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Data Privacy Statement –Prosperity Solutions AG.

1. Introduction

The protection of your personal data is of particular concern to us. We treat the data which you provide to us within the scope of the utilisation of our website and offers confidentially and in line with the legal data protection regulations, as well as within the scope of this data privacy statement. In the following, we would like to inform you in detail of which of your personal data we collect, for which purposes we use it, with whom it is shared and which monitoring and information-related rights you may be entitled to.

2. Responsible party and contact information

The responsibly party in terms of the General Data Protection Regulation (hereinafter referred to as “GDPR“) for the Prosperity platform within the scope of the website and app (hereinafter referred to as “platform“) is Prosperity Solutions AG, Industriering 40, 9491 Ruggell, Principality of Liechtenstein (hereinafter referred to as “Prosperity“, “we“, “us“, “our“).

You can contact our data protection officer at Prosperity support@prosperity.app.

If you have questions regarding this data privacy statement or the collection, processing or utilisation of your personal data, you are welcome to contact our data protection officer per e-mail, in which case you should enter “Data protection“ in the reference field.

3. Definitions

3.1

Personal data is any information that may be used to identify a natural person directly or indirectly. This includes, for instance, names, addresses, e-mail addresses, telephone numbers, dates of birth, ages, sexes, tax identification numbers etc.

3.2

Processing is any action in connection with personal data, e.g. the collection, recording, organisation, sorting, saving, adaptation or amendment, disclosure or any other kind of utilisation.

4. Processing of your personal data within the scope of the use of the app

4.1

Information collected while downloading the app

Upon downloading the app, certain required information is conveyed to the respective app store. In particular, your Apple or Android ID, the time of the download, payment information and your individual device identification number may be processed during this step. The processing of this data is only undertaken by the respective app store and does not lie within our discretion.

The legal foundation for data processing is Art. 6, Paragraph 1, Sentence 1, lit. b of the GDPR.

4.2

Information that is automatically collected when using the app

Within the scope of the use of the app, we collect certain data automatically that are necessary to use the app. This includes, for instance, your device model, system version and the IP address of your mobile device or computer.

This data is automatically processed by us

in order to provide you with the app and the associated functions;

to improve the functions and performance features of the app and

to prevent and eliminate misuse and errors.

This processing is warranted, since the processing is necessary for the fulfilment of the contract between you and us in terms of Art. 6, Paragraph 1, lit. b of the GDPR so that you can use the app.

5. Processing of your personal data within the scope of the use of the website

5.1

Upon visiting the website

Upon accessing our website, information is automatically sent by the browser used on your terminal to the server of our website. This information is temporarily stored in a so-called log file. The following information is collected and stored until its automatic deletion in this step:

website user (IP addresses are automatically anonymised),

time of access, incl. details of the time zone,

user’s request (HTTP request method, requested file, version of the HTTP protocol),

HTTP status code (server’s response) and size of the server’s response,

name and URL of the accessed file,

website whence the access occurs (referrer URL),

utilised browser and potentially the operating system of your computer, as well as the name of your access provider.

This information is processed in order to make it possible for you to use our website (e.g. by adapting our website to the needs of your device). This data is not merged with other sources of data.

The legal foundation for this data processing is Art. 6, Paragraph 1, Sentence 1, lit. b of the GDPR, since we require automatically collected data for the effective provision of our website, as well as Art. 6, Paragraph 1, Sentence 1, lit. f of the GDPR, since storage serves our justified interest in order to guarantee the stability and security of the website. Further information about the collection of personal data within the scope of visiting our website can be found in the Section “Cookies“ (see No. 7).

We will only process the automatically collected personal data until the aforementioned objectives are fulfilled, unless we require this data for purposes of fulfilling the contract or there are legal, statutory or contractual retention period or further storage is necessary to assertion, execution or defence of legal claims.

5.2

In the case of using our contact possibilities and making applications

Due to legal regulations, our website includes details that make quick electronic contact with our company as well as direct communication with us possible. If a concerned party contacts us per e-mail, the personal data conveyed by the concerned party will be automatically stored by us. In this respect, data processing is undertaken for the purpose of handling and establishing contact in line with Art. 6, Paragraph 1, Sentence 1, lit. a of the GDPR on the basis of your voluntarily provided approval. This personal data is not forwarded to their parties. The aforementioned is also valid insofar as you send us the corresponding application documents via electronic means as an applicant, for instance per e-mail. If no employment relationship arises, the application documents will be deleted by us four (4) months after you receive the notification of rejection, as long as their deletion does not conflict with any other justified interests.


6. Processing of your personal data when using our services in the app and on the website

6.1 Creation of an account

Within the scope of our platform, you can create an account in order to select products and conclude contracts. Within the scope of your registration, we will process the following obligatory details that you provide:

name,

user name,

e-mail address

und Log-In- and passwort details

Furthermore, we will store the information that you voluntarily provide for the period that you utilise the account, as long as you do not delete it beforehand. You can administrate and amend all the information in the protected client area.

The legal foundation for this data processing is Art. 6, Paragraph 1, lit. b of the GDPR, since it serves the effective provision and administration of the account.

As long as no exceptions take effect within the services described below, your personal data will be stored until you delete it or your user account altogether. Following the deletion of your account, your personal data will be deleted within ninety (90) days. Legal retention obligations or the necessity of your personal data for legal proceedings due to wrongdoing during the utilisation of the services or with regard to payment problems can lead to us storing your personal data for a longer period.

6.2 Establishing contact

If you establish contact with us, e.g. via chat or e-mail, we will store and process your personal data that you convey to us in the chat or e-mail. This normally includes your name and e-mail address as well as the information that you have otherwise conveyed. This data will only be utilised to respond to you issue and/or for establishing contact and the associated technical administration.

The legal foundation for this data processing is Art. 6, Paragraph 1, Sentence 1, lit. b of the GDPR, as long as it occurs to fulfil a contract or pre contractual measures, as well as Art. 6, Paragraph 1, Sentence 1, lit. f of the GDPR, since handling these enquiries is in the interest of both parties.

You personal data will be stored after handling your enquiry for a period of three (3) years as of the end of the calendar year in which the handling takes place. Afterwards, we will delete your data and/or only retain it insofar as legal, statutory or contractual retention terms exist or further storage is required to assert, exercise or defend legal claims.

6.3

Conclusion of a contraction within the scope of the products we offer

If you have created an account and subsequently decide on a product from our selection, you must provide personal details to conclude the contract. These normally include your name, date of birth, address, occupation and potentially tax-related information.

The legal foundation for this data processing is Art. 6, Paragraph 1, Sentence 1, lit. b of the GDPR, since your information is required to fulfil a contract or pre contractual measures. Insofar as you transfer funds to pay for your contractual instalments, we will process your payment data for the purpose of fulfilling the contract.

For certain products, we require further information about your health situation, for instance information about certain illnesses and potentially documents in this connection or information about your financial situation and your knowledge of investment products.

The legal foundation for this data processing is your previously granted approval, in line with Art. 6, Paragraph 1, Sentence 1, lit. a of the GDPR.

In order to verify your identity for the purpose of concluding the contract, we require your identity document and your image via a video function. We will process this data based on your previously granted approval, in line with Art. 6, Paragraph 1, Sentence 1, lit. a of the GDPR.

7. Cookies

We utilise cookies on our platform. These are small files that are stored on your terminal (laptop, tablet, smartphone or similar) when you visit our platform. Cookies do not cause any damage to your terminal, do not contain any viruses, trojans or other malware. Information is stored in the cookie that results from the respective context with the specifically utilised terminal.

The utilisation of cookies on the one hand serves to design the use of our selection in a more comfortable manner for you. We therefore utilise cookies in order to recognise that you have already visited certain pages of our platform. The data is deleted as soon as the purpose for which it was collected is fulfilled, unless we require it for the purpose of fulfilling the contract or there are legal, statutory or contractual retention periods or further storage is required to assert, exercise or defend legal claims.

Moreover, we also utilise temporary cookies to optimise the user-friendliness which are stored for a certain determined period on your terminal. If you visit our platform once again in order to utilise our services, it will be automatically recognised that you have already visited us and which preferences you have set so that you do not have to re-enter these.

On the other hand, we utilise cookies in order to statistically record the use of our platform and for the purpose of analysing the optimisation of our selection for you. These cookies make it possible for us to recognise automatically when you visit our platform again that you have already visited us. These cookies are automatically deleted after a respectively defined period.

The data processed by means of cookies is necessary for the aforementioned purposes to protect our justified interests, as well as the interests of third parties in line with Art. 6, Paragraph 1, Sentence 1, lit. f of the GDPR.

Most browsers accept cookies automatically. You can configure your browser in such a manner, though, that no cookies are stored on your computer or a notification always appears before a new cookies is installed. The complete deactivation of cookies can lead to you not being able to use all of the functions on our platform, though.

8. Online advertising and analysis tools

We utilise the tools mentioned in the following for online advertising and analysis. The tracking measures mentioned in the following and utilised by us are conducted on the basis of Art. 6, Paragraph 1, Sentence 1, lit. f of the GDPR. By means of the tracking measures utilised, we want to ensure an appropriate design and the ongoing optimisation of our website. On the other hand, we utilise tracking measures in order to record the use of our website for statistical purposes and to analyse the optimisation of our selection for you. The respective data processing purposes and data categories can be gathered from the respective tracking tools.

8.1 Google Analytics

For the purpose of designing our platform appropriately and continually optimising our platform, we utilise Google Analytics, a web analysis service of Google Inc. (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).

Google Analytics utilises so-called cookies.The information about your use of our platform which is generated by the cookies are normally conveyed to a Google server in the USA and stored there. We have activated the IP anonymization function on this website. This will cause Google to shorten your IP adress within the member states of the European Union or in other member states of the European Economic Area before it is transmitted to the United States. Only in exceptional cases the full IP adress will be transmitted to a server of Google in the United States and shortened there. On behalf of the operator of this website, Google will use this information to analyse your use of our platform in order to compile reports on the activities and to render further services to us that are associated with the use of the platform and internet. The IP address conveyed within the scope of Google Analytics by your browser will not be merged with other data by Google.

We have concluded a contract with Google regarding the commissioned data processing in line with Art. 28 of the GDPR. Google has subjected itself to the EU-US Privacy Shield for exceptional cases in which personal data is conveyed to the USA. https://www.privacyshield.gov/EU-US-Framework.

You can prevent the use of Google Analytics at any time, either by installing the Google browser plug-in, which will set an opt-out cookie, or by selecting the corresponding preference in your browser software. We refer you to the fact that, in such a case, you may not be able to use all of the functions of this website to their full extent. Further information can be found at https://tools.google.com/dlpage/gaoptout?hl=de und https://www.google.com/analytics/terms/de.htm. You can find more information about Google Analytics’ handling of user data in Google’s data privacy statement: https://support.google.com/analytics/answer/6004245?hl=de.

Moreover, you can prevent the collection of the data generated by the cookie and related to your used of the website (incl. your IP address) as well as the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=de).

In addition to the browser add-on, in particular in the case of browsers on mobile devices, you can also prevent the collection by Google Analytics by clicking on this link. An opt-out cookie will be installed that will prevent the future collection of your data when visiting our website. The opt-out cookie is only effective for this browser and only for our website and is installed on your terminal. If you delete the cookies for this browser, you will have to re-install the opt-out cookie.

Further information about data protection in association with Google Analytics can be found, for instance, in the Google Analytics help section (https://support.google.com/analytics/answer/6004245?hl=de).

8.2 Facebook-Pixel

Furthermore, we utilise the “vistor action“ pixel of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter referred to as “Facebook”) on our website. With its help, we can follow users’ actions after seeing a Facebook advert or clicking on it. In this manner, we can measure the effectiveness of the Facebook adverts for statistical and market research purposes. The data collected in this manner is anonymous for us, i.e. we do not see the personal data of individual users. This data is stored and processed by Facebook, though, which we will inform you of to the best of our knowledge. Facebook can connect this data to your Facebook account and utilise it for its own purposes, in line with Facebook’s data utilisation guideline (https://www.facebook.com/about/privacy/).

We also utilise the “custom audience“ function of Facebook. That allows us to activate individualised, interest-related advertising for the users of our website if they have an account with Facebook or one of its partners. In order to conduct the analysis of the use of the website, Facebook utilises cookies. By doing so, the visitors to the website and anonymised data about their use of the website are recorded.

8.3 Typeform

We utilise the Typeform took in order to improve the user experience by means of appropriately designed surveys. Information about the corresponding data protection can be found here: https://admin.typeform.com/to/dwk6gt

8.4 CrazyEgg

We utilise the CrazyEgg tool in order to understand which pages are more or less relevant for users. Information about the corresponding data protection can be found here: https://www.crazyegg.com/privacy

8.5 Google Optimize

We utilise the Google Optimize tool in order to understand which different versions of our website are more helpful to users. Information about the corresponding data protection can be found here: https://policies.google.com/?hl=en and https://support.google.com/optimize/answer/6292487?hl=en

9. Social media plug-ins

On the basis of Art. 6, Paragraph 1, Sentence 1, lit. f of the GDPR, we utilise social plug-ins of the social networks Facebook, Instagram, LinkedIn and YouTube on our website in order to make our company better known. The purpose behind that is to improve your user experience and to optimise our services and is considered a justified interest in terms of Art. 6, Paragraph 1, lit. f of the GDPR. Responsibility for operations in line with data protection regulations must be guaranteed by the respective provider. Our inclusion of these plug-ins occurs by means of the so-called two-click method in order to protect the users of our website as well as possible.

9.1 Facebook

Social media plug-ins of Facebook are utilised on our website in order to design its use in a more personal manner. To do so, we use the “LIKE“ or “SHARE“ buttons. This is an offer by Facebook. If you activate the Facebook plug-in, the contents of the plug-in will be conveyed directly to your browser and included in the website by Facebook. We have no influence on the amount of data that Facebook collects by means of this plug-in and therefore inform you to the best of our knowledge: https://www.facebook.com/help/186325668085084

By including the plug-ins, Facebook receives the information that a user has accessed the corresponding website. If the user is logged into Facebook, Facebook can match the visit to the user’s Facebook account. If users interact with the plug-ins, for instance by clicking the LIKE button or leaving a comment, the corresponding information will be conveyed directly to Facebook by your browser and stored there. If a user is not a member of Facebook, there is still a possibility that Facebook could find out his/her IP address and store it. According to Facebook, only an anonymised IP address is stored in Germany.

The purpose and extent of data collection and the further processing and utilisation of the data by Facebook as well as your rights in this context and preference-setting options to protect your private sphere can be found in Facebook’s data protection information (https://www.facebook.com/about/privacy/).

9.2 Instagram

Functions of the service Instagram are integrated into our website. These functions are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged into your Instagram account, you can link the contents of our website with your Instagram profile by clicking on the Instagram button. By doing so, Instagram can match you visit to our website with your Instagram profile. We refer you to the fact that we, as the website provider, do not receive any knowledge of the contents of the data conveyed or of their utilisation. Further information about this topic can be found in Instagram’s data privacy statement: http://instagram.com/about/legal/privacy/.

9.3 Linkedin

We utilise components of the network LinkedIn on our website. LinkedIn is a service of LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Every time our website is accessed and is equipped with such a component, this component causes the browser you use to download a corresponding representation of LinkedIn. By means of this process, LinkedIn is informed of which specific website of our internet platform is currently being visited. If you click on the LinkedIn “Recommend“ button while you are logged into your LinkedIn account, you can link the contents of our website with your LinkedIn profile. Thus, LinkedIn is able to match the visit to our website with your LinkedIn user account.

We do not have an influence on the data that LinkedIn collects in this way, nor do we have an influence on the extent of the data collected by LinkedIn. We do not have any knowledge of the contents of the data conveyed to LinkedIn, either. Details about data collection by LinkedIn as well as about your rights and preference-setting options can be found in the data protection information of LinkedIn. This information can be found at: http://www.linkedin.com/legal/privacy-policy.

10. Provision of personal data to third parties

Personal data can be provided to third parties that act on our behalf in order to process the personal data with regard to its underlying purpose, for instance to fulfil the services offered, analyse the user behaviour on our website or for technical support. These third parties are contractually obliged by us by means of legal foreseen agreements to utilise personal data only for the agreed upon purpose or not to provide your personal data without permission to other parties, unless it is not necessary from a legal point of view. If you would like additional information about our commissioned data processors, please contact us at the aforementioned address. If other categories of recipients of personal data should arise within the scope of future data collection, we will inform you of this at the time of the collection of these details for this purpose.<br /><br />Prosperity is part of the group of companies The Prosperity Company AG. We can also provide your personal data within our partner companies for purposes of administrating contracts or developing and marketing products, but will always provide a corresponding contract or receive your permission to do so.<br /><br />Some of the recipients are located outside of the European Union and European Economic Area (EEA). Further information about cross-border transmissions in general and transmissions outside of the EEA can be found in No. 8.<br /><br />If we are legally entitled or obliged (for instance due to effective legislation or based on a court order), we can disclose your personal data.

11. Provision of personal data to third countries

In some instances, it is necessary to provide your personal data as described above to states outside of the EU or EEA (so-called third countries). In particular, we provide personal data to the USA.

In this context, please note that the extent of data protection legislation in third countries may not attain the same standard as in the EU. Upon conveying your personal data to third countries, we will undertake appropriate measures, though, in order to secure your data adequately. Adequate guarantees are, for instance, an adequacy ruling by the EU or the company being subjected to the Privacy Shield. If neither of the guarantees holds, we will conclude standard contractual provisions with the respective. These can be found at: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF.

You can request further details about the respective guarantees by means of send an e-mail to the aforementioned address.

12. Storage periods

It is our aim to process your personal data to the least extent possible. If not exact storage periods are mentioned in this statement, we will only store your personal data for as long as it is necessary to fulfil the purpose for which it was originally collected and, if appropriate, as long as legally stipulated.

13. Your rights

Depending on the details of the particular case, you have the following data protection rights:

right to information and access to personal data that concerns you

right to correction or deletion or limitation of the processing of your personal data

right to objection and revocation of your approval

right not to be subjected to a decision based solely on automated processing

right to data transferability

right to submit complaints to the competent authority

The supervisory authority responsible for us is as follows:

Datenschutzstelle Liechtenstein

Städtle 38

Postfach 684

FL-9490 Vaduz

Telephone: +423 236 60 90

E-Mail: info@dss.llv.li

The supervisory authority responsible for Switzerland is as follows:

Federal Data Protection and Information Comissioner

(Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter(EDÖB))

Feldeggweg 1

CH-3003 Bern

Telephone: +41 (0)58 462 43 95

Contact formular: https://edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt/Kontaktformular.html

Moreover, you also have the right to object to the processing of your personal data at any time:

insofar as we process your personal data for purposes of direct advertising; or

insofar as we process your personal data to pursue our justified interests and there are grounds that arise from you special situation.

You can (i) exercise the aforementioned rights or (ii) pose questions or (iii) submit a complaint regarding our processing of your personal data by contacting us, as described in No 1.

Current version and amendment of this data privacy statement

This data privacy statement is currently valid and was last updated in November 2018. Due to the further development of our website and selection of offers that extends beyond or due to altered legal and/or official stipulations, it may be necessary to amend this data privacy statement. The respectively current data privacy statement can be accessed and printed on the website at any time at: https://prosperity.app/.