privacy policy

privacy policy

Privacy Policy of adblue financial systems GmbH

The protection of your personal data and your privacy is very important to us. With this privacy policy, we explain in detail what personal data we collect, what happens to your personal data, the purpose of data collection and on what legal basis this is done. Furthermore, how long we store such data, which rights you enjoy under applicable data protection laws and whom you can contact if you have questions regarding adblue's data protection.

Responsible office for data processing
The responsible body for data collection, data processing and data use is adblue financial systems GmbH, Josef-Orlopp-Str. 42, 10365 Berlin - Germany, Managing Director Helmut Stephan - registered at the Amtsgericht Charlottenburg - HRB: 80729.

For questions regarding this privacy policy
Should you have any questions or require further explanations regarding adblue's data protection, please contact our data protection officer Mr. Helmut Stephan - adblue financial systems GmbH, Josef-Orlopp-Str. 42, 10365 Berlin - Germany or by email to: admin@adblue.de or by phone at +49 (0)30 / 243 42 -0

To whom does this privacy policy apply?
Visitors of our websites and persons who are interested in or register for adblue products or services. All interested parties and customers of adblue, as well as persons who are in contact with us, such as authorized representatives, beneficial owners of our customers, representatives or employees of legal entities, cooperation and sales partners, as well as contact persons for the aforementioned groups. Furthermore, if you get in contact with us e.g. via email, chat, telephone, fax or other communication channels. You can access the declaration at any time on the Internet at www.adblue.de/dataprivacy.htm.

What are personal data?
Personal data is data which you provide us with and which can be used to identify you personally. For example, if you give us your name or your e-mail address.

What is anonymous data?
This is data that records, for example, user behaviour on the website or statistical data, such as the number of website visits, etc. However, this data does not provide any information or features that make a user identifiable. This data is not personal data.

What is an IP address?
An IP address is assigned to any device that is connected to a network. The Internet is one such network. For example, if you use a PC to visit a website, your IP address and the IP address of the server hosting the website are required. The IP addresses are required to transfer data. On Wikipedia you can find more comprehensive information about IP addresses: https://de.wikipedia.org/wiki/IP-Adresse The IP address is often used to identify the location from which the device connects to the Internet.

What is a pixel tag?
A pixel tag is set on a website or within an email message. It can be used to measure web page impressions or opening rates of an email message.

What are cookies and JavaScript?
A cookie is text information that is placed on the viewer's computer. Wikipedia provides more comprehensive information about cookies: https://de.wikipedia.org/wiki/HTTP-Cookie Such cookies and similar technologies make it possible, for example, to store user settings and information about the website visitor. JavaScript is a scripting language that runs in Internet browsers. JavaScript can be used to make websites functional. For example, that when clicking on a button, a function is executed. On Wikipedia you will find further extensive information about JavaScript: https://de.wikipedia.org/wiki/JavaScript You can prevent the acceptance of cookies or the execution of JavaScript at any time. To do this, it is sufficient to deactivate the acceptance of cookies or the execution of JavaScript in your Internet browser under the user settings. Your internet browser offers the possibility to delete or deactivate cookies or to reject all cookies. If cookies or JavaScript are deactivated, the functionality of the website may be limited. www.adblue.de

adblue does not use tracking or marketing cookies or similar cookies
For more information on deleting, disabling and managing cookies and disabling JavaScript, please click here for Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies for Firefox:https://support.mozilla.org/de/kb/cookies-loeschen-daten-von-websites-entfernen and for Google Chrome: https://support.google.com/accounts/answer/32050?co=GENIE.Platform=Desktop&hl=de If you are using another company's web browser, please refer to their support website for instructions.

General information on data protection and data processing

We collect, process, store and use personal data only if this is necessary for the provision of a service or offer. The collection and use of personal data is only carried out with the consent of the user. An exception is made in such cases when consent cannot be obtained for factual reasons or when the processing of the data is permitted by legal regulations. In the following, we would like to inform you in detail about the handling of your data:

Use of our websites

Use of our websites - Server Logfiles
Whenever you visit our website, our system collects information that your internet browser and computer system automatically and technically transmits. This information is stored in a log file, so-called server logs. The following information is collected and stored:

- The IP address of the user
- Information about the browser type and version used
- The user's operating system
- Date and time of access to the adblue website
- Websites from which the user's system accesses the adblue website
- Websites that are called up by the user's system via the adblue websites.
- Status messages like file transfer or file not found.

The data stored here shall not be linked with other personal data and shall not be stored together, e.g. in a log file. A user allocation or profiling does not take place.

Purpose and legal basis of the data processing
To enable the delivery of the website to the user's computer, it is absolutely necessary to store the IP address for the duration of the visit. Furthermore, the data is necessary to prove or prevent any unauthorized server access and to ensure IT security. In these purposes lies our legitimate interest in the data processing according to article 6 paragraph. 1 letter f of the DSGVO.

Duration of storage
The data will be deleted as soon as they are no longer necessary for the purpose of their collection. In the case of the collection of data for the provision of the website after 90 days.

Opposition and possibility of removal
The storage of data in log files is mandatory for the use of the adblue websites. Without this data, the retrieval of a website would not be technically possible. Consequently, a possibility of objection by the user is therefore not possible.

Registration, registration and contact forms for products and services of adblue

Basic information on data processing
For all registration, login and contact forms on the adblue websites, for products or services of adblue, adblue uses the adblue, web technologies of the company Mailjet SAS (Mailjet). The data entered by you in the corresponding input masks, as well as the IP address, the date and time at the time the form was sent and the website address at which the form was filled out, are transmitted to adblue and also to Mailjet SAS and stored.

Duration of storage
The data will be deleted as soon as they are no longer necessary for the purpose of their collection. In the case of the collection of data for information offers by email, if you unsubscribe to this. A corresponding unsubscribe link can be found at the end of each information email. Statistical data on email dispatch is deleted after 365 days.
Objection and possibility of removal
The user has the possibility to revoke his consent to the processing of personal data at any time. See point 'Your right to object' of this privacy policy. In the case of data collection for the newsletter, if you unsubscribe. A corresponding unsubscribe link can be found at the end of each information email. In such a case, the user will no longer receive information via the newsletter system.

Purpose and legal basis of data processing with Mailjet SAS
The company Mailjet SAS (Mailjet) 13-13bis, rue de l`Aubrac, 75012 Paris, France is an email sender based in France and in Germany. The adblue uses the service to send emails to people. With Mailjet the delivery of emails is guaranteed, Mailjet offers the possibility to create and optimize email templates and to send emails according to individual time constraints. Furthermore Mailjet provides us with statistical data. For example the opening rate after sending an email. Furthermore, the data is necessary for the proof or defense of possible unauthorized server access, form abuse and to ensure IT security. Furthermore, we use the web technology of Mailjet to verify your email address. This takes place in the form of a confirmation email, which is sent to the email address provided by the user after submitting a form and must be confirmed by the user via a confirmation link. The IP address, the date and the time are transmitted to adblue and also to the Mailjet SAS (Mailjet) when the confirmation link is confirmed. This ensures that the email address will not be misused by third parties and serves as proof and security. The Mailjet SAS has been committed to data protection and data security in the form of an EU contract data agreement. The privacy policy of Mailjet SAS can be found here: https://www.mailjet.de/privacy-policy/ and further information about the order data agreement here: https://www.mailjet.de/av-vertrag/ Data is stored exclusively on European servers and Mailjet is certified according to ISO/IEC 27001:2013: https://www.mailjet.com/wp-content/uploads/2019/11/Mailjets_Certification_ISO-27001.pdf These purposes also include our legitimate interest in data processing in accordance with Article 6 paragraph 1 letter f of the DSGVO. Furthermore, the processing of data, after registration, login or use of a contact form by the user, is, if the user has given his consent, this consent is the legal basis Article 6 paragraph 1 letter a of the DSGVO.

Duration of storage
The data will be deleted as soon as they are no longer necessary for the purpose of their collection. In the case of the collection of data for information offers by email, if you unsubscribe to this. A corresponding unsubscribe link can be found at the end of each information email. Statistical data on email dispatch is deleted after 365 days.
Registration for an adblue Webinar
The adblue regularly organizes webinars on the topic of the stock exchange. A webinar is comparable to a presence seminar. In contrast to a presence seminar, however, the webinar takes place via the Internet and is supported by computer software. adblue offers an electronic registration form to register for a webinar. The data entered in the input mask is transmitted to us and stored. These data are:

- First name
- Name
- Phone number
- email address
- Date and time of registration
- IP address at time of registration
- Website address of the registration form

In addition, this data is transmitted to and stored by the Rocket Science Group and Unbounce Marketing Solutions. Please refer to the explanations under 'Basic information on data processing' of this privacy policy. Purpose and legal basis of data processing to conduct the webinar, adblue uses the software solution GoToWebinar from LogMeIn Inc. 320 Summer Street - Boston, MA 02210, USA. For the order-related execution of the webinar, we transfer your registration data to LogMeIn Inc. LogMeIn Inc. processes, transfers and stores this data in the USA. LogMeIn, Inc. is responsible for the provision of this service and the associated data processing. During and after the webinar, statistical data will be provided to adblue. For example, the number of participants or the length of stay of webinar participants. This data helps us to improve and optimize webinar content. In addition, the data is necessary to prove or defend against possible unauthorized server access, form abuse and to ensure IT security. Furthermore, we use your registration data to inform and remind you of dates for stock exchange webinars or to draw your attention to other webinars or information about the stock exchange. LogMeIn Inc. has been committed to privacy and data security in the form of an EU Commissioned Data Protection Agreement. LogMeIn Inc.'s Privacy Policy can be found at https://www.logmeininc.com/de/legal/privacy and further information on the Order Data Agreement can be found at https://www.logmeininc.com/de/gdpr/gdpr-compliance . LogMeIn Inc. is also a member of the EU-U.S. Privacy Shield and is certified under it: https://www.privacyshield.gov/participant?id=a2zt0000000013fAAA Further information on the EU-U.S. Privacy Shield can be found at https://www.privacyshield.gov/welcome These purposes also include our legitimate interest in data processing in accordance with Article 6 paragraph 1 letter f of the DSGVO. Furthermore, the processing of data, after the user has registered for a webinar, if the user has given his consent, this consent is the legal basis Article 6 paragraph 1 letter a of the DSGVO.

Duration of storage
The data will be deleted as soon as they are no longer necessary for the purpose of their collection. In the case of the collection of data for information offers by email for the stock exchange webinars, if you unsubscribe. You will find a corresponding unsubscription link at the end of each information email. Statistical data for completed webinars are deleted after 365 days.

Objection and possibility of removal
The user has the possibility to revoke his consent to the processing of personal data at any time. See point 'Your right to object' of this privacy policy. In case of collection of data for information offers by email for the stock exchange webinars, if you unsubscribe. You will find a corresponding unsubscription link at the end of each information email. In such a case, the user can no longer participate in adblue webinars without renewed consent.

Registration for the TradeMaster exchange software
adblue offers the TradeMaster stock exchange software to interested users. With this software it is possible to trade financial products. Registration is necessary to use the adblue TradeMaster. The data entered in the input mask is transmitted to us and stored. This data is:

• First name
• Name
• Phone number
• Email address
• Date and time of registration
• IP address at the time of registration
• Website address of the registration form

Furthermore, these data are transmitted to and stored by Mailjet SAS. Please refer to the explanations in the section 'Basic information on data processing' of this privacy policy.
Additional data is collected when using the TradeMaster exchange software. These are:

- User name
- Password

If financial transactions are carried out with the TradeMaster stock exchange software, adblue can log individual transactions that are related to the transaction you carried out via our system, for example

- login information
- Buy and sell orders
- Placing stop and limit orders and other types of orders
- Deletion of orders
- Time and date of transactions
- IP address of the user

Transaction data also includes such usage data which is directly related to the respective transaction, e.g. the click on a certain button including date, time, etc. This transaction data is stored together with your registration data and, if necessary, is linked to usage data, if this is necessary to document the process.
Purpose and legal basis of data processing
Software and especially stock exchange software with which financial transactions can be carried out requires a particularly high level of IT security and logging. The collected data and the logging of transaction and usage data are required for the security of the authorization process, for the proof or defense of any unauthorized server access, form abuse - and software access and to ensure IT security. Furthermore, the processing is necessary for the assertion, exercise or defense of legal claims. We also use your registration data to inform you. E.g. about updates of the software, new features, modes of operation of the software or also for information about the stock market. These purposes also include our legitimate interest in data processing according to article 6 paragraph 1 letter f of the DSGVO. In addition, the processing of data after registration for the TradeMaster exchange software by the user, if the user has given his consent, this consent is the legal basis in Article 6 paragraph 1 letter a of the DSGVO. In addition, processing operations are also carried out that are necessary to carry out pre-contractual and contractual measures. The legal basis here is Article 6 paragraph 1 letter b of the DSGVO.

Duration of storage
The data will be deleted as soon as they are no longer necessary for the purpose of their collection. In the case of the collection of data for information offers via email for the TradeMaster exchange software, if you unsubscribe to this. You will find a corresponding unsubscribe link at the end of each information email. Statistical data is deleted after 365 days. If transactions are made with the software, this transaction data can be stored for a period of 10 years together with your registration data and, if applicable, usage data for legal reasons, e.g. due to documentation and storage obligations, and also for the assertion, exercise or defense of legal claims.

Objection and possibility of removal
The user has the possibility to revoke his consent to the processing of personal data at any time. In such a case the user can no longer use the stock exchange software.

Registration for the adblue newsletter
On our website you have the possibility to subscribe to a free newsletter. When registering for the newsletter, the data from the input mask is transmitted to us and stored. These data are:

• first name
• Name
• Email address
• Date and time of registration
• IP address at the time of registration
• Website address of the registration form

Furthermore, these data are transmitted to and stored by Mailjet SAS. Please refer to the explanations in the section 'Basic information on data processing' of this privacy policy. Purpose and legal basis of the data processing

The adblue offers interested users in the form of an email newsletter, information about the stock exchange and information about products and services of adblue. The data is required to be able to send corresponding emails and to address the user correctly. In addition, the data is necessary to prove or defend any unauthorized server access, form abuse and to ensure IT security. These purposes also constitute our legitimate interest in data processing in accordance with article 6 paragraph 1 letter f of the DSGVO. Furthermore, the processing of data, after registration for the newsletter, if the user has given his consent, this consent is the legal basis Article 6 paragraph 1 letter a of the DSGVO.

Duration of storage
The data will be deleted as soon as they are no longer necessary for the purpose of their collection. In the case of the collection of data for information offers by email, if you unsubscribe to this. You will find a corresponding unsubscription link at the end of each information email. Statistical data on email dispatch is deleted after 365 days.

Objection and possibility of removal
The user has the possibility to revoke his consent to the processing of personal data at any time. See point 'Your right to object' of this privacy policy. In the case of data collection for the newsletter, if you unsubscribe. A corresponding unsubscribe link can be found at the end of each information email. In such a case, the user will no longer receive information via the newsletter system.

Contact Form; Call Back and Email Contact
The adblue offers the possibility to contact us via a contact form or a call back form. The data from the corresponding input mask is transmitted to us and saved. These data are:

• first name
• Name
• Email address
• Date and time of registration
• IP address at the time of registration
• Website address of the contact form

Furthermore, these data are transmitted to and stored by Mailjet SAS. Please refer to the explanations in the section 'Basic information on data processing' of this privacy policy. Optionally, additional information can be provided. For example, your 'request' and, in the case of the Call Back Form, additionally the day and time for the desired call back. As an alternative to the contact forms, it is also possible to contact us via our specified email address. In this case the personal data of the user transmitted with the email will be stored. Purpose and legal basis of data processing

The data provided by the user is required for the processing of the contact. In addition, the data is necessary to prove or defend against possible unauthorized server access, form abuse and to ensure IT security. These purposes also constitute our legitimate interest in data processing in accordance with article 6 paragraph 1 letter f of the DSGVO. Furthermore, the processing of the data, after the contact has been established, is, if the user has given his consent, this consent is the legal basis Article 6 paragraph 1 letter a of the DSGVO. The legal basis for the processing of data transmitted when sending an email is Article 6 paragraph 1 letter f of the DSGVO. If the e-mail contact is aimed at pre-contractual or contractual purposes, the additional legal basis for processing is Article 6 paragraph 1 letter b of the DPA.

Duration of storage
The data will be deleted as soon as they are no longer necessary for the purpose of their collection. This is the case if, after the end of the conservation, it is foreseeable that this data is no longer relevant for a future customer relationship. Statistical data is deleted after 365 days.

Objection and possibility of removal
The user has the possibility to revoke his consent to the processing of personal data at any time. See point 'Your right to object'. In such a case the conservation cannot be continued.

Your data and rights
Are you obliged to provide certain personal data? Within the scope of our business relationship, you must provide those personal data which are necessary for the execution, fulfillment, commencement or termination of a business relationship and the associated contractual obligations or which we are legally obliged to collect. Without this personal data, we are generally not in a position to enter into or execute a contract with you. Does automated decision making or profiling take place? In principle, no fully automated decision making or profiling in the sense of Article 22 Paragraph 1 of the DSGVO takes place.

Your right to information, disclosure and authorization
You have the right of information and inspection of your personal data at any time and also the possibility to correct or complete personal data that is no longer current or incorrect. To do this, you can simply contact us by email or in writing by post. We will respond to all requests immediately and free of charge in accordance with the applicable law. You will find the contact details under the heading 'If you have any questions about this privacy policy' in this privacy policy. Your right to limit the processing of your personal data

You have the right to limit the processing of your personal data if one of the following conditions is met: 1) a) The accuracy of personal data is disputed by you for a period of time that allows us to verify the accuracy of the personal data:
b) the processing is unlawful and you object to the deletion of the personal data and request instead the restriction of the use of your personal data
c) adblue no longer needs the personal data for the purposes of processing, but you need it to assert, exercise or defend legal claims, or
d) you have lodged an objection against the processing pursuant to Article 21 paragraph 1 of the DSGVO, as long as it is not yet clear whether the legitimate reasons outweigh the adblue's interests
2) If the processing referred to in paragraph 1 has been restricted by you, such personal data, apart from being stored, may be processed only with your consent or for the purpose of pursuing, exercising or defending legal claims or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or of a Member State.
3) If you have obtained a restriction on processing pursuant to paragraph 1, you will be informed by adblue before the restriction is lifted.

Your right to data transferability
You have the right to receive personal data that you have given us in a transferable format or the right to have this data transferred to another body.

Your right to have your personal data deleted
You always and at any time have the right to have your personal data deleted. A right to deletion does not exist if there is a legitimate reason, e.g. if there are obligations to keep records or also to assert, exercise or defend legal claims or also, for example, if further processing of the data is necessary to fulfil a legal obligation.

Your right to revoke the declaration of consent under data protection law
If you have given us permission to process personal data for specific purposes, you have the right to revoke your declaration of consent under data protection law at any time. Revocation of your consent does not affect the legality of the processing of your personal data that has taken place on the basis of your consent until revocation.

Your right to information
If you have asserted the right to delete, correct or restrict the processing of personal data against adblue, we are obliged to inform all recipients to whom your personal data has been disclosed accordingly, unless this proves impossible or involves a disproportionate effort. You also have the right vis-à-vis adblue to be informed about these recipients.

Your right to complain
If you have any questions or if you would like further explanations or if you have a complaint, you can contact the person responsible for data protection at adblue directly. The contact details can be found under the point 'For questions regarding this privacy policy'. Furthermore, you also have the right to complain to the responsible data protection supervisory authority.

Your right to appeal
1. right of objection in individual cases
You have the right to object to the processing of your personal data for reasons arising from your particular situation. The prerequisite for this is that the data processing is carried out in the public interest or on the basis of a balancing of interests (Article 6 paragraph 1 letters e or f of the DSGVO). This also applies to profiling based on these provisions. In the event of an objection, the personal data concerned will no longer be processed by us, unless we can prove compelling reasons for processing worthy of protection that outweigh your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims.

2. right to object to the processing of data for the purposes of direct marketing
If the personal data concerned are processed for the purpose of direct marketing, you have the right to object to the processing of such data for the purpose of marketing at any time. This also applies to the profiling associated with such direct mail. If you object, the data concerned will no longer be processed for this purpose.

The objection can be made in writing by email or by post:
By email to: admin@adblue.de or in writing to:
adblue financial systems GmbH Responsible for data protection Mr. Helmut Stephan Josef-Orlopp-Str. 42 10365 Berlin - Germany