Privacy Policy

Conditions of Participation and Use for the Holdings.STO Waitlist Procedure

Information pursuant to Articles 13, 14 and 21 of the GDPR (General Data Protection Regulation)

Protection of your privacy is important to us. Here you can find out which personal data we will collect when you visit our website, why we do it, how we process the data and how we protect it. Moreover, we inform you about your rights regarding data protection.

1. Who we are?

We, Bitbond Finance GmbH, are the operator of this website www.holdings.sto. As such we are responsible for the protection of the processed personal data. Please contact us if you have any questions about this Privacy Policy or the Protection of your data:

Bitbond Finance GmbH
Strelitzer Str. 60
10115 Berlin

Phone: +49 30 5683 8191
Email: invest@holdings.sto

2. What data we use and how we obtain it?

When we process personal data, this means that we collect, store, submit, delete or use personal data in some other form. ‘Personal data’ means any information relating to a natural person, e.g.:

  • anyone who visits our website,
  • people who signed up for our Waitlist.

When you visit our website, we process usage and log data, such as:

  • IP address of the accessing computer,
  • name of the retrieved file,
  • date and time of retrieval,
  • amount of data transferred,
  • notification of successful retrieval,
  • browser type and version as well as the operating system you are using,
  • referrer URL,
  • requesting provider,
  • screen resolution.

If you sign up for our Waitlist and/or our Newsletter, we will process your personal data and contact details, e.g.:

  • name,
  • Email address,
  • telephone number.

How and on what legal basis do we process your data when you visit our website?

Log data

If you visit our website we process usage and log data to display our website and to ensure its stability and security. Moreover, we use the protocol data for statistical evaluations in the context of our website’s operation.

In the case of the unlawful use of our website, the protocol data facilitate detection of possible breach or rights violation - for example, in the case of a cyber attack on our website. We use your data in these cases to defend against the attack and to determine the origin of the attack with the aim of taking criminal and civil action against the responsible persons and preventing future attacks more effectively.

The data mentioned above is processed on the basis of a balancing of interests in accordance with Article 6(1)(1)(f) GDPR.

Cookies

Our website contains cookies. Cookies are text files that are stored in the internet browser or by the internet browser on your end device. The cookie contains a string of characters that enables the unique identification of your system when you return to the website. The cookies are transferred to your browser either from our server or a third-party server.

Technically required cookies

We use technically required cookies to make the use of this website safer and more user-friendly. Among other things, these cookies can ensure the availability of content and prevent the repeated loading of content. Some elements of this website also require that the requesting browser can be identified even after a page change. The data collected from you using these technically necessary cookies will not be used to create user profiles. The following data is stored and transmitted in the cookies:

  • current session ID
  • use of certain website content, e.g. frequency or extent of use
  • taking note of certain website contents, e.g. product information
  • language settings

Processing is based on a balancing of interests that always takes your interests into account according to Article 6(1)(1)(f) GDPR.

Most of the cookies ("session cookies") used by us and the data stored and transmitted therein are automatically deleted at the end of your visit. Other cookies ("persistent cookies") remain stored on your device until you delete them.

You can set your browser in such a way that you are informed about the setting of cookies and only allow the acceptance of cookies for certain cases, or generally exclude it. You can also activate the automatic deletion of cookies when closing the browser. You can delete cookies that have already been stored at any time. When cookies are deactivated, the functionality of our website may be limited.

Analytical cookies

We also use cookies to analyze your surfing behavior for advertising purposes and to measure reach. Your data collected in this way will be pseudonymized through technical measures. The data will not be stored together with other personal data that we collect from you.

Information on specific ways to opt out of the use of analytic cookies can be found in the corresponding description of the cookie. You can also usually 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 you close your browser. You can delete cookies that have already been saved at any time. When cookies are deactivated, the functionality of this website may be limited.

The processing of data by means of cookies is based on a balance of interests that always also takes your interests into account article 6(1)(1)(f) GDPR. Our legitimate interest in the processing lies in the aforementioned purposes of the use of the respective cookies. Where required, the legal basis for the data processing is your given consent as per article 6(1)(1)(a) GDPR.

We use analytical cookies by the following service providers:

Google Analytics

The website uses Google Analytics, a web analysis service of Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA (‘Google’).

Google Analytics also uses cookies which are stored on your end device and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there on the basis of a data processing agreement that we have concluded with Google according to article 28 GDPR.

However, as part of the IP anonymization activated for this website, your IP address will be shortened by Google within member states of the European Union or in other signatories to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on our behalf to analyze your use of the website, to compile reports on website activity, and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics will not be merged with other Google data.

This website uses Google Analytics with the extension ‘_anonymizeIp()’. This means that IP addresses are further processed in abbreviated form so that they cannot be linked to a particular individual. Insofar as the data collected about you is personally identifiable, it will be excluded immediately and the personally identifiable data will be promptly deleted.

We use Google Analytics to analyze and improve the use of this website on a regular basis. Using the statistics we acquire, we can improve our service to you and make it more interesting for you as a user. In the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

The information for the provider of Google Analytics can be found here: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland. Fax: +353 (1) 436 1001. You can find the terms of service here: https://www.google.com/analytics/terms/us.html.

Information on data protection can be found at http://www.google.com/analytics/learn/privacy.html and in Google’s privacy policy at http://www.google.de/policies/privacy.

You can prevent Google from collecting the data related to your use of the website generated by the cookie (including your IP address) and Google’s processing of this data by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

You can also prevent the collection of data by Google Analytics by clicking on the following link. An opt-out cookie will then be set to prevent future collection of your data when you visit this website: https://tools.google.com/dlpage/gaoptout/eula.html.

Google Ads Conversion

We use the services of Google Ads Conversion to draw attention to our attractive offers with the help of advertising media (so-called Google Ads) on external websites. In relation to the data of the advertising campaigns, we can determine how successful the individual advertising measures are. In doing so, we pursue the interest of displaying advertising to you that is of interest to you, of making our website more interesting for you and of achieving a fair calculation of advertising costs.

These advertising media are delivered by Google via so-called "Ad Servers". We use ad server cookies for this purpose, which can be used to measure certain parameters for measuring success, such as the display of ads or clicks by users. If you access our website via a Google advertisement, Google Ads stores a cookie on your terminal device. These cookies usually lose their validity after 30 days and are not intended to identify you personally. For this cookie, the unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be addressed) are usually stored as analysis values.

These cookies enable Google to recognize your Internet browser. If a user visits certain pages on an ad customer's website and the cookie stored on their computer has not expired, Google and the customer may recognize that the user clicked on the ad and was directed to that page. Each ads customer is assigned a different cookie. Cookies cannot therefore be tracked through the websites of ads customers. We ourselves do not collect or process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. These evaluations enable us to identify which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising media; in particular, we cannot identify users on the basis of this information.

Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the extent and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: By integrating Ads Conversion, Google receives the information that you have called the relevant part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible for the provider to find out and store your IP address.

Google Ads Remarketing

We use the remarketing function within the Google Ads service. With the remarketing function we can present users of our website on other websites within the Google advertising network (in Google search or on YouTube, so-called "Google ads" or on other websites) ads based on their interests. For this purpose, the interaction of users on our website is analysed, e.g. which offers the user is interested in in order to be able to display targeted advertising to users on other pages even after they have visited our website. For this purpose, Google stores a number in the browsers of users who visit certain Google services or websites in the Google display network. This number, known as a "cookie," is used to track the visits of these users. This number is used to uniquely identify a web browser on a particular device and not to identify a person; personal data is not stored.

Google Ads Opt-out

You can prevent participation in this tracking procedure by Google Ads Conversion and Remarketing in different ways:

by an appropriate setting in your browser software, in particular, the disabling of third-party cookies, such will result in you not receiving ads from third-party providers;

by disabling cookies for conversion tracking, by setting your browser to block cookies from the “www.googleadservices.com” domain, https://www.google.de/settings/ads, whereby this setting will be erased when you erase your cookies;

by deactivating the provider’s interest-themed ads that are part of the self-regulation campaign “About Ads” at the link http://www.aboutads.info/choices, whereby this setting will be erased when you erase your cookies;

by means of permanent deactivation in the browsers Firefox, Internet Explorer or Google Chrome under the link http://www.google.com/settings/ads/plugin. Please note that in this case you may not have full use of all the functions on this website.

Further information on data protection at Google can be found here: http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/en.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) under http://www.networkadvertising.org besuchen. Google complies with the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

The legal basis for the data processing is your given consent as per article 6(1)(1)(a) GDPR.

How and on what legal basis do we process your data when you sign up for our Waitlist and/or our Newsletter?

On our website you can sign up for our Waitlist. Subscribers to our Waitlist will be informed in good time about the start of the Bitbond STO and will receive an invitation for participation in the Public Sale. For more information refer to the Terms & Conditions on the Bitbond STO Waitlist procedure:

To sign up for the Waitlist you have to enter your name and your email address. If you wish to receive more information about early investors’ discounts by us via telephone you may additionally enter your telephone number.

When signing up for the Waitlist you can choose also to sign up for our Newsletter. Our Newsletter will provide you with the latest news about the planned Bitbond STO.

Registration for the Waitlist requires a double opt-in. After having signed up for the Waitlist by clicking on the button labelled “Submit” you will receive an email asking you to confirm your registration by clicking on a link in the email. If you confirm your registration within the specified time, your email address and – if applicable – your telephone number will be stored for the purposes stated. Otherwise your data will be automatically deleted after the specified time.

The legal basis for the data processing is your given consent as per article 6(1)(1)(a) GDPR.

You can object to the use of your email address at any time, i.e. revoke your consent. You will find a link to unsubscribe from our newsletter at the end of each newsletter. We may save the submitted email addresses for up to three years before we delete them based on our legitimate interest to prove your prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

Upon registration, we also store your IP address and the time of registration and confirmation in order to being able to prove your registration and, if necessary, to clarify any misuse of your personal data. The legal basis for this is article 6(1)(1)(f) GDPR.

For the registration process we use the services provided by TYPEFORM S.L. (“Typeform”), a Spanish company with registered address at Carrer Bac de Roda, 163, 08018 Barcelona, and C.I.F. (tax identification code) B65831836. Typeform’s privacy policy can be found here: https://admin.typeform.com/to/dwk6gt.

For the storage of the entered data and the sending of the email messages we use MailChimp, a newsletter-mailing service provider of Rocket Science Group, LLC, 675 Ponce De Leon Ave # 5000, Atlanta, GA 30308, USA. The privacy policy of MailChimp can be found here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC is certified under the EU-US Privacy Shield Agreement, which provides a guarantee to comply with European data protection standards: https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active.

The use of Typeform’s services and of MailChimp is based our legitimate interests according to article 6(1)(1)(f) GDPR and the data processing agreement according to article 28(3)(1) GDPR we have concluded with Typeform and the Rocket Science Group.

MailChimp may use the data of our newsletter-recipients in a pseudonymized form, i.e. without assignment to a user, to optimize or improve its own services, e.g. for the technical optimization of mailings and the presentation of newsletters or for statistical purposes. However, MailChimp itself does not use the data of our newsletter recipients to contact them or to pass the data on to third parties.

YouTube Videos

We have included YouTube videos on our website, which are stored at http://www.YouTube.com and can be played directly from our website. These are all integrated in the "extended data protection mode", i.e. no data about you as a user is transferred to YouTube if you do not play the videos. Only when you play the videos will the data mentioned in the next paragraph be transmitted. We have no influence on this data transfer.

When you visit the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, your IP address will be sent to YouTube and cookies will be installed on your machine. This occurs regardless of whether YouTube provides a user account that you are logged in to or whether there is no user account. If you are logged in to Google, your data will be assigned directly to your account. If you do not wish your profile to be associated with YouTube, you must log out before activating the button. YouTube stores your data as user profiles and uses them for advertising, market research and/or the design of its website to meet your needs. Such evaluation is carried out in particular (even for users who are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

Further information on the purpose and scope of data collection and processing by YouTube can be found in the Privacy Policy. There you will also find further information on your rights and setting options to protect your privacy:

https://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Your data will be processed on the basis of a balance of interests that always takes your interests into account according to Article 6(1)(1)(f) GDPR.

Who receives my data?

We will transmit your personal data only if you have given your consent, if there is a legal basis for such, or it is necessary for enforcing our rights. We will transmit your data to service providers only if these meet the relevant data protection requirements.

When do we delete your data?

We will delete your data, as soon as the data is no longer needed for the purpose for which it was originally collected. For example, we will delete your usage data after your visit to our website, if we are not allowed to process it in the anonymized or pseudo-anonymized form for statistical purposes, as described above. For example, we delete your data from inquiries immediately after successful processing, if we are not allowed to process them further in order to provide you with information on new developments and events. In addition, we store your data even after fulfilment of the original collection purpose, if we are obliged to store them for other reasons, e.g. for archiving.

Will your data be transferred to a third country or an international organization?

If we process data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of article 44 ff. GDPR. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

What rights do you have when it comes to processing your data?

Regarding protection of your personal data, you have the following rights:

  • the right to be informed in accordance with article 15 GDPR,
  • the right to correct and update your data in accordance with article 16 GDPR,
  • the right to delete your data in accordance with article 17 GDPR,
  • the right to restrict the data processing in accordance with article 18 GDPR,
  • the right to data transferability in accordance with the article 20 GDPR.

Your right to information and the data deletion are subject to limitations set out in Sections 34 and 35 of the German Federal Data Protection Act. In addition, you have a right of appeal to the data protection supervisory authority (article 77 GDPR in connection with section 19 of the German Federal Data Protection Act).

Will we use your data for automated decisions making including profiling?

Data from visits to this website will not be used for automated decision-making or profiling in terms of article 22 GDPR.

Information on your right of objection in accordance with Article 21 GDPR

Individual case-related right of objection

You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data relating to you, which is required by art. 6(1)(e) GDPR (data processing due to public interest) and article 6(1)(f) GDPR (data processing due to balancing of interests); this also applies to the profiling based on this provision within the meaning of article 4 no. 4 of the GDPR.

If you object, we will no longer process your personal data, unless we can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

Objection to the processing of your data for our direct marketing purposes

In individual cases, we may process your personal data for our direct marketing and advertising. You have the right to object to processing of your personal data for the purposes of such advertising at any time; this also applies to the profiling, as far as it is associated with such direct marketing.

If you object to the data processing for direct marketing purposes, we will not process your personal data for these purposes.

Your objection does not need any special form. Please send it to the following address:

Bitbond Finance GmbH
Strelitzer Str. 60
10115 Berlin

Phone: +49 30 5683 8191
Email: invest@holdings.sto