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Privacy Policy



1. Data protection at a glance

General information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.
Data collection on this website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. Their contact details can be found in the “Information on the responsible body” section of this privacy policy.
How do we collect your data?
On the one hand, your data is collected when you provide it to us. This may be data that you enter in a contact form, for example.
Other data is collected automatically or with your consent when you visit the website by our IT systems. This is primarily technical data (e.g., Internet browser, operating system, or time of page view). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior.


What rights do you have regarding your data?

You have the right to receive information about the origin, recipient, and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You can contact us at any time if you have any questions about this or other data protection issues.
Analysis tools and third-party tools
When you visit this website, your surfing behavior may be statistically evaluated. This is mainly done using so-called analysis programs.
Detailed information about these analysis programs can be found in the following privacy policy.



2. Hosting

Strato

We host our website with Strato. The provider is Strato AG, Otto-Ostrowski-Straße 7, 10249 Berlin (hereinafter referred to as “Strato”). We use Strato's website builder system. When you visit our website, Strato collects various log files, including your IP addresses.

For more information, please refer to Strato's privacy policy: https://www.strato.de/datenschutz/.
The use of Strato is based on Art. 6 (1) lit. f GDPR. We have a legitimate interest in ensuring that our website is as reliable as possible. If consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and § 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's terminal device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.


Order processing

We have concluded an order processing agreement (AVV) with the above-mentioned provider. This is a contract required by data protection law, which ensures that the provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.




3. General information and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.


When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.


We would like to point out that data transmission over the Internet (e.g., when communicating by email) can have security gaps. Complete protection of data against access by third parties is not possible.



Hinweis zur verantwortlichen Stelle


The responsible body for data processing on this website is:


Kostas Thomas
Parkstraße 26
22605 Hamburg


E-Mail: hello@thomasmarkets.com


The responsible body is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g., names, email addresses, etc.).


Storage period
Unless a more specific storage period is specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, deletion will take place once these reasons no longer apply.




General information on the legal basis for data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, if special categories of data are processed in accordance with Art. 9 (1) GDPR. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 (1) (a) GDPR. If you have consented to the storage of cookies or access to information on your end device (e.g., via device fingerprinting), data processing is also carried out on the basis of Section 25 (1) TTDSG. Consent can be revoked at any time. If your data is necessary for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 (1) lit. b GDPR. Furthermore, we process your data if it is necessary to fulfill a legal obligation on the basis of Art. 6 (1) lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 (1) lit. f GDPR. The relevant legal basis in each individual case is explained in the following paragraphs of this privacy policy.


Note on data transfer to the USA and other third countries
Among other things, we use tools from companies based in the USA or other third countries that do not have secure data protection laws. When these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that these countries cannot guarantee a level of data protection comparable to that of the EU. For example, US companies are required to disclose personal data to security authorities without you, as the data subject, being able to take legal action against this. It cannot therefore be ruled out that US authorities (e.g., secret services) may process, evaluate, and permanently store your data located on US servers for surveillance purposes. We have no influence on these processing activities.


Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)



IF DATA PROCESSING IS BASED ON ART. 6 PAR. 1 LIT. E OR F OF THE GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS DATA PROTECTION DECLARATION. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA, UNLESS WE CAN PROVE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING PURPOSES; THIS ALSO APPLIES TO PROFILING, INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).



Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.


Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent that it is technically feasible.


SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.



Information, deletion, and correction
Within the framework of the applicable legal provisions, you have the right to receive information free of charge at any time about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to correct or delete this data. You can contact us at any time with any questions you may have about this or other topics related to personal data.


Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:


  • If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
  • If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
  • If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balance must be struck between your interests and ours. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.


If you have restricted the processing of your personal data, this data may only be processed—apart from its storage—with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a member state.


Objection to advertising emails
We hereby object to the use of contact data published within the scope of the imprint obligation for sending unsolicited advertising and information material. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, for example through spam emails.



4. Data collection on this website



Cookies
Our websites use so-called “cookies.” Cookies are small text files and do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or your web browser automatically deletes them.
In some cases, cookies from third-party companies may also be stored on your device when you visit our site (third-party cookies). These enable us or you to use certain services provided by the third-party company (e.g., cookies for processing payment services).
Cookies have various functions. Numerous cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or display advertising.
Cookies that are necessary for the electronic communication process, for the provision of certain functions requested by you (e.g., for the shopping cart function) or for the optimization of the website (e.g., cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6 (1) lit. f GDPR, unless there is another legal basis.




Cookies that are necessary for the electronic communication process, for the provision of certain functions you have requested (e.g., for the shopping cart function) or for the optimization of the website (e.g., cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and similar recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6 (1) (a) GDPR and § 25 (1) TTDSG); consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.

If cookies are used by third-party companies or for analysis purposes, we will inform you separately in this privacy policy and, if necessary, ask for your consent.





Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us.
These are:


  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

This data is not merged with other data sources.


This data is collected on the basis of Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be collected.


Contact form
If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We will not pass on this data without your consent.



This data is processed on the basis of Art. 6 (1) (b) GDPR, provided that your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR), if this has been requested; consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions—in particular retention periods—remain unaffected.

Enquiries by email, telephone, or fax
If you contact us by email, telephone, or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.
This data is processed on the basis of Art. 6 (1) (b) GDPR, provided that your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR), if this has been requested; consent can be revoked at any time.
The data you send us via contact requests will remain with us until you request us to delete it, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions—in particular statutory retention periods—remain unaffected.


5. Social Media

Instagram


This website incorporates features of the Instagram service. These features are provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
When the social media element is active, a direct connection is established between your device and the Instagram server. Instagram thereby receives information about your visit to this website.
If you are logged into your Instagram account, you can link the content of this website to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate your visit to this website with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the data transmitted or its use by Instagram.
If consent has been obtained, the use of the above-mentioned service is based on Art. 6 (1) lit. a GDPR and § 25 TTDSG. Consent can be revoked at any time. If no consent has been obtained, the use of the service is based on our legitimate interest in achieving the widest possible visibility on social media.



Insofar as personal data is collected on our website using the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 GDPR). This joint responsibility is limited exclusively to the collection of data and its transfer to Facebook or Instagram. The processing by Facebook or Instagram after the transfer is not part of the joint responsibility. The obligations incumbent upon us jointly have been set out in a joint processing agreement. The text of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing data protection information when using the Facebook or Instagram tool and for the secure implementation of the tool on our website in accordance with data protection laws. Facebook is responsible for the data security of Facebook or Instagram products. You can assert your rights as a data subject (e.g., requests for information) regarding the data processed by Facebook or Instagram directly with Facebook. If you assert your rights as a data subject with us, we are obliged to forward them to Facebook.


Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://help.instagram.com/519522125107875 and https://de-de.facebook.com/help/566994660333381.


Further information on this can be found in Instagram's privacy policy.: https://instagram.com/about/legal/privacy/.

LinkedIn


This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Each time you access a page on this website that contains LinkedIn elements, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited this website with your IP address. If you click on the LinkedIn “Recommend” button and are logged into your LinkedIn account, LinkedIn can associate your visit to this website with you and your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the data transmitted or its use by LinkedIn.
If consent has been obtained, the use of the above-mentioned service is based on Art. 6 (1) lit. a GDPR and § 25 TTDSG. Consent can be revoked at any time. If no consent has been obtained, the use of the service is based on our legitimate interest in achieving the widest possible visibility on social media.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.linkedin.com/help/linkedin/answer/a1343190/-?lang=de


Further information on this can be found in LinkedIn's privacy policy at: https://www.linkedin.com/legal/privacy-policy.


6. Newsletter


Newsletter and dispatch via Substack
If you would like to subscribe to the newsletter offered on the website, we require your email address and information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. Further data will not be collected or will only be collected on a voluntary basis. We use newsletter service providers, which are described below, to process the newsletter.

Newsletter via Substack



We offer a free newsletter in which we regularly inform you about market analyses and the “Trade of the Week.” We use the service Substack Inc., 548 Market St, San Francisco, CA 94104, USA (“Substack”) to send and manage the newsletter.
When you subscribe to our newsletter, the data you enter (email address, name if applicable) is stored on Substack's servers in the USA. Registration is carried out using the double opt-in procedure: after registering, you will receive an email in which you must confirm your registration. This is the only way to ensure that no third-party email address is used for our newsletter.
Your data is processed on the basis of your consent (Art. 6 (1) (a) GDPR). You can revoke this consent at any time with future effect by unsubscribing from the newsletter via the unsubscribe link in each issue or directly with Substack.
Please note that when using Substack, data is transferred to the USA. Substack declares that it complies with the requirements of the GDPR. For more information, please refer to Substack's privacy policy: https://substack.com/privacy.


The data you provide us with for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter. After unsubscribing, the data will be deleted from our distribution list; this does not affect data that we have stored for other purposes.


Order processing

We have concluded an order processing agreement (AVV) with the above-mentioned provider. This is a contract required by data protection law, which ensures that the provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.



7. Plugins and Tools

YouTube with enhanced data protection


This website embeds videos from YouTube. The operator of the site is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
We use YouTube in extended data protection mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, the extended data protection mode does not necessarily exclude the transfer of data to YouTube partners. YouTube establishes a connection to the Google DoubleClick network regardless of whether you watch a video.
As soon as you start a YouTube video on this website, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to associate your surfing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.



Furthermore, YouTube may store various cookies on your device after you start a video or use comparable recognition technologies (e.g., device fingerprinting). This allows YouTube to obtain information about visitors to this website. This information is used, among other things, to collect video statistics, improve user-friendliness, and prevent fraud attempts.
After starting a YouTube video, further data processing operations may be triggered over which we have no control.
YouTube is used in the interest of an appealing presentation of our online offerings. This constitutes a legitimate interest within the meaning of Art. 6 (1) lit. f GDPR. If consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and § 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's terminal device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
Further information about data protection on YouTube can be found in their privacy policy at: https://policies.google.com/privacy?hl=de.


Google Web Fonts (local hosting)
This site uses web fonts provided by Google to ensure uniform font display. The Google fonts are installed locally. No connection to Google servers is established.
For more information about Google Web Fonts, please visit: https://developers.google.com/fonts/faq und in der Datenschutzerklärung von Google: https://policies.google.com/privacy?hl=de.


8. eCommerce and payment provider


Processing of customer and contract data
We collect, process, and use personal customer and contract data for the establishment, content design, and modification of our contractual relationships. We collect, process, and use personal data relating to the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill for it. The legal basis for this is Art. 6 (1) lit. b GDPR.
The customer data collected will be deleted after completion of the order or termination of the business relationship and expiry of any statutory retention periods. Statutory retention periods remain unaffected.



9. Audio and video conferences

Data Processing

We use online conferencing tools, among others, to communicate with our customers. The specific tools we use are listed below. If you communicate with us via video or audio conference over the internet, your personal data will be collected and processed by us and the provider of the respective conferencing tool.
The conferencing tools collect all data you provide/use to use the tools (email address and/or your telephone number). Furthermore, the conferencing tools process the duration of the conference, the start and end (time) of participation in the conference, the number of participants, and other "context information" related to the communication process (metadata).
Furthermore, the provider of the tool processes all technical data necessary to process online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and the type of connection.



If content is exchanged, uploaded, or otherwise made available within the tool, this content is also stored on the servers of the tool providers. Such content includes, in particular, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards, and other information shared while using the service.


Please note that we do not have full control over the data processing practices of the tools used. Our options are largely determined by the company policies of the respective provider. Further information on data processing by the conference tools can be found in the privacy policies of the respective tools used, which we have listed below this text.


Purpose and Legal Basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 (1) (b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest within the meaning of Art. 6 (1) (f) GDPR). If consent has been requested, the use of the relevant tools is based on this consent; consent can be revoked at any time with future effect.

Storage Period
The data we collect directly via the video and conference tools will be deleted from our systems as soon as you request deletion, revoke your consent to storage, or the purpose for storing the data no longer applies. Stored cookies remain on your device until you delete them. Mandatory statutory retention periods remain unaffected.



We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.

Conference tools used

We use the following conference tools:


Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Details on data processing can be found in the Microsoft Teams privacy policy: https://privacy.microsoft.com/de-de/privacystatement.



Data processing
We have entered into a data processing agreement (DPA) with the above-mentioned provider. This agreement is required by data protection law and guarantees that the provider will only process the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.