Privacy Policy

Last updated: November 8, 2023

Thank you for visiting ourwebsite and for your interest in our company and services.

Data Protection isof a particularly high priority for the management of 21.finance AG and itssubsidiaries. The use of the website of the 21.finance AG and 21.financeDLT-TSS AG is possible without any indication of personal data. However, if adata subject wants to use special services of our enterprise via the website,collection and processing of personal data will be necessary. If the processingof personal data is necessary and there is no legal basis for such processing,we will generally obtain the consent of the data subject.The Data Protection Policyapplies exclusively to the website of 21.finance AG and 21.finance DLT-TSS AG.This can be accessed via the following links: and 21x.eu. For websites of other operators that are linked to the websites of21.finance AG and 21.finance DLT-TSS AG, please refer to the Data ProtectionPolicy of the respective operators.

All references to “21.finance,“we” or “our” in this data privacy policy shall mean the 21.finance AG and/or21.finance DLT-TSS AG.21.finance reserves the rightto amend or supplement this statement from time to time. You should thereforecheck this statement regularly or each time you access the 21.finance websitesto see whether they have changed and, if so, whether you also agree with thecurrent version. You will find the respective update date at the beginning ofthis declaration.

If you do not agree with thisstatement, please refrain from accessing the websites of 21.finance. Pleasealso read the terms of use, which inform you about the conditions under whichthe websites of 21.finance may be used.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the country-specific laws:

– 21.finance AG: Principality of Liechtenstein.
– 21.finance DLT-TSS AG: Germany

By means of this Data Protection Policy, 21.finance and its affiliated companies would like to inform the public about the type, scope and purpose of the personal data collected, used and processed by 21.finance. Furthermore, data subjects are informed of their rights by means of this Data Protection Policy. As the controller, 21.finance has implemented numerous technical and organizational measures to ensure themost complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can always be subject to security vulnerabilities, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example in writing.

1. Definitions

The Data Protection Policy of 21.finance is based on the terms used by the European Directive and Ordinance when issuing the General Data Protection Regulation (GDPR). Our Data Protection Policy is intended to be easy to read and understand for the public as well as for our customers (i.e. investors and issuers) and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms, among others, in this privacy policy:

Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter “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.

Person concerned
Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

Processing
Processing is any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

Profiling
“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.

Pseudonymisation
Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separate and is subject to technical as well as organisational measures which ensure that the personal data cannot be attributed to an identified or identifiable natural person.

Controller or person responsible for the processing
The controller or person responsible for 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 designation may be provided for under Union or Liechtenstein law.

Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.ReceiverA recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.

Third Party
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller and its associated companies, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

Consent
Consent shall mean any freely given specific and informed indication of the data subject’s wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

2. Personal Data

21.finance collects, processes, and uses your personal data exclusively in accordance with the provisions of Art. 5 and 6 GDPR (contract, legal obligation, legitimate interest or consent of the data subject).

We only collect personal data that is required for the implementation and processing of our services or that you have provided voluntarily.

3. Cookies

The websites of 21.finance use cookies. Cookies are text files that are placed and stored on a computer system via an internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters by which internet pages and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the visited Internet pages and servers to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific internet browser can be recognized and identified via the unique cookie ID.

Through the use of cookies, 21.finance can provide the users of this websites with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimised in the sense of the user. As already mentioned, cookies enable us to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter his or her access data each time he or she visits the website, because this is done by the website and the cookie stored on the user’s computer system.

21.finance uses the Consent Management Platform (CMP) of Usercentrics GmbH, Rosental 4, 80331 Munich, Germany, to obtain the consent of each data subject for the use of their data in accordance with the GDPR. The data subject can prevent the setting of cookies by our website at any time by means of an appropriate setting on the CMP and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via all common internet browsers or via the CMP. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

4. Collection of general data and information

The websites of 21.finance collect a series of general data and information every time a data subject or automated system calls up the website. This general data and information is stored in the log files of the server. The following data may be collected: (1.) the browser types and versions used, (2.) the operating system used by the accessing system, (3.) the website from which an accessing system accesses our website (so-called “referrer”), (4.) the sub-websites that are accessed via an accessing system on our website, (5.) the date and time of an access.) the date and time of access to the website, (6.) an Internet protocol address (IP address), (7.) the Internet service provider of the accessing system and (8.) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using these general data and information, 21.finance does not draw any conclusions about the data subject. Rather, this information is needed (1) to deliver the contents of our website correctly, (2) to optimize the contents of our website and the advertising for these, (3) to ensure the long-term operability of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, 21.finance analyzes anonymously collected data and information on one hand, and on the other hand, with the aim of increasing the Data Protection and data security of our enterprise so that we can ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.

5. Registration on our website

The data subject has the possibility to register on the website of the controller by providing personal data. The personal data that is transmitted to the data controller in this context results from the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be passed on to one or more processors, for example the German postal service for video identification, who will also use the personal data exclusively for an internal use attributable to the controller.

By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) of the data subject, the date and the time of registration are also stored. The storage of this data takes place against the background that only in this way can the misuse of our services be prevented and, if necessary, this data makes it possible to clarify criminal offences that have been committed. In this respect, the storage of this data is necessary for the protection of the data controller. As a matter of principle, this data is not passed on to third parties unless there is a legal obligation to pass it on or the passing on serves the purpose of criminal prosecution.

The registration of the data subject by voluntarily providing personal data serves the purpose of the controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have it completely deleted from the data of the controller.

The controller shall provide any data subject at any time, upon request, with information on what personal data is stored about the data subject. Furthermore, the controller shall correct or delete personal data at the request or indication of the data subject, provided that this does not conflict with any statutory retention obligations.

6. Subscription to our newsletter

On the websites of the 21.finance, users are given the opportunity to subscribe to our enterprise’s newsletter. The personal data transmitted to the controller when the newsletter is ordered is specified in the input mask used for this purpose. 21.finance informs its customers (these are investors and issuers) and business partners at regular intervals by means of a newsletter about enterprise offers and issues. In principle, the newsletter of our company can only be received by the data subject if (1.) the data subject has a valid e-mail address and (2.) the data subject registers to receive the newsletter. For legal reasons, a confirmation e-mail is sent to the e-mail address entered by a data subject for the first time for the dispatch of the newsletter using the “double opt-in” procedure. This confirmation email serves to verify whether the owner of the email address as the data subject has authorized the receipt of the newsletter.

When registering for the newsletter, we also store the IP address of the computer system used by the data subject at the time of registration as well as the date and time of registration, which is assigned by the Internet service provider (ISP). The collection of this data is necessary in order to be able to trace the (possible) misuse of the e-mail address of a data subject at a later point in time and therefore serves as a legal safeguard for the controller.

The personal data collected in the context of a registration for the newsletter is used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, as could be the case in the event of changes to the newsletter offer or changes in the technical circumstances. No personal data collected as part of the newsletter service will be passed on to third parties. The subscription to our newsletter can be cancelled by the data subject at any time. The consent to the storage of personal data that the data subject has given us for sending the newsletter can be revoked at any time. For the purpose of revoking consent, a corresponding link can be found in each newsletter. Furthermore, it is also possible to unsubscribe from the sending of the newsletter at any time directly on the website of the controller or to inform the controller of this in another way.

7. Newsletter tracking

The newsletters of 21.finance contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in such emails that are sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, 21.finance may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the dispatch of the newsletter and to better adapt the content of future newsletters to the interests of the data subject. This personal data will not be disclosed to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the “double opt-in” procedure. After a revocation, this personal data will be deleted by the data controller. 21.finance automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. Contact option via the website

The websites of 21.finance contains legal requirements which enable a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or by using a contact form, the personal data transmitted by the data subject will be stored automatically. Such personal data transmitted on a voluntary basis by a data subject to the controller will be stored for the purposes of processing or contacting the data subject. This personal data will not be disclosed to third parties.

9. Routine deletion and blocking of personal data

The controller shall process and store personal data of the data subject only for the time necessary to achieve the purpose of storage or where provided for by the European Directive and Regulation or other legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies or if a storage period prescribed by the European Directive and Regulation or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

8. Conta10. Privacy policy on the use and application of AddThisct option via the website

The controller has integrated components of the company AddThis on this website. AddThis is a so-called bookmarking provider. The service enables a simplified bookmarking of Internet pages via buttons. By moving the mouse over the AddThis component or by clicking on it, a list of bookmarking and sharing services is displayed. AddThis is used on more than 15 million websites and the buttons are displayed more than 20 billion times a year, according to the operating company.

The operating company of AddThis is AddThis, Inc. 1595 Spring Hill Road, Suite 300, Vienna, VA 22182, USA.

Each time one of the individual pages of this website operated by the data controller is accessed and on which an AddThis component has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective AddThis component to download data from the website www.addthis.com. The data subject’s internet browser is then automatically informed by the AddThis component. As part of this technical procedure, AddThis receives knowledge about the visit and which specific individual page of this website is used by the information technology system used by the data subject. Furthermore, AddThis obtains knowledge of the IP address of the computer system used by the data subject assigned by the Internet service provider (ISP), the browser type, the browser language, the website called up from our website, the date and the time of the visit to our website. AddThis uses this data to create anonymised user profiles. The data and information transmitted to AddThis in this way enable the company, AddThis itself and the companies associated with AddThis or its partner companies to target visitors to the website of the controller with personalised and interest-based advertising.

AddThis displays personalised and interest-based advertising on the basis of a cookie set by the company. This cookie analyses the individual surfing behaviour of the computer system used by the person concerned. The cookie stores the visits to Internet pages originating from the computer system.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent AddThis from setting a cookie on the information technology system of the data subject. In addition, cookies already set by AddThis can be deleted at any time via an internet browser or other software programmes.

However, with the setting of the opt-out cookie, there is the possibility that the website of the controller is no longer fully usable for the data subject.

The applicable privacy policy of AddThis can be found at http://www.addthis.com/privacy/privacy-policy.

11. Privacy policy on the use and application of Facebook

The controller has integrated components of the company Facebook on this website. Facebook is a social network.

A social network is a social meeting place operated on the Internet, an online community that usually allows users to communicate and interact with each other in virtual space. A social network can serve as a platform for exchanging opinions and experiences or enables the internet community to provide personal or company-related information. Facebook and Instagram, among others, allow social network users to create private profiles, upload photos and network via friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The controller of personal data where a data subject lives outside the USA or Canada is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website operated by the data controller is called up and on which a Facebook component (Facebook plug-in) has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook. A complete overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=de_DE. Within the scope of this technical procedure, Facebook receives information about which specific sub-page of our website is visited by the data subject.

If the data subject is logged into Facebook or Instagram at the same time, Facebook recognises which specific sub-page of our website the data subject is visiting each time the data subject calls up our website and for the entire duration of the respective stay on our website. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook or Instagram account of the data subject. If the data subject activates one of the Facebook buttons integrated on our website, for example the “Like” button, or if the data subject posts a comment, Facebook assigns this information to the personal Facebook  user account of the data subject and stores this personal data.

Facebook always receives information via the Facebook component that the data subject has visited our website if the data subject is simultaneously logged into Facebook or Instagram at the time of calling up our website; this takes place regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not want this information to be transmitted to Facebook, he or she can prevent the transmission by logging out of his or her Facebook  account before accessing our website.

The data policy published by Facebook, which can be accessed at https://de-de.facebook.com/about/privacy/ (Facebook) and https://help.instagram.com/519522125107875/ (Instagram), provides information on the collection, processing and use of personal data by Facebook. It also explains which setting options Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.

12. Privacy policy on the use and application of Google AdWords

The controller has integrated Google AdWords on this website. Google AdWords is an internet advertising service that allows advertisers to place ads both in Google’s search engine results and in the Google advertising network. Google AdWords allows an advertiser to specify certain keywords in advance, by means of which an ad is displayed in Google’s search engine results exclusively when the user retrieves a keyword-relevant search result with the search engine. In the Google advertising network, the advertisements are distributed on topic-relevant internet pages by means of an automatic algorithm and in compliance with the previously defined keywords.

The operating company of the Google AdWords services is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to advertise our website by displaying interest-relevant advertising on the websites of third-party companies and in the search engine results of the Google search engine and to display third-party advertising on our website.

If a data subject accesses our website via a Google ad, a so-called conversion cookie is stored by Google on the data subject’s information technology system. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the data subject. If the cookie has not yet expired, the conversion cookie is used to track whether certain sub-pages, for example the shopping basket of an online shop system, have been called up on our website. The conversion cookie enables both us and Google to track whether a data subject who has accessed our website via an AdWords ad has generated a sale, i.e. has completed or cancelled a purchase of goods.

The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. These visit statistics are in turn used by us to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimise our AdWords ads for the future. Neither our company nor other advertisers of Google AdWords receive information from Google by means of which the data subject could be identified.

By means of the conversion cookie, personal information, such as the websites visited by the data subject, is stored. Each time the data subject visits our website, personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical procedure to third parties.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a conversion cookie on the information technology system of the data subject. In addition, a cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programmes.

Furthermore, the data subject has the option to object to interest-based advertising by Google. To do this, the data subject must call up the link www.google.de/settings/ads from any of the internet browsers he or she uses and make the desired settings there.Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/.

13. Privacy policy on the use and application of Google Analytics (with anonymisation function)

The controller has integrated the Google Analytics component including Google Tag Manager and Google Ads remarketing (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, compilation and evaluation of data about the behaviour of visitors to websites. A web analysis service collects, among other things, data on which website a data subject came to a website from (so-called “referrers”), which sub-pages of the website were accessed or how often and for how long a sub-page was viewed. A web analysis is mainly used to optimise a website and to analyse the costs and benefits of internet advertising.

The operating company of the Google Analytics component is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.

The controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this addition, the IP address of the internet connection of the data subject is shortened and anonymised by Google if access to our website is from a member state of the European Union or from another state party to the Agreement in the European Economic Area.

The purpose of the Google Analytics component is to analyse the flow of visitors to our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing the activities on our website, and to provide other services related to the use of our website.

Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website operated by the data controller is called up and on which a Google Analytics component has been integrated, the internet browser on the data subject’s information technology system is automatically caused by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to track the origin of visitors and clicks and subsequently to enable commission calculations.

By means of the cookie, personal information, for example the access time, the location from which an access originated and the frequency of visits to our website by the data subject, is stored. Each time the data subject visits our website, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programmes.

Furthermore, the data subject has the option to object to the collection of data generated by Google Analytics and related to the use of this website as well as to the processing of this data by Google and to prevent such processing. For this purpose, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information on visits to Internet pages may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the data subject’s information technology system is deleted, formatted or reinstalled at a later date, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within his or her control, it is possible to reinstall or reactivate the browser add-on.

Further information and the applicable Google privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail under this link https://www.google.com/intl/de_de/analytics/.

14. Privacy policy on the use and application of Leadfeeder

The controller has integrated functions of the web service Leadfeeder, operated by Liidio Oy, on this website.

The operating company of Leadfeeder is Liidio Oy, a European company with its registered office at Mikonkatu 17 C, 00100 Helsinki, Finland.

Leadfeeder uses cookies. These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Leadfeeder server and stored there.

Leadfeeder Tracker collects data on Amazon Web Services infrastructure. All data is encrypted in transit and at rest. Leadfeeder collects the behavioural data of all website visitors. This includes: pages visited, source of visitors and time spent on the website. The visitor’s IP address is collected to identify the company and geographical location. Leadfeeder only displays company visits; Leadfeeder automatically filters out all users visiting the website from private IP addresses. All visit data is aggregated at the company level.

Leadfeeder also enriches this company data with contact details for individuals from publicly available data sources. Leadfeeder’s data partners for contact data include Hunter and Full Contact.

You can object to the use of Leadfeeder. By sending an email to privacy@leadfeeder.com.

Further information and Leadfeeder’s applicable privacy policy can be found at https://www.leadfeeder.com/privacy/ and https://help.leadfeeder.com/en/articles/3561400-gdpr-privacy-and-security-summary.

15. Privacy policy on the use and application of LinkedIn

The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is an Internet-based social network that allows users to network with existing business contacts and to make new business contacts. Over 400 million registered people use LinkedIn in more than 200 countries. This makes LinkedIn currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. For Data Protection issues outside the USA, LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

With each individual call-up of our website that is equipped with a LinkedIn component (LinkedIn plug-in), this component causes the browser used by the person concerned to download a corresponding representation of the component from LinkedIn. Further information on LinkedIn plug-ins can be found at https://developer.linkedin.com/plugins. As part of this technical procedure, LinkedIn receives information about which specific sub-page of our website is visited by the data subject.

If the data subject is logged in to LinkedIn at the same time, LinkedIn recognises which specific sub-page of our website the data subject is visiting each time the data subject calls up our website and for the entire duration of the respective stay on our website. This information is collected by the LinkedIn component and assigned by LinkedIn to the respective LinkedIn account of the data subject. If the data subject activates a LinkedIn button integrated on our website, LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores this personal data.

LinkedIn always receives information via the LinkedIn component that the data subject has visited our website if the data subject is simultaneously logged into LinkedIn at the time of calling up our website; this takes place regardless of whether the data subject clicks on the LinkedIn component or not. If the data subject does not want this information to be transmitted to LinkedIn, he or she can prevent the transmission by logging out of his or her LinkedIn account before accessing our website.

LinkedIn offers the ability to unsubscribe from email messages, SMS messages and targeted ads, as well as manage ad settings at https://www.linkedin.com/psettings/guest-controls. LinkedIn also uses partners, such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua and Lotame, which may set cookies. Such cookies can be rejected at https://www.linkedin.com/legal/cookie-policy. LinkedIn’s applicable privacy policy is available at https://www.linkedin.com/legal/privacy-policy. LinkedIn’s cookie policy is available at https://www.linkedin.com/legal/cookie-policy.

16. Privacy policy on the use of a newsletter via HubSpotion via the website

We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Double opt-in and logging. Registration for our newsletters takes place in a so-called double opt-in procedure. This means. After registration, you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes saving the time of registration and confirmation, as well as the IP address. Changes to your data stored by HubSpot are also logged.

Use of the dispatch service provider HubSpot: The newsletter is sent using “HubSpot”, a dispatch platform for newsletters from HubSpot, Inc. , 2nd Floor 30 North Wall Quay, Dublin 1, Ireland. The email addresses of our newsletter recipients, as well as their other data described in this notice, are stored on HubSpot servers in the USA. HubSpot uses this information to send and evaluate the newsletter on our behalf. Furthermore, according to its own information, HubSpot may use this data to optimise or improve its own services, e.g. to technically optimise the dispatch and display of the newsletters or for economic purposes to determine from which countries the recipients come. However, HubSpot does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties. We trust in the reliability and IT and data security of HubSpot. HubSpot is certified and thus obligated to comply with EU Data Protection Regulation. Furthermore, we have concluded a “Data Processing Agreement” with HubSpot. This is a contract in which HubSpot undertakes to protect the data of our users, to process it on our behalf in accordance with its Data Protection Policy and, in particular, not to pass it on to third parties. You can view HubSpot’s Data Protection Policy under the link https://www.inxmail.de/datenschutz.

Statistical collection and analyses: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from HubSpot’s server when the newsletter is opened. As part of this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual recipients of the newsletter. However, it is neither our intention nor that of HubSpot to observe individual users. The evaluations serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. There are cases where we direct newsletter recipients to HubSpot’s websites. For example, our newsletters contain a link with which recipients of the newsletters can access the newsletters online (e.g. in the event of display problems in the email program). Furthermore, newsletter recipients can subsequently correct their data, such as the email address. Likewise, HubSpot’s privacy policy can only be accessed on their site. In this context, we would like to point out that cookies are used on HubSpot’s websites and personal data is thus processed by HubSpot, its partners and service providers used (e.g. Google Analytics). We have no influence on this data collection. For further information, please refer to HubSpot’s privacy policy. We would also like to draw your attention to the options for objecting to the collection of data for advertising purposes on the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European region).

Cancellation/revocation: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. Your consent to the sending of the newsletter via HubSpot and the statistical analyses will expire at the same time. Unfortunately, it is not possible to separately cancel the sending of the newsletter via HubSpot or the statistical analysis. You will find a link to cancel the newsletter at the end of each newsletter.

17. Privacy policy on the use and application of HubSpot 

On this website, we use HubSpot for our online marketing activities. HubSpot is a software company from the USA with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland.

This is an integrated software solution that we use to cover various aspects of our online marketing. These include, among others:Email marketing (newsletters as well as automated mailings, e.g. to provide downloads), social media publishing & reporting, reporting (e.g. traffic sources, accesses, etc. …), contact management (e.g. user segmentation & CRM), landing pages and contact forms.

Our sign-up service allows visitors to our website to learn more about our company, download content and provide their contact information and other demographic information. This information, as well as our website content, is stored on servers operated by our software partner HubSpot. It may be used by us to contact visitors to our website and to determine which of our company’s services are of interest to them. All information we collect is subject to this privacy policy. We use all collected information exclusively to optimise our marketing measures.

The legal basis for using the services of HubSpot is Art. 6 I f DS-GVO – legitimate interest. Our legitimate interest in using this service is the optimisation of our marketing measures and the improvement of our service quality on the website.

HubSpot is certified under the terms of the “EU – U.S. Privacy Shield Framework” and is subject to TRUSTe ‘s Privacy Seal and the “U.S. – Swiss Safe Harbor” Framework.

You can object to the use of HubSpot at any time. You can object to the use of cookies via settings.

Further information and HubSpot’s applicable privacy policy can be found at http://legal.hubspot.com/privacy-policy and http://legal.hubspot.com/terms-of-service.

18. Privacy policy on the use and application of Twitter (X)

The controller has integrated Twitter components on this website. Twitter is a multilingual publicly accessible microblogging service on which users can publish and distribute so-called tweets, i.e. short messages limited to 280 characters. These short messages can be accessed by anyone, including people who are not registered with Twitter. However, the tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow the tweets of a user. Furthermore, Twitter makes it possible to address a broad audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

Each time one of the individual pages of this website operated by the controller is called up and on which a Twitter component (Twitter button) has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective Twitter component to download a representation of the corresponding Twitter component from Twitter. Further information on the Twitter buttons can be found at https://about.twitter.com/de/resources/buttons. Within the scope of this technical procedure, Twitter receives information about which specific sub-page of our website is visited by the data subject. The purpose of integrating the Twitter component is to enable our users to distribute the content of this website, to make this website known in the digital world and to increase our visitor numbers.

If the data subject is logged into Twitter at the same time, Twitter recognises which specific subpage of our website the data subject is visiting each time the data subject calls up our website and for the entire duration of the respective stay on our website. This information is collected by the Twitter component and assigned by Twitter to the respective Twitter account of the data subject. If the data subject activates one of the Twitter buttons integrated on our website, the data and information thus transmitted will be assigned to the personal Twitter user account of the data subject and stored and processed by Twitter.

Twitter always receives information via the Twitter component that the data subject has visited our website if the data subject is logged into Twitter at the same time as calling up our website; this takes place regardless of whether the data subject clicks on the Twitter component or not. If the data subject does not want this information to be transmitted to Twitter, he or she can prevent the transmission by logging out of his or her Twitter account before accessing our website.

Twitter’s applicable privacy policy is available at https://twitter.com/privacy?lang=de.

19. Privacy policy on the use and application of YouTube

The controller has integrated YouTube components on this website. YouTube is an Internet video portal that allows video publishers to post video clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube allows the publication of all types of videos, which is why complete film and television programmes, but also music videos, trailers or videos made by users themselves can be accessed via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.

Each time one of the individual pages of this website operated by the data controller is called up and on which a YouTube component (YouTube video) has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information on YouTube can be found under the link https://www.youtube.com/yt/about/de/. Within the scope of this technical procedure, YouTube and Google receive information about which specific sub-page of our website is visited by the data subject.

If the data subject is logged into YouTube at the same time, YouTube recognises which specific sub-page of our website the data subject is visiting when a sub-page containing a YouTube video is called up. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google always receive information via the YouTube component that the data subject has visited our website if the data subject is logged into YouTube at the same time as calling up our website; this takes place regardless of whether the data subject clicks on a YouTube video or not. If the data subject does not want this information to be transmitted to YouTube and Google, he or she can prevent the transmission by logging out of his or her YouTube account before accessing our website.

The privacy policy published by YouTube, which can be accessed at the link https://www.google.de/intl/de/policies/privacy/, provides information on the collection, processing and use of personal data by YouTube and Google.

20. Legal basis of the processing

Article 6 I lit. a GDPR serves as the legal basis for our company for processing operations in 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 a party, as is the case, for example, with processing operations that are necessary for the provision of another service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data might become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result his or her name, age, health insurance details or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d GDPR. Finally, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47, sentence 2 of the GDPR).

21.Legitimate interests in the processing pursued by the controller or a third party

Where the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our owners.

22. Duration for which the personal data are stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data is routinely deleted if it is no longer required for the fulfilment or initiation of the contract.

23. Legal or contractual requirements to provide the personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We would like to inform youthat the provision of personal data is sometimes required by law (e.g. taxlaws) or may also result from contractual provisions (e.g. information on thecontractual partner). Sometimes, in order to conclude a contract, it may benecessary for a data subject to provide us with personal data that mustsubsequently be processed by us. For example, the data subject is obliged toprovide us with personal data if our companies conclude a contract with him orher. Failure to provide the personal data would mean that the contract with thedata subject could not be concluded. Before providing personal data by the datasubject, the data subject must contact one of our employees. Our employee willexplain to the data subject on a case-by-case basis whether the provision ofthe personal data is required by law or by contract or is necessary for theconclusion of the contract, whether there is an obligation to provide thepersonal data and what the consequences of not providing the personal datawould be.

24. Existence of automated decision making

As a responsible company, we refrain from automated ¬decision-making (profiling), unless this is required by legal provisions of the member states of the European Union or the European Economic Area.

25. Rights of the data subject

1. Right to confirmation

Every data subject shall havethe right, granted by the European Directive and the Regulation, to obtainconfirmation from the controller as to whether personal data concerning him orher are being processed.

2. Right to information

Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain from the controller, at any time and free of charge, information about the personal data stored about him or her and a copy of that information. Furthermore, the European Directive and Regulation has granted the data subject access to the following information:

• The processing purposes.
• The categories of personal data that are processed.
• The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations.
• If possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration.
• The existence of a right to rectification or erasure of personal data concerning them or 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.• If the personal data are not collected from the data subject: All available information about the origin of the data.
• 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.

Furthermore, the data subject has the right to be informed whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information on the appropriate safeguards in connection with the transfer.

3. Right of rectification

Any person concerned by the processing of personal data shall have the right granted by the European Directive and the Regulation to obtain the rectification without delay of inaccurate personal data relating to him or her. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, considering the purposes of the processing

4. Right to erasure (right to be forgotten)

Any person concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, to obtain from the controller the erasure without delay of personal data concerning him or her, where one of the following grounds applies and insofar as the processing is not necessary:

• The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
• The data subject revokes his/her consent on which the processing was based pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR and there is no other legal basis for the processing.
• The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
• The personal data were processed unlawfully.
• The deletion of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
• The personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

If the personal data have been made public by 21.finance and our enterprise as the controller is obliged to delete the personal data pursuant to Article 17 (1) of the Data Protection Regulation, 21.finance shall implement appropriate measures, including technical measures, taking into account the available technology and the cost of implementation, in order to inform other data controllers which are processing the published personal data that the data subject has requested from those other data controllers to delete all links to or copies or replications of the personal data, unless the processing is necessary. 21.finance will arrange the necessary in individual cases.

5. Right to restrict processing

Any person concerned by the processing of personal data has the right, granted by the European Directive and the Regulation, to obtain from the controller the restriction of processing where one of the following conditions is met:

• The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful, the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.
• The controller no longer needs the personal data for the purposes of processing, but the data subject needs it for the establishment, exercise or defence of legal claims.
• The data subject has objected to the processing pursuant to Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

6. Right to data portability

Every person affected by the processing of personal data has the right granted by the European Directive and Regulation to receive the personal data concerning him or her, which have been provided by the data subject to a controller, in a structured, commonly used and machine-readable format. The data subject shall also have the right to transmit such data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to obtain that the personal data be transferred directly from one controller to another controller, to the extent that this is technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.

7. Right to object

Any person affected by the processing of personal data shall have the right granted by the European Directive and Regulation to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is carried out on the basis of Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

21.finance shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defence of legal claims.

If 21.finance processes personal data for the purpose of direct marketing, the data subject shall have the right to object at any time to processing of personal data processed for such marketing. This also applies to the profiling, insofar as it is related to such direct marketing. If the data subject objects to 21.finance to the processing for direct marketing purposes, 21.finance will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her which is carried out by 21.finance for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the Data Protection Regulation, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

8. Automated decisions in individual cases including profiling

Any person concerned by the processing of personal data shall have the right, granted by the European Parliament and the Council, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1.) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2.) is permissible under Union or Member State law to which the controller is subject and that law contains suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3.) is made with the data subject’s explicit consent.

If the decision (1.) is necessary for entering into, or the performance of, a contract between the data subject and the data controller, or (2.) it is made with the data subject’s explicit consent, 21.finance shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain the data subject’s involvement on the part of the controller, to express his or her point of view and to contest the decision.

9. Right to revoke consent under Data Protection Regulation

‍Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to withdraw consent to the processing of personal data at any time.

10. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, a data subject shall have the right to lodge a complaint with the supervisory authority if he or she considers that the processing of his or her data infringes the General Data Protection Regulation.

The competent supervisory authority within the meaning of the General Data Protection Regulation is:

21.finance AG:
Liechtenstein Data Protection Authority
Kirchstrasse 8
PO Box 684
9490 Vaduz
Principality of Liechtenstein
Tel.: +423 236 60 90
E-mail: info.dss@llv.li

21.finance DLT-TSS AG:
The Federal Commissioner for Data Protection and Freedom of Information (BfDI)
Graurheindorfer Str. 1535
3117 Bonn
Germany
Tel: +49 (0)228 997799-0
E-Mail: poststelle@bfdi.bund.de

The Data Protection Authorities shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy.

26. Name and address of the controller

The responsible party within the meaning of the General Data Protection Regulation, other Data Protection laws applicable in the Member States of the European Union or the European Economic Area and other provisions of a Data Protection nature is:

21.finance AG

Industriering 40
9491 Ruggell
Liechtenstein
Tel:+423 78 325 32

office@21.finance

Trade Register No: FL-0002.541.900-1, Liechtenstein Office of Justice

Company ID:CHE-485.763.114 HR, Swiss Federal Office for Statistics

VAT- No: 60 067, Liechtenstein Tax Administration
Supervisory Authority according to Liechtenstein E-Commerce Law (ECG): Liechtenstein Office of National Economy

21.finance DLT-TSS AG

Große Gallusstraße 16-18,
60311 Frankfurt
Germany
Tel:+423 78 325 32

office@21.finance

Trade Register No: HRB 131029

This Data Protection Policy  was also created with the help of the Data Protection Policy generator of the German Association for Data Protection (https://dsgvo-muster-datenschutzerklaerung.dg-datenschutz.de/?lang=en), which is in cooperation with the law firm Wilde, Beuger, Solmecke Rechtsanwälte (https://www.wbs-law.de/taetigkeitsgebiete/medienrecht/).

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21X AG

Große Gallusstraße 16-18,
60311 Frankfurt
Germany

21.finance AG

Industriering 40
9491 Ruggell
Liechtenstein

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