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Privacy Policy

Privacy Policy

Privacy Policy

Last Updated: February 2026

We, TxStrategies, take the protection of your personal data and the legal obligations serving this protection very seriously. The legal requirements demand comprehensive transparency about the processing of personal data. Only if the processing is comprehensible for you as a data subject, you are sufficiently informed about the meaning, purpose and scope of the processing. Our privacy policy therefore explains in detail which so-called personal data is processed by us when you use our website.

Please note that links on our website may take you to other Internet pages that are not operated by us but by third parties. Such links are either clearly marked by us or are recognizable by a change in the address line of your browser. We are not responsible for compliance with data protection regulations or for the secure handling of your personal data on these websites operated by third parties.

I. General

As a matter of principle, we collect and use personal data of our users only to the extent that this is necessary for the provision of a functional website as well as our contents and services. The collection and use of personal data of our users is regularly only carried out with the consent of the user. An exception applies in those cases where it is not possible to obtain prior consent for factual reasons and the processing of the data is permitted by legal regulations.

Legal basis of processing

Insofar as we obtain the consent of the data subject for processing operations involving personal data, Art. 6 (1) lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) (b) GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

Insofar as processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d GDPR serves as the legal basis.

If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the first-mentioned interest, Art. 6 (1) f GDPR serves as the legal basis for the processing.

Updates

We may update this privacy policy at our discretion from time to time by posting a new version on our website. You should check our website occasionally to ensure any changes are suitable for you.

The current version of this privacy policy was modified on November 02, 2023.

Data deletion and storage

The personal data of the data subject will be deleted or protected by technical and organizational measures (e.g. pseudonymization, encryption) as soon as the purpose of storage ceases to apply. In addition, storage may take place if this has been provided for by the European or national legislator in Union regulations, laws or other regulations to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

Cooperation with processors and third parties

Insofar as we disclose data to other persons and companies (order processors or third parties) in the course of our processing, transmit it to them or otherwise grant them access to the data, this shall only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is required for the performance of the contract pursuant to Art. 6 (1) lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 GDPR.

II. Data processing in connection with the use of the website

Collection of access data and log files

We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of 31 days and then deleted. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the final clarification of the respective incident.

Cookies

To ensure the operation of the WebApp TradeTracer, we use cookies on the basis of GDPR Art. 6 para. 1 lit. b and GDPR Art. 6 para. 1 lit. f. The cookies we use are exclusively functional cookies. The use of third-party cookies for tracking or advertising purposes does not take place.

1. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance user experience and analyze website traffic. The following services utilize cookies:

Google Tag Manager

We use Google Tag Manager, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Tag Manager is a solution that allows us to manage website tags through a single interface. The Tag Manager itself (which implements the tags) is a cookie-less domain and does not collect personal data. The service triggers other tags, which may in turn collect data.

Legal basis: Art. 6 (1) lit. f GDPR (legitimate interest in efficient management of website services)

More information: Google Privacy Policy

Cookiebot

We use Cookiebot, a service provided by Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark, for managing cookie consents. Cookiebot enables us to obtain and document user consent for the use of cookies. When visiting our website, a Cookiebot cookie is set to store your consent preferences.

Legal basis: Art. 6 (1) lit. c GDPR (legal obligation to obtain and document cookie consents)

More information: Cookiebot Privacy Policy

TrackLution (Server-Side Tracking)

We use TrackLution for server-side tracking. With this method, tracking data is not sent directly from the user's browser to third-party providers, but is first transmitted to our own server and then forwarded. This enables better control over the processed data and increases data security.

Legal basis: Art. 6 (1) lit. a GDPR (consent) for marketing tracking, Art. 6 (1) lit. f GDPR (legitimate interest) for technically necessary tracking

META Pixel

We use the Meta Pixel, a tracking tool from Meta Platforms Ireland Limited, to measure the effectiveness of our Meta advertising campaigns and optimize our marketing efforts. The Pixel allows us to track user interactions after clicking on a Meta ad and being redirected to our site. The collected data, such as IP address, browser information, and visited pages, may be processed by Meta for advertising purposes.

Legal basis: Art. 6 (1) lit. f GDPR (legitimate interest in analyzing and optimizing marketing activities).

More information: Meta Privacy Policy

Opt-out: You can manage Meta ad settings in your Meta account or use third-party tools like "Meta Pixel Blocker".

Rewardful Cookies

We use Rewardful, a service by Rewardful Inc., for managing affiliate and referral programs. Rewardful places cookies on your device to track referrals and commissions for affiliate partners. The cookies store information about your visit and may collect data such as referral sources, click activity on our website, and user session duration.

Legal basis: Art. 6 (1) lit. b GDPR (contract fulfillment for tracking referrals) and Art. 6 (1) lit. f GDPR (legitimate interest in affiliate marketing tracking).

More information: Rewardful Privacy Policy

Opt-out: You can disable cookies in your browser settings.

Encharge

We use Encharge, a service by Encharge Inc., for email marketing, site tracking, and identity resolution (linking anonymous visits to user profiles). Encharge enables us to send personalized email campaigns and analyze user behavior on our website. With identity resolution, anonymous website visits are linked to known user profiles once a user identifies themselves (e.g., through login or newsletter signup).

Legal basis: Art. 6 (1) lit. a GDPR (consent) for marketing emails and tracking, Art. 6 (1) lit. f GDPR (legitimate interest) for analyzing and optimizing our communications.

More information: Encharge Privacy Policy

Opt-out: You can unsubscribe from marketing emails via the unsubscribe link in each email. Site tracking can be disabled through your cookie settings.

2. Informational use of the website

When you visit our website and use it purely for information purposes, i.e. without using additional functions such as the contact form, we automatically collect personal data. This is the following information: IP address of your end device as well as the date and time of accessing the website. This information is transmitted by your browser unless you have configured it to suppress the transmission of this information.

This personal data is processed to ensure the functionality and optimization of the website and to ensure the security of our information technology systems. This is also our legitimate interest, which is why processing is permitted under Art. 6 (1) (f) GDPR.

3. Amazon Web Services

For the provision of this website and the platform services we use the web hosting service Amazon Web Services of Amazon Web Services EMEA Sàrl, Rue Plaetis 5, 2338 Luxembourg, Luxembourg. In this context, Amazon Web Services, Inc. in the USA may also be used as a sub-service provider (collectively "AWS").

AWS stores this website on its servers (hosting). The storage location is the EU (Frankfurt, eu-central-1).

In connection with hosting, Amazon Web Service processes personal data on our behalf as follows:

  • AWS S3 (AWS storage service): Storage of user profile pictures as encrypted files
  • AWS RDS (AWS database service): Storage of user data in an encrypted database that can only be accessed by the application itself
  • AWS SNS/Pinpoint (push services from AWS): Identification of the device for delivery of push messages
  • AWS CloudWatch (log service from AWS): Storage of temporary log messages

Other AWS services process user data non-persistently as part of technical operations: AWS CloudFront, AWS EC2, AWS Lambda, AWS ECS

Amazon Web Service certified by trusted security standards, including ISO 27001, SOC 1/2/3, and PCI DSS Level 1.

4. Social sign-in

To facilitate your registration on our website and in the mobile apps, you have the option of registering with the so-called single sign-on solution (via Google, Discord, etc.) at the beginning of the registration process.

The providers' data protection and terms of use apply to registration and use. In any case, your account details are entered directly on the provider's server. We do not learn your account details. The respective providers will inform you whether and which data of your social media account will be made accessible to us.

If you have expressly given your consent to the provider (Google, Discord) in accordance with Art. 6 (1) p. 1 lit. a GDPR, your personal data (first name, last name, e-mail address) will be transmitted to us as part of the registration via the provider.

Legal basis: Art. 6 para. 1 lit a GDPR (consent), or Art. 6 para. 1 lit e/f GDPR (interest in securely authenticating your access through established services)

5. Auth0

We use the Auth0 service, provided by Okta Inc, P.O. Box 743620, Los Angeles, CA 90074 – 3620 to manage logins (username and password), including single sign-ons. In doing so, we do not obtain access to your password from third-party providers such as Google or Discord. We only receive your email address and information about the successful login, as well as additional data if you authorize the third-party providers to do so.

Okta Inc acts as our processor. The USA is a country outside the EU for which there is no adequacy decision by the EU Commission stating that this country offers an adequate level of data protection comparable to that of the EU. We have therefore concluded a contract with Okta Inc in the USA in accordance with the EU standard data protection clauses.

6. Contact form and e-mail

If you use the contact form on our website or send us an e-mail, the personal data you provide there will be processed by us. This information is transmitted by your browser or e-mail client and stored in our information technology systems. The processing of this personal data is necessary for answering your request. In addition, your IP address and the date and time of the contact request are stored if you send us an e-mail.

The data processing serves the purpose of answering your inquiry and preventing misuse of the contact form and ensuring the security of our IT systems.

Legal basis: Art. 6(1)(f) GDPR (legitimate interests in responding to inquiries and protecting IT systems)

7. Stripe

Payments will be processed via Stripe Payments Europe Ltd, Block 4, Harcourt Center, Harcourt Road, Dublin 2, Ireland ("Stripe"). All data required for payment processing will be used by Stripe for the sole purpose of making the payments and will be securely transmitted via the SSL process.

Legal basis: Art. 6 para. 1 cl. 1 lit. b GDPR

More information: Stripe Terms

III. Your rights as a data subject

If personal data is processed by you, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:

1. Right to information

You may request confirmation from the controller as to whether personal data concerning you are being processed by us. If such processing is taking place, you may request information from the controller about various aspects of the processing.

2. Right to rectification

You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you is inaccurate or incomplete. The controller shall carry out the rectification without undue delay.

3. Right to restriction of processing

You may request the restriction of the processing of personal data concerning you under certain conditions.

4. Right to deletion

You may request from the controller that the personal data concerning you be erased without undue delay, and the controller is obliged to erase such data without undue delay, provided that one of the statutory reasons applies.

5. Right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing.

6. Right to data portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format.

7. Right of objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions.

8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

9. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

IV. Data security

All data transmitted by you personally is encrypted using the generally accepted and secure TLS (Transport Layer Security) standard. TLS is a secure and proven standard that is also used in online banking, for example. You can recognize a secure TLS connection by the s appended to the http (i.e. https://..) in the address bar of your browser or by the lock symbol at the bottom of your browser.

We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

As of February 2026