We, TxStrategies, take the protection of your personal data and the legal obligations serving this protection very seriously. The legal requirements demand comprehensive transparency about the processing of personal data. Only if the processing is comprehensible for you as a data subject, you are sufficiently informed about the meaning, purpose and scope of the processing. Our privacy policy therefore explains in detail which so-called personal data is processed by us when you use our website.

Please note that links on our website may take you to other Internet pages that are not operated by us but by third parties. Such links are either clearly marked by us or are recognizable by a change in the address line of your browser. We are not responsible for compliance with data protection regulations or for the secure handling of your personal data on these websites operated by third parties.

I. General

As a matter of principle, we collect and use personal data of our users only to the extent that this is necessary for the provision of a functional website as well as our contents and services. The collection and use of personal data of our users is regularly only carried out with the consent of the user. An exception applies in those cases where it is not possible to obtain prior consent for factual reasons and the processing of the data is permitted by legal regulations.

Legal basis of processing

Insofar as we obtain the consent of the data subject for processing operations involving personal data, Art. 6

(1) lit. a EU General Data Protection Regulation (DSGVO) serves as the legal basis for the processing of personal data.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) (b) DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures. Insofar as processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) lit. c DSGVO serves as the legal basis.

In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.

If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the first-mentioned interest, Art. 6 (1) f DSGVO serves as the legal basis for the processing.

Updates

We may update this privacy policy at our discretion from time to time by posting a new version on our website. You should check our website occasionally to ensure any changes are suitable for you.

The current version of this privacy policy was modified on November 02, 2023

Data deletion and storage

The personal data of the data subject will be deleted or protected by technical and organizational measures (e.g. pseudonymization, encryption) as soon as the purpose of storage ceases to apply. In addition, storage may take place if this has been provided for by the European or national legislator in Union regulations, laws or other regulations to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

Cooperation with processors and third parties

Insofar as we disclose data to other persons and companies (order processors or third parties) in the course of our processing, transmit it to them or otherwise grant them access to the data, this shall only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is required for the performance of the contract pursuant to Art. 6 (1) lit. b DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called „order processing agreement“, this is done on the basis of Art. 28 DSGVO. The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services, which we use for the purpose of operating this online offering.

In this context, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO (conclusion of order processing contract).

Collection of access data and log files

We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of 31 days and then deleted. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the final clarification of the respective incident.

Cookies

To ensure the operation of the WebApp TradeTracer, we use cookies on the basis of DSGVO Art. 6 para. 1 lit. b and DSGVO Art. 6 para. 1 lit. f. The cookies we use are exclusively functional cookies. The use of third-party cookies for tracking or advertising purposes does not take place.

II Data processing in connection with the use of the website

2. informational use of the website

When you visit our website and use it purely for information purposes, i.e. without using additional functions such as the contact form, we automatically collect personal data. This is the following information: IP address of your end device as well as the date and time of accessing the website. This information is transmitted by your browser unless you have configured it to suppress the transmission of this information.

This personal data is processed to ensure the functionality and optimization of the website and to ensure the security of our information technology systems. This is also our legitimate interest, which is why processing is permitted under Art. 6 (1) (f) GDPR.

Data will only be passed on to third parties if this is necessary for the operation of our website. We employ an outside company to process debit, credit, and other payments and to perform related services. Paid Users will also receive a notification email from Stripe if there are any issues regarding billing their cards for auto-renew subscriptions. Users cannot opt out of these messages, though they can delete their account.

3. Amazon Web Services

For the provision of this website and the platform services (DorfFunk, LösBar) we use the web hosting service Amazon Web Services of Amazon Web Services EMEA Sàrl, Rue Plaetis 5, 2338 Luxembourg, Luxembourg (hereinafter: „Amazon Web Services“). In this context, Amazon Web Services, Inc. in the USA may also be used as a sub-service provider (collectively „AWS“).

AWS stores this website on its servers (hosting). The storage location is the EU (Frankfurt, eu-central-1). The provision of a website requires the commissioning of a web hosting service. The use of AWS takes place according to Art. 6 para. 1 p. 1 lit. e/f DSGVO due to our legitimate economic interest to provide our offer on this website. In connection with hosting, Amazon Web Service processes personal data on our behalf as follows: AWS S3 (AWS storage service): Storage of user profile pictures as encrypted files. AWS RDS (AWS database service): storage of user data in an encrypted database that can only be accessed by the application itself AWS SNS/Pinpoint (push services from AWS): identification of the device for delivery of push messages AWS Cloudwatch (log service from AWS): storage of temporary log messages. Other AWS services process user data non-persistently as part of technical operations: AWS CloudFront, AWS EC2, AWS Lambda, AWS ECS Amazon Web Service certified by trusted security standards, including ISO 27001, SOC 1/2/2, and PCI DSS Level 1.

4. Social sign-in

To facilitate your registration on our website and in the mobile apps, you have the option of registering with the so-called single sign-on solution (via Google, Discord, etc.) at the beginning of the registration process.

The providers‘ data protection and terms of use apply to registration and use. In any case, your account details are entered directly on the provider’s server. We do not learn your account details. The respective providers will inform you whether and which data of your social media account will be made accessible to us. If you have expressly given your consent to the provider (Google, Discord) in accordance with Art. 6 (1) p. 1 lit. a DSGVO, your personal data (first name, last name, e-mail address) will be transmitted to us as part of the registration via the provider.

You can cancel the connection again within your account.

The purpose and scope of the data collection and the further processing and use of the data by Google, Facebook or Apple, as well as your rights in this regard and settings options for protecting your privacy, can be found in the privacy notices of Google and Discord. The respective provider is responsible under data protection law for the respective single sign-on solution.

The use of the data transmitted to us by the provider takes place

– to set up your user account and

– to check the plausibility of the data entered.

Your data will be deleted upon deletion of the user account with us. The legal basis for the processing is the implementation of the user relationship between you and us, Art. 6 para. 1 lit a DSGVO, or between your employer and us, Art. 6 para. 1 lit e/f DSGVO (interest in securely authenticating your access through established services).

5. Auth0

We use the Auth0 service, provided by Okta Inc, P.O. Box 743620, Los Angeles, CA 90074 – 3620 (hereinafter: „Auth0“) to manage logins (username and password), including single sign-ons (see section 4.2) in our system. In doing so, we do not obtain access to your password from third-party providers such as Google or Discord. We only receive your email address and information about the successful login, as well as additional data if you authorize the third-party providers to do so (see Section 4.2).

Okta Inc acts as our processor. The USA is a country outside the EU for which there is no adequacy decision by the EU Commission stating that this country offers an adequate level of data protection comparable to that of the EU. We have therefore concluded a contract with Okta Inc in the USA in accordance with the EU standard data protection clauses. The text of the standard data protection clauses is available at https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32010D0087 (there: Appendix). You can find the completed text of the contract from Okta at okta.com/gdpr >> „GDPR Resources“ „Data Processing Addendum“ (https://www.okta.com/sites/default/files/2021-02/OKTA-DPA-2-1-21.pdf). Alternatively, you can obtain the text from us.

6. contact form and e-mail

If you use the contact form on our website or send us an e-mail, the personal data you provide there will be processed by us. This information is transmitted by your browser or e-mail client and stored in our information technology systems. The processing of this personal data is necessary for answering your request. In addition, your IP address and the date and time of the contact request are stored if you send us an e-mail.

The data processing serves the purpose of answering your inquiry and preventing misuse of the contact form and ensuring the security of our IT systems.

This processing is lawful because responding to your inquiry and protecting our IT systems constitute legitimate interests within the meaning of Article 6(1)(f) GDPR. The personal data will be stored for as long as is necessary to answer your request. If your inquiry leads to the conclusion of a contract at a later date, the data will be stored for as long as is necessary to carry out pre-contractual measures or to fulfill the contract. We do not merge this personal data with other data sources. Data is not passed on to third parties. A transfer to a third country or to an international organization is not intended. You are not obliged to provide this personal data, but it is not possible to use the contact form or send an e-mail without providing it.

7. Stripe

Payments will be processed via Stripe Payments Europe Ltd, Block 4, Harcourt Center, Harcourt Road, Dublin 2, Ireland („Stripe“). All data required for payment processing will be used by Stripe for the sole purpose of making the payments and will be securely transmitted via the SSL process. The transfer of your data takes place in accordance with Art. 6 para. 1 cl. 1 lit. b GDPR and solely for the purpose of payment processing. For more information about Stripe’s privacy policy, visit https://stripe.com/terms.

III. Your rights as a data subject

If personal data is processed by you, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:

1. right to information

You may request confirmation from the controller as to whether personal data concerning you are being processed by us.

If such processing is taking place, you may request information from the controller about the following:

• the purposes for which the personal data are processed;
• the categories of personal data which are processed;
• the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
• the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage period;
• the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
• the existence of a right of appeal to a supervisory authority;
• any available information about the origin of the data, if the personal data are not collected from the data subject;
• The existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer.

2. right to rectification

You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you is inaccurate or incomplete. The controller shall carry out the rectification without undue delay.

3. right to restriction of processing

You may request the restriction of the processing of personal data concerning you under the following conditions:

if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;

the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;

the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims; or

if you have objected to the processing pursuant to Article 21 (1) DSGVO and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.

Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. right to deletion

a) Obligation to delete

You may request from the controller that the personal data concerning you be erased without undue delay, and the controller is obliged to erase such data without undue delay, provided that one of the following reasons applies:

• The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
• You withdraw your consent on which the processing was based pursuant to Art. 6 (1) (a) or Art. 9 (2) (a) of the GDPR and there is no other legal basis for the processing.
• You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
• The personal data concerning you have been processed unlawfully.
• The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
• The personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.

b) Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.

c) Exceptions

The right to erasure does not exist insofar as the processing is necessary For the exercise of the right to freedom of expression and information; for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) DSGVO, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or for the assertion, exercise or defense of legal claims.

5. right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right against the controller to be informed about these recipients.

6. right to data portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Art. 6 (1) a DSGVO or Art. 9 (2) a DSGVO or on a contract pursuant to Art. 6 (1) b DSGVO and the processing is carried out with the help of automated procedures.

In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. right of objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.

The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.

8. right to revoke the declaration of consent under data protection law.

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

9. right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

IV. Data security

All data transmitted by you personally is encrypted using the generally accepted and secure TLS (Transport Layer Security) standard. TLS is a secure and proven standard that is also used in online banking, for example. You can recognize a secure TLS connection by the s appended to the http (i.e. https://..) in the address bar of your browser or by the lock symbol at the bottom of your browser. We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

As of Feburary 2025