This privacy policy applies exclusively to the use of our website www.mifid-recorder.com and all its subpages. It contains detailed information about what we do with your personal data when you visit our website. We attach great importance to ensuring that your visit to our website is secure and that the processing of your data is transparent for you.

The responsible party within the meaning of the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union, and other provisions of a data protection nature is:

MiFID-Recorder GmbH
Managing Directors: Thomas Jasper, Pius Stucki
Rüdesheimer Strasse 11
80686 Munich
Germany
Tel.: +49 89 7244 9740
Email: kontakt@mifid-recorder.com
Website: www.mifid-recorder.com

You are welcome to contact our data protection officer with any suggestions, complaints, or requests. You can reach him using the following information.

Email: DSB@etops.com. If you wish to contact him by post, please use the following address: niiio finance group AG, Attn: Group Data Protection Officer, Konsulplatz 10, 02826 Görlitz, Germany

We use technical and organizational security measures to protect the data we process against manipulation, loss, destruction and access by unauthorized persons. We continuously improve our security measures in line with technological developments and have them regularly reviewed by an external auditor.

 

In addition, we use SSL or TLS encryption for security reasons and to protect the transmission of confidential content. You can recognize an encrypted connection by changing the browser’s address line from “http://” to “https://” and by the lock symbol in your browser line. If SSL or TLS encryption is activated, third parties cannot read the data you transmit to us.

In principle, you will find the respective legal bases under the purposes of processing; the following overview is intended to provide a quick overview of all applicable legal bases:

If you have given us your consent to process your personal data, this constitutes the legal basis for the processing (Article 6(1)(a) GDPR).

For processing personal data to initiate or fulfil a contract with you, Article 6(1)(b) GDPR is the legal basis.

Insofar as the processing of your personal data is necessary to fulfil our legal obligations (e.g. to store data), we are authorized to do so under Article 6 (1) (c) GDPR.

We also process personal data under Article 6 (1) (f) GDPR for the purposes of our legitimate interests and the legitimate interests of third parties.

As part of the necessary balancing of interests, we consider the type of personal data collected from you, the purpose of processing, the circumstances of processing and your interest in the confidentiality of your personal data.

Cookies are stored and read based on Section 25 TDDDG .

We want to point out that some functions of our website are linked to providing personal data. If you do not wish to provide us with your personal data in these cases, this may mean that the desired function (e.g. a download) is not available or only available to a limited extent.

Responsible party: Etops Group AG, MiFID-Recorder GmbH,

Which data: The following data is collected from you when you use our contact form: Title, first name and surname, email address, telephone number, company name, message that you send us

Purpose of data processing: We use your data to process your inquiry and store your contact in our CRM system Hubspot if you have expressed an interest in our products in your inquiry.

Legal basis: Art. 6 para. 1 lit. b and f GDPR

Duration of storage: If your request is independent of our products, we will delete your data six months after the final response to your request. If we conclude a service contract with you based on your inquiry, the transmitted data will be stored to process the contract in compliance with the statutory provisions. If no service contract is concluded with you, we will delete your data two years after your last contact.

third-party providers/recipients/processors: If your contact request results in email communication, this will be conducted via Microsoft Outlook (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, US and Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich, Germany). Further information and the data protection provisions can be found in Microsoft’s privacy policy at https://www.microsoft.com/en-us/privacy/privacystatement

If you have expressed interest in our products in your contact request, we will store your contact information in our CRM system, HubSpot (HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA). Further information and the data protection provisions can be found in HubSpot’s privacy policy at https://legal.hubspot.com/privacy-policy

Third-country transfer: The providers HubSpot and Microsoft are based in the USA, so the data you submit is also processed in a third country. We have concluded EU-standard contractual clauses with the providers to guarantee an appropriate level of data protection.

We use cookies to make visiting our website more attractive and to enable certain functions. To explain this to you, cookies are small files stored on your desktop, notebook, or mobile device during your visit to our website. This allows us to recognize, for example, whether there has been a connection between your device and our website in the past. It also reads out, for example, your preferred language or other settings that you have selected on our website. Cookies may also contain personal data.

Whether and which cookies are used when you visit our website depends on which areas and functions you use and whether you consent to the use of cookies that are not absolutely necessary, i.e., typically essential for technical reasons.

Types of cookies and how to activate them

Necessary cookies/technically essential cookies: Certain cookies we use are necessary to enable you to move around a website and use its features. Without these cookies, actions such as text input made during a visit cannot be retained, even if you navigate between individual website pages.

Functional cookies: These enable our website to store information that has already been entered (such as language selection) and to offer you improved, personalized functions based on your interaction with the website. We or third-party providers whose services we use may set these cookies.

Performance cookies: These collect information about how a website is used and enable us to carry out analyses, such as which sub-pages are accessed most frequently. These cookies are used exclusively to improve the website’s performance and, thus, the user experience. They may be set by us or by third-party providers.

Marketing cookies: We use these to show you relevant content that matches your interests. These cookies may be set by us or by third-party providers whose services we use.

You can influence the use of cookies. Most browsers have an option that limits or completely prevents the storage of cookies.

Your consent to our cookies is tied to the device and web browser you use. If you use multiple devices and/or web browsers, you can make your decisions and the settings concerned differently for each one.

Suppose you decide against the use of cookies or delete them. In that case, it is possible that not all functions of our websites will be available to you or that individual functions will only be available to you to a limited extent.

Cookie services from third-party providers

Our website also uses so-called third-party cookies, which are managed by third parties to provide certain services. You can find the cookie settings you have made and information about which third-party providers store which data, for what purpose, for how long, and on what legal basis in detail at any time via our cookie manager (which can be accessed in the bottom left corner).

We also use third-party providers on our website. Below are all the third-party providers used. You can view this information at any time in our cookie manager (accessible in the bottom left corner).

Cookie Consent Manager CCM19
Purpose: Our website uses the cookie consent technology of CCM19 to obtain your consent to the storage of certain cookies in your browser and to document them in a data protection-compliant manner.
Provider of this technology is Papoo Software & Media GmbH, Auguststr. 4, 53229 Bonn.
What data is collected by the provider: none
Legal basis: Art. 6 para. 1 sentence 1 lit. c GDPR, § 25 TDDDG and Art. 17 sentence 1 b.2 DSB (Switzerland).
Link to the privacy policy of the provider: https://www.ccm19.de/en/privacyclarification.html

HubSpot
Purpose: Marketing and sales activities (CRM tool).
Provider of this technology is HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA.
What data is collected by the provider? The data is entered via the forms. More detailed information can be found in the section Legal basis for processing your personal data.
Legal basis: Art. 6 para. 1 sentence 1 lit. a, b, f GDPR
Link to privacy policy of the provider: https://legal.hubspot.com/privacy-policy

Google Ads
Purpose: For marketing purposes, it enables us to draw attention to our products with the help of advertising material on external websites and to determine how successful individual advertising measures are.
Provider of this technology is Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland.
What data is collected by the provider: This varies depending on your personal Google account settings.
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the privacy policy of the provider: https://policies.google.com/technologies/ads?hl=en

Google Analytics
Purpose: For marketing and analytical purposes, to provide us with insights and statistics on how visitors interact with our website to improve the user experience.
Provider of this technology is Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland.
What data is collected by the provider: the browser you use, your operating system, the date and time of your visit, the access status (e.g. whether you received an error message), the use of website functions, the search terms you entered, the frequency with which you access individual sub-pages of our website, the names of files retrieved and how often, the data volumes transferred, the loading times of the sub-pages accessed, the website from which you accessed our website, the website you visited from our website (e.g. by clicking on links), your IP address, the name of your internet service provider, the clicks you have made on our website and their frequency, your movement behavior on our website (behavioral flow analysis and user path), the areas of our website you have selected and clicked on, JavaScript error messages during your visit, whether and how often you clicked on non-functional areas of our website (so-called dead clicks), whether you repeatedly clicked on certain elements and which ones (so-called rage clicks), video retrieval and time of video viewing, a recording of your session on our website (session replay), provided you have authorized this in your own Google account: age, gender, country, location, type of device used, network and your interests, as part of campaign actions: campaign URL, campaign source, campaign medium
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the provider’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en

Google Tag Manager
Purpose: For marketing and analysis purposes.
Provider of this technology is Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland.
What data is collected by the provider: none
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the provider’s privacy policy: https://policies.google.com/technologies/ads?hl=en

Microsoft Clarity
Purpose: For analysis purposes, to better understand what happens on our website from the viewer’s perspective and to use this information to optimize the website in order to provide you with a better user experience.
Provider of this technology is Microsoft Schweiz GmbH The Circle, P.O. Box, 8058 Zurich Airport, Switzerland and Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.
What data is collected by the provider: none
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the provider’s privacy policy: https://privacy.microsoft.com/privacystatement

LinkedIn
Purpose: For marketing purposes, it enables us to increase the visibility of our products.
The provider of this technology is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland
What data is collected by the provider: Device information, IP address, timestamp, referrer URL, browser information
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the provider’s privacy policy: https://www.linkedin.com/legal/privacy-policy

YouTube
Purpose: For analysis purposes, to better understand what viewers are doing on our website and to use this information to optimize the website in order to create a better visitor experience for you as a user.
The provider of this technology is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
What data is collected by the provider: If you are logged in to YouTube, YouTube recognizes which specific subpage of our website you are visiting when you call up a subpage that contains a YouTube video. This information is collected by YouTube and Google and assigned to the respective YouTube account.
Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR
Link to the provider’s privacy policy: www.google.de/intl/de/policies/privacy/

Leadinfo
Purpose: For analysis purposes, to be able to track which companies visit our website based on IP addresses.
The provider of this technology is Leadinfo B.V., Rivium Quadrant 141, 2909LC Capelle aan den IJssel, Netherlands.
What data is collected by the provider: IP address and publicly available information about the company, such as company name and address. On this page: www.leadinfo.com/en/opt-out you have the option to opt out. If you opt out, your data will no longer be collected by Leadinfo.
Legal basis: Art. 6 (1) (a) GDPR
Link to the provider’s privacy policy: https://www.leadinfo.com/de/rechtliches/datenschutz/

– Information (Article 15 GDPR)

You have the right to request confirmation from us as to whether we are processing your personal data. If such processing has taken place, you have the right to request information about the personal data concerning you that we have processed, the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients to whom your data has been or will be disclosed, the planned storage period or the criteria for determining the storage period, the origin of your data if we did not collect it from you, the existence of automated decision-making including profiling and, where applicable, meaningful information about the logic involved and the significance and the envisaged consequences of such processing for you, as well as your right, to be informed of the safeguards under Article 46 GDPR for the transfer of your data to third countries.

– Rectification (Article 16 GDPR)

You have the right to request the immediate correction of incorrect personal data concerning you and/or the completion of your incomplete data at any time. Please provide us with the relevant data using the contact form.

– Data deletion (Article 17 GDPR)

You have the right to request the deletion of your personal data if one of the following reasons applies to you:

the personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

you withdraw your consent on which the processing is based according to point (a) of Article 6(1) or point (a) of Article 9(2) GDPR and where there is no other legal ground for the processing.

You object to the processing under Article 21(1) of the GDPR, and there are no overriding legitimate reasons for the processing. You object to the processing in accordance with Article 21(2) of the GDPR.

your personal data has been unlawfully processed.

Deleting your personal data is necessary to fulfil a legal obligation under Union or national law to which the controller is subject.

your personal data has been collected in relation to information society services offered under Article 8 (1) GDPR.

Suppose we have made your personal data public and are obliged to delete it under Article 17 (1) of the GDPR. In that case, we will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform those responsible for the processing that you, as the data subject, have requested the deletion of all links to the personal data or of copies or replications of this personal data.

The right to erasure does not apply if processing is necessary for us. If this is the case, we will provide you with comprehensive information.

– Restriction of processing (Article 18 GDPR)

You have the right to request the restriction of the processing of your personal data under the following conditions:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. During the review, you have the right to demand that the processing of your personal data be restricted.

If the processing was or is unlawful, you may request its use restriction instead of deletion.

If we no longer need your personal data, but you need it to assert, exercise or defend legal claims, you can demand the restriction of its use instead of deletion or

If you have objected to processing under Article 21(1) of the GDPR, a balance must be struck between your interests and ours. If it is not yet clear whose interests prevail, you have the right to demand that the processing of your personal data be restricted.

If you have restricted the processing of your personal data, these data – apart from being stored – may be processed only with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or on the grounds of a significant public interest of the EU or a Member State.

If the processing restriction has been set in accordance with the above conditions, we will inform you before the restriction is lifted.

– Data portability (Article 20 GDPR)

Suppose the processing is based on your consent under Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract under Article 6(1)(b) GDPR and is carried out by automated means. In that case, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller or to request the transmission to another controller as far as technically feasible.

– Revocation of consent

If you have given us consent, you have the right to revoke it at any time in the future. This means that the revocation does not affect the legality of the previous processing of your personal data. We are no longer allowed to process your data based on consent from the time of the revocation. Likewise, your revocation does not affect further processing of this data on another legal basis, such as fulfilling legal obligations.

You can end the revocation of your newsletter subscription at any time by using the unsubscribe option provided in the newsletter. You do not need to assert your rights under point d below.

– Objection (Article 21 GDPR)

Insofar as we base the processing of your personal data on the weighing of interests under Article 6 (1) (f) GDPR, you have the right at any time, for reasons that arise from your particular situation, to object to the processing of your personal data; this also applies to profiling based on this provision. If you file an objection, we will no longer process your personal data unless we can prove compelling reasons for the processing worthy of protection that outweighs your interests, rights and freedoms or the processing serves the assertion, exercise or defence of legal claims. Where your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object, your personal data will no longer be processed for direct marketing purposes.

We ask that you please assert your rights as a data subject in the following contact form if possible:

When using service providers and passing on data to third parties with your consent, personal data may be transferred to recipients in countries outside the European Union (“EU”), Iceland, Liechtenstein and Norway (= European Economic Area) and processed there. You can find detailed information on this in the section on the respective purposes for data processing in the section “Which data, for which purpose, with which legal basis, for which duration, to which third country are transferred and, if applicable, with the involvement of which third-party provider are processed by us?”

From the EU’s point of view, countries with adequate protection for processing personal data in line with EU standards can be approved with a so-called adequacy decision. The current list can be found at:

https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

We agree to apply the EU standard contractual clauses (Implementing decision – 2021/914 – EN – EUR-Lex) with recipients in countries without an adequacy decision to create an “adequate level of protection” in accordance with the legal requirements. We will be happy to provide you with information on this. Please use the contact form.

If you believe that the processing of your personal data violates legal requirements, you have the right to lodge a complaint with a data protection supervisory authority (Article 77 GDPR). As the data subject, you are free to choose which supervisory authority you wish to contact.
The supervisory authority responsible for us is:

The Bavarian State Commissioner for Data Protection
P.O. Box 22 12 19, 80502 Munich, Germany
Phone: +49 89 212672-0, email: poststelle@datenschutz-bayern.de

In addition, you can find all supervisory authorities for the EU at: https://www.edpb.europa.eu/about-edpb/about-edpb/members_de#member-at and for Germany at: https://www.datenschutz-bayern.de/zustaendigkeiten/

This privacy policy is valid from 17.03.2025. We reserve the right to change this privacy policy at any time in compliance with the applicable data protection regulations. This may be necessary, for example, to comply with new legislation or to consider changes to our website or new services on our website. The version available at the time of your visit applies.

If this data protection declaration changes, the current version will be available on our website. Please use the contact form if you have any questions about the changes.