Information obligations according to Art. 13 and 14
1. Name and contact data of the Controller and the Company Data Protection Officer
With this data protection statement, we wish to give you an overview of how we process your personal data and to inform you about your data protection rights. The type and use of data processed in the individual case depends on the service agreed and the contract concluded.
Telephone: +423 239 820 0
Fax: +423 239 820 9
The Company Data Protection Officer of Systrade AG is available at the address of Landstrasse 63, 9490 Vaduz, Liechtenstein, attn. of Ms Beatrix Friedrich and/or at firstname.lastname@example.org.
2. Collection and storage of personal data; type and purpose of use thereof
We collect and process data which we obtain from you within the framework of any queries or which we obtain from our clients and/or contractual partners within the framework of contractual relationships. In addition, we process – to the extent this is required for rendering our services – personal data which we admissibly obtain from sources available to the general public (e.g. the client’s/contractual partner’s web presence; commercial registers; the press; the internet) or which third parties who have a right to do so disclose to us.
Relevant personal data shall mean any and all personal details (e.g. the name; (e-mail) address; telephone number; fax number) and legitimisation data (e.g. identity card information). In addition to the above, this may also include data from executing our contractual obligations, possibly also information on your financial situation (e.g. the origin of assets) and other data comparable with the above categories.
a) When visiting our website
When accessing our websites at www.systrade.com, the browser used by your terminal automatically sends information to our website server. This information is temporarily stored in a so-called logfile. In this context, the following information is collected without any action on your part, and stored until automatic erasure:
- IP address of the requesting computer,
- Date and time of access,
- name and URL of the file retrieved;
- website, from which access is made (Referrer-URL),
- browser used and, if applicable, operating system of your computer and name of your access provider.
The mentioned data are processed by us for the following purposes:
- ensuring smooth website connection,
- ensuring comfortable use of our website,
- analysing the system security and stability and
- for further administrative purposes.
The relevant legal basis for data processing is point (f) of Art. 6(1) of the GDPR. Our legitimate interest follows from the above-listed purposes for the collection of data. In no case do we use the collected data for the purpose of drawing any conclusions in respect of you.
b) When using our contact form
If you have any questions whatsoever, you can contact us via a form provided on our website. You need to state a valid e-mail address, your name and a telephone number so that we know who sent the enquiry, and to enable us to respond either by e-mail or by telephone.
Any data processing for the purpose of contacting us is subject to point (a) of Art. 6(1)of the GDPR, based on your voluntary consent.
The personal data we collect for the use of the contact form will be automatically deleted once your enquiry was dealt with.
c) When concluding a contract with Systrade AG
In the case where you make use of our services, we particularly, but also depending on the type of contract, collect the following information:
- form of address; given name and family name;
- a valid e-mail address;
- postal address;
- date of birth;
- telephone number (landline and/or mobile phone);
- fax number, if applicable;
- legitimisation data (information from the identity card);
- commercial register excerpts and, if applicable, shareholders’ lists;
- information on the professional activities;
- depending on the service; evidence of the origin of assets, e.g. bank statements and information on investment experience.
All the above data will be collected
- to be able to identify you as our (potential) client/contractual partner;
- to be able to process your queries or to provide an answer to your questions;
- for correspondence with you;
- for invoicing purposes;
- to fulfil all of our contractual obligations.
The data processing shall be based on your query, and the processing is required in terms of point (b) of Art. 6(1) of the GDPR for the purposes referred to above, that is, for the proper processing your queries and for the mutual fulfilment of obligations under the contractual relationship.
Any personal data we collect for the purpose of contract processing will be stored for and erased after the statutory data retention period for lawyers (6 years from the end of the calendar year in which the contract relationship was established) has terminated, unless we are obliged to retain such data for longer periods because of retention and documentation obligations under valid tax and trade law in compliance with point (c) of Art. 6(1) of the GDPR or unless you consented to longer storage periods in terms of point (a) of Art. 6(1) of the GDPR.
3. Transfer of data
Your personal data is not transferred to third parties for any purposes other than those stated below.
We transfer your personal data to third parties only if
- you expressly granted your consent according to point (a) of Art. 6(1) of the GDPR;
- the transfer is required according to point (b) of Art. 6(1) of the GDPR for exercising or defending against legal claims and if there is no reason to presume that you have an overriding interest in protection regarding the transfer of your data;
- the transfer is required for compliance with a legal obligation according to point (c) of Art. 6(1) of the GDPR; and
- this is permitted by law and required according to point (b) of Art. 6(1) of the GDPR for the performance of contractual relationships with you.
The cookie stores information resulting in connection with the terminal specifically used. This, however, does not mean that your identity becomes directly known to us.
In addition, we use temporary cookies, also for optimising user-friendliness, which are stored on your terminal for a specifically determined period. When you visit our website again to use our services, the system will automatically recognise that you were here before and what entries and settings you used, so that you do not need to enter them again.
The data processed by cookies are required for the specified purposes in order to safeguard our legitimate interests and those of the third parties according to point (f) of Art. 6(1) of the GDPR.
Most browsers automatically accept cookies. However, you can configure your browser in such manner that no cookies are stored on your computer or that you are always notified before a new cookie is created. However, if you fully deactivate cookies, you might not be able to use all our website functions.
5. Rights of data subjects
You are entitled
- according to Art. 15 of the GDPR, to obtain information on your personal data processed by us. In particular, you can request information on the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data was or will be disclosed, the envisaged period for which the personal data will be stored, the existence of the right to request rectification, erasure, restriction of processing or objection, the right to lodge a complaint, the source of your data if not collected by us and the existence of automated decision making, including profiling and if applicable meaningful information on details;
- according to Art. 16 of the GDPR, to request prompt rectification of incorrect or incomplete personal data stored by us;
- according to Art. 17 of the GDPR, to request the erasure of the personal data stored by us, unless the processing is required for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims;
- according to Art. 18 of the GDPR, to request the restriction of processing of your personal data, insofar as you contest the accuracy of the personal data, the processing is unlawful but you oppose erasure, and we no longer need the data, but you require them to assert, exercise or defend legal claims or you objected to the processing according to Art. 21 of the GDPR;
- according to Art. 20 of the GDPR, to request to receive your personal data provided to us, in a structured, commonly used and machine-readable format or request transmission of those data to another controller;
- according to Art. 7(3) of the GDPR, to withdraw your consent at any time. This means that we are in the future no longer allowed to process the data based on such consent; and
- according to Art. 77 of the GDPR to lodge a complaint with a supervisory authority. Usually, for this purpose you can contact the supervisory authority in charge at your usual place of abode, workplace or the registered office of our law firm.
6. Right to object
Insofar as your personal data is processed on the basis of legitimate interests according to point (f) of Art. 6(1) of the GDPR, you are entitled, according to Art. 21 of the GDPR, to object to the processing of your personal data on the grounds relating to your particular situation or if the objection is aimed at direct marketing. In the latter case, you have a general right to object – we will implement this right without you being required to specify a particular situation.
If you wish to exercise your right to withdraw or object, you can simply send an email to email@example.com
7. Data security
Within the scope of the visit to our website, we use the wide-spread SSL procedure (Secure Socket Layer) in connection with the highest encryption level available and supported by your browser. As a general rule, this is 256-bit encryption. If your browser does not support 256-bit encryption, we use a 128-bit v3 technology instead. You can see whether an individual page of our website is transferred with encryption by means of the closed key or lock symbol in the bottom status line of your browser.
In addition to the above, we employ suitable technical and organisational security measures to protect your data from accidental or intentional manipulations, partial or full loss, destruction or unauthorized access by third parties. Our security measures are constantly improved in accordance with new technological developments.
8. Up-to-dateness and amendment of this Data Protection Statement
This Data Protection Statement is currently valid and came into effect in July 2020.
Owing to further development of our website and offers relating thereto, or due to changed statutory or regulatory requirements, it may become necessary to amend this Data Protection Statement. The relevant Data Protection Statement as amended can be downloaded and printed at any time from our website at www.systrade.com/data-protection.