Privacy Police

RESPONSIBLE

Trice Markets Pte. Ltd.

4 Battery Road
#25-01
Bank of China Building

Singapore 049908

Mail :hello@tricemarkets.com

Authorized representatives

Managing Directors: Christoph Bauer, Jeroen de Smet, Sabyasachi Mohapatra

The company data protection officer of Trice Markets Pte. Ltd. can be reached at the above address, Attn: Mr. Christoph Bauer, or at hello@tricemarkets.com.

1. COLLECTION AND STORAGE OF PERSONAL DATA AND THE NATURE, PURPOSE AND USE THEREOF

We process the data of our customers, trading partners, interested parties and other contractual partners (hereinafter referred to as „contractual partners“) in accordance with Art. 6 para. 1 lit. b. DSGVO, in order to provide them with our pre-contractual or contractual services and to carry out our commercial transactions with our contractual partners. The data processed in this context, its type and scope as well as the purpose and necessity of its processing, are determined by the underlying contractual relationship.

The processed data include:

• Salutation, first name, last name
• a valid business e-mail address
• the business address
• telephone number (landline and/or mobile)
• The IP address used for registration and the last IP address used in each case
• The position within the company
• Information that is necessary for the conclusion and support of our commercial contracts as well as for the provision of our contractual services.

This data is collected in particular in order to be able to identify you as our customer

• for correspondence with you
• to issue invoices
• to be able to initiate and conclude commercial transactions with you or with companies named by you on the basis of our commercial contracts.

In addition, we process and store personal data as part of our administrative tasks, the organization of our company, our financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our pre-contractual and contractual services and within our commercial operations. The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO.

Furthermore, we process and store personal data in order to operate our business economically, to recognize market trends and conduct market research, to carry out marketing measures and to be able to assess the wishes of our contractual partners and users. For this purpose, we analyze the data we have on commercial transactions, contracts, inquiries, other business transactions, etc. In doing so, we process contract data, usage data, inventory data, communication data, as well as metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include our contractual partners, interested parties, customers, as well as users and visitors of our online offer or our trade portal.

The analyses serve us to increase the user-friendliness, the optimization of our offer and the business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized values. If such analyses or profiles are personal, they will be deleted or anonymized upon termination by the user, otherwise after two years from the conclusion of the contract. In all other cases, the overall business analyses and general trend analyses are prepared anonymously wherever possible.

In the context of the use of our online services as well as our trade portal, we store the IP addresses used as well as the time of the respective use. The storage is based on our legitimate interests to prevent misuse as well as unauthorized use of our online services or our trading portal. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit and enforcement of our claims pursuant to Art. 6 para. 1 lit. f. DSGVO or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. DSGVO.

Beyond that, we do not process any special categories of personal data, unless these are components of a processing commissioned by our contractual partners or resulting from our commercial transactions.

We point out the necessity of providing personal data, unless this is evident to the contractual partners. Disclosure to external persons or companies only takes place if it is necessary in the context of the initiation and conclusion of commercial contracts. When processing the data provided to us, we act in accordance with the instructions of the client as well as the legal requirements.

The deletion of the data takes place when the data is no longer required for the fulfillment of contractual or legal duties of care as well as for the handling of any warranty and comparable obligations, whereby the necessity of the retention of the data is reviewed every three years; in all other respects, the legal retention obligations apply.

2. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

According to Art. 6 para. 1 lit. b. DSGVO, Art. 6 para. 1 lit. c. DSGVO as well as Art. 6 para. 1 lit. f. DSGVO, we transfer company-related data, which may include personal data, to the third parties listed below for the purposes listed below:

• to insurers, in particular trade credit insurers to obtain insurance cover, which is the basis of our commercial transactions;
• to banks, financial institutions, financial service providers and financing companies of all kinds, insofar as there is a legitimate interest in doing so
• to credit agencies for obtaining creditworthiness information concerning the respective company
• to intermediaries, intermediary platforms and financial portals, insofar as this is necessary to obtain corresponding offers, to submit offers, for correspondence or on the basis of other contractual relationships with these.
• to other cooperation partners not mentioned here, if this is necessary for the fulfillment of the contract
• to financial administrations, consultants (such as tax advisors), auditors as well as other fee offices and payment service providers.
• to services that serve the operation of this website and the entire website, its optimization and analysis (see also sections 8 to 11 of this privacy policy).

We have no influence on the data and data processing procedures collected here. With regard to the purpose, scope of data collection and processing, we refer to the respective data protection declarations of the services mentioned in items 8 to 11.

We have concluded commissioned processing agreements with the parties involved in accordance with Art. 28 DSGVO.

Data transfer to third countries: If the processing is carried out by third party services outside the European Union or the European Economic Area, these must meet the special requirements of Art. 44 et seq. DSGVO, or in the case of US companies, the so-called „Privacy Shield“.

3. COLLECTION OF ACCESS DATA AND LOG FILES
We, or rather our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes

• IP address of the requesting computer
• Date and time of access
• Name and URL of the accessed file
• website from which the access was made (referrer URL)
• Browser used, browser version, operating system of your computer, as well as the name of your access provider
• access status/HTTP status code;

The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website or serve the purpose of user-friendly, functional and secure delivery of our website to you with functions and content, as well as their optimization and statistical analysis. For security reasons, we store this data in server log files for a storage period of 30 days. After this period, they are automatically deleted, unless we need to store them for evidence purposes in the event of attacks on the server infrastructure or other legal violations. Further storage may take place in individual cases if required by law.

4. REGISTER FUNCTION

Users can create a user account with us. As part of the registration process, the required mandatory information is communicated to the users and processed on the basis of Art. 6 (1) lit. b DSGVO for the purpose of providing the user account. The processed data includes in particular the login information (name, password as well as an email address). The data entered during registration is used for the purposes of using the user account.

Users may be informed about information relevant to their user account – such as technical changes – by e-mail. If users have terminated their user account, their data with regard to the user account will be deleted – subject to a legal obligation to retain data. It is the responsibility of users to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as those of the users in protection against misuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c DSGVO.

5. CONTACT

Bei der Kontaktaufnahme mit uns (z.B. per Kontaktformular, E-Mail, Telefon oder via sozialer Medien) werden die Angaben des Nutzers zur Bearbeitung der Kontaktanfrage und deren Abwicklung gem. Art. 6 Abs. 1 lit. b) DSGVO verarbeitet. Die Angaben der Nutzer können in einem Customer-Relationship-Management System („CRM System“) oder vergleichbarer Anfragenorganisation gespeichert werden.

Wir löschen die Anfragen, sofern diese nicht mehr erforderlich sind. Wir überprüfen die Erforderlichkeit alle zwei Jahre; Ferner gelten die gesetzlichen Archivierungspflichten.

6. AFFECTED RIGHTS

You have the right

• to revoke your consent at any time in accordance with Art. 7 (3) DSGVO. This has the consequence that we may no longer continue the data processing based on this consent for the future;
• to request information about your personal data processed by us in accordance with Art. 15 DSGVO. In particular, you may request information about the processing purposes, the category of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, and the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details;
• pursuant to Art. 15 DSGVO, to demand the correction of incorrect or the completion of your personal data stored by us without undue delay;
• pursuant to Art. 17 DSGVO, to request the erasure of your personal data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the assertion, exercise or defense of legal claims;
• pursuant to Art. 18 DSGVO, to request the restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful, you object to its erasure and we no longer require the data, but you need it for the assertion, exercise or defense of legal claims, or you have objected to the processing pursuant to Art. 21 DSGVO;
• pursuant to Art. 20 DSGVO, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transferred to another controller; and
• complain to a supervisory authority in accordance with Art.77 DSGVO. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our registered office for this purpose.

7. DATA PROTECTION IN APPLICATIONS AND THE APPLICATION PROCESS

Applications sent electronically or by mail to the office responsible within the company are processed electronically or manually for the purpose of handling the application process.

We expressly point out that application documents with „special categories of personal data“ according to Art. 9 DSGVO (e.g. a photo that gives conclusions about your ethnic origin, religion or marital status), with the exception of a possible severe disability, which you wish to disclose of your own free will, are undesirable. You should submit your application without this data. This will not affect your chances of applying.

The legal basis for the processing is Art. 6 para. 1 p.1 lit. b) DSGVO as well as § 26 BDSG n.F..

If an employment relationship is entered into with the applicant after completion of the applicant procedure, the applicant data will be stored in compliance with relevant data protection regulations. If you are not offered a position after completion of the application process, your submitted letter of application including documents will be deleted 6 months after the rejection is sent in order to be able to satisfy any claims and obligations to provide evidence in accordance with the AGG.

8. HOSTING, E-MAIL & NEWSLETTER DISPATCH

The hosting services we use through ionos (by 1&1) serve the following purposes: the provision of infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services.

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

1. We use the following dispatch service providers for e-mail & newsletter dispatch:
   Mailchimp (The Rocket Science Group, LLC – 675 Ponce de Leon Ave NE – Atlanta, GA 30308 USA),
2. You can subscribe to our newsletter with your voluntary consent by entering your e-mail address and confirming the „double opt-in procedure“. After your registration, you will receive an e-mail from us with a confirmation link to confirm your registration. Only after you click on this link will your e-mail be included in the newsletter distribution list and stored for the purpose of sending e-mails.
3. To comply with legal requirements, we log your IP address used for registration as well as the date and time of the double opt-in (registration and confirmation).
4. For statistical evaluation and optimization of our newsletter, we evaluate your user behavior (opening of the newsletter, link clicks) with the help of so-called „web beacons“ or „tracking pixels“.
5. You can object to the tracking and consent to the sending of the newsletter at any time by clicking on the unsubscribe link at the end of the newsletter. In this case, the newsletter receipt will also be terminated. If you deactivate the display of images in your e-mail software, tracking is also not possible. However, this may have restrictions regarding the functions of the newsletter and included images will then not be displayed. We store your data as long as you have subscribed to the newsletter. After unsubscribing, your data will only be stored anonymously for statistical purposes

9. ONLINE PRESENCES IN SOCIAL MEDIA

We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing policies of their respective operators apply. The US providers are certified in accordance with the so-called Privacy Shield and are thus obliged to comply with European data protection. When you use and call up our profile in the respective network, the respective privacy notices and terms of use of the respective network apply. Unless otherwise stated within the scope of our notes on data processing, we process the data of users insofar as they communicate with us within the social networks and platforms, e.g. send us messages.

10. COOKIES