Privacy Policy Scalable Capital

1. Data Controller

The Data Controller within the meaning of the General Data Protection Regulation ("GDPR") is Scalable Capital GmbH, Seitzstraße 8e, 80538 Munich, Germany (hereinafter "Scalable Capital" or "we"). In the following, we would like to inform you about the collection and processing of your personal data in connection with your use of our website as well as our web application and our mobile app (hereinafter the last two collectively referred to as "app") within the scope of our duty to inform you in accordance with Art. 13 GDPR.

Further information on Scalable Capital can be found in the imprint.

2. Processing of your personal data when accessing our website and apps

2.1. General information

In general, you decide which personal data you provide to us. Within the scope of the business relationship, you are required to provide the personal data that is necessary for the initiation, implementation and termination of a business relationship and which we are legally obliged to collect and process, e.g. in accordance with anti-money laundering regulations. Without this data, we are not able to provide you with our services or functions.
Insofar as service providers process personal data on our behalf, we have concluded a data processing agreement with these service providers and agreed on appropriate guarantees to ensure the protection of personal data. We carefully select our service providers. Service providers may comprise third parties or entities affiliated with Scalable Capital within the group. In addition, these service providers process personal data exclusively for the performance of their tasks and are contractually bound to our instructions, have appropriate technical and organisational measures in place to protect personal data and are regularly audited by us. Where relevant, appropriate EU standard contractual clauses have been concluded for the transfer of personal data to processors in third countries (as an appropriate guarantee for data processing in non-European countries). You can view the EU standard contractual clauses used via the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0914.
The transfer of personal data to certain third countries, such as Switzerland, is based on an adequacy decision. According to the EU Commission, such countries have an "adequate level of protection" and a data transfer does not require any special authorisation. An overview of the countries with an adequacy decision can be found here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

2.2 Hosting

For hosting the database and web content, we use Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg, Luxembourg ("AWS"), a subsidiary of Amazon Web Services, Inc., P.O. Box 81226, Seattle, WA 98108-1226, USA, as an order processor. The data is stored exclusively in a German data centre (Frankfurt/Main), which is certified according to ISO 27001, 27017 and 2018 as well as PCI DSS Level 1 and accordingly meets the highest security standards. In addition, we have agreed on corresponding EU standard contractual clauses with Amazon Web Services, Inc. You can view the EU standard contractual clauses used via the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0914. In conjunction with additional technical and organisational measures to ensure an adequate level of protection, it is guaranteed that the EU data protection requirements can also be met when processing data in the USA.

2.3. Informational use of our website

When you visit our website, we process access data that is stored in so-called log files. The following personal data is processed automatically in the log files:

• IP address of the requesting device
• Type of web browser used
• Language of the web browser used
• Version of the web browser used
• Operating system and its version
• Date and time of the visit
• Time zone difference from Greenwich Mean Time (GMT)
• Access status/ http status code
• Amount of data transferred
• Web page visited
• Referrer
• Web pages that are called up by the visitor's system via our website
• Internet service provider of the user

The processing of this data is carried out in accordance with Art. 6 (1) (f) GDPR due to our legitimate interest in being able to properly display the website to you as well as to defend against attacks and for the purpose of the security of our systems. The log files are deleted or anonymised immediately after they are no longer required to achieve the aforementioned purposes, but at the latest after 14 days.
We use AWS as a processor for hosting the website.

2.4. Comfort settings (e.g. language settings)

In order to be able to display content such as your country and language settings as desired, we use session-based or persistent cookies. Your country settings are deleted as soon as your browser session ends, your language settings are stored for a maximum of one year. The legal basis for the processing of these cookies is §25 (2) Telecommunications and Telemedia Data Protection Act (TTDSG) so that we can provide the telemedia service expressly requested by the user. The legal basis for the further processing of this technically necessary personal data is Article 6 (1) (f) GDPR.

2.5. Performance Monitoring

We use DataDog, Inc. 620 8th Avenue, 45th Floor New York, NY 10018, USA ("DataDog") as a data processor to collect information about the performance of our website and any technical malfunctions that may occur. For this purpose, DataDog sets up a cookie for the browser session and collects geolocation, device, and operating system data of the user of our website and apps. We process the aforementioned data in accordance with § 25 para. 2 TDDDG in conjunction with Art. 6 (1) (f) GDPR in order to ensure the security of our platform for the provision of our services and to minimise a possible risk of damage. Your personal data will be deleted after 15 days. For analysis purposes, we collect and process additional usage data on the basis of your consent in accordance with Section 25 (1) TDDDG in conjunction with Art. 6 (1) (a) GDPR which you have given us in the course of your visit to our website or apps.
Corresponding EU standard contractual clauses were concluded in accordance with Commission Implementing Decision (EU) 2021/914 of 4 June 2021 as an appropriate guarantee for data processing in non-European countries. You can view this implementing decision (EU) 2021/914, including the EU standard contractual clauses used, via the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0914.

2.6. Cybersecurity Incident Monitoring

We use DataDog as a processor to collect information for the purpose of detecting cybersecurity incidents, or any cybersecurity malfunctions that may occur and respond to the said incident. For this purpose, we process login data incl. email address, IP address, device information, geolocation data derived from IP address of the user when accessing our apps. We process the above data on the basis of our legitimate interest to ensure and maintain IT security in accordance with Art. 6 (1) (f) in conjunction with Art. 32 GDPR. Your data will be deleted after 15 days unless it is required for forensic analysis and investigations.

3. Use of our services

3.1. Registration/ Creation of customer profile

In order to use our services (wealth management, brokerage), you must first register and create a user account ("registration"). For this purpose, we collect your private contact and identification data (e.g. title, first and last name, address, e-mail address, telephone number, date, place and country of birth as well as nationality), certain tax data (e.g. tax number, tax residency) as well as your reference account (e.g. IBAN). As part of the registration process, you will also set a password for your personal access. In addition, depending on the services you use, we may collect information about your knowledge and experience of dealing in certain types of financial instruments or investment services, your investment objectives, including your risk tolerance, and your financial circumstances, including your ability to bear losses. We process this data in order to be able to recommend a suitable investment strategy to you or to assess the appropriateness of certain financial instruments (Art. 6 (1) (b) GDPR).
Please note that in order to use our services it is necessary to open a custody account with a custodian bank cooperating with us.
At present, we cooperate with Baader Bank Aktiengesellschaft, Weihenstephaner Str. 4, 85716 Unterschleißheim, Germany ("Baader Bank") and ING-DiBa AG, Theodor-Heuss-Allee 2, 60486 Frankfurt am Main, Germany ("ING"). The custodian banks process your data under their own responsibility. Information on how the custodian banks process your data can be found following https://www.baaderbank.de/Data+Protection+Declaration-436 for Baader Bank and https://www.ing.de/datenschutz/ for ING.
To enable you to use our services securely and to facilitate a secure log-in, we rely on Auth0 Inc, 10800 NE 8th Street, Ste. 600, Bellevue, WA, 98004, USA ("Auth0") as a processor. For this purpose, Auth0 processes your user name or e-mail address and password together with your IP address, geolocation data derived from IP address, and device information in accordance with Art. 6 (1) (b) GDPR. Your data is encrypted at all times and processed exclusively within the European Union. In individual cases, however, a transient processing of data in the USA cannot be ruled out.
To further protect the access to your account from criminal activities and access by third parties, we implement various measures. In the course of the login process, we analyse the IP address, the location of the requesting device as well as metadata of the access (e.g. date and time of the request, information about the device, action executed, etc.). In addition, we use the functions of Auth0 to monitor at regular intervals whether your login credentials have been part of published third-party security breaches. We immediately notify you in case of any suspicion or in case your access data was part of such a security breach to assist you in changing your login credentials. The aforementioned purposes constitute our legitimate interest in processing the data on the basis of Art. 6 (1) lit. f GDPR.
Auth0 does not have access to any other personal data at any time. We have concluded the EU standard contractual clauses as appropriate safeguarding measures. You can view the EU standard contractual clauses used via the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0914.
As part of the use of our digital offer, we use Futurae Technologies AG, Eichstrasse 23, 8045 Zurich, Switzerland ("Futurae") as a processor for the two-factor authentication. For the activation of the two-factor authentication on the mobile device, data (e.g. IP address, device/browser information) is processed by Futurae. The transfer of the aforementioned data to Switzerland is based on the adequacy decision of the European Commission according to Art. 45 GDPR. You can find further information here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32000D0518
After your cancellation, you can still log in to your personal area and retrieve documents in your mailbox. You will continue to receive important documents there, such as your annual tax certificate. Your account will be deactivated no later than two years after the end of your contract. If required, access to your personal area can also be deactivated immediately after the end of the contract. To do so, please contact us using the contact options mentioned below under “Points of contact”.

3.2. Identification

For the purpose of identification, we process the private contact and identification data provided by you (e.g. your name, nationality, date and place of birth, address, email address, telephone number). Pursuant to the German Anti-Money Laundering Law, we are legally obliged to verify your identity by means of a valid identification document as part of the account opening process, to store the required information and a copy of the identification document as well as a visual and acoustic recording of the identification process carried out with us. The legal basis for the data processing is Art. 6 (1) (b) GDPR in connection with Art. 6 (1) (c) GDPR (contractual and legal obligation) in conjunction with the German Anti-Money Laundering Law.
For the purpose of identification, we use Deutsche Post AG ("Deutsche Post"), Charles-de-Gaulle-Straße 20 in 53113 Bonn, Germany, as data processor. For this purpose, we use the POSTIDENT process which, in addition to identification by means of the online ID function ("eID"), also enables identification by video chat or at a post office branch. After completion of the process, Deutsche Post AG transmits to us your identification data, a copy of the identification document and a visual and acoustic recording of the identification process that has taken place, which are processed exclusively for the purpose of fulfilling the statutory obligations under German Anti-Money Laundering Law. Further information on the data processing within the POSTIDENT process by Deutsche Post AG can be found here: https://www.deutschepost.de/de/p/postident/postident-datenschutzhinweise.html
We reserve the right to transfer your personal contact and identification data (such as your first and last name, address and date of birth) to our data processor Fourthline B.V., Tesselschadestraat 12, 1054 ET, Amsterdam, The Netherlands (“Fourthline”) for the purpose of checking against sanctions lists and whether our customers are so-called politically exposed persons (“PEP”) at regular intervals. We process this data for the purpose of complying with legal and regulatory obligations.
For Brokerage clients residing in Spain, Italy, The Netherlands and France, the identification process is usually carried out by Fourthline. In order to comply with regulatory requirements, it is necessary to accept Fourthline's Terms and Conditions, which do not impose any obligations on you as a customer other than verifying your identity. Once you have gone through the identification process, Fourthline will send the results to us. We process this data for the purpose of complying with legal and regulatory obligations. For Fourthline privacy notices, please visit https://fourthline.com/privacy-statement.
If you opt for identification via video chat ("video identification"), the provider is obliged to ensure the authenticity of your identification document (e.g. ID card or passport). At the beginning of the video identification, your explicit consent is obtained in accordance with Art. 6 (1) (a) GDPR to take the photos and record the conversation. You can object to this processing at any time by cancelling the video identification process and choosing an alternative method of identification.
We process this above-mentioned data for as long as is necessary for the aforementioned purpose and generally delete it immediately after the legal basis ceases to apply. According to §§ 8, 10 GwG we are obliged to keep your private identification and contact data as well as the results of the check against PEP and sanctions lists for at least five years.

3.3. Securities trading

In order to be able to provide our services and in particular to enable the transmission of trading orders to the custodian banks and securities trading to the custodian banks, we process the personal data mentioned in section 3 Use of our Services. This includes, in particular, the transmission of orders (together with the corresponding personal data) to the custodian bank. The legal basis of the processing is Art. 6 (1) (b) GDPR (fulfilment of contractual obligations). The data is processed in our hosting databases provided by AWS.

3.4. Credit brokerage (“Credit”)

For brokerage clients with residence in Germany, Scalable Capital offers the possibility of brokering granted overdraft facilities on the clearing accounts maintained by the custodian bank, Baader Bank. For this purpose, we transmit your client reference number stored at the custodian bank, your first and last name, your clearing account number and your email address to Baader Bank. The result of the credit request is then transmitted to us by Baader Bank and made available to you in your personal customer area. The legal basis for the processing of the aforementioned data is the fulfilment of contractual obligations pursuant to Art. 6 (1) (b) GDPR.
Please note that Baader Bank processes your data under its own authority and, if necessary, transmits it to external recipients for the purpose of checking your creditworthiness. You can find further information on the processing of your data by Baader Bank under https://www.baaderbank.de/Data+Protection+Declaration-436.

3.5. Tax information for brokerage clients outside Germany

For brokerage clients residing outside of Germany the overview of the taxes to be paid is prepared by KPMG AG, Badenerstrasse 172, CH-8036 Zurich, Switzerland ("KPMG"). For this purpose, we forward your internal user-ID and financial transaction data (e.g. portfolio ID, security number, type of order, time of execution) to KPMG. The legal basis for processing the aforementioned data is Art. 6 (1) (b) GDPR (fulfilment of contractual obligations). The transfer of the aforementioned data to Switzerland is based on the adequacy decision of the European Commission pursuant to Art. 45 GDPR. You can find further information here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32000D0518
Please note that KPMG processes your data under its own responsibility. For more information, please see KPMG's privacy notice at: https://home.kpmg/ch/de/home/misc/privacy.html.

3.6. Risk management and fraud prevention, detection and investigation

We process the personal data collected when initiating the contract or during the contractual relationship, for the purposes of fraud and money laundering prevention as well as for risk management purposes in order to identify and assess the financial risks arising for the institution and to counteract them appropriately. In the event of suspicious cases, we may collect further information from publicly available sources and take this into consideration in the decision-making process for blocking/unblocking suspicious transactions. The processing is carried out on the basis of our legitimate interest in averting damage to Scalable Capital pursuant to Art. 6 (1) (f) GDPR in conjunction with the relevant legal obligation pursuant to Art. 6 (1) (c) GDPR. At the same time, these measures also serve to protect clients from possible unauthorised dispositions by third parties.
To process and coordinate cases of suspicion, we are using a ticketing system provided by Atlassian. Pty Ltd, Level 6, 341 George Street, Sydney NSW 2000, Australia ("Atlassian") as a data processor. We have entered into a processing agreement with Atlassian. In addition, we have concluded appropriate EU standard contractual clauses with Atlassian based in Australia. You can view the EU standard contractual clauses used via the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0914.

3.7. Creation of statistics and analyses

We process personal data that we collect as part of the contract initiation or contractual relationship with you, as well as usage data of our products and services, as part of our legitimate interest according to Art. 6 (1) (f) GDPR, to provide you with personal analyses, evaluations and statistics (e.g. year-end recap) and for the purpose of analysing our current client base. We also process this data to create anonymous statistical data sets. This processing is based on our legitimate interest pursuant to Art. 6 (1) (f) GDPR to prepare forecasts and reports and to evaluate and optimise the performance of the company and product quality. These anonymised data sets are not personal data.

3.8 Communication in connection with the use of our products and services

To inform you about the processes related to your use of our products and services, we use emails, SMS, letters and push notifications as well as other communication channels within our apps as part of the fulfilment of our contractual obligations pursuant to Art. 6 (1) (b) GDPR. We use the following data processors for this purpose. Salesforce.com Germany GmbH, Erika-Mann-Str. 31-37, 80636 Munich, Germany ("Salesforce") for sending emails and push notifications, Sipgate GmbH, Gladbacher Straße 74, 40219 Düsseldorf, Germany ("Sipgate") for sending text messages and Deutsche Post AG, Charles-de-Gaulle-Straße 20, 53113 Bonn, Germany ("Deutsche Post") and Deutsche Post E-POST Solutions GmbH, Vorgebirgsstraße 49, 53119 Bonn, Germany ("Deutsche Post E-POST Solutions") for sending letters.

3.9. Retention obligations/ disclosure to third parties

We store and process your personal data for the duration of the contractual relationship with you. We delete your data after completion and settlement of the legal relationship with you, at the earliest, however, after expiry of the statutory, regulatory and/or other sovereign retention periods and insofar as the data is no longer required for the assertion, exercise and/or defence of legal claims.
As a regulated company, we are subject to various statutory recording and storage obligations, which stem primarily from the German Banking Act (KWG), the German Securities Trading Act (WpHG), the German Anti-Money Laundering Law (GwG), the German Commercial Code (HGB) and the German Fiscal Code (AO). These statutory obligations to retain data and records require us to store information for at least two years and up to ten years, depending on the regulation. These obligations also apply to processes that enable the initiation of a contractual relationship or the conclusion of a contract. The legal basis for the storage of personal data for these purposes is Art. 6 (1) (c) GDPR (legal obligations).
In addition, the retention periods under civil law are also relevant to determine the duration of the data storage. These limitation periods can be up to 30 years according to the regulations in the German Civil Code (BGB), however, the regular limitation period is three years.
Furthermore, we may be required to disclose personal data processed in connection with the provision of our services to public authorities and institutions such as the German Federal Bank (Deutsche Bundesbank), the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht - BaFin), European banking supervisory authorities, the European Central Bank (ECB) and financial authorities.

4. Data processing in the context of wealth management "Oskar”

Oskar is a brand of Oskar.de GmbH, Gartenstraße 67, 76135 Karlsruhe, Germany ("Oskar"), under which it operates the websites and apps on its own responsibility. Scalable Capital manages your assets, while Baader Bank AG manages the custody accounts with the clearing accounts.
As part of the registration process, Oskar collects your private contact and identification data (e.g. title, first and last name, address, email address, telephone number, date, place and country of birth and nationality), your tax data (e.g. tax number, tax residency), the account number of your reference account (e.g. IBAN), your details of your financial circumstances and, if necessary, private contact and identification data of third parties such as children or grandchildren of the Deposit Account Holder (e.g. birth certificates of minors), details of your financial circumstances and, if necessary, private contact and identification data of third parties such as children or grandchildren of the securities account holder (e.g. birth certificates of minors, certificates of guardianship) and forwards these to us. We process your data for the purpose of fulfilling the contract pursuant to Art. 6 (1) (b) GDPR in order to offer you our service and to fulfil our legal obligations pursuant to Art. 6 (1) (c) GDPR.
For written communication we use the service address service@oskar.de. This email address is made available to us by Oskar.de GmbH.
Please note that Oskar operates its websites and apps under its own responsibility and that we are not responsible for them. Information on Oskar's data protection policy can be found at https://www.oskar.de/datenschutz.

5. Data processing in the context of wealth management "Gerd Kommer Capital”

Gerd Kommer Capital ("GKC") is a brand under which Scalable Capital offers financial portfolio management. Scalable Capital is advised by Gerd Kommer Invest GmbH, Sendlinger Straße 41, 80331 Munich ("Gerd Kommer Invest GmbH") in the management of the portfolios. The custodian bank is Baader Bank AG. In the context of asset management GKC, we share data with Gerd Kommer Invest GmbH and Baader Bank AG. For further information on the processing of your personal data in the context of the provision of the service, please refer to section 3 Use of our Services in this document.
As part of the conclusion of the contract, you can consent to receiving the newsletter by Gerd Kommer (Art. 6 (1) (a) GDPR). In the course of your consent, we transmit the email address to Gerd Kommer Invest GmbH.
The website https://www.app.gerd-kommer-capital.de used for registration and login at GKC is technically provided by us. Within the scope of this website, we use marketing and statistics cookies. You have the possibility to individually consent to the use of cookies by means of the Consent Management Tool. If you give your consent, this data will also be transmitted to Gerd Kommer Invest GmbH, among others. On the website we use services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). For more information, please refer to section 9 Use of cookies, tracking tools and third-party services on our websites in this document. The data processing is based on your consent (Art. 6 (1) (a) GDPR).
We use the service email address service@gerd-kommer-capital.de for written communication. This email address is made available to us by Gerd Kommer Invest GmbH.

6. Customer service and support

6.1. General Information about the processing of Client Service requests

You can contact us via our service hotline, the contact form, the chat as well as by email and send us a request. In this context, we process the information and data you provide (including personal data such as first name, last name, email address and telephone number) and, if applicable, the time and duration of your call in a ticket in order to contact you and process your request (Art. 6 (1) (b) GDPR). When using the chat, the chat log, your usage data (e.g. start and end time of request, duration of interaction, IP address), device identification data (e.g. type of operating system, device model) as well as event data are stored and, if applicable, assigned to your account. In order to efficiently respond to your requests and to ensure a high level of service, user input may be viewed by our staff during the current request ("session") in the context of the live chat. We delete your data as soon as we have answered your inquiry to your satisfaction, provided that no other retention periods (e.g. tax retention periods) are opposed.

6.2. Information about Processors

We are supported in processing your requests by Sipgate GmbH, Gladbacher Straße 74, 40219 Düsseldorf, Germany ("Sipgate"), Aircall.io, Inc, 11 Rue Saint-Georges, 75009 Paris, France ("Aircall"), Teleperformance A.E., 330 Thisseos Avenue, 17675 Kallithea, Greece ("Teleperformance"), TELUS International Services Limited, Point Village, East Wall Road, Dublin 1, Ireland (“Telus International”) and Salesforce.com Germany GmbH, Erika-Mann-Str. 31-37, 80636 Munich, Germany ("Salesforce") as data processors. In addition, we have agreed to appropriate EU standard contractual clauses with Salesforce.com Inc. based in the US. You can view the EU standard contractual clauses used via the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0914.

6.3. Client Success Call Recordings for client interaction analysis and feedback surveys

When you contact us via phone or take part in satisfaction surveys over the phone, before the conversation begins, we ask you for your consent to record the call for quality assurance purposes and to derive and implement measures to enhance our Client Success experience as well as products and services (Art. 6 (1) (a) GDPR). You can revoke your consent to the recording of the conversation at any time by informing the agent during the conversation or by contacting us using the contact details mentioned below under “Points of contact”.
If you have given us your express consent to record one or more conversations, we will record your conversation and link the recording to the existing history of previous conversations. Call recordings and client interactions will be used to assist in the quality assurance of agent performance, investigating and resolving complaints, identifying training needs and ensuring Client Success quality standards, improving our Client Support as well as our products and services. We delete the recording after 30 days if the deletion is not contrary to any other retention obligations.

7. Information events

To provide more insights about us and our services, we offer on-site events, webinars and information sessions. For the implementation of webinars, events and information sessions, we process your private contact and identification data that you have provided to us, e.g. by means of a registration form (e.g. first and last name, email address, telephone number) (pursuant to Art. 6 (1) (b) GDPR).
In the course of conducting webinars, we use the GoToWebinar webinar software of GoTo Technologies Ireland Unlimited Company, The Reflector, 10 Hanover Quay, Dublin 2, D02R573, Ireland ("GoToWebinar"), which we use as a processor. In the course of conducting webinars, personal data may be processed, e.g. your IP address, your email address and, if applicable, your first and last name. After the webinar has been held, we receive from GoToWebinar the information as to whether a user has attended the webinar, the registration date as well as the user's registration time and the duration of participation.
The integration of GoToWebinar is based on our legitimate interest (Art. 6 (1) (f) GDPR) to facilitate a technically flawless execution of the webinar with professional tools.
We use the Youtube.com platform of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, to conduct online live seminars. Further information on the processing of your data can be found in our data protection information on social networks.
The collection and processing of your personal data is based on the contract initiation or contract performance with regard to the implementation of an online webinar in accordance with Art. 6 (1) (b) GDPR. After participation in a webinar, your data will be stored for a maximum of 12 months.

8. Marketing activities and communication

8.1. Marketing emails

To conduct market research, facilitate product improvements and to send out personalised marketing content of us and affiliated third parties, we ask for your consent when opening an account or when signing up for the newsletter on our website. To ensure that you receive personalised information that is relevant to you and matches your personal interests, we review and analyse your user behaviour (e.g. recent transactions, participation in events and webinars) and use this information for some marketing emails. In addition, we have embedded so-called pixels in our newsletter to better understand your interaction with our newsletter and content. The processing is based on your consent (Art. 6 (1) (a) GDPR). You may revoke your consent at any time with effect for the future by clicking the “unsubscribe” link at the bottom of each marketing email or by contacting us using the contact options mentioned below under “Points of contact”. The revocation of consent does not invalidate the lawfulness of the processing carried out on the basis of the consent until revocation.
To ensure that no one can register with a third-party email address, we have implemented the so-called double opt-in procedure. This means that you will receive an email after registration asking you to confirm your registration. The confirmation of the subscription to the newsletter is logged in order to be able to prove the subscription process in accordance with the legal requirements. For this purpose, we process the IP address, date and time of access in accordance with Art. 6 (1) (f) GDPR.
To facilitate marketing communication, we rely on Salesforce as a data processor. Appropriate EU standard contractual clauses have been concluded in order to adequately protect your personal data. You can view the EU standard contractual clauses used via the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0914.

8.2. Marketing Push notifications

To send out marketing content of us and affiliated third parties based on your personal interests via push notifications, we ask for your consent when opening an account. For this purpose, a device token from Apple or Google is assigned to a device to provide push notification services. The legal basis for push notification is based on your consent in accordance with Art. 6 (1) (a) GDPR.
Your data is only processed for the purpose of sending push notifications once you have completed the registration process, logged in to the app and activated the "System Opt-In" for push notifications on the device. The marketing push consent is managed on a device basis, where consent is defined on each device. You can activate and deactivate this function at any time in your device settings. The revocation of consent does not invalidate the lawfulness of the processing carried out on the basis of the consent until revocation. The confirmation of the subscription to Marketing Push notification is logged in order to be able to prove the subscription process in accordance with the legal requirements. For this purpose, we process the device ID, date and time of registration of the device in accordance with Art. 6 (1) (f) GDPR. To facilitate push notifications we rely on Salesforce as a data processor. Appropriate EU standard contractual clauses have been concluded in order to adequately protect your personal data. You can view the EU standard contractual clauses used via the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0914.

8.3. Press Newsletter

To receive current press releases by email, you can be added to our distribution list. To do so, please send us your email address and your first and last name by email to presse@scalable.capital. We process your data exclusively to inform you about the current developments of our company and to send press releases. We cooperate with Finsbury Glover Hering Europe GmbH, Berliner Allee 44, 40212 Düsseldorf, Germany, as a consulting firm for strategic communication for the management of press releases. You can object to the processing at any time by sending an email to presse@scalable.capital or by using the contact details mentioned below under “Points of contact” and revoke your consent. The revocation of consent does not invalidate the lawfulness of the processing carried out on the basis of the consent until revocation.