Privacy policy – Optima Trading

Privacy policy

I.  Introduction – contact details

This Privacy Policy contains general information on the use (processing) by OPTIMA TRADING GMBH based in Hamburg (Germany) (hereinafter: “Optima Trading“) of personal data of current and potential Customers, including visitors to the website https://optimatrading.de (hereinafter collectively “Customers“). The privacy of our Customers is extremely important to us and for this reason, we provide this Privacy Policy so that each Customer knows to what extent his / her personal data is processed and that he / she can independently, consciously and freely decide whether to use our services.
The policy is general in nature, and its additional clarification will be an information clause, which the Customer will receive at the stage of starting the order, as well as on the occasion of, inter alia, subscription (in the form of a newsletter), contact forms or promotional campaigns – provided that you consent to the processing of your personal data for the above-mentioned purpose.

II. Provisions of the law on the protection of personal data

The Privacy Policy applies to the following provisions on the protection of personal data

  1. the Act of 10 May 2018 on the Protection of Personal Data
  2. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (general data protection regulation) (Journal of Laws UE.L No. 119, p. 1) – hereinafter referred to as “GDPR“.

 

III. Principles of processing personal data of Customers

When processing Customers’ personal data, we follow the following rules:

1. THE PRINCIPLE OF COMPLIANCE WITH LAW, ACCURACY AND TRANSPARENCY Personal data must be processed lawfully, fairly and in a transparent manner for the data subject (“lawfulness, fairness and transparency”).
2. THE PRINCIPLE OF LIMITING THE PURPOSE OF THE PROCESSING OF PERSONAL DATA Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes (“purpose limitation”).
3. THE PRINCIPLE OF DATA MINIMISATION Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (“data minimisation”).
4. THE PRINCIPLE OF DATA CORRECTNESS Personal data must be correct and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data that is inaccurate in view of the purposes of processing is immediately deleted or rectified (“correctness”).
5. THE PRINCIPLE OF LIMITATION OF DATA STORAGE Personal data must be kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which the data is processed.
6. THE PRINCIPLE OF DATA INTEGRITY AND CONFIDENTIALITY Personal data must be processed in a way that ensures adequate security of personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage, by appropriate technical or organisational measures.
7. THE PRINCIPLE OF ACCOUNTABILITY The Controller must be able to demonstrate that its actions comply with all of the above principles (listed in Article 5 (1) of the GDPR).

IV. Users’ rights in connection with the processing of personal data

The Customer has the right to:

  1. access to the content of your personal data,
  2.  rectify the data,
  3. delete the data,
  4. restrict data processing,
  5. transfer data,
  6. object the processing,
  7. withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

If it is found that the processing of personal data violates the provisions of the GDPR, the Customer has the right to lodge a complaint with the supervisory body of the Office for Personal Data Protection.

V. Security of personal data

We take technical and organisational measures to protect personal data against unlawful or unauthorised access or use, as well as against accidental destruction, loss or breach of integrity. As part of ensuring the security of personal data processed, we undertake to take into account:

  1. CONFIDENTIALITY – we will protect data against accidental disclosure to third parties,
  2. INTEGRITY – we will protect data against unauthorised modification,
  3. AVAILABILITY – we will provide authorised persons access to the Customer’s data, if necessary.

The Customer’s personal data may be processed by third parties only if such entity undertakes to provide appropriate technical and organisational measures to ensure the security of personal data processing, as well as to maintain the confidentiality of this data.

Each of our employees who has access to personal data has the appropriate authorisation and is obliged to maintain confidentiality.

VI. How do we process your data?

Customers’ personal data will be processed for the purposes of:

  1. performance of the contract or taking actions necessary to conclude the contract, e.g. contact by phone or e-mail in order to send an offer, to determine the date of service performance, to cancel or to change the date of service performance (Article 6 (1) (b) of the GDPR);
  2. marketing of products and services offered by ADO, including sending commercial information by electronic means or making telephone calls for marketing purposes – in connection with art. 10 sec. 2 of the Act of 18 July 2002 on the provision of electronic services or art. 172 sec. 1 of the Act of 16 July 2004 – Telecommunications Law, after expressing a separate consent (Article 6 (1) (a) of the GDPR);
  3. implementation of the legitimate interests of ADO, such as handling civil, enforcement, administrative and criminal proceedings, handling internal processes related to running a business (Article 6 (1) (f) of the GDPR);
  4. performance of obligations arising from legal provisions (Article 6 (1) (c) of the GDPR).

VII. Consent – withdrawal of consent

The Customer may be asked to consent to the processing of personal data for marketing purposes, including electronic marketing. We do not require consent in a situation where it is not necessary in a specific case (although the obligation to obtain consent may result from other legal provisions, e.g. consent to telephone or electronic marketing). The Customer has the right to withdraw consent at any time, and the withdrawal of consent does not have any negative consequences for him / her. It should be emphasised that the withdrawal of consent does not affect the compliance with the law of processing the Customer’s data which was made on the basis of consent before its withdrawal.
The application for the exercise of the right to be forgotten will be considered immediately, and after its consideration, we will cease processing the Customer’s data for marketing purposes, including the provision of marketing and commercial information by e-mail and by phone.

VIII. Data storage

We store personal data for the period necessary to achieve the goals about which the Customer has been informed. The period of storage of personal data is determined in strict accordance with applicable law. The Customer has the right to obtain information from us about the probable period of storage of his / her personal data.

IX. Sharing data with other entities

With the consent of the Customer, depending on the purpose of data processing and the content of the consent for processing and disclosure, his / her personal data may be made available to entities indicated in the consents. We may share data with processors – companies providing services on our behalf, to which we will commission activities that require data processing, in particular in the field of IT services, marketing services (including marketing agencies), market research, organisation and implementation of events.

X. Cookies

In connection with the Customer’s use of websites, we also collect data contained in system logs. We use it primarily for technical purposes related to the administration of our servers. In addition, we use this information to create statistical demographic information. The system logs collect information about IP addresses (network interface number), however, the data does not allow us to uniquely identify the user (indication of a specific natural person using a computer or other device connected to the Internet).

USE OF COOKIES

Cookies are text files saved by the web browser on the user’s computer hard drive while browsing the website. The cookies saved from the website may be used by entities that provide us with marketing and analytical services.

TYPES OF COOKIES

  • session – deleted when the web browser is closed,
  • permanent – deleted after a predetermined time, regardless of closing the web browser.
  • own – set by the website servers,
  • of third parties (our partners) – set by web servers of parties other than the website.

 

PURPOSE OF USING COOKIES

The website uses the following cookies:

  1. NECESSARY COOKIES (website functioning) – we use cookies to allow you to log into your account on the website, access services intended only for logged-in website users and enable navigation on the website without the need to repeat the authentication process each time. The use of this type of files is always active and necessary to use the website.
  2. ANALYTICAL COOKIES – the website uses third party cookies (e.g. Google Analytics, Google Analytics 360, Google Optimize) in order to, for example, verify visits to the website, their length and determine which functionalities of the website or its parts were most often used or visited. Consent to use this type of cookie is required.
  3. FUNCTIONAL COOKIES – this type of cookies allows you to provide various functions on the website and remember your settings or interests. Consent to use this type of cookie is required.
  4. ADVERTISING COOKIES – these cookies allow you to display advertisements tailored to the preferences of users. Consent to use this type of cookie is required.

Cookies process personal data for the purpose of:

  1. collecting static data via the analytical tools of Google Analytics (cookie administrator: Google LLC based in the USA); cookies expire after 2 years, while user-level data will be automatically deleted from Analytics servers after 50 months;
  2. marketing of own products or services on Facebook (cookie administrator: Facebook Inc., 1601 S. California Ave. Palo Alto, CA 94304, USA), stored for 3 months;
  3. from time to time for website optimisation;
  4. tracking anonymous data about website traffic via analytical tools.

 

COOKIES MANAGEMENT

  • You can give your consent to the use of cookies by using the message displayed when entering the website and later in the Privacy Policy tab. By using the buttons “I accept” or “Only necessary cookies” you can give the appropriate consents and manage your preferences. The “I accept” button means that you agree to enable all cookies available on the website. You can withdraw your consent at any time.

XI. Profiling

As part of the processing of the Customer’s personal data, we can use profiling:

  1. based on the consent of the Customer – in order to select product and service offers according to the Customer’s needs (including the use of automatic processes, consisting in compiling the Customer’s data in the scope of the consent granted, coming from various sources and a profile assigned on this basis, the consequence of which is selecting and presenting advertisements or offers corresponding to the Customer’s profile;
  2. without consent, based on our legitimate interest in the processing of cookies, in order to adapt the content and marketing messages displayed on other websites visited by the Customer to his / her preferences and interests. Profiling is based on data from social networking sites (Facebook, Instagram) to create personalised ads on these sites and the Google profiling system that allows you to create personalised banner ads that match the Customer’s preferences. These advertisements do not use data directly pointing to a given Customer, such as name and surname, e-mail address or telephone number.

XII. Changes to the Policy

We reserve the right to make changes to this Policy, which may result from the need to adapt to changes in legal regulations or applicable privacy standards, or to extend our offer. Therefore, we will inform about any changes with an appropriate message on our websites.

XIII. Copyright

All rights to the Platform https://optimatrading.de including all its graphic elements, photos and the layout of the Website’s pages and any other elements thereof, are reserved. The website and all its elements are protected by law, in particular the Act of 4 February 1994 on Copyright and Related Rights, the Act of 16 April 1993 on Combating Unfair Competition and the Act of 27 July 2001 on the Protection of Databases.

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