (Art. 16 GDPR), the right to restriction of processing (Art. 18 GDPR), the right to erasure (Art. 17 GDPR), the right to object (Art. 21 GDPR) and the right to data portability (Art. 20 GDPR).
If the data processing is based on consent, you can revoke this consent at any time with effect for the future. The data processing carried out up to the time of revocation remains lawful. You can send a cancellation, for example, by e-mail to info@tradium.com or to the postal address given above.
Furthermore, you have the right to lodge a complaint with the competent supervisory authority (Art. 77 GDPR).
11. right of objection
If your personal data is processed on the basis of legitimate interests in accordance with Art. 6 (1) (f) GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR, provided that there are reasons for this arising from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right to object, which will be implemented by us without specifying a particular situation. If you wish to exercise your right to object, simply send an email to info@tradium.com.
12. data security
We use the widespread SSL method on our websites in conjunction with the highest level of encryption supported by your browser. As a rule, this is 256-bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead.
We also use suitable technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.
13. amendment of this data protection notice
We reserve the right to adapt this data protection notice so that it always complies with the current legal requirements and our services and offers with the associated data processing procedures. When visiting our websites and appearances on social media channels, please always observe the currently accessible data protection information.