Your privacy is critically important to us. We strongly respect your privacy and security.
We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the Ex-Trade. The use of the Internet pages of the Ex-Trade is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The data protection declaration of the Ex-Trade is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
DK – 8300 Odder
Data Protection Officer: Birte Dittweiler Gerber
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
4. Collection of general data and information
The website of the Ex-Trade a.m.b.a. collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, the Ex-Trade a.m.b.a. does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Ex-Trade a.m.b.a. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
Like most website operators, Ex-Trade a.m.b.a. collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Ex-Trade a.m.b.a.’s purpose in collecting non-personally identifying information is to better understand how Ex-Trade a.m.b.a.’s visitors use its website. From time to time, Ex-Trade a.m.b.a. may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.
Ex-Trade a.m.b.a. also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on https://www.ex-trade.com/ blog posts. Ex-Trade a.m.b.a. only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below.
Gathering of Personally-Identifying Information
Certain visitors to Ex-Trade a.m.b.a.’s websites choose to interact with Ex-Trade a.m.b.a. in ways that require Ex-Trade a.m.b.a. to gather personally-identifying information. The amount and type of information that Ex-Trade a.m.b.a. gathers depends on the nature of the interaction. For example, we ask visitors who sign up for a membership at https://www.ex-trade.com/ to provide a username and email address and other information.
On Membership apply we ask for:
|Company, VAT, Registration number, Address, City, Country, Postal code||For identifying you as a company||We keep this information 3650 days since the last connection with you|
|Contact person name, phone number, email||For contacting with you||We keep this information 3650 days since the last connection with you|
|Other entered data or actions||For the business workflow||We keep this information 3650 days since the last connection with you|
For the existing membership.
We collect all the data you entered in the system which require the business workflow.
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
We define that we keep all your entered data, logs or activities for 3650 days since your last login or contact with us.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Links To External Sites
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites, products or services.
Https://www.ex-trade.com/ uses Google AdWords for remarketing
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
Protection of Certain Personally-Identifying Information
Ex-Trade a.m.b.a. discloses potentially personally-identifying and personally-identifying information only to its employees, contractors and affiliated organizations.
If Ex-Trade a.m.b.a., or substantially all of its assets, were acquired, or in the unlikely event that Ex-Trade a.m.b.a. goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Ex-Trade a.m.b.a. may continue to use your personal information as set forth in this policy.
Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
5. Ex-Trade Mobile application on Play Market and Apple Store Changes
ExTrade’s Mobile application (can be downloaded from Google Play Market or Apple Store) ensures GDPR compliance within their mobile applications, such as when processing any information, collecting email addresses at account sign-up and transmitting data to other services.
Following is a summary of key elements that help explain how mobile applications will be impacted by this data privacy.
• We collect and transmit the PUSH notifications
• We collect the messages history and their statuses, including some technical information, ID, device ID, device Type, registration ID, Uniq User ID, emails, Application name.
The main purpose of the mobile application to deliver the notification from the server-side to the client using PUSH notifications.
Some of your actions like browsing history visited pages will be stored for further processing.
The PUSH notifications have to be transmitted via Firebase Cloud Messaging which means transferring the message via 3rd parties’ provider.
By removing the application on the mobile devices – you remove the application itself but all the history and data are stored on the server-side.
All the data stores the same as described for the web application.
Installing the mobile application, you automatically accept all Informed Consent from ExTrade’s app for collecting or processing personal information.