Privacy Policy

Last Update: January 10, 2023

The protection of your personal data is very important to Stableton Financial AG, Poststrasse 24, 6300 Zug ("Stableton", "we", "us"). Therefore, we process your data exclusively on the basis of the statutory provisions, in particular on the basis of the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP). In this privacy policy we inform you about the most important aspects of data processing by our website www.stableton.com ("Website") and the use of our related services.

This website of Stableton Financial AG and its affiliates contains two sections: (i) a generally accessible portion that is available without customer classification and contains certain documentation made available on it (collectively, the "Site") and (ii) a section with additional information and documentation ("Marketplace") available only to registered persons residing in Switzerland, who are considered to be at least qualified or professional investors, as described in detail below.

In the following, you will learn which types of your personal data are processed when you visit and use our website, for what purpose and duration this data is stored and what rights you have with regard to your data processing.

1. General information on data processing by us

1.1 Controller

Controller within the meaning of the EU General Data Protection Regulation (GDPR) is:

Stableton Financial AG

Poststrasse 24,

6300 Zug

represented by Konstantin Heiermann

E-Mail: privacy@stableton.com

If you have any questions or suggestions regarding data protection, please do not hesitate to contact us. You can contact our data protection officers as follows:

Data protection officer:

Dr. Alexander Deicke

K11 Consulting GmbH

Kaffeeberg 11,

71634 Ludwigsburg, Germany

Email: datenschutz@k11consulting.de

1.2 Protection of your data

We take appropriate technical and organizational security measures within the meaning of Article 32 GDPR to ensure a level of data protection appropriate to the risk, in particular to protect your personal data against accidental or unlawful deletion, correction or loss and against unauthorized disclosure or access.

2. Data processing on our website and creation of log files (server log files)

2.1 Server log files

Each time you visit our website, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following server log files, which are technically necessary for the presentation of the website: our visited website, date and time of access, amount of data sent in bytes, source/reference from which you came to the page, browser used, operating system used, IP address used (possibly in anonymous form).

This data is processed separately from other data. The processing of this data together with other personal data of the visitor or user does not take place. It is not possible for us to assign this data to a specific person.

The temporary storage of data and log files is based on the legal basis of Art. 6 para. 1 lit. f) GDPR. Our overriding legitimate interest in this data processing lies in the provision of the website, and the improvement of the stability and functionality of our website. The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

2.2 Contacting us

If you contact us via a form on the website or by e-mail, the personal data you provide (name, e-mail address, phone number, and content of the message) will be collected and processed. This data will be processed, stored, and used exclusively for the purpose of answering your inquiry or contacting you and the associated technical handling or administration. This data processing is therefore necessary to fulfill our (pre-)contractual interests.

2.3 Registration for our newsletter

You have the option of subscribing to our newsletter via our website. If you sign up for our email newsletter, we will periodically send you updates and marketing information. For this purpose, we collect your personal data such as your e-mail address, and possibly your name. The data collected by us when registering for the newsletter will be used exclusively for advertising purposes within the framework of the newsletter for the above-mentioned purposes.

The legal basis for processing your data is consent in accordance with Art. 6 para. 1 lit. a) GDPR.

You can change your mind at any time and revoke your consent to receive the newsletter with effect in the future. For example, you can unsubscribe from the newsletter by clicking on the unsubscribe link located in the footer of every email you receive from us or by contacting us at info@stableton.com. After unsubscribing, we will delete your data in connection with the newsletter dispatch immediately.

2.4 Feedback and Surveys

If you give us feedback about our services or participate in surveys on our website, we process the personal data that you voluntarily provide to us (the email address and the content of your feedback or responses as part of the survey). This data is processed solely for the purpose of processing your feedback or contacting you if desired and to improve our services.

The processing of personal data in this way takes place on the basis of your consent in accordance with Art. 6 para. 1 lit. a) GDPR.

2.5 Data on the use of the website

We also collect information about your use of our website. This usage data is collected via cookies. We use this usage data for (i) web analytics, (ii) improvements to our services and our website, (iii) usability improvements.

This data processing is based on your consent to the use of cookies on our website. You can revoke this consent at any time (e.g. via your browser settings for cookies) with effect for the future and free of charge.

3. Third-party tracker and other tools

When you use our website, the following third-party services are used. Some third-party providers also process your data in the USA. We would like to point out that, according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. This can lead to various risks regarding data processing lawfulness and security.

The data transmission of your personal data in connection with the use of these services takes place on the basis of your expressly declared consent in accordance with Art. 49 para. 1 lit. a) GDPR in conjunction with Art. 6 para. 1 lit a) GDPR and on the basis of the legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR.

3.1. Segment

To analyze visitor behavior and improve our offer, we use the software of Segment.io, Inc. 101 15th St San Francisco, CA 94103 USA on this website. Data is collected and stored from which user profiles are created using pseudonyms.

Segment, for its part, uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

The legal basis for data processing is our legitimate interest in accordance with Art. 6 para. 1 lit. f) GDPR.

Further information can be found in Segment's privacy policy: https://segment.com/docs/legal/privacy/

3.2 Zapier

To integrate different tools, we use Zapier, a service of Zapier Inc., 548 Market St #62411, San Francisco, California 94104, USA ("Zapier"). The use of Zapier is in the interest of an efficient structuring of the tools we use.

In order to manage the services, Zapier processes your contact and demographic data. In addition, user behavior is analyzed.

The legal basis for data processing is your consent in accordance with Art. 6 para. 1 lit. a) GDPR.

Further information on data protection at Zapier can be found at: https://zapier.com/privacy.

3.3 Typeform

If you use our "Marketplace" as a registered user, we use Typeform from TYPEFORM SL, C/Bac de Roda, 163 (Local), 08018 Barcelona Spain (Typeform) for our survey[s]. This allows us to provide you with an easy contact option.

For this purpose, we pass on the following personal data from you to Typeform: e-mail

In addition, Typeform collects the following personal data with the help of cookies: information about your device (IP address, device information, operating system, browser settings), usage data (date and time when you used the contact form). Typeform needs this data to ensure the display of the survey and its functionality.

Data processing by Typeform for the purpose of contacting us is carried out in accordance with Art. 6 para. 1 lit. a) GDPR on the basis of your voluntarily given consent.

For more information on objection and removal options against Typeform, please visit: https://admin.typeform.com/to/dwk6gt.

3.4 Hotjar

We use Hotjar on our website. This is provided by Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe. Hotjar is a technology service that helps us better understand how you use this website (e.g. how much time you spend on which pages, which links you click, what users like and don't like, etc.) and that allows us to develop and maintain our service based on user feedback.

Hotjar uses cookies and other technologies to collect data about the behavior of our users and their devices (such as the IP address of the device – anonymized -, the screen size of the device, the device type, browser information, geographic location -country only- , the preferred language in which our website is displayed). Hotjar stores this information in a pseudonymised user profile. Neither Hotjar nor we will ever use this information to identify individual users or match it with other data about an individual user. Further details can be found in Hotjar's privacy policy. If you do not want to be recorded by Hotjar, you can disable this by setting the DoNotTrack header in your browser. Further information and more about data processing by Hotjar can be found at: https://www.hotjar.com/legal/policies/privacy/

This data processing is based on your consent (Art. 6 para. 1 lit. a) GDPR) to the use of cookies on our website. You can revoke this consent at any time (e.g. via your browser settings for cookies) with effect for the future and free of charge.

3.5 Rollbar

In order to be able to resolve error messages quickly, we use the service of "Rollbar", Rollbar, Inc., 51 Federal Street, Suite 401, San Francisco, USA on our website.

The following information is also processed by Rollbar for error detection and analysis, such as browser type, IP address, screen and window resolution, languages et in the browser, date and time of access and time zone, referrer URL, detected error or bug.

We have a legitimate interest in this data processing pursuant to Art. 6 para. 1 lit. f) GDPR, namely the interest in error detection and analysis.

Further information on data protection at Rollbar can be found at: https://docs.rollbar.com/docs/privacy-policy.

3.6 LaunchDarkly

If you use our "Marketplace" as a registered user, the services of LaunchDarkly, Catamorphic Co., 405 14th Street, Oakland, CA 94612, USA are used. LaunchDarkly allows us to provide additional features for investments based on user activity. The legal basis for the processing is Art. 6 para. 1 lit. f) GDPR, whereby our legitimate interest lies in the customer-oriented provision of additional functions on our marketplace. Further information can be found in Launch Darkly's privacy policy: https://launchdarkly.com/policies/privacy/

3.7 Amplitude

We use Amplitude, a digital optimization system, on our website. The service provider is the American company Amplitude, Inc., 631 Howard Street, Floor 5, San Francisco, CA 94105, USA.

Amplitude is used to analyze user behavior. For this purpose, we transmit pseudonymised information about your use to an Amplitude server. There is no transfer of data that allows conclusions to be drawn about an individual user.

The legal basis for the transfer is your consent in accordance with Art. 6 para. 1 lit. a) GDPR.

You have the option of revoking your consent to tracking at any time in the settings of your browser.

You can find out more about the data processed through the use of Amplitude in the Privacy Policy on https://amplitude.com/privacy.

3.8 Pipedrive

We use the CRM system Pipedrive of the provider Pipedrive OÜ on our website. Pipedrive OÜ is a limited liability company under Estonian legislation (EU) with address at Mustamäe tee 3a, 10615 Tallinn, Estonia, registered in the Estonian Commercial Register under code 11958539.

We use Pipedrive as our CRM tool for processing and storing contact data. If you contact us, your details will be processed by Pipedrive to process the contact request and its processing. In addition, demographic, analytical and financial data are collected and stored.

Data processing is carried out on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f) GDPR (efficient and fast processing of user inquiries, existing customer management, new customer business).

Pipedrive's privacy policy can be found here: https://www.pipedrive.com/en/privacy.

3.9 SendGrid

We use SendGrid to send e-mails. The service provider is SendGrid Inc., 1801 California Street, Suite 500, Denver, CO 80202.

SendGrid is a service that automatically sends an email from the website to individuals after they have performed a transaction or a specific action (e.g. password reset or download of content).

Data processing is carried out in accordance with Art. 6 para. 1 lit. a) GDPR on the basis of your consent.

For more information, please refer to SendGrid's privacy policy.

3.10 OneSignal

If you use our "Marketplace" as a registered user, the technology of the provider OneSignal, 201 San Antonio Circle Suite #140, Mountain View, CA, USA is used. This tool allows us to send you push notifications to your mobile phone if you use our native mobile app. With these push notifications we would like to draw your attention to news.

In order to be able to send you the push notifications, it is necessary that the anonymized data, such as a message, is transmitted to OneSignal's server. It is necessary that an anonymous ID is assigned for the unambiguous assignment of the device, which does not allow OneSignal to draw any conclusions about the person.

The legal basis for the use of cookies is the consent given in accordance with Art. 6 para. 1 lit a) GDPR. Otherwise, the legal basis is Art. 6 para. 1 lit. f) GDPR, as we have a legitimate interest in processing voluntarily addressed inquiries addressed to us.

You have the option of unsubscribing from the push notifications at any time. This is possible through your profile within the app.

The data protection information of the provider can be found at here: https://onesignal.com/privacy_policy.

3.11 Userpilot

In order to make it as easy as possible to get started using our service, we use a user guidance service from our processor Userpilot Inc., 2035 Sunset Lake Road, Newark, Delaware 19702, USA.

During the use of our service, for example by clicking on certain buttons, the user guidance gives you additional information and assistance in some places so that you can find your way around more easily and understand how the service is operated. In addition, you will receive help with user guidance so that you are made aware of new functions within our service.

For this purpose, demographic and analytical data are processed.

The legal basis for the analysis and optimisation of user guidance is your explicit consent in accordance with Art. 6 para. 1 lit. a) GDPR.

3.12 Google Ads

We use Google Ads on our website. Google Ads is an online advertising program of Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms into Google (keyword targeting). Furthermore, targeted advertisements can be displayed on the basis of the user data available on Google (e.g. location data and interests) (target group targeting). As a website operator, we can evaluate this data quantitatively by, for example, analyzing which search terms led to the display of our advertisements and how many ads led to corresponding clicks. For this purpose, Google Ads places the cookie on our website. This reads and stores the IP address as well as the interactions of our users who have come to the company's site via an advertisement.

The use of this service is based on your consent in accordance with Art. 6 para. 1 lit a) GDPR.

3.13 Google reCAPTCHA

We use "Google reCaptcha" (hereinafter "reCAPTCHA") on our website. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. This helps us to distinguish whether a certain action on our website is performed by a human or by a computer program or bot. For this purpose, reCAPTCHA analyzes your behavior based on various characteristics. This analysis starts automatically as soon as you visit the website. For analysis, reCAPTCHA evaluates various information (e.g. IP address, length of stay on the website or mouse movements made by you).

Data processing is carried out on the basis of Art. 6 para. 1 lit. f) GDPR. We have a legitimate interest in protecting our websites from abusive automated spying and SPAM.

Further information about Google reCAPTCHA and Google's privacy policy can be found at the following links: https://policies.google.com/privacy?hl=de&tid=331670223587

3.14 LinkedIn Conversion Pixel

We have integrated the so-called LinkedIn pixel on our website to use the conversion tracking technology of LinkedIn Corporation. This pixel is used to collect information about the use of this website (e.g. information about viewed content). The transmitted data of the pixel can be used to address you on LinkedIn specifically with individualized advertising, provided that you have a LinkedIn account.

With the help of this pixel, the following data can be collected and analyzed:

Operating system used
Screen resolution of the device you are using
Time of access to the e-mail or website
Activities on the website during a session when using tracking pixels
IP address for inferences about ISP and location

The use of LinkedIn pixels is based on Art. 6 para. 1 lit. a) GDPR.

Please refer to LinkedIn's privacy policy under https://www.linkedin.com/legal/privacy-policy for more information on data collection and use as well as the options and rights to protect your privacy. If you are logged in to LinkedIn, you can deactivate data collection at any time under the following link: https://www.linkedin.com/psettings/enhanced-advertising.

3.15 Facebook Conversion Pixel

We use the "visitor action pixels" from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook")) on our website.

This allows user behavior to be tracked after they have been redirected to the provider's website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook's Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.

The legal basis for the use of this service is your explicit consent in accordance with Art. 6 para. 1 lit. a) GDPR

4. General information on the storage period of your personal data

We only store your personal data for as long as is necessary for the purposes for which they are processed. In addition, we may be obliged to store your data longer due to applicable statutory retention periods. This includes access data and log files. In particular, we store your data in connection with contacting us for a period of usually 180 days, provided that they are no longer useful to us. We store data about your usage behavior until you revoke your consent, at the latest until 180 days. Personal data that you provide to us in the context of feedback and surveys will remain stored until deleted by you or us. If you have only registered for our newsletter and are not a customer of ours, we will store your data until you revoke your consent.

We also store your personal data beyond the aforementioned periods if legal claims can be asserted from the relationship between you and us or until the final clarification of a specific incident or legal dispute. This longer storage is necessary to safeguard our legitimate interests in asserting, investigating and defending legal claims.

5. Your rights as a data subject

When processing your personal data, the GDPR grants you the following rights:

Right to information (Art. 15 GDPR)
You have the right to request confirmation from us as to whether personal data concerning you is being processed. For this purpose, you have the right to information about this personal data and to the information listed in detail in Article 15 GDPR.
Right of correction (Art. 16 GDPR)
You have the right to demand the immediate correction of incorrect personal data concerning you and, if necessary, the completion of incomplete data if the legal requirements for this are fulfilled in each case.
Right to erasure (Art. 17 GDPR)
You have the right to obtain from us the erasure of your personal data without undue delay, provided that one of the reasons listed in Article 17 GDPR applies and insofar as processing or storage is not necessary.
Right to restriction of processing (Art. 18 GDPR)
You have the right to demand that we restrict processing if one of the conditions listed in Article 18 GDPR is met.
Right to data portability (Art. 20 GDPR)
You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to request the transmission of this data to a third party, provided that the conditions listed in Article 20 GDPR are met.
Right to object (Art. 21 GDPR)
You have the right, for reasons arising from your particular situation or your objection to direct marketing, to object at any time to the processing of personal data concerning you, which is carried out by us on the basis of Art. 6 para. 1 lit f) GDPR. When processing your personal data for direct marketing purposes, including profiling for this purpose, you can object to such processing of your data at any time.
Right of revocation (Art. 7 GDPR)
You have the right to revoke your consent to the processing of personal data at any time with effect for the future. The processing of your personal data up to this point remains lawful.
Right of complaint to a supervisory authority (Art. 77 GDPR)
You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters.

6. Contact

If you have any questions about the use of cookies on our website and how to assert your rights, please do not hesitate to contact us at any time using the following contact details:

Stableton Financial AG

Poststrasse 24, 6300 Zug - CH

E-Mail: privacy@stableton.com

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