Privacy Policy

 

 

 

 

In the following, we would like to inform you about the processing of personal data by AGORA direct™ - First Quant GmbH. In addition, we inform you about the use of cookies on our website on the Consent Management Platform ("CMP"). The CMP is displayed in the centre of the screen when you first access the website. You can also find and access the CMP at any time at the bottom of the website under "Cookies".

1 Responsible provider

The controller within the meaning of Art. 4 No. 7 of the European General Data Protection Regulation (GDPR) is

AGORA direct™ - First Quant GmbH
Schwäbische Str. 5
10781 Berlin
Phone: +49 30 789 59 75 0
Fax: +49 30 789 59 75 99
E-mail: datacontroller@agora-direct.de

You can reach our data protection officer using our contact details and by email at: datacontroller@agora-direct.de. We are committed to protecting the personal data we hold about you ("your data"). As your trusted partner, we collect, process and use your data in accordance with the content of this Privacy Notice and the applicable data protection regulations, in particular the GDPR and the German Federal Data Protection Act ("BDSG").

2 Scope of application and amendments

This privacy policy applies to all websites, applications, services or tools (hereinafter summarised as "services") provided by First Quant GmbH and its partners (hereinafter summarised as "AGORA direct™", or "we"), regardless of how they are accessed or used by you. Partners of AGORA direct™ are always kept up to date on our website under Imprint.

The constant development of laws and regulations makes it necessary to adapt and supplement the data protection declarations. Please therefore always refer to the website. We always endeavour to provide timely information via our website https://www.agora-direct.com and/or by e-mail and/or text message and/or, if applicable, via other information channels of the so-called social media channels, but naturally we cannot give any guarantee/warranty for this.

3 Personal data

3.1 What is personal data?

Personal data is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to identifiers such as account numbers, database identification numbers or to specific information which reveals his or her physical, physiological, mental, economic, cultural or social identity.

Anonymised or aggregated data that can no longer be used to identify an identifiable natural person is not considered personal data.

In order to be able to use our services, AGORA direct™ will collect personal data from you. When we refer to data below, we are referring to personal data.

3.2 Personal data that you provide when using our services or when commissioning a trading account

3.3 Personal data that we automatically collect when you use our services or commission a trading account

Any interested party can visit the AGORA direct™ website without providing personal data. Only for reasons of continuous system improvement and for statistical purposes are the IP address, the time of access, the data volume, the source page and the browser version recorded. In the event that this data can be used to draw conclusions about personal data, it is of course subject to the statutory data protection regulations, in this case the BDSG (Federal Data Protection Act) and the TMG (Telemedia Act).

3.4 Personal data that we collect with the help of cookies or similar technologies

AGORA direct™ may use text information files, also known as cookies, on its website. This serves to provide a more customised offer and service. These text information files are sent from an Internet server to the customer's user computer in order to identify this (computer) for the duration of the visit. For better transparency, computers can be set to inform about the placement of these so-called cookies. For more information on cookies, see also sections and .

3.5 Recording telephone calls

As a regulated securities institution, we are legally obliged to record telephone conversations with customers and store them in accordance with legal regulations for your protection. If you do not wish to be recorded, please use another communication channel.

3.6 Data and notifications from service providers with whom AGORA direct™ cooperates

We are an Introducing Broker, i.e. you instruct us to open a securities account with another service provider. The current contractual service providers are described in the GTCs. When you instruct us to open a custody account, we require your above-mentioned data to enable us to open a custody account with this service provider. Service providers with whom we work can send us notifications and information addressed to you in accordance with the postal authorisation you grant us, see also section

3.7 Personal data from other sources

4 Processing of personal data

4.1 How do we use your personal data?

AGORA direct™ continuously endeavours to ensure the strict confidentiality of personal data. All employees, any representatives or other vicarious agents, the shareholders of AGORA direct™, as well as all contractual and cooperation partners are obliged to maintain confidentiality in accordance with §5 BDSG.

AGORA direct™ respects and protects the personal data of customers and users of the AGORA direct™ website. Personal data is only collected and processed if the user/customer of the AGORA direct™ website provides it voluntarily. This data is then only used for the purpose for which it is intended when it is entered or AGORA direct™ can assume that it is intended for a specific purpose.

4.2 Use for the fulfilment of our contractual relationships

Data that is collected is used to provide the services offered by AGORA direct™ and is limited in type and scope. In the course of issuing a securities account opening order, AGORA direct™ is obliged by other legal regulations to collect and process personal data.

The processing of personal data can be any operation. This includes the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of data.

AGORA direct™ uses other service-providing contractual partners so that it can perform the services offered. However, these contractual partners shall only obtain knowledge of the customer data disclosed to AGORA direct™ insofar as this is also necessary for the performance of the services. The disclosure of customer data to third parties is prohibited by contract and in accordance with statutory provisions, as is the further use of the data outside the contractual relationship with AGORA direct™. Our contractual service providers are documented in accordance with the General Data Protection Regulation and can be made available on request.

4.3 Use for the pursuit of our legitimate interests

4.4 Controller for the processing of personal data

Responsible for the processing of personal data of its customers and website visitors ("you") within the meaning of the GDPR is: AGORA direct™ - First Quant GmbH Niederlassung, Schwäbische Str. 5, 10781 Berlin, Germany

We are committed to protecting the personal data that we have stored about you ("your data"). As your trusted partner, we collect, process and use your data in accordance with the content of this Privacy Notice and the applicable data protection regulations, in particular the GDPR and the German Federal Data Protection Act ("BDSG").

5 Your choices regarding the use of your personal data by us

5.1 Notification settings

Under "My AGORA" you can make various settings to determine how we can send you information, e.g. general information about your custody account, annual custody account statements, margin requirements, etc.

5.2 Advertising

If you do not wish to receive targeted advertising and do not wish to be tracked via social networks, please consult the manufacturer of your browser to find out how certain data protection settings work in your browser. Keywords here are e.g. cookie use and storage, browser tracking, anonymous mode.

5.3 Newsletter

Newsletters can be obtained for the continuous supply of information. For this purpose, the user/customer must provide an e-mail address, as well as their surname, first name and date of birth. The customer assures that this data is not false or third-party data. By entering this data, the customer consents to the sending of newsletters. AGORA direct™ is not obliged to send newsletters on a regular basis. AGORA direct™ is expressly permitted to contact the customer in writing, by telephone, email or SMS in order to provide information about products and services. Customers can request permission at any time in writing to datacontroller@agora-direct.com or by telephone on +49 30 789 59 75 0. In the case of subscriptions, the agreed cancellation periods apply. All data collected in this context will not be passed on to third parties under any circumstances and will otherwise be treated as described above. This data may be stored by AGORA direct™ and analysed for statistical purposes.

5.4 Login mechanisms

We use and store cookies to check the login and login duration. This cookie saves your session. At the end of your login, this cookie is deleted.

6 Information, control and correction of your personal data

Users/customers who enquire whether and, if so, which of their data has been stored and/or processed by AGORA direct™ can request information about this. In this case, the request must be made in as much detail as possible and, in the case of corresponding reservations, with corresponding evidence in writing exclusively to:

AGORA direct™ - First Quant GmbH
Data Protection Officer
P.O. Box 304235
10757 Berlin
Germany

to be addressed to the data controller. Requests for information about data by e-mail or fax can only be requested by post, in accordance with the written form with a personal signature, due to the lack of clear identification. AGORA direct™ can and will request further identification information if there is any doubt about the identity of the person making the request.

7 Disclosure of your personal data

7.1 Service partners and brokers/banks

We are an introducing broker, i.e. you instruct us to open a custody account with another service provider. We always provide up-to-date information about the current contractual service providers on our website. When you instruct us to open a custody account, we require your above-mentioned data to enable us to open a custody account with this service provider.

7.2 law enforcement authorities, to third parties in the context of legal proceedings or to legally authorised third parties

We may disclose data to the above-mentioned authorities or third parties in order to comply with statutory provisions and regulations, to enforce our terms and conditions and the terms and conditions of our service partners, and in defence of legal claims.

If legally authorised third parties involved in legal proceedings provide us with a legal order, a court order or an equivalent legal order, or if we assume in good faith that the disclosure of the data is necessary to avert imminent danger to life and limb or financial loss or to report a suspicion of an unlawful act, we may also disclose data.

7.3 Change of ownership

In the event of a merger, sale or other equivalent event, we may transfer information to that company in accordance with our Privacy Policy. If such an event occurs, we will require the new company to comply with this Privacy Policy.

8 Storage periods and storage locations

8.1 Retention periods

Data is stored in accordance with legal deadlines and regulations. Data that contains a potential for complaint will be retained for the period during which a complaint or legal action against us is possible, see also section .

8.2 Storage locations

Data is stored at our locations within the European Union. Account opening data may be transferred to our contractual partners in Switzerland, the United Kingdom and the USA and is naturally stored there, see also section .

9 Responsible for data protection

is responsible for the processing of personal data of its customers and website visitors ("you") within the meaning of the GDPR:

AGORA direct™ - First Quant GmbH
Markus Nowatzki
Schwäbische Str. 5
10781 Berlin
Germany

We are committed to protecting the personal data that we have stored about you ("your data"). As your trusted partner, we collect, process and use your data in accordance with the content of this Privacy Notice and the applicable data protection regulations, in particular the GDPR and the German Federal Data Protection Act ("BDSG").

10 Legal basis

In principle, we process your data on the basis of the following legal bases:

Art. 6 sentence 1 11 lit. a Consent to the processing of personal data for one or more specific purposes in accordance with GDPR. For the fulfilment of a contract to which you are a party or for the implementation of pre-contractual measures carried out at your request in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR. Art. 6 para. 1 sentence 1 lit. c GDPR for the fulfilment of our legal obligations to which we are subject. This includes, for example, compliance with retention periods and other legal obligations to provide evidence and documentation.

Art. 6 para. 1 sentence 1 lit. f GDPR serves to safeguard our legitimate interests or the legitimate interests of a third party, unless your interests or fundamental rights and freedoms, which require the protection of personal data, prevail. As part of your use of our website, we store information on your device or access such information if the requirements of Section 25 TTDSG are met.

11 Purposes of data processing

Your data is essentially processed for the following purposes:

So that we can fulfil our obligations arising from contracts concluded between you and us. In particular, this involves the brokerage of investment transactions and securities accounts, the execution of a securities account transfer and customer support. In addition, your data is processed to inform you about changes to our services and to ensure that our website is presented to you in the most effective and interesting way possible. This includes the personalisation of website content, web analysis and storage of cookies and similar technologies.

To provide services that you have requested, such as playing videos on our website. To display personalised advertising or, if requested, as part of email marketing. If you have consented to this, we use your data to optimise products and services as part of profiling, as well as to improve internal processes and display interest-based advertising. To fulfil our legal and regulatory obligations, e.g. to store customer orders, verify customer identity and prevent money laundering and terrorist financing.

12 Recipients of your data

In some cases, your data will be accessible to departments of the AGORA direct™ - First Quant GmbH group of companies that require your data to fulfil their contractual and legal obligations. Service providers and vicarious agents employed by us, such as technical service providers, freight forwarders and waste disposal companies, may also receive data for these purposes. In some cases, the recipient receives your data as a processor and is strictly bound by our instructions when handling your personal data. In some cases, the recipients act independently within the scope of their own data protection responsibility and are also obliged to comply with the requirements of the GDPR and other data protection regulations.

Finally, we will transfer your data to legal or tax advisors in individual cases.

These recipients are subject to special confidentiality and secrecy obligations due to their professional position. If it is necessary to clarify or prosecute a legal or abusive case, we will transfer your data to law enforcement authorities and, if necessary, to injured third parties in individual cases. However, this only happens if there are concrete indications of unlawful or abusive behaviour. We are also legally obliged to provide information to certain authorities on request. These are primarily law enforcement authorities, regulatory offence authorities and tax authorities. The disclosure of your data is limited to what is necessary in accordance with data protection regulations. The disclosure of your data will be limited to what is necessary in accordance with data protection regulations.

13 Non-European data processing

In some cases, contractual partners and external service providers based outside the European Economic Area ("EEA") are used to fulfil the purposes described in this data protection information or to provide services. In such cases, where the processing of data to such contractual partners is relevant, the data will only be transferred to the extent necessary if the place of processing guarantees an adequate level of data protection.

In doing so, we ensure that there is a corresponding decision by the European Commission for the respective data processing, or we conclude so-called standard contractual clauses with our business partners to ensure an appropriate level of data transfer and subsequent data protection. process. In the latter case, we also check whether contractual obligations must be guaranteed by additional safeguards. In exceptional cases, we will transfer your data outside the EEA subject to separate notification and your express consent. You can object to this transfer to a third country at any time.

14 Guidelines on storage duration and data deletion

Your data is generally stored for the duration of the contractual relationship. Irrespective of the contractual or subsequent relationship, we only store your data if this is required by law, if you have consented to the data processing or if the processing is necessary to protect our legitimate interests. We also have automatic deletion routines. This means that you do not have to actively take care of the deletion of your data. Your data is automatically deleted as soon as your contract with us ends and the statutory retention and storage period of 5, 6 or even 10 years has expired. Other data will be deleted if you withdraw your consent to processing or object to processing for important reasons arising from your particular situation.

15 Advice and conclusion of contracts for the brokerage of investment transactions and securities accounts

We process your data primarily to advise you on investment transactions and securities accounts. The legal basis for this is Art. 6 para. 1 sentence 1 lit. b GDPR. For our services, we are obliged to carry out legitimisation checks in accordance with Art. 6 para. 1 sentence 1 lit. c GDPR and the Money Laundering Act. Solutions from the providers Deutsche Post AG POSTIDENT BASIC or IDnow KYC platforms for video identification can be used for this purpose.

16 Commitment to provide

As soon as we conclude a contract to open a brokerage account, we are legally obliged as an intermediary to collect and check certain data about you. Other data should only be provided if it is necessary for the conclusion of the contract. If you do not provide this data, you will not be able to open a brokerage account. As a customer, you are only obliged to entrust us with your data in order to conclude a contract.

17 Contact us

Our website has contact forms for electronic contact. By clicking on the "Send message" button, your data in the input mask will be transmitted to us. We also store the date and time you contact us. You also have the option of using a callback service. Alternatively, you can contact us via the e-mail address provided datacontroller@agora-direct.de.

In this case, the data transmitted by e-mail and our reply will be stored. The data transmitted will be used to process your request and to contact you. The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. 1 lit. b or f GDPR. We use the data for the aforementioned purposes until the end of the respective conversation with you. If it can be inferred from the circumstances that the matter in question has been conclusively clarified, the conversation is ended.

18 Newsletter order

Our newsletter contains information and offers on various financial products from AGORA direct™ - First Quant GmbH and its partners in the financial services sector. To ensure that the correct e-mail address is entered, we use a so-called double opt-in procedure. As soon as you have entered your name and e-mail address in the registration field and clicked on "Subscribe to newsletter", we will send you a confirmation link. Your data will not be recorded in our system until you click on this confirmation link. If the registration is not confirmed within 48 hours, the data will be deleted.

Data processing is based on your consent in accordance with Art. 6 para. 1 sentence 1 GDPR. You can revoke your consent at any time with effect for the future. To do so, send an email to datacontroller@agora-direct.de or click on the "Unsubscribe" button at the end of each newsletter.

After expiry, the data will be deleted from the corresponding system in accordance with section 8.1. In addition to sending newsletters, we also collect information about the opening and clicking behaviour of recipients. We link your e-mail address with the ID of the opening link for evaluation purposes.

We record when you read our newsletter and which links you click on. This enables us to better understand your interests and improve our products and services. The registration of opening and click actions is based on the legitimate interest in accordance with point 2 Art. 6 para. 1 sentence 1 lit. f GDPR. You can object to the processing at any time, stating reasons arising from your particular situation. We will examine your specific case thoroughly. If your objection is successful, your data will be deleted from the relevant systems in accordance with section 8.1. We have commissioned a European service provider to handle the sending of our newsletter and to evaluate the opening and clicking behaviour of our newsletter.

19 Data processing for advertising purposes

The following declaration relates to the processing of personal data for advertising purposes. The GDPR declares such data processing as a fundamentally possible legitimate interest in accordance with Art. 6 para. 1 f). The retention period for data for advertising purposes depends on whether storage is necessary for advertising purposes.

If you conclude a contract with us, we will treat you as an existing customer. In this case, we will process your postal contact details without your separate consent in order to send you information about new products and services. We will only use your e-mail address for advertising purposes with your consent. If you provide us with your telephone number, we will only use it with your prior consent. In this case, you will receive information from us about various financial instruments of AGORA direct™ - First Quant GmbH and its business partners.

You can object to the use of your address for postal advertising at any time in writing or by e-mail to datacontroller@agora-direct.de. You can revoke your consent to advertising measures at any time with effect for the future. This can be done in the case of electronic advertising by e-mail to datacontroller@agora-direct.de or in the case of sending advertising directly to the contact person by telephone.

20 Utilisation profile

With your consent, we create a profile about you. To do this, we use various data from different sources and merge them. Firstly, this is the data that you provide when you open the custody account. For example, contact details and securities account numbers are taken into account. Data resulting from your surfing behaviour on our website or the websites of our business partners is also relevant. This is primarily information about the content you visit and your interests. We also use information about your use of Smartbroker, such as transaction data that has occurred.

Information is analysed and weighted according to your interests. The evaluation results help us to understand your interests in our products and services. This enables us to continuously improve our products and services for our customers. In addition, we use the data to optimise our internal processes. Finally, we can address your concerns after the evaluation so that we can offer you the right products and services. However, the advertising itself will take place unless you object to the advertising material or revoke your consent to advertising.

The creation of profiles is intended solely for the purposes described above and has no legal effect or similar prejudice. We have commissioned a European service provider to consolidate and analyse the data. You can revoke your consent at any time by sending a message to datacontroller@agora-direct.de. The data collected during the creation of your profile will be deleted after completion, but at the latest after you withdraw your consent.

21 Our contact details and your rights

You have extensive rights with regard to the processing of your personal data. Firstly, you have extensive rights of access and can request the rectification and/or erasure of your data if necessary, see also section 8.1. You can also request the restriction of processing. You also have the right to object and the right to data portability. If you would like to exercise your rights or require further information about your rights, please contact datacontroller@agora-direct.de.

If our processing of your data is based on your consent, you have the right to withdraw your consent at any time by notifying us.

The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. A simple notification to datacontroller@agora-direct.com is sufficient to declare the revocation.

You also have the right to lodge a complaint with a supervisory authority. However, you can send questions, suggestions, criticism or enquiries regarding the collection, processing and use of your personal data by AGORA direct™ - First Quant GmbH directly to datacontroller@agora-direct.de or in writing at any time.

AGORA direct™ - First Quant GmbH
Berlin branch
Schwäbische Str. 5
10781 Berlin

If you have any questions about the processing of your personal data or about exercising your rights under the GDPR, please contact our data protection officer. You can reach him confidentially at datacontroller@agora-direct.de.

22 Consent management platform (CMP) and web-specific data processing

22.1 Consent Management Platform (CMP)

The CMP contains certain information about our use of cookies. This information shows you from which provider, for what purpose and what type of cookies are stored on your end device. If you give us your consent, your consent extends on the one hand to the permission to store and access the declared information on your end device, and on the other hand to the use of collected data, provided that a personal reference is given. This consent can be revoked at any time with effect for the future.

By confirming a button, you can also decide which cookies or other information should be stored on your end device or, if already stored, which cookies or other information the end device can access. You can also object to the storage or retrieval of information on your end device and revoke any consent you have already given. Certain processes identified in the CMP do not require your consent.

As a provider of telemedia services, this includes the storage or retrieval of information already stored, insofar as this is absolutely necessary so that we can provide you with the telemedia services you have expressly requested.

22.2 Processing of server log files

Each time you visit our website, we collect the following information about your end device: IP address of the end device, the browser request and the time of this request. In addition, the status and the amount of data transferred are recorded as part of this request. We also collect product and version information about the browsers and device operating systems used. We also record from which other website our website is accessed. The IP address of your device is only recorded while you are using the website and is deleted or shortened and anonymised immediately afterwards. This data is used for the operation of the website, in particular to recognise and eliminate website errors and to determine how the website is used as well as to make adjustments or improvements.

The legal basis for data collection is Art. 6 para. 1 sentence 1 lit. f GDPR and § 25 para. 1 sentence 1 lit. f GDPR. 2 No.2 TTDSG. The data will be deleted as soon as the purpose of the processing has been fulfilled, see section 8.1.

22.3 Use of browser cookies

So-called browser cookies may also be used to collect information about your use of our website. These are text files that are stored on your end device and that log certain settings and information for exchange between your browser and our systems. A cookie usually contains at least the name of the domain from which that cookie originates, information about how long the cookie is valid and an alphanumeric identifier, also known as a "cookie ID".

A cookie ID is never combined with your name, IP address or similar data that would allow a cookie to be directly assigned to you. The cookies themselves are stored by activating scripts embedded in websites. This script requests the cookie server to send a cookie to the user's device. The cookie ID enables us to recognise that the user has already visited the website.

This recognition enables us to provide you with preferences, speed up the processing of requests for website content, track user interest in specific website content and track user activity on your website. This allows us to optimise your browsing experience on our website. In addition, the content of the website can be better customised to the user's needs. For more information on the individual cookies used on our website, please refer to the Consent Management Platform (CMP)

22.4 User behaviour analysis and personalised advertising on the web

AGORA direct™ - First Quant GmbH works together with several business partners who support us in providing the Internet and making our website more interesting for you. With your consent, cookies from these partners are also stored on your device. The resulting cookie ID enables partner companies to target you with interest-based advertising. These cookies have different lifetimes, which are determined by our partners and are automatically deleted after a certain period of time. You can find a list of partners and their cookies at CMP. There you can consent to the use of individual or all cookies and revoke them accordingly.

22.5 Integration of social networks

Social media providers are integrated on our website (Facebook, Twitter, Instagram, YouTube, LinkedIn, etc.). These are only integrated on our website as a link to the corresponding service. By clicking on the embedded graphic, you will be redirected to the website of the respective provider. This means that only then will personal data be transmitted to the respective provider. Further information on the collection and use of personal data when using these websites can be found in the respective data protection provisions of the providers.

22.6 Integration of videos

In the case of videos that are integrated into our website via interfaces of our third-party providers, the technical implementation is carried out in such a way that no personal usage data, such as your IP address, is transmitted to the respective provider of the website.

22.7 Integration of YouTube

YouTube videos are integrated on our website. These videos are stored on http://www.youtube.com and can be played directly from our website. The provider is YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066 (USA). All these videos are integrated in "extended data protection mode". This means that if a user does not play the video, no data about the user is transmitted to YouTube. Only when you play the video will the "personal data" under paragraph 2 be stored. This data transfer takes place without our influence. When you visit the website, YouTube receives the information that you have accessed the corresponding subpage of the website. Your data will be transmitted regardless of whether YouTube provides a user account that you can use to log in or whether no user account exists.

If you are logged in to Google, your data will be assigned directly to your account. If you do not wish your data to be associated with your YouTube profile, you must log out before activating the button. YouTube stores your data as usage profiles and uses them for the purposes of advertising, market research and/or customising its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide customised advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube directly to exercise this right. Further details on the purpose and scope of data collection and its processing by YouTube can be found in the privacy policy. There you will also find detailed information on your rights in this regard and setting options to protect your privacy. See https: //www.google.de/intl/de/policies/privacy.

22.8 Integration of Google Maps

This website uses Google Maps. This means that an interactive map is displayed directly on the website and you can use the map function conveniently. The provider is Google LLC, 600 Amphitheatre Parkway, Mountain View, CA 94043 (USA). By visiting the website, Google receives the information that you have accessed the corresponding subpage of our website. In addition, the data mentioned in paragraph 2 of this privacy policy will be transmitted. This takes place regardless of whether Google provides a user account for the login or whether no user account exists.

If you are logged in to Google, your data will be assigned directly to your account. If you do not wish your data to be associated with your Google profile, you must log out before activating the button. Google stores your data as usage profiles and uses them for the purposes of advertising, market research and/or customising its website. Such an analysis is carried out in particular (even for users who are not logged in) to provide customised advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right. Google is EU-U.S. Privacy Shield certified. Registration is possible at: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

22.9 Google Analytics

This website uses Google Analytics, a web analysis service. With your consent, we use Google Analytics, a web analysis service of Google Inc ("Google"), for the purpose of designing and continuously optimising our website to meet your needs. In this context, pseudonymised user profiles are created and cookies are used. Information generated by cookies about your use of this website may include the following:

the operating system used, time of the server request, browser type/version, referrer URL (the previously visited page), host name of the accessing computer (IP address). This information is transmitted to a Google server based in the USA and stored there.

This information is used for the purpose of analysing website usage, compiling reports on website activity, market research and tailoring these websites to meet requirements and other purposes relating to website activity and internet usage in order to provide our services. This information may be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. IP masking is in place, which means that IP addresses are anonymised and cannot be assigned.

22.10 Representation of voting seals

We have included corresponding graphics on this website to display voting seals and any collected and/or aggregated ratings. This serves to safeguard our legitimate interests, which predominate in the context of a balancing of interests, in the optimal marketing of our offer in accordance with Art. 6 Para. 1, S. 1 lit. f GDPR. The sources of the integrated graphics are specified below. When the voting seal is called up as an integrated graphic, the web server automatically saves a so-called server log file with the provider of the seal, which contains, for example, your IP address, the date and time of the call, the amount of data transferred and the source of the call (access data) and documents the call.

The corresponding data protection agreement of the provider of these voting seals can be found below:

22.11 Facebook Pixel

We use a basic version of the Facebook conversion pixel on our website to display personalised advertising from us and third parties on the Facebook and Instagram platforms and to determine the effectiveness of this advertising for statistical and market research purposes. Facebook and Instagram belong to Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland ("Facebook") For this purpose, we transmit information about user activities on our website (e.g. pages viewed and buttons clicked) and certain other personal data (e.g. pixel ID and IP address) to Facebook via the pixel. and other cookies).

If you are registered with a Facebook service and logged in, Facebook can assign this data to your account. This means that you will be shown adverts tailored to you when you visit Facebook, Instagram or other websites that use this function. The Facebook conversion pixel also enables a statistical analysis of the effectiveness of Facebook adverts. This was reported to us anonymously by Facebook. Even if you are not logged in to one of the Facebook services, Facebook can process your IP address and other identifiers and link them to other data.

The legal basis for the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR or § 25 para. 1 TTDSG. You can revoke or change your consent at any time in your cookie settings. Facebook processes your data on servers in the USA. Data transfers to the United States are not protected by further data protection guarantees beyond your consent. Please note that the USA does not have the same level of data protection as the EU and that government authorities may have access to your data. Facebook users can deactivate the "Facebook Custom Audiences" function at www.facebook.com/settings/. Further information on data processing by Facebook can be found in Facebook's privacy policy.

22.12 Affiliate Marketing

Our website uses affiliate tracking cookies to record sales/leads. These cookies do not store any personal data. Only information to identify the referral partner and the serial number of the advertising material clicked on by the website visitor is recorded. This information is required for payment processing between us and our referral partners. Once a transaction has been completed, the partner ID is used to allocate and determine the commission paid to the referring partner. The legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.

22.13 Use of financeAds

We participate in the affiliate programme of financeAds GmbH & Co KG, Karlstraße 9, 90403 Nuremberg, Germany (hereinafter "FinanceAds"). FinanceAds is a German affiliate network that offers affiliate marketing. Affiliate marketing is an internet-supported form of distribution that enables commercial operators of websites to display adverts, which are usually remunerated via click or sale commissions, on third-party websites. An advertising medium is made available via the affiliate network, e.g. advertising banners or other suitable means of internet advertising, which are subsequently integrated by an affiliate on their own website.

As part of the partner programme, the provider financeAds uses so-called tracking cookies to correctly record leads and sales in the customer's browser (user of the partner's website). These cookies are only used to allocate transactions to FinanceAds partners. If the information also contains personal data, the processing described is carried out on the basis of our legitimate financial interest in the processing of commission payments with FinanceAds in accordance with Art. 6 para. 1 lit. f GDPR. Further information on the use of data by FinanceAds can be found in the FinanceAds privacy policy. If you wish to block the analysis of user behaviour via cookies, you can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general.

23 Data security

We use technical and organisational measures to secure our website and other systems against loss, destruction, access, modification or dissemination of your data by unauthorised persons. We use the Secure Socket Layer (SSL) method at the highest level of communication. This is typically 256-bit encryption.

If your browser does not support 256-bit encryption, please use 128-bit v3 technology instead. You can see from the status bar of your browser whether individual pages of our website guarantee correspondingly encrypted communication. It has a lock symbol and our website URL begins with https://. This allows you to send SSL-encrypted messages via the contact form.

24 Use of Lexis Nexis

AGORA direct™ works together with the provider LexisNexis GmbH, Heerdter Sandberg 30, 40549 Düsseldorf, Germany for the identity verification and authentication of its customers. You can find more information on the data protection provisions and which of your data is used by the provider and how at: https://www.lexisnexis.com/global/privacy/de/privacy-policy.page

25 Further important information on data protection

25.1 Unsolicited and threatening emails

We do not tolerate any misuse of our services.

Unless expressly authorised, we do not tolerate any commercial use of our services. AGORA direct™ does not send spam. Please report any spam or fraudulent e-mail or SMS messages in connection with AGORA direct™ and forward them to datacontroller@agora-direct.de.

25.2 Communication tools

We may automatically scan messages sent through our messaging tools to check for spam, viruses, phishing content or other malicious activity, illegal or prohibited content, or violations of our Terms and Conditions, this Privacy Policy or our other policies.

25.3 Children's privacy

Our websites are intended for the general public and not for children. We do not knowingly collect personal data from users who are considered children under national legislation.

25.4 Data protection rules of third parties

This Privacy Policy only applies to the use and disclosure of personal data that we collect from you in connection with the provision of our services. If you disclose your data to third parties or if you are redirected to the website of a third party, their privacy policy applies to all personal data that you provide to this third party or that they collect from you.

26 Complaint to the competent data protection authority

You have the right to lodge a complaint with the competent data protection authority:

Berlin Commissioner for Data Protection and Freedom of Information
Friedrichstr. 219
10969 Berlin

27 Amendment of this privacy policy

Our further development may also affect the processing of personal data. We therefore reserve the right to amend this data protection notice in the future within the framework of the applicable data protection laws. We will inform you separately of any significant changes to the content. We will also inform you separately if your personal data is processed for purposes other than those for which it was collected.

(Status: 09/02/2024)

 

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