06 April 2014

Whether you are a customer, prospective customer or visitor of our website: We respect and protect your privacy. What exactly does this mean when it comes to your personal data?

In the following we would like to give you a quick and easy overview of what data we collect and what we do with it. We will also inform you of your rights under applicable data protection law and tell you who to contact if you have any questions.

This document is based on an automatic translation tool. In case of doubt or incorrect translation, the German version of this document is always decisive for any legal interpretation.

Who are we?

sentix GmbH is a service company under German law specializing in the behavioral analysis of financial markets. To this end, sentix has conducted regular surveys of investors on the Internet since 2001 in order to obtain information about what investors know, what they feel and what actions they have taken or intend to take.

sentix GmbH is a 100% subsidiary of sentix Holding GmbH, which also owns the rights to the "sentix" brand.

As the responsible body, we the

sentix GmbH, Mainzer Straße 4b, 65550 Limburg, Germany

seize all legally required measures to protect your personal data.

The data protection officer appointed is: heyData GmbH, Schützenstraße 5, 10117 Berlin, datenschutz@heydata.eu

To whom does this privacy policy apply?

If we process personal data, this means in plain language that we collect, store, use, transmit or delete them.

This is personal data of:

• Interested parties and customers of sentix GmbH who are natural persons
• All other natural persons in contact with us, e.g. employees of legal persons
• Visitors to our website or users of our electronic offers (e.g. apps)

What personal data do we collect from you?

We collect personal data from you when you contact us, e.g. as an interested party or customer. This means: In particular if you are interested in our offers, register for the sentix survey or for another website offer, conclude a data or research contract with us, fill in a contact form on our website, contact us by e-mail or telephone or use our products and services within the scope of an existing business relationship.

We process the following personal data:

• Personal identification data, e.g. first and last name, address, date of birth, e-mail address
• Payment transaction data: e.g. your bank details for direct debit or credit card data for shop purchases
• Information about your characteristics as an investor and socio-demographic data: whether you are a private or institutional investor, your company, areas of interest, regional allocation and language codes
• Data on your capital market expectations when participating in the sentix Global Investor Survey: e.g. market assessments over the short and medium term, expectations of specific asset classes or sectors, assessments of political or economic events, positioning in specific asset classes and products
• Data on your online behaviour and preferences: e.g. IP addresses, unique allocation features within the scope of the survey, data on your visits to our websites and applications, data on terminal devices used (this enables the optimised presentation of our website on your terminal device)
• Information about your interests and wishes that you communicate to us: e.g. via our customer dialogue or our website
• and other data comparable with these categories

Information about data that we receive via the Internet

• General call data / log files: For technical reasons, every time you call up a website, data is transmitted from your computer to us, such as the date and time of the call up of one of our pages, your browser type, the browser settings and the operating system, the last page you visited, the transferred data volume and the access status (file transferred, file not found, etc.). These data are regularly non-personal data. In addition, however, your computer usually also transmits us your IP address, which may be personal in individual cases. For more information on the IP address, see c) below. The log file data is used by us exclusively to ensure the functionality of our services (e.g. error analysis, guarantee of system security and protection against misuse).
• Cookies: In order to design your visit to our website, we transfer so-called cookies to your computer. Cookies are small text files that can be used to identify your computer. They do not interfere with your computer's operating system. Among other things, we use cookies to measure and control the frequency of page views and general page navigation. A number of the plugins and analysis tools described below also use cookies. You can block the use of cookies. Under certain circumstances, however, individual functions of our offer may not be usable. To learn how to block the use of cookies, please refer to the instructions for your browser software
• Details of your IP address: Your IP address, which in many cases is transmitted to us, is a globally valid identification of your computer that is unique at the time of allocation by your Internet provider. An IP address consists of four number blocks separated by dots. In most cases, as a private user, you will not use a constant IP address, as this is only temporarily assigned to you by your provider (so-called "dynamic IP address"). Your provider can trace which IP address was assigned to which customer at which time. As a rule, it is not possible to assign a dynamic IP address to a specific person to other persons, including us. This is different only with a permanently assigned IP address (so-called "static IP address"), which in principle enables a unique assignment of user data via this characteristic. Except for the purpose of tracking unauthorized access to our website, we do not use this data on a personal basis, but only evaluate on an anonymous basis which of our websites are favored, how many accesses are made daily and the like.
• Newsletter: We collect and store personal reactions (e.g. opening and clicking behaviour within the scope of newsletter use) and evaluate this data accordingly in order to always orientate and optimise our offer according to the needs of the users.

We do not collect sensitive data, e.g. on religious affiliation or biometric information.

Plugins and statistics tools

We collect additional data for individual services provided by our company. Some of these serve statistical purposes. For example, we determine how often our pages are visited in order to create the basis for our media data. We would also like to get an overview of which of our online offers are particularly in demand. Some of our websites also include plugins (or add-ons - the terms are used synonymously) such as Facebook or Twitter.

Plugins

Plugins are offers from third party companies such as Facebook. They establish connections to these providers. In some cases, only data on browser behavior is transmitted. However, if you actively use plugins (e.g. in the context of your Google profile) this information is also transferred. You can find out more about the individual plug-ins below:

• Plugin of the social network Facebook: Some of our website contains plugins from the social network Facebook. These plugins are offered by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA. You can recognize the plugins by the Facebook logo and/or the addition "I like". If you access a page with such a plugin when you visit this website, your Internet browser will establish a direct connection to the servers of Facebook Inc. The content of the plugin is transmitted to your Internet browser and integrated into the displayed page. The information that you have visited this website is transmitted to Facebook Inc. If you are logged into your personal Facebook account while viewing the relevant page, Facebook Inc. will associate the site visit with your user account.
  
  If you use the plugin, for example by clicking on the "I like" button, this information is transmitted directly to Facebook Inc. and stored there. If you wish to prevent such data transmission, you must log out of your Facebook account before visiting our website.
  
  Active use of the plug-in is subject to the Privacy Policy and Terms of Use of Facebook Inc. information on the collection, storage and use of your data by Facebook Inc. can be found in the Facebook Privacy Policy and the Privacy Policy.
• Plugin for retargeting the social network Facebook: Retargeting tags of the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA are integrated on our pages. When you visit our pages, retargeting tags establish a direct connection between your browser and the Facebook server. Facebook receives the information that you have visited our site with your IP address. This allows Facebook to associate the visit to our pages with your user account. We can use the information obtained in this way to display Facebook Ads. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the data transmitted or of their use by Facebook. For more information, please see Facebook's Privacy Policy at www.facebook.com/about/privacy/. If you do not wish to use Custom Audience, you can deactivate Custom Audiences here: facebook.com/ads/website_custom_audiences/.
• Twitter social network plugin: With Twitter and the re-tweet functions we use plugins from twitter.com, an offer from Twitter Inc, 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. If you use the Re-Tweet functions, the pages you visit will be made known to third parties and connected to your Twitter account. For details on how Twitter Inc. handles your data and your rights and setting options to protect your personal data, please refer to Twitter's privacy policy.
• Plugin of the social network Google+: With the Google +1 button we use a plugin of the social network Google+, an offer of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Use the Google +1 button to publish information worldwide. The Google +1 button provides you and other users with personalized content from Google and our partners. Google stores both the information you provided for a content +1 and information about the page you viewed when you clicked +1. Your +1 can appear in Google services, such as search results or your Google profile, or elsewhere on websites and ads, along with your profile name and photo.
  
  Google records information about your +1 activity. To use the Google +1 button, you need a public Google profile that is visible worldwide and must contain at least the name chosen for the profile. This name is used in all Google services. In some cases, this name may also replace another name you used when sharing content through your Google Account. The identity of your Google profile may be displayed to users who know your email address or have other identifying information about you.
  
  For details on how Google uses your information and your rights and preferences to protect your personal information, please see Google+'s privacy policy and the Google +1 button (http://www.google.com/intl/de/+/policy/index.html and http://www.google.com/intl/de/+/policy/+1button.html).

Analysis tools

We use numerous analysis tools. These have very different functions. It is important for our work, for example, what reach we achieve with our site in order to have direct feedback for our work.

• Google Analytics: Our websites use Google Analytics, a web analysis service of Google Inc. "("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site (see Section 2 above). The information generated by the cookie about your use of our websites is usually transferred to a Google server in the USA and stored there. However, if IP anonymisation is activated on our pages, Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google uses this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing the website operator with other services relating to website activity and internet usage. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
  If you do not wish to do so, you can prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
• Google Retargeting: This website uses so-called "retargeting tags". Third-party providers, including Google, use stored cookies to serve ads based on a user's previous visits to this site. Studies have shown that the insertion of interest-related advertising is more interesting for Internet users than advertising that has no direct connection to interests or previously visited websites. No personal data is stored and the retargeting technology is used in accordance with the applicable legal data protection regulations.
  
  You can disable the use of cookies by visiting the Google Advertising opt-out page. Alternatively, users can disable the use of cookies by third parties by visiting the opt-out page of the Network Advertising Initiative.

Newsletter

If you subscribe to a newsletter on our website, you can unsubscribe at any time (e.g. via a link in the newsletter). After registration you will receive a confirmation e-mail with a link. Only by clicking on the link the registration becomes active (so-called "Double-Opt-In" procedure).

Our newsletters contain images (web bugs) that allow us to know if and when an email has been opened. Even if a link is clicked in a newsletter, we usually save it. However, we only use this data statistically (i.e. without personal reference) in order to optimize our newsletters and offers and to better understand customer interests.

Embedded YouTube videos

We embed YouTube videos on some of our websites. YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA is the operator of the corresponding plug-ins. When you visit a page with the YouTube plug-in, a connection to YouTube servers is established. YouTube is informed which pages you visit. If you are logged into your YouTube account, YouTube can associate your surfing behavior with you personally. You can prevent this by logging out of your YouTube account beforehand.

When a YouTube video is started, the provider uses cookies that collect information about user behavior. If you want to prevent this, you must block the saving of cookies in your browser.

Further information on data protection at "YouTube" can be found in the provider's data protection declaration at: https://www.google.de/intl/de/policies/privacy/

What do we use your data for and on what legal basis?

Fulfilment of contractual obligations (Art. 6 para. 1b DSGVO)

We use your data to fulfil contractual obligations so that you can use our products and services. In order to fulfil our contracts, we must process your data. This also applies to pre-contractual information that you give us in the context of applications or pre-contractual negotiations. The purposes of data processing depend on which product or service you use with us.

For the execution of the contractual relationship we need your name, your address and your e-mail address in order to be able to contact you. We need your data as an investor and your capital market assessments in order to assign your capital market assessments to the right group and to be able to calculate the indices and create the charts that you as our customer expect from us.

We process personal data, such as credit card data, your name or bank details, in connection with online purchase transactions (orders, subscriptions) and inform the payment transaction provider of your choice (Stripe, Paypal, Bank).

Balancing of interests (Art. 6 Par. 1f DSGVO)

If necessary, we process your data beyond the actual performance of the contract to protect the legitimate interests of us or third parties. Examples:

• Examination and optimization of procedures for needs analysis for the purpose of direct customer approach
• Advertising, market research and measurement of the efficiency of marketing activities, provided you have not objected to the use of your data
• Assertion of legal claims and defense in legal disputes
• Guarantee of IT security and IT operation of sentix GmbH
• Identification when using our offers
• Prevention and investigation of criminal offences
• Measures for building security and access control
• Measures to secure the domiciliary right
• Measures for business management and further development of services and products
• Risk management

We also need your personal data in order to be able to offer you relevant products and services or charts and information, to fulfil your wishes or to improve our services. Your individual needs are important to us. We try to offer you the information that best suits your needs. The aim of this processing is to offer you personalised suggestions (after consideration of your interests). Important: You can object to this form of personalization at any time.

We write you letters or e-mails with a personal touch. Or make you very personal offers on our website or our applications (apps). You have the right to object to this personalized advertising at any time.

Data processing with your consent (Art. 6 Par. 1a DSGVO)

If you have given us your consent to process personal data for specific purposes, the processing of such data is legal. You can revoke your consent at any time. This also applies to the revocation of declarations of consent that you have given to us before the validity of the DSGVO (Basic Data Protection Ordinance), i.e. before 25 May 2018. The revocation of the consent does not affect the legality of the data processed until the revocation.

Due to legal requirements (Art.6 para. 1c DSGVO) and in the public interest (Art. 6 para. 1e DSGVO)

As a company we are subject to numerous legal obligations (e.g. commercial law, tax laws). Under these laws, we are obliged to store data and surrender data in certain cases.

Who gets your data and why?

Within sentix GmbH, only those entities will have access to your data which are required to protect our legitimate interests or to fulfil our contractual and legal obligations.

Outside of sentix GmbH we may only pass on your data if required to do so by law or if you have given your consent.

A legal obligation to pass on your personal data to external parties is particularly relevant for the following recipients:

• Public authorities, supervisory authorities and bodies, such as tax authorities and courts
• Lawyers and notaries, e.g. in case of late payment
• certified public accountant

We work with other companies to fulfil our contractual obligations. These include:

• banks and financial service providers who are also legally obliged to treat personal data with the necessary care
• Service providers who support us, e.g. IT service providers

In all cases mentioned, we ensure that third parties only have access to personal data that is necessary for the performance of individual tasks. In addition, we ensure that third parties comply with industry best practices and that third parties' data is treated securely and confidentially and only used for the purposes we specify.

For third parties outside the European Economic Area (EEA), the protection of personal data is handled differently than in the EEA. In these cases we take security measures (e.g. special contractual clauses) so that your personal data is treated with the same care as in the EEA.

Very important: Under no circumstances do we sell personal data to third parties.

How we protect your data

To protect your personal data, we take physical, electronic and procedural security measures that correspond to the current state of the art and the legal data protection requirements. These security measures include the implementation of certain technologies and procedures to protect your privacy, such as secure servers, firewalls and SSL encryption. We will always act in accordance with applicable laws and regulations regarding the confidentiality and security of personal data.

Your rights

We want to answer all your questions as soon as possible. However, sometimes it can still take up to one month before you receive an answer from us, if this is legally permissible. Should it take longer than one month, we will of course let you know in advance how long it will take.

In some cases we cannot or must not give you any information. If this is legally permissible, we will always inform you promptly of the reason for the refusal. You have the right to file a complaint.

What rights do you have as an interested party or customer of sentix GmbH when it comes to the processing of your data (details result from the respective regulations of the basic data protection regulation (Articles 15-21))?

Your right of access, information and rectification

You can request information about your personal data processed by us. If your details are no longer correct, you may request a correction. If your data is incomplete, you can request a completion. If we have passed on your details to third parties, we will inform these third parties of your correction - insofar as this is required by law. 

Your right to have your personal data deleted

You can request the immediate deletion of your personal data for the following reasons:

• If your personal information is no longer needed for the purposes for which it was collected
• If you revoke your consent and there is no other legal basis
• If you object to the processing and there are no overriding reasons for processing worthy of protection
• If your personal data have been processed unlawfully
• If your personal data must be deleted in order to comply with legal requirements

Please note that a claim for deletion depends on whether there is a legitimate reason that requires the processing of the data.

Your right to restrict the processing of your personal data

You have the right to request a restriction on the processing of your personal data for one of the following reasons:

• If you dispute the accuracy of your personal data and we have had the opportunity to verify that it is correct
• If the processing is not lawful and you request a restriction of use instead of deletion
• If we no longer need your data for the purposes of processing, but you do need it to assert, exercise or defend against legal claims
• If you have lodged an appeal until it has been determined whether your interests predominate

Your right of objection

We may process your data on the basis of legitimate interest or in the public interest. In these cases you have the right to object to the processing of your data. This also applies if we use your data for our direct advertising. Please note our separate notice "Information about your right of objection".

Your right of appeal

In some cases it can happen that you are not satisfied with our answer to your request. Then you are entitled to file a complaint with the management of sentix GmbH and the responsible data protection supervisory authority.

Your right to data transferability

You have the right to receive personal data that you have given us in a transferable format.

Are you obliged to give sentix GmbH certain personal data?

In the context of our business relationship, we require the following personal data from you:

• Data used for the establishment and implementation of the business relationship
• Data needed to conduct the sentix survey (if you participate)
• Data necessary for the fulfilment of the contractual obligations associated with the business relationship
• Data that we are legally obliged to collect

Without this personal data we are usually not in a position to enter into a contract with you, to enable you to use our services or to participate in the sentix survey.

How long do we store your data?

We do not store your data longer than we need it for the respective processing purposes.

If the data are no longer required for the fulfilment of contractual or legal obligations, they are regularly deleted, unless their - temporary - storage is still necessary. Reasons for this could be, for example, the following:

• The fulfilment of obligations under commercial law and tax law to retain data. In this context, the legal retention period is up to 10 years.
• Obtaining evidence for legal disputes within the framework of the statutory statute of limitations. The limitation periods under civil law can be up to 30 years, whereby the regular limitation period is three years.

Personal capital market assessments by you will, in principle, be made anonymous, unless you have been provided at your request during the period of use of our service. The same happens as soon as you no longer use our services. In anonymous form it is no longer possible to draw any conclusions about your person. Accordingly, this data is no longer considered personal data of your person and is no longer subject to this data protection guideline.

Information about your right of objection according to Art. 21 DSGVO

Right to object on a case-by-case basis

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 data processing is in the public interest or on the basis of a balance of interests.

In the event of a contradiction, we will no longer process your personal data. Unless we can prove compelling reasons worthy of protection for the processing of these data, which outweigh your interests, rights and freedoms. Or your personal data are used to assert, exercise or defend legal claims.

Objection to the processing of your data for our direct marketing purposes

In individual cases we use your personal data for our direct advertising. You have the right to object at any time. In the event of an objection, we will no longer process your personal data for these purposes.

The objection can be made form-free and should be addressed to:

sentix GmbH, Mainzer Straße 4b, 65550 Limburg, Germany
E-Mail: datenschutz@sentix.de

Amendments

This data protection declaration is currently valid and dated January 5th, 2023.

We reserve the right to change this data protection declaration from time to time with effect for the future. However, we will not subsequently use data collected once for other purposes without your consent if our data protection declaration has changed in the meantime.