Data Protection

Raisin GmbH is pleased about your visit to the ZINSPILOT website and your interest in our services. The protection of your personal data is very important to us and we want you to feel safe when using ZINSPILOT. For this reason, we have designed all of our services from the outset to ensure that your personal data enjoys special protection. Below we have compiled information about the information that is collected, processed and used when using our open and registration-required areas of the ZINSPILOT website in compliance with the statutory data protection regulations.

1. RESPONSIBLE BODY

The ZINSPILOT website is provided to you by:

Raisin GmbH
Schlesische Strasse 33-34
10997 Berlin

Tel.: 040 - 22866500
Fax.: 040 - 228665010

service@zinspilot.de

Authorized managing directors are:
Dr. Frank Freund, Dr. Tamaz Georgadze, Katharina Lüth, Michael Stephan

You can reach our data protection officer at: datenschutz@zinspilot.de

2. COLLECTION, PROCESSING AND USE OF PERSONAL DATA WHEN VISITING THE ZINSPILOT WEBSITE

The ZINSPILOT website has two different areas, namely a freely accessible area and an area that requires registration.

If you use our website as a visitor and do not register with us, our web server will only collect the following connection data:

Request (What should be done)
IP address
Browser type and settings
Request URL
Page from which the file was requested
Date, time
Operating system
The pages you visit
For this we use Google Analytics, a web analysis service from Google Inc. (“Google”). Statistics are generated from this data, which help us to further adapt our site to your needs. During the statistical evaluation, the IP address is previously anonymized. A personal reference is therefore excluded for us.

Registration interest pilot
If you would like to actively use our service, you must register for certain services with ZINSPILOT. For registration, only your salutation, surname, first name, title and email address are collected and stored. You will also be assigned a unique customer number.

Opening ZINSPILOT account
To open a ZINSPILOT account with a partner bank, we collect various personal information, which you can find on our account opening form on the website. This information is required to open an account if it is marked as a mandatory field. At the end of registration you will receive an overview that you can print out and use for the Postident procedure. We would like to point out that we also send the registration data you enter encrypted to the respective partner bank and store the information on our servers for the purpose of preserving evidence.

In order to clearly assign customers and investments, to ensure the proper processing of your investments and to prepare annual tax reports, we receive the following data from the partner bank:

Title
First and last name
Full address of the registration address
Full address of an optionally provided postal address
Telephone number
Nationality
Place of birth/country of birth
IBAN of the ZINSPILOT account at the partner bank
IBAN and account holder of the reference account
Tax Identification Number (TIN)
ID card data (type, date of issue, number, issuing authority)
ID card copy
Financial transaction data (investment amount, selected investment offer, status information on investment processes)
Information on any exemption order or NV certificate that may have been deposited
Information about power of attorney in the event of death
Any personal data beyond this is not collected when you visit the ZINSPILOT website, unless this information is voluntarily provided by the user or collected with their consent.

3. COLLECTION, PROCESSING AND USE OF PERSONAL DATA WHEN USING CERTAIN
FUNCTIONALITIES
The use of the essential functionalities of the area of our website that requires registration requires the collection of personal data and informationtransaction-related information to carry out our services. This is in particular data relating to the deposit and withdrawal processes of investment amounts at the ZINSPILOT partner bank and the product banks. In order to create your ZINSPILOT investment cockpit, we also need the relevant information about your investments from the banks.

We will also receive investors' tax information from the banks and make it available to the investor and also store it so that the user can use this information in the "Archive &" section. documents” can be accessed collectively.

Further information can be found in Section II. 14 of the General Terms and Conditions.

4. PRECAUTIONS
All employees of our company are trained and obliged to maintain data secrecy in accordance with the legal provisions of the General Data Protection Regulation. Our data center and the in-house IT department continually adapt the technical security precautions to current circumstances and requirements. Both are subject to constant monitoring.

5. LEGAL BASIS
Your data is processed on the following legal basis:

your consent (Art. 6 Para. 1 a GDPR),
to implement the contractual provisions with you (Art. 6 Para. 1 b GDPR), because of a legitimate interest on our part (Art. 6 Para. 1 f GDPR), namely the improvement of our offer, the protection against misuse and for ;r our statistics.

6. DATA RECEIVER
Your personal data will be passed on to the service providers we use to carry out our contractual obligations as well as the partner and product banks involved.

7. DATA SOURCES
We receive data from you, including about the devices you use. In addition, we receive data from our partner banks and, if necessary, the responsible tax offices.

8. STORAGE DURATION
We store your data,

if you have consented to the processing, at most until you revoke your consent after the statutory storage periods have expired. if we need the data to carry out a contract, at most as long as the contractual relationship with you exists or as long as statutory retention periods run. if we use the data on the basis of a legitimate interest, at most as long as your interest in deletion or anonymization does not outweigh it. 9. YOUR RIGHTS AS A DATA SUBJECT You have - partly under certain conditions — the right,

To request information about the processing of your data,
to correct your data,
to have your data deleted or blocked,
to restrict processing,
to object to the processing of your data,
To receive your data in a transferable format and to transmit it to a third party,
to revoke your consent to the processing of your data in the future and
to complain to the responsible supervisory authority about unauthorized data processing. The supervisory authority responsible for you is the Hamburg Commissioner for Data Protection and Freedom of Information. (https://www.datenschutz-hamburg.de/). 10. REQUIREMENT OR OBLIGATION TO PROVIDE DATA Unless this is expressly stated during the collection, the provision of data is not necessary or obligatory.

11. USE OF CUSTOMER TICKET SYSTEMS FOR PROCESSING CUSTOMER SERVICE
Raisin uses a customer ticket system to process individual customer service inquiries. This customer ticket system is used to answer incoming emails and, in the case of customer-specific inquiries, outgoing emails are generated without prior inquiry. A customer ticket is also generated when using the contact form.

The customer ticket system is currently Zendesk Inc., 1019 Market Street, San Francisco, CA 94103, as a “Software-as-a-Service” (SaaS) used. When you register for the ZINSPILOT investor service, or by sending an email to ZINSPILOT, or using the contact form, personal data such as email address, name and gender are transferred to Zendesk Inc. This also applies to all content of an email and any attachments. Raisin has agreed with Zendesk Inc. that all Zendesk Inc. data will be stored exclusively on servers within the European Union.

12. USE OF A SERVICEISTERS FOR RECEIVING AND SENDING LETTER MAIL
Raisin uses a service provider to process letter mail. Incoming documents are received, opened and scanned by this service provider and made available to Raisin. In addition, the service provider sends letters for ZINSPILOT customers. DATA 2000 GmbH, Kaiser-Wilhelm-Straße 93, 20355 Hamburg, is currently commissioned with this service.

In the course of this processing, the service provider receives and processes personal data for shipping (name and address), as well as the contents of the documents for incoming mail. Electronic documents are exchanged via an encrypted server connection (Secure File Transfer Protocol, SFTP for short).

Raisin has entered into an order data processing agreement with the provider within the meaning of Art. 28 GDPR.

13. USE OF AN EMAIL PROVIDER
Raisin uses an email provider to handle email communication between customers, interested parties and ZINSPILOT. The email infrastructure is currently 1&1 Internet SE, Elgendorfer Strasse 57, 56410 Montabaur, Germany, as “Software-as-a-Service” (SaaS) used. For every email that is sent from the ZINSPILOT system (“Investment Cockpit”) or exchanged with ZINSPILOT customer service, personal data such as email address, name and content of the email is sent to 1&1 Internet SEü ;transferred and saved. Raisin has agreed with 1&1 that all email data will be stored exclusively on servers within the European Union.

14. COOKIES
In order to make visiting our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted at the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your device and enable us to recognize your browser on your next visit (persistent cookies). You can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or exclude the acceptance of cookies for certain cases or in general. If you do not accept cookies, the functionality of our website may be limited.

Of course, you can also visit our website without cookies. If you do not accept cookies, this may lead to functional restrictions on our offerings. The use of cookies is necessary for the use of the area that requires registration.

Here you can set your personal cookie settings.

Google Analytics
Our website uses Google Analytics, a web analysis service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”). Google Analytics uses so-called “cookies”, i.e. text files that are stored on your computer and which enable your use of the website to be analyzed. The information generated by a cookie about your use of our website is usually transferred to a Google server in the USA and stored there.

We use Google Analytics with the extension “_anonymizeIp()” so that the IP addresses transferred to Google are only processed there in a shortened form and in this way direct personal reference is excluded. If IP anonymization is activated on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator.

The IP address transmitted by your browser as part of Google Analytics is not combined with other Google data. You can prevent the storage of cookies by setting the appropriate settings in your browser software; However, we would like to point out that in this case you may not be able to fully use all of the functions of this website. You can also:You can prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout

If you visit our site via a mobile device (e.g. smartphone or tablet), you can object to the future use of Google Analytics via this link. By activating the link, we will set a cookie in your browser, which signals us to prevent the use of Google Analytics for your device. Please note that you will have to object again if you remove the cookies in your browser.

Google AdWords
Our website uses the online advertising program “Google AdWords” and as part of this, conversion tracking. The conversion tracking cookie is set when a user clicks on an ad placed by Google. These cookies expire after 30 days and are not used for personal identification. If the user visits certain pages on this website and the cookie has not yet expired, we and Google can recognize that the user clicked on the ad and was redirected to this page. Each Google AdWords customer receives a different cookie. Cookies cannot therefore be tracked via the websites of AdWords customers. The information collected using the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, you will not receive any information that can be used to personally identify users. Users who do not want to participate in tracking can easily deactivate the Google conversion tracking cookie via their Internet browser under user settings. These users are not included in the conversion tracking statistics. Further information about data protection at Google can be found at https://www.google.com/policies/?hl=de. Users can also deactivate or object to Google ads in whole or in part at https://privacy.google.com/?hl=de#google-experience.

Google Remarketing for interest-based advertising
We also use Google’s remarketing technology. Through this technology, users who have already visited our websites and online services and are interested in the offer are addressed again through targeted advertising on the pages of the Google Partner Network. The advertising is displayed through the use of cookies (see section 7). With the help of the text files, user behavior when visiting the website can be analyzed and then used for targeted product recommendations and interest-based advertising. For this purpose, the Google Remarketing tracking pixels are integrated on this page, which record user behavior on the website (e.g. products viewed), the technical characteristics of the webshop visit (e.g. the browser used, the IP address) and purchasing behavior (e.g. products ordered) is recorded without personal reference and transmitted to Google. Google uses cookies for the purposes of recognizing and assigning users.

If you do not want to receive interest-based advertising, you can deactivate Google's use of cookies for these purposes by visiting https://www.google.de/settings/ads/onweb. Alternatively, users may opt out of the use of third-party cookies by visiting the Network Advertising Initiative opt-out page.

Microsoft Bing Ads
We use Microsoft Bing Ads from Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”) and in connection with it the Universal Event Tracking (UET) tool: https://advertise.bingads.microsoft.com /de-de/solutions/functions/universal-event-tracking. On the one hand, we can use this to track, among other things, whether an ad led to a purchase/conversion goal - so-called completion tracking. On the other hand, remarketing target groups can be created. If you can be assigned to a corresponding user group, we can in the future show you advertisements optimized for your interests on sites maintained and operated by Bing and Bing partner sites, e.gmake available. The cookies used in Universal Event Tracking (UET) remain on your computer for up to 180 days. No personal information about the user's identity is shared. If you do not want to take part in the tracking process, you can also refuse to set a cookie required for this - For example, via a browser setting that generally deactivates the automatic setting of cookies. Further information about data protection and the cookies used by Microsoft Bing can be found on the Microsoft website: https://advertise.bingads.microsoft.com/de-de/immobilien/linien/linien-zur-datensicherheit-und-datnschutzerklaerung.

Facebook We use the “Website Custom Audiences” Pixel from the social network Facebook (1601 South California Avenue, Palo Alto, CA 94304, USA). So-called “counting pixels” integrated on our pages. When you visit our pages, a direct connection is established between your browser and the Facebook server via the counting pixel. Facebook thereby receives, among other things, the information from your browser that our site was accessed from your device. If you are a Facebook user, Facebook can assign your visit to our pages to your user account. We would like to point out that as users of the tracking service we do not receive any information about Facebook profiles or user activities.

If you do not want to consent to data collection by Facebook, you can deactivate this under Facebook Ads.

When using Facebook advertising, Raisin can only select which anonymous segments of Facebook users (such as age, interests) our advertising should be shown. Further information can be found in Facebook's data protection declaration at https://www.facebook.com/about/privacy/.

LinkedIn

On our website we use the analysis — and conversion tracking technology from the LinkedIn platform, an offering from LinkedIn (Ireland, Wilton Plaza, Wilton Place, Dublin 2). For this purpose, the LinkedIn Insight Tag is integrated into our website. LinkedIn's aforementioned technology can be used to show you more relevant advertising based on your interests. We also receive aggregated and anonymous reports of ad activity and information about how you interact with our website from LinkedIn. You can object to LinkedIn analyzing your usage behavior and displaying interest-based recommendations (“opt-out”). To do this, follow this link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. Further information can also be found in LinkedIn's data protection declaration.

AdDefend
We use AdDefend, a service provided by AdDefend GmbH, Borselstrasse 3, 22765 Hamburg, to display advertising. This service uses cookies to determine whether you have visited a website before. You can object to AdDefend's use of these cookies at any time by using the opt-out option at https://www.addefend.com/de/opt-out/.

Cookies by advertising networks (affiliates or publishers)
We work with advertising networks to display banner ads on our website. This is necessary in order to continue to offer our website free of charge to you. When you visit our website, tracking cookies from affiliates or publishers are set, which remain stored beyond your current visit to our offers. These cookies do not store any personal data. Rather, only the identification number of the intermediary partner and the serial number of the advertising material clicked on by the website visitor are recorded. When a transaction is completed, the partner identification number is used to assign the commission to be paid to the brokering partner. It is possible that when redirects from marketing partner websites to zinspilot.de, an identifier is stored in the cookie so that the redirect can later be assigned to the correct partner. Cookies are currently set by the partners financeAds, Moneytrax and Adcell.

If you do not wish to use cookies of this type or would like to delete existing cookies, you can switch them off and remove them via your internet browser. You can find more information about deleting or preventing cookies in the help texts for your browser or on the Internet using the search terms “delete cookies”. or “Cookies disabledivate”.

Conversion measurement with the Facebook conversion pixel
We set the “conversion pixel” or visitor action pixels from Facebook Inc. (1601 S. California Ave, Palo Alto, CA 94304, USA; “Facebook”). By calling up this pixel from your browser, Facebook can subsequently recognize whether a Facebook ad was successful, for example, whether it led to an online purchase. We only receive statistical data from Facebook without reference to a specific person. This allows us to record the effectiveness of Facebook advertisements for statistical and market research purposes. In particular, if you are logged in to Facebook, we would like to refer you to their data protection information https://www.facebook.com/about/privacy/.

Please click on the following link here: https://www.facebook.com/settings?tab=ads if you would like to revoke your consent to Conversion Pixel.

Hotjar
Our website uses Hotjar, a web analysis service provided by Hotjar Ltd (Hotjar). Hotjar uses so-called “cookies”, text files that are stored on your computer and that enable your use of the website to be analyzed. The information generated by the cookie about your use of our website is usually transmitted to a Hotjar server in Ireland and stored there. The IP address transmitted by your browser as part of Hotjar will not be merged with other Hotjar data. You can prevent the storage of cookies by setting your browser software accordingly; However, we would like to point out that in this case you may not be able to fully use all of the functions of our website. You can also deactivate Hotjar tracking at any time (and thus prevent the data generated by the cookie and related to your use of the website, including your IP address, from being sent to Hotjar and the processing of this data by Hotjar) by Follow the instructions to turn off Hotjar.

Mix panel
We use Mixpanel, a web analytics service from Mixpanel, Inc. (“Mixpanel”). Mixpanel uses so-called “cookies”, text files that are stored on your computer and that enable your use of the website to be analyzed. The information generated by the cookie about your use of this website is usually transferred to a Mixpanel server in the USA and stored there. The IP address transmitted by your browser as part of Mixpanel will not be merged with other Mixpanel data. You can prevent the storage of cookies by setting your browser software accordingly; However, we would like to point out that in this case you may not be able to fully use all of the functions of this website. You can also deactivate Mixpanel tracking at any time (and thus prevent the data generated by the cookie and related to your use of the website, including your IP address, from being sent to Mixpanel and the processing of this data by Mixpanel) by You can deactivate Mixpanel.

Tisoomi
We use Tisoomi, a service provided by Tisoomi GmbH, Gänsemarkt 31, 20537 Hamburg, to display advertising. This service uses a tracking pixel to track registrations. You can object to the use of this tracking pixel at any time by using the opt-out option at https://www.tisoomi-services.com/datasecurity#optout.

15. USE OF NEWSLETTER SOFTWARE
Raisin can send promotional newsletters via email to users who have consented to this. To provide the services, the user data is stored and managed by software-as-a-service providers for mailing systems (with double opt-in). The service providers are obliged to comply with data protection law and, where applicable, telecommunications secrecy. In addition, an order data processing agreement within the meaning of Art. 28 GDPR has been concluded with the provider. Raisin works with service providers who store data exclusively on servers within the European Union.

Raisin works with the service provider episerver Deutschland, Wallstraße 16, 10179 Berlin. User data is transmitted to episerver via an encrypted server connection (SFTP). This includes personal data such as name, gender, date of birth, as well as behavioral data regarding the use of our products, for example number/amount of visitsGten attachments, type of attachment or date of last attachment.

We reserve the right to use your email address, which we receive in connection with your registration, to advertise our own similar goods from Raisin or its subsidiaries, unless you have objected to this. You can object to this use at any time without incurring any costs other than transmission costs according to the basic tariffs for the objection.

You can revoke your consent to the storage of data, the email address and their use to send the newsletter at any time at service@zinspilot.de. Alternatively, we offer you an opt-out link in every newsletter through which you can object to further sending of advertising emails in the future.

16. DATA TRANSFER TO EXTERNAL PARTNERS

For the purpose of processing the investment, only the following data is transmitted to external partners: first name, last name, product(s), term(s), investment amount(s). In addition, contract data processing within the meaning of Art. 26 GDPR has been concluded with the partners.

The above-mentioned data is currently being transmitted to the following partners

Weser-Elbe-Sparkasse, Mayor-Smidt-Str. 24-30, 27568 Bremerhaven
FinMarie GmbH, Kurfürstendamm 194, 10707 Berlin
Sparkasse Neu-Ulm - Illertissen, Insel 13, 89231 Neu-Ulm
17. USE OF A TELEPHONE SYSTEM TO PROCESS CUSTOMER SERVICE
In order to ensure that you as a customer can be reached easily by telephone, we use the services of nextID GmbH, Konrad-Zuse-Platz, 53227 Bonn, for our telephony system. nextID GmbH is the body responsible for processing data within the meaning of the GDPR and is not used by us as a processor. If you have any questions about data protection, please contact nextID GmbH directly. Further information can be found at https://www.next-id.de/datenschutz NOTES/.

18. DATA SECURITY
We will comply with all reasonable technical and organizational security measures to protect personal data from loss, unauthorized access or other misuse. The data is stored in a secure operating environment that is not accessible to the public. In certain cases (e.g. when processing login data), the personal data is encrypted during transmission.