TraderClub24 Privacy Policy

This is a translation from the German version of the privacy policy. The German version applies.

Responsible person:

TradersClub24 GmbH
c/o WeWork
Axel-Springer-Platz 3
20355 Hamburg
Phone: +49 (0) 40 605 909 190
Mail: info@tradersclub24.de
Commercial register/no.: Hamburg, HRB 145319
Managing Director: Carlos Martins

Version: March 2018

1.   Basic information on data processing and legal framework

1.1. This data protection statement provides you with information regarding the manner, scope and purpose of processing of personal data within our online service and the associated websites functions and content (hereafter referred to as “online service” or “website”). The data protection statement applies independently of the domains, systems, platforms and devices employed (e.g. desktop or mobile) to run the online service.

1.2. The terminology used, such as “personal data” or “processing” of the personal data, refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

1.3. Personal user data processed in the context of this online service includes inventory data (e.g. customer name and address), contractual information (e.g. services used, names of contact persons, payment information), usage data (e.g. the websites visited in our online service, interest in our products) and content data (e.g. information entered on the contact form).

1.4. The term “user” covers all categories of persons affected by data processing. These include our business partners, customers, interested parties and other visitors to our online service. The terminology deployed, such as “user”, is intended to be gender neutral.

1.5. We process personal data only in compliance with the relevant data protection regulations. This means that user data is only processed when legal permission is given, i.e. in particular if data processing is necessary in order to provide our services (e.g. order processing) as well as other online services, or where user agreement is a statutory requirement, as well as due to our legitimate interests (i.e. analysis, improvement and security of our online service in the sense of Art. 6 (1) (f) GDPR, in particular for the assessment and creation of profiles for advertising and marketing purposes, as well as collection of access data and deployment of third-party services.

1.6. We draw your attention to the fact that the legal basis of the agreements is Art. 6 (1 lit a) and Art. 7 GDPR, the legal basis of data processing for the fulfillment of our services and the execution of contractual measures is Art 6 (1) letter b GDPR, the legal basis of data processing for the fulfillment of our legal obligations is Art. 6 (1 letter c) GDPR, and the legal basis of data processing for the protection of our rightful interests is Art 6 (1 letter f) GDPR.

2.   Security Measures

2.1. We make organizational, contractual and technical security measures according to the latest technology in order to ensure that the rules of data protection laws are complied with and in order to protect the data that we process against incidental or intentional manipulations, loss, destruction or against access by unauthorized persons.

2.2. Security measures include in particular the encrypted transfer of data between your browser and our server.

3.   Transfer of data to third parties and third-party providers

3.1. Any transfer of data to third parties shall only take place in the context of the statutory requirements. We shall only pass on user data to third parties if this is necessary for example on the basis of Art 6 (1) (b) GDPR for contractual purposes or on the basis of legitimate interests in accordance with Art 6 (1) (f) GDPR in the profitable and effective operation of our commercial business.

3.2. Where we utilize sub-contractors for the provision of our services, we shall make the appropriate legal arrangements and we will put in place relevant technical and organizational measures to ensure the protection of personal data in accordance with the relevant statutory provisions.

3.3. Where third-party content, tools or other means are deployed in the context of this data protection statement (hereafter summarized as “third-party providers”), whose registered offices are in a third country, it shall be assumed that a data transfer is made to countries of the third-party providers. Third countries are defined as countries in which the GDPR is not directly applicable law, meaning in principle countries outside of the EU or of the European Economic Area. The transfer of data to third countries shall be made either if an appropriate level of data protection, an agreement by the users, or otherwise a legal authorization has been given.

4.   Provision of contractual services

4.1. We process inventory data (e.g. names and addresses as well as user contact information), contractual information (e.g. services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and service performance in accordance with Art. 6 (1) (b) GDPR.

4.2. Users can choose to create a user account. In the context of executing an order, the required obligatory information is provided to the users. The user accounts are not public and cannot be indexed by search engines. If users have given notice to terminate their user account, their data will be deleted with regard to the user account, subject to its storage being required for commercial or tax reasons in accordance with Art 6 (1) c) GDPR. It is the responsibility of the users to secure their data before the end of the contract once notice to terminate it has been given. We are entitled to permanently delete all user data stored during the term of the contract.

4.3. We store the IP address and the time of the relevant user action in the context of the registration and renewed registration as well usage of our online services. The storage is made on the basis of our legitimate interests, as well as the interest of the user in protection from misuse and other unauthorized uses. Data will not be forwarded to third parties, unless it is necessary for the pursuit of our claims or there is a statutory obligation to do so under Art 6 (1) c) GDPR.

4.4. We process usage data (e.g. the websites of our online service visited by the user, interest in our products) and content data (e.g. entries in the contact form or user profile) and for advertising purposes in a user profile in order, for example, to show the user product information based on the services they have used up to that point.

5.   Contact

5.1. When contacting us (through the contact form or email), the user information is processed for the purpose of processing and fulfillment of the contact request in accordance with Art. 6 (1) (b) GDPR.

5.2. The user information can be stored in our Customer Relationship Management System (CRM System) or comparable reference system.

6.   Collection of access data and log files

6.1. On the basis of our legitimate interests in the sense of Art. 6 (1) (f) GDPR, we collect data every time the server is accessed on which this service is located (known as server log files). The access data includes the name of the website accessed, file, date and time of the access, data volume transferred, notification of successful access, browser type and version, user operating system, referrer URL (previously visited sites), IP address and the provider making the access request.

6.2 For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum of seven days and then deleted. Data whose further storage is required for evidential purposes is excluded from deletion until the respective incident has been finally clarified.

7.   Cookies & reach measurement

7.1 Cookies are information that is transferred from our web server or web servers of third parties to the web browsers of users and stored there for later retrieval. Cookies can be small files or other types of information storage.

7.2 We use “session cookies”, which are only stored for the duration of the current visit to our online presence. A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. In addition, a cookie contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online services and, for example, log out or close the browser.

7.3 Users are informed about the use of cookies in the context of pseudonymous range measurement within the scope of this data protection declaration.

7.4 If the users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

7.5 You can object to the use of cookies, which serve to measure reach and advertising purposes, via the deactivation page of the network advertising initiative (networkadvertising) and additionally the US website (aboutads) or the European website (youronlinechoices).

8.   Cookies settings

In addition or as an alternative to the cookie settings, you can prevent tracking by Google Analytics on our pages by clicking this link. This will create an opt-out cookie on your device. This will prevent Google Analytics from tracking this website and this browser in future as long as the cookie remains stored in your browser.

Cookie opt-out function

Google Tag Mananger

9.   Google analytics

9.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) Google Analytics, a web analysis service of Google Inc. (“Google”). Google uses cookies. The information generated by the cookie about the use of the website by the user is usually transferred to a Google server in the USA and stored there.

9.2 Google is certified under the Privacy-Shield-Agreement and thus offers a guarantee to comply with European data protection law (Privacyshield).

9.3 Google will use this information on our behalf in order to evaluate the use of our website by users, to compile reports on the activities within this website and to provide us with further services associated with the use of this website and the use of the Internet. In doing so, pseudonymous user profiles of the users can be created from the processed data.

9.4 We only use Google Analytics with activated IP anonymisation. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.

9.5 The IP address transmitted by the user’s browser is not combined with other data from Google. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and relating to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link Tools Google.

9.6 You can find further information on data use by Google, setting and objection options on the Google websites: Google data use (“Data use by Google when you use websites or apps of our partners”), Google data use for advertising purposes (“Data use for advertising purposes”), Google information on advertising (“Manage information that Google uses to show you advertising”).

10.       Google Re/Marketing Services

10.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) the marketing and remarketing services (in short “Google Marketing Services”) of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

10.2 Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (Privacyshield).

10.3 Google’s marketing services allow us to display advertisements for and on our website in a more targeted manner in order to show users only those advertisements that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is referred to as “remarketing”. For these purposes, when our and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (instead of cookies, comparable technologies can also be used). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, what content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, visiting time and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform within the framework of Google Analytics that the IP address is shortened within member states of the European Union or in other states which are party to the Agreement on the European Economic Area and only in exceptional cases is it transmitted in full to a Google server in the USA and shortened there. The IP address is not merged with user data within other Google offers. Google may also combine the above-mentioned information with information from other sources. If the user subsequently visits other websites, advertisements tailored to the user’s interests may be displayed.

10.4 User data is processed pseudonymously as part of Google’s marketing services. This means that Google does not store and process the name or e-mail address of the user, for example, but processes the relevant data on a cookie-related basis within pseudonymous user profiles. This means that from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.

10.5 The Google marketing services used by us include the online advertising programme “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected through the cookie is used to compile conversion statistics for AdWords customers who have opted in to conversion tracking. AdWords customers are informed of the total number of users who have clicked on their ad and been redirected to a page with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.

10.6 We may include third party ads based on the Google marketing service “DoubleClick”. DoubleClick uses cookies to enable Google and its partner sites to serve ads based on users’ visits to this site or other sites on the Internet.

10.7 For more information about Google’s use of data for marketing purposes, please visit the Google Data Usage Marketing overview page, Google’s privacy policy is available at Google Privacy Policy.

10.8 If you wish to opt out of receiving interest-based advertising through Google’s marketing services, you may do so using the opt-out and opt-in options provided by Google: Opt-out from Google advertising.

11.       Facebook pixel

11.1 Our website uses the visitor action pixel of Facebook, Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) to measure conversion. This allows us to track the behaviour of site visitors after they have clicked on a Facebook advertisement to be directed to the provider’s website. This allows the effectiveness of the Facebook Ads to be evaluated for statistical and market research purposes and future advertising efforts to be optimised.

11.2 The collected data is anonymous to us as the operator of this website, we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook Data Usage Policy. This enables Facebook to enable the placement of advertisements on pages of Facebook as well as outside of Facebook. This use of the data cannot be influenced by us as a site operator.

11.3 The use of Facebook pixels is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in effective advertising measures including social media.

11.4 You will find further information on the protection of your privacy in the Facebook data protection information: Facebook data protection information. You can also deactivate the remarketing function “Custom Audiences” in the settings for advertisements under Facebook Remarketing. To do this, you must be logged in to Facebook.

11.5 If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: Youronlinechoices.

12.       Social media offerings

12.1 Data processing through social networks

We maintain publicly accessible profiles in social networks. You can find the social networks we use in detail below.

Social networks such as Facebook, Google+ etc. can usually analyse your user behaviour comprehensively when you visit their website or a website with integrated social media content (e.g. like buttons or advertising banners). A visit to our social media sites triggers numerous data protection-relevant processing procedures. In detail:

If you are logged in to your social media account and visit our social media presence, the operator of the social media portal can assign this visit to your user account. However, your personal data may also be collected if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies that are stored on your end device or by recording your IP address.

With the help of the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. In this way, interest-related advertising can be displayed to you within and outside the respective social media presence. If you have an account with the respective social network, interest-based advertising can be displayed on all devices on which you are or were logged in.

Please also note that we cannot trace all processing on the social media portals. Depending on the provider, further processing may therefore be carried out by the operators of the social media portals. For details, please refer to the terms of use and data protection regulations of the respective social media portals.

12.1.1 Legal framework

Our social media appearances are designed to ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which must be specified by the operators of the social networks (e.g. consent within the meaning of Art. 6 Para. 1 letter a GDPR).

12.1.2 Responsibility and assertion of rights

If you visit one of our social media sites (e.g. Facebook), we are jointly responsible with the operator of the social media platform for the data processing operations triggered during this visit. You can assert your rights (information, correction, deletion, restriction of processing, data transferability and complaints) both against us and against the operator of the respective social media portal (e.g. against Facebook).

Please note that despite the joint responsibility with the social media portal operators, we do not have full influence on the data processing procedures of the social media portals. Our possibilities depend largely on the corporate policy of the respective provider.

12.1.3 Storage period

The data collected directly by us via the social media presence will be deleted from our systems as soon as the purpose for storing them no longer applies, you request us to delete them, revoke your consent to storage or the purpose for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal provisions – in particular retention periods – remain unaffected.

We have no influence on the storage period of your data, which is stored by the operators of social networks for their own purposes. For details, please contact the social network operators directly (e.g. in their data protection declaration, see below).

12.2 Social networks in detail

12.2.1 Facebook

We have a profile on Facebook. The provider is Facebook Inc, 1 Hacker Way, Menlo Park, California 94025, USA. Facebook is certified according to the EU-US Privacy Shield.

We have concluded a joint processing agreement (Controller Addendum) with Facebook. This agreement defines which data processing operations we or Facebook are responsible for when you visit our Facebook page. You can view this agreement under the following link: Facebook Agreement.

You can adjust your advertising settings independently in your user account. To do so, click on the following link and log in: Customise Facebook.

Details can be found in the Facebook privacy policy: Facebook Privacy Policy.

12.2.2 Twitter

We use the short news service Twitter. The provider is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. Twitter is certified according to the EU-US Privacy Shield.

You can adjust your Twitter privacy settings independently in your user account. To do so, click on the following link and log in: Twitter privacy settings.

Details can be found in the Twitter privacy policy: Twitter privacy settings details.

12.2.3 XING

We have a profile on XING. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Details on how they handle your personal data can be found in the XING Privacy Policy: Xing Privacy Statement.

12.2.4. LinkedIn

We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn is certified under the EU-US Privacy Shield. LinkedIn uses advertising cookies.

If you wish to disable LinkedIn advertising cookies, please use the following link: Disable LinkedIn.

For details of how LinkedIn handles your personal information, please see the LinkedIn Privacy Policy: Linkedin Privacy Policy.