1. Identity and contact details of the controller

This Privacy Policy applies to data processing by:

Stockcircle

(hereinafter “Stockcircle” or “We”)

2. Collection and storage of personal data and the type and purpose of their use

a) When you visit the website

When you visit our website www.stockcircle.com, information is automatically sent by the browser used on your end device to our website servers hosted by Cloudflare Inc (101 Townsend St., San Francisco, CA 94107) and DigitalOcean LLC (101 Avenue of the Americas 10th Floor, New York, NY 10013) in the USA. This information is stored temporarily in what is called a log file. The following information is collected during this process without any action on your part and stored until it automatically deleted in accordance with applicable data protection regulations:

• IP address of the requesting computer,
• Date and time of access,
• Name and URL of the requested file,
• Website from which access is obtained (Referrer URL),
• Browser used and, where applicable, the your computer’s operating system and the identity of your access provider.

The specified data are processed by us for the following purposes:

• Ensuring that the website can establish a connection smoothly,
• ensuring that our website is easy to use,
• analysis of system security and stability, as well as
• for additional administrative purposes.

The legal basis for the data processing is Article 6 (1) (f) of the General Data Protection Regulation (GDPR). Our legitimate interest is based on the data collection purposes listed above. We do not on any account use the data collected for the purpose of identifying you. The provision of this data is not required by law or contract or to enter into a contract. You are not obliged to provide the personal data. It is not, however, possible to access the website if the data are not provided.

We also use cookies and analysis services when you visit our website. More detailed explanations can be found below.

b) When you subscribe to our newsletter

If you have provided your express consent in accordance with point Article 6 (1) (a) GDPR, we use your name and e-mail address to send you our newsletter on a regular basis. Stating an e-mail address is sufficient for receiving the newsletter.

You can unsubscribe at any time by using the link at the end of each newsletter.

c) When you use our contact form

We offer you the possibility to contact us via a contact form provided on the website. A valid e-mail address is required for this so that we know who the inquiry is coming from and can respond to it. Additional information can be provided on a voluntary basis.

Data is processed for the purpose of contacting us in accordance with Article 6 (1) (a) GDPR on the basis of the consent you provide on a voluntary basis. The personal data collected by us when you contact us are deleted in accordance with statutory requirements once your inquiry has been dealt with.

d) User account

You also have the option of creating a user account (“Stockcircle Profile”) on our website so that you can use the additional functions of the website.

You have to specify and e-mail address and set a password for this. You can also voluntarily specify your first and last name.

Once you have completed your registration, you can also optionally specify several data points about the amount you want to invest, deposits and payouts (amount + date) and stock purchases and sales (stock id, date, price, number of stocks, fees and total price). We use this data to give you an overview of your stock holdings similar to a virtual stock portfolio and we use the data to generate information about potential stock transactions.

3. Disclosure of data

With the exception of the service providers who act on our behalf to provide our website (e.g. see 2.a. above), we do not generally disclosure your personal data to third parties. Exceptions only apply in the following cases if:

• You have given your express consent to this in accordance with Article 6 (1) (a) GDPR,
• disclosure in accordance with Article 6 (1) (f) GDPR is necessary for the purposes of pursuing our legitimate interests or the legitimate interests of third party and there is no reason to assume that you have any overriding interest in your data not being disclosed which is worthy of protection,
• disclosure in accordance with Article 6 (1) (c) GDPR as required by law, and
• this is permitted by law and required by Article 6 (1) (b) GDPR for the performance of contractual relationships with you.

4. Cookies and Web Storage

When you visit our websites, we store information on your computer in the form of cookies and by way of web storage (so-called super cookies). Cookies and super cookies are small files sent from an internet server to your browser and stored on your hard disk. Information is stored in the cookie or super cookie which is generated in each case in connection with the end device specifically used. This does not, however, mean that we as a result receive any direct knowledge of your identity.

The following cookies and super cookies are used on our website:

Cookies and super cookies on the one hand serve to make our offer easier for you to use. We use session cookies for example to detect that you have already visited individual pages of our website. These are automatically deleted when you leave our website. We also use temporary cookies to optimize user-friendliness which are stored on your end device for a specifically determined period of time. If you visit our website again in order to use our services, it is automatically detected that you have already visited us and which entries you have made and settings you have chosen so that you do not have to enter these again.

We also use cookies and super cookies to statistically record the use of our website and to analyze this for the purpose of optimizing our offer for you (see “Analysis tools” below). These cookies allow us to detect that you have already been on our website when you visit us again. We also use cookies for retargeting purposes (see “Marketing” below). These cookies are automatically deleted in each case after a defined period.

The data processed via cookies and super cookies are required for the specified purposes in order to safeguard our legitimate interests and those of third parties in accordance with Article 6 (1) (f) GDPR.

Naturally you can also visit our website without accepting cookies and super cookies. If you do not want your computer to be recognized again during your next visit, you can also block the use of cookies and super cookies by changing the setting in your browser to “disable cookies”. Instructions on how to do this are found in your browser’s user guide.

Your use of some areas of our websites may, however, be restricted is you block the use of cookies and super cookies.

5. Analysis tools

The tracking measures listed below which are used by us are carried out on the basis of Article 6 (1) (f) GDPR. By using these tracking measures we want to ensure that our website is designed in line with your user preferences, can be optimized continuously and that we can provide you with personalized recommendations based on the information you have entered into your Stockcircle Profile. We also use the tracking measures to statistically record the use of our website and for the purpose of optimizing our offer for you. These interests are to be considered legitimate within the meaning of the regulation specified above. The provision of these data is not required by law or contract or to enter into a contract. You are not obliged to provide these personal data.

The individual data processing purposes and data categories are specified under the relevant tracking tools.

a) Use of Google Analytics with anonymization function

We use Google Analytics, a web analysis service of Google Inc. (www.google.de/intl/de/about) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter “Google”) for the purpose of designing our websites in line with your user preferences and continuously optimizing these. Pseudonymized usage profiles are created and cookies are used in this context. The information generated by the cookies about your use of this website such as

• type/version of browser,
• operating system used,
• referrer URL (last website visited),
• host name of the accessing computer (IP address),
• time of server request,

are transferred to a Google server in the USA and stored there. The information is used to analyze the use of the website, to compile reports on website activities and to provide additional services associated with website and internet use for market research and design of these websites in line with user preferences. This information may also be disclosed to third parties if this is required by law or if these third parties process these data for us. Your IP address will on no account be combined with other Google data. IP addresses are anonymized so that they cannot be linked to any specific person (IP masking).

You can also prevent the installation of these cookies by configuring your browser software settings accordingly; we would, however, advise you that in this case you may not be able to use all website functions fully. You can also prevent the data generated by the cookie and data relating to your use of the website being collected (including your IP address) and the processing of these data by Google by downloading and installing a browser add-on.

Instead of using a browser add-on, in particular for browsers on mobile end devices, you can also prevent data being collected by Google Analytics by clicking on this link. An opt-out cookie is set that prevents your data being collected in future when you visit this website. The opt-out cookie is only valid in this browser and for our websites and is stored on your device. If you delete the cookies in this browser, you will have to place the opt-out cookie again.

Addition information on privacy in connection with Google Analytics can for example be found here: Google Analytics Help

6. Marketing

a) BuySellAds

We embed banner advertising on this website which is supplied by the provider BuySellAds.com Inc. (P.O. Box 55071 #30027, Boston, MA 02205-5071, USA) “BuySellAds”).

Adverts placed via the BuySellAds advertising network can be shown to you in various formats (e.g. text, images, videos). Which adverts you see may depend on your previous usage behavior on other websites that likewise participate in the BuySellAds advertising network. The following factors can also determine which adverts are placed for you: websites you have visited and apps on your device; anonymous identifiers linked to your mobile devices; previous interactions with adverts or advertising services of BuySellAds.

You can object to the collection of data for these purposes by deactivating cookies in your browser or device setting.

Additional information on privacy in connection with BuySellAds.com Inc. can be found here: www.buysellads.com/about/privacy.

b) Facebook pixel

We also carry out retargeting using the Facebook pixel.

• Retargeting is an online marketing process in which the visitor to a website is tagged and then retargeted on other websites with targeted advertising.
• We use the Facebook pixel of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”) for retargeting. The Facebook pixel serves to present visitors to this website with interest-based adverts based on the information regarding their use of this website in the social network Facebook or when they visit websites that participate in the Facebook advertising network (“Facebook Ads”).

The Facebook pixel is a program code implemented on this website. The program code can prompt the storage of certain information on your end device in the form of cookies and trigger the transfer of certain data to Facebook. This includes information which is generated for technical reasons via the Hypertext Transfer Protocol (HTTP) when you access the website, for example your IP address, as well as information already stored in cookies on your end device, for example your Facebook ID. When you access the website, Facebook can therefore detect that you have visited this website and what content you have accessed. If you have a user account on Facebook, Facebook can relate this information to your user account.

If you do not want Facebook to relate the information gathered directly to your Facebook user account, you can deactivate the remarketing function here. You have to be logged on to Facebook to do this. You can also object to data collection for these purposes by installing add-ons for your browser (e.g. with the “Facebook Blocker”), by deactivating cookies in your browser or device settings.

More detailed information on the processing of personal data by Facebook, your rights and options for protecting your privacy in this respect can be found in Facebook’s privacy policy at www.facebook.com/about/privacy.

7. Social media plug-ins

We use social plug-ins of the social networks Facebook, Twitter and Instagram on our website on the basis of Article 6 (1) (f) GDPR in order to increase the awareness of our website via these. The advertising purpose behind this is to be considered a legitimate interest within the meaning of the GDPR. Operation in line with data protection requirements is to be ensured by the relevant plug-in operator. We embed this plug-in by means of the “2-click method” to protect visitors to our website as best as possible.

a) Facebook

Facebook social media plug-ins are used on our website to make its use more personal. We use the “LIKE” and “SHARE” button for this. This service is offered by Facebook.

If you access a page of our website that contains such a plug-in, your browser connects directly to the servers of Facebook. The content of the plug-in is sent directly to your browser by Facebook and embedded in the website by it.

By embedding this plug-in, Facebook receives the information that your browser has accessed the relevant page of our website, even if you do not have a Facebook account or are not currently logged on to Facebook. This information (including your IP address) is sent by your browser directly to a Facebook service in the USA and stored there.

If you are logged on to Facebook, Facebook can directly relate the visit to our website to your Facebook account. If you interact with the plug-in, for example by clicking on the “LIKE” or “SHARE” button, the relevant information is likewise sent directly to a Facebook server and stored there. The information is also published on Facebook and shown to your Facebook friends.

Facebook can use this information for the purpose of advertising, market research and designing Facebook pages in line with your personal preferences. Facebook creates usage, interest and relationship profiles for this, e.g. to analyze your use of our website with regard to the adverts displayed to you on Facebook, to inform other Facebook users about your activities on our website and to provide additional services relating to the use of Facebook.

If you do not want Facebook to relate the data collection via our website to your Facebook account, you must log out from Facebook before visiting our website.

The purpose and scope of data collection and the further processing and use of the data by Facebook and your rights and settings options for protecting your privacy in this respect to protect your privacy can be found in Facebook’s privacy policy at www.facebook.com/about/privacy.

b) Twitter

Plugs-ins of the short message network of Twitter Inc. (“Twitter”) are also integrated into our website. You can identify the Twitter plug-ins (tweet buttons) with the Twitter logo on our website. General information about tweet buttons can be found here: https://about.twitter.com/resources/buttons.

If you access a page of our website that contains such a plug-in, a direct connection is created between your browser and the Twitter server. Twitter as a result receives the information that you have visited our website with your IP address. If you click on the Twitter tweet button while you are logged on to your Twitter account, you can link the content of our pages to your Twitter profile. Twitter can as a result relate your visit to our pages to your user account. We would advise you that as provider of the pages we do not receive any information regarding the content of the data transferred or their use by Twitter.

If you do not want Twitter to relate your visit to our websites to your Twitter account, please log off from your Twitter account.

Additional information on this can be found in Twitter’s privacy policy at https://twitter.com/privacy.

c) Instagram

Social plug-ins of Instagram operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”) are also used on our website.

The plug-ins are identified with an Instagram log, for example in the form of an Instagram camera. If you access a page of our website that contains such a plug-in, your browser connects directly to Instagram’s servers. The content of the plug-in is sent directly to your browser by Instagram and embedded in the page. By embedding this plug-in, Instagram receives the information that your browser has accessed the relevant page of our website, even if you do not have an Instagram account or are not currently logged on to Instagram.

This information (including your IP address) is sent directly by your Browser to an Instagram server in the USA and stored there. If you are logged on to Instagram, Instagram can relate your visit to our website directly to your Instagram account. If you interact with the plug-in, for example by clicking on the Instagram button, this information is likewise sent directly to an Instagram server and stored there.

This information is also published on your Instagram account and shown there to your followers.

If you do not want Instagram to relate the data collected via our website directly to your Instagram account, you have to log off from Instagram before visiting our website.

Additional information on this can be found in Instagram’s privacy policy at https://help.instagram.com/155833707900388.

8. Security

During your website visit you use the widespread SSL process (Secure Socket Layer) in connection with a modern encryption level. This is normally 128-bit encryption. Whether an individual page of our website is transmitted in encrypted form can be seen with the closed key or lock icon in your browser’s status bar.

We have also taken technical and organizational security measures to protect your personal data against loss, destruction, manipulation and unauthorized access. All our employees and any service providers who work for us are obliged to comply with all applicable data protection legislation. Are security measures are subject to a continuous improvement process and our privacy policies are constantly revised. Please ensure that you have the most up-to-date version.

9. Rights of data subjects

You have the right:

• in accordance with Article 15 GDPR to obtain information about the personal data processed by us;
• in accordance with Article 16 GDPR DSGVO to obtain without undue delay the rectification or completion of your personal data stored by us;
• in accordance with Article 17 GDPR to obtain the erasure of the personal data stored by us, unless the processing is necessary for exercising the right of freedom of expression or information, for compliance with a legal obligation, for reasons of public interest or for the establishment exercise or defense of legal claims. If we have made your personal data public, we are obliged, taking account of available technology and the technical possibilities, to inform controllers which are processing the personal data that the you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data;
• in accordance with Article 18 GDPR to obtain the restriction of the processing of your personal data if you contest the accuracy of the personal data, the processing is unlawful, but you oppose their erasure and we no longer require the data, but you require these for the establishment, exercise or defense of legal claims or you have objected to their processing in accordance with Article 21 GDPR;
• in accordance with Article 20 GDPR to receive your personal data in a structure, commonly used and machine-readable format or have such transmitted to another controller;
• in accordance with Article 7 (3) GDPR to withdraw your consent given to us at any time. This means that we may no longer continue the data processing based on this consent in future, and
• in accordance with Article 77 GDPR to complain to a supervisory authority. You can usually contact the supervisory authority at your normal place of residence or your workplace or where we are headquartered for this.
• If your personal data are processed on the basis of legitimate interests in accordance with Article 6 (1) (f) GDPR, you have the right in accordance with Article 21 GDPR to object to the processing of your personal data if grounds for this relating to your particular situation exist or the objection is to direct marketing. In the latter case you have a general right to object, which is implemented by us without any particular situation being specified. Sending an appropriate e-mail to [email protected] is sufficient if you wish to exercise your right to withdraw consent or your right to object.

10. Amendments to this Privacy Policy

This Privacy Policy is currently valid.

It may be necessary to amend this Privacy Policy due to the development of our website and its offers or due to any changes to statutory or regulatory requirements. You can access and print our Privacy Policy as amended at any time at our website at www.stockcircle.com/privacy/.

Last modified: May 24, 2018