DATA PROTECTION

1. Introduction
With the following information we would like to give you as the “data subject” an overview of the processing of your personal data by us and your rights under data protection laws. It is generally possible to use our website without entering personal data. However, if you would like to use our company’s special services via our website, processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain your consent.

The processing of personal data, such as your name, address or email address, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to “Walluta GmbH”. With this data protection declaration we would like to inform you about the scope and purpose of the personal data we collect, use and process.

As the person responsible for processing, we have implemented numerous technical and organizational measures to ensure the most complete protection possible for the personal data processed via this website. However, internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, you are free to transmit personal data to us by alternative means, for example by telephone or post.

2. Responsible person
The person responsible within the meaning of the GDPR is:

Walluta GmbH
Sierksdorferstrasse 14a
23730 Neustadt in Holstein
Germany

Representative of the person responsible: Werner Wildberger

3. Data protection officer

You can reach the data protection officer as follows:
e-mail: info@walluta.de

If you have any questions or suggestions regarding data protection, you can contact our data protection officer directly at any time.

4. Definitions
The data protection declaration is based on the terms used by the European legislator for directives and regulations when issuing the General Data Protection Regulation (GDPR). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms, among others, in this data protection declaration:

Personal Data
Personal data is any information relating to an identified or identifiable natural person. A natural person is considered to be identifiable if he or she can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

Affected person
The data subject is any identified or identifiable natural person whose personal data is processed by the data controller (our company).

Processing
Processing is any operation or series of operations carried out on personal data, whether or not by automated means, such as the collection, recording, organisation, structuring, storage, adaptation or modification, reading, querying, use, disclosure by transmission, distribution or other form of provision, alignment or association, restriction, deletion or destruction.

Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of restricting their future processing.

Profiling
Profiling is any type of automated processing of personal data which consists in using these personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal Analyze or predict the preferences, interests, reliability, behavior, location or movements of that natural person.

Pseudonymization
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data not be assigned to an identified or identifiable natural person.

Processor
Processor is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller.

Recipient
The recipient is a natural or legal person, public authority, institution or other body to which personal data is disclosed, regardless of whether it is a third party or not. However, public authorities which may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.

Third
Third party is a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

Consent
Consent is any voluntary, informed and unambiguous expression of wishes given by the data subject for a specific case in the form of a statement or other unambiguous confirmatory act by which the data subject indicates that he or she agrees to the processing of personal data concerning him or her is.

5. Legal basis for processing
Art. 6 Para. 1 lit. a GDPR (in conjunction with Section 15 Para. 3 TMG) serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6 Paragraph 1 Letter b GDPR. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services.

If our company is subject to a legal obligation that requires the processing of personal data, such as to fulfill tax obligations, the processing is based on Article 6 (1) (c) GDPR.

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance details or other vital information would then have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Article 6 Paragraph 1 Letter d GDPR.

Ultimately, processing operations could be based on Article 6 Paragraph 1 Letter f of the GDPR. Processing operations that are not covered by any of the above-mentioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, he was of the opinion that a legitimate interest could be assumed if you are a customer of our company (Recital 47 Sentence 2 GDPR).

6. Technique

6.1 SSL/TLS encryption
To ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator, this site uses an SSL or. TLS encryption. You can recognize an encrypted connection by the fact that there is an “https://” instead of “http://” in the browser’s address line and by the lock symbol in your browser line.

We use this technology to protect your transmitted information.

6.2 Data collection when visiting the website
If you use our website for informational purposes only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (in so-called “server log files”). Our website collects a series of general data and information every time you or an automated system accesses a page. This general data and information is stored in the server’s log files. They can be recorded
• browser types and versions used,
• the operating system used by the accessing system,
• the website from which an accessing system accesses our website (so-called referrer),
• the sub-websites that are accessed via an accessing system on our website,
• the date and time of access to the website,
• a shortened Internet protocol address (anonymized IP address),
• the Internet service provider of the accessing system.
• When using this general data and information, we do not draw any conclusions about you personally.

Rather, this information is needed to
• to deliver the content of our website correctly,
• to optimize the content of our website and the advertising for it
• to ensure the long-term functionality of our IT systems and the technology of our website and
• To provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack.

We therefore evaluate this collected data and information statistically and also with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

The legal basis for data processing is Article 6 Paragraph 1 Sentence 1 Letter f GDPR. Our legitimate interest follows from the data collection purposes listed above.

7. Cookies

7.1 General information about cookies
We use cookies on our website. These are small files that your browser creates automatically and that are stored on your IT system (laptop, tablet, smartphone, etc.) when you visit our site.

The cookie stores information that arises in connection with the specific end device used. However, this does not mean that we receive direct knowledge of your identity.

On the one hand, the use of cookies serves to make the use of our offer more pleasant for you. We use so-called session cookies to recognize that you have already visited individual pages on our website. These are automatically deleted after you leave our site.

In addition, to optimize user-friendliness, we also use temporary cookies that are stored on your device for a specific period of time. If you visit our site again to use our services, it will automatically be recognized that you have already been with us and what entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offering for you. These cookies enable us to automatically recognize that you have already been with us when you visit our site again. These cookies are automatically deleted after a defined period of time.

7.2 Legal basis for the use of cookies
The data processed by cookies, which is required for the website to function properly, is therefore necessary to protect our legitimate interests and those of third parties in accordance with Article 6 Paragraph 1 Sentence 1 Letter f of the GDPR.

For all other cookies it applies that you have given your consent to this via our opt-in cookie banner within the meaning of Art. 6 Para. 1 lit. a GDPR.

8. Contents of our website

8.1 Data processing when opening a customer account and for contract processing
In accordance with Article 6 Paragraph 1 Letter b of the GDPR, personal data is collected and processed if you provide it to us to execute a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. Your customer account can be deleted at any time and can be done by sending a message to the above address of the person responsible. We store and use the data you provide to process the contract. After the contract has been fully processed or your customer account has been deleted, your data will be blocked in consideration of tax and commercial law retention periods and deleted after these periods have expired, unless you have expressly consented to further use of your data or reserve the right to further use of your data as permitted by law on our part which we will inform you about below.

8.2 Data processing when registering to use Walluta online media
In accordance with Article 6 Paragraph 1 Letter b of the GDPR, personal data is collected and processed if it is provided to us for registration to use Walluta online media via the web application. The following basic steps are required in detail:

The customer registers on the domain www.walluta.de or a walluta.de landing page and follows the instructions for opening the account. Verification of the email address is required.

This is followed by the activation of the account at Walluta and the creation of a crypto wallet at Tangany. This requires acceptance of Tangany’s General Terms and Conditions. It is then possible to receive cryptocurrency.

To send cryptocurrencies, two-factor authentication (2FA) via, for example, Google Authenticator and KYC verification by the partner NowID or by Walluta’s trained staff are required.

After successfully setting up 2FA and KYC, the customer data is shared with the provider Tangany and the “send” function of the wallet is available.

The KYC information is passed on to Tangany to carry out the services.

8.3 Data processing when registering to use Walluta online media using mobile applications
In accordance with Article 6 Paragraph 1 Letter b of the GDPR, personal data is collected and processed if it is provided to us for registration by the customer to use the Walluta online media using the mobile application. The following steps are then required as above, with the exception of the following:

The customer visits the respective app store (Google Play or Apple App Store) and downloads the mobile application.

The customer registers in the mobile application and follows the instructions for opening the account. Verification of the email address is required.

By accessing the link in the confirmation email sent to the customer, the customer confirms the identity of his/her email address. By confirming his/her registration, the customer accepts these general terms and conditions. When registering, the customer is obliged to use an email address whose mailbox only he/she has personal access to.

8.4 Data processing for order processing
The personal data we collect will be passed on to the transport company commissioned with the delivery as part of the contract processing, to the extent that this is necessary to deliver the goods. We pass on your payment data to the commissioned credit institution as part of payment processing, provided this is necessary for payment processing. If payment service providers are used, we will provide explicit information about this below. The legal basis for passing on the data is Article 6 Paragraph 1 Letter b GDPR.

8.5 Contact / contact form
When you contact us (e.g. via contact form or email), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in answering your request in accordance with Article 6 (1) (f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Article 6 (1) (b) GDPR. Your data will be deleted after your request has been processed, this is the case if it can be seen from the circumstances that the matter in question has been conclusively clarified and provided that there are no legal retention obligations to the contrary.

9. Web analytics

9.1 Google Analytics
On our websites we use Google Analytics, a web analysis service provided by Google Ireland Limited (https://www.google.de/intl/de/about/) (Gordon House, Barrow Street, Dublin 4, Ireland; hereinafter “Google”) . In this context, pseudonymized usage profiles are created and cookies are used (see “Cookies”). The information generated by the cookie about your use of this website such as:

• Browser type/version,
• operating system used,
• Referrer URL (the previously visited page),
• Host name of the accessing computer (IP address),
• time of server request,

are transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services related to website and internet use for the purposes of market research and the needs-based design of these websites. This information may also be transferred to third parties if this is required by law or if third parties process this data on behalf of you. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymized so that assignment is not possible (IP masking).

You can prevent the installation of cookies by setting the browser software accordingly; However, we would like to point out that in this case not all functions of this website may be able to be used to their full extent.

These processing operations only take place if express consent is given in accordance with Article 6 Paragraph 1 Letter a of the GDPR.

You can also prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https: //tools.google.com/dlpage/gaoptout?hl=de).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent data collection by Google Analytics by clicking on the following link: Deactivate Google

Analytics. An opt-out cookie will be set to prevent future collection of your data when you visit this website. The opt-out cookie only applies in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you will have to set the opt-out cookie again.

Further information on data protection in connection with Google Analytics can be found in the Google Analytics help (https://support.google.com/analytics/answer/6004245?hl=de).

10. Plugins and other services

10.1 Google Tag Manager
This website uses Google Tag Manager, a cookie-free domain that does not collect any personal data.

With this tool, “website tags” (i.e. keywords that are integrated into HTML elements) can be implemented and managed via an interface. By using Google Tag Manager, we can automatically track which button, link or personalized image you have actively clicked and can then record which content on our website is particularly interesting to you.

The tool also triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If you have made a deactivation at the domain or cookie level, this will remain in effect for all tracking tags implemented with Google Tag Manager.

These processing operations only take place if express consent is given in accordance with Article 6 Paragraph 1 Letter a of the GDPR.

10.2 Google WebFonts
Our website uses so-called web fonts for the uniform display of fonts, which are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When you access a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.

For this purpose, the browser you use must connect to Google’s servers. This gives Google knowledge that our website was accessed via your IP address. The use of Google Web Fonts is in the interest of a uniform and attractive presentation of our website.

These processing operations only take place if express consent is given in accordance with Article 6 Paragraph 1 Letter a of the GDPR.

Further information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/

11. YOUR RIGHTS AS A DATA SUBJECT

11.1 Right to Confirmation
You have the right to request confirmation from us as to whether personal data concerning you is being processed.

11.2 Right to information Art. 15 GDPR
You have the right to receive free information from us at any time about the personal data stored about you as well as a copy of this data in accordance with the statutory provisions.

11.3 Right to correction Art. 16 GDPR
You have the right to request that inaccurate personal data concerning you be corrected. You also have the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

11.4 Deletion Art. 17 GDPR
You have the right to request that the personal data concerning you be deleted immediately if one of the reasons provided for by law applies and if processing or storage is not necessary.

11.5 Restriction of processing Art. 18 GDPR
You have the right to request that we restrict processing if one of the legal requirements is met.

11.6 Data portability Art. 20 GDPR
You have the right to receive the personal data relating to you, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another person responsible without hindrance from us to whom the personal data has been provided, provided that the processing is based on consent in accordance with Article 6 Paragraph 1 Letter a of the GDPR or Article 9 Paragraph 2 lit. a GDPR or on a contract in accordance with Article 6 Paragraph 1 lit or occurs in the exercise of official authority which has been transferred to us.

Furthermore, when exercising your right to data portability in accordance with Art. 20 Para. 1 GDPR, you have the right to have the personal data transmitted directly from one person responsible to another person responsible, to the extent that this is technically feasible and to the extent that this is not the case the rights and freedoms of other people are impaired.

11.7 Objection to Art. 21 GDPR
You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you, which is based on Art. 6 Para. 1 lit. e (data processing in the public interest) or f (data processing on the basis of a Balancing of interests) DS-GVO is necessary to lodge an objection.

This also applies to profiling based on these provisions within the meaning of Article 4 No. 4 GDPR.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

In individual cases we process personal data in order to conduct direct advertising. You can object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling insofar as it is connected to such direct advertising. If you object to us processing it for direct advertising purposes, we will no longer process your personal data for these purposes.

In addition, you have the right, for reasons arising from your particular situation, to object to the processing of personal data concerning you that is carried out by us for scientific or historical research purposes or for statistical purposes in accordance with Article 89 (1) GDPR unless such processing is necessary to fulfill a task carried out in the public interest.

In connection with the use of information society services, notwithstanding Directive 2002/58/EC, you are free to exercise your right to object using automated procedures using technical specifications.

11.8 Revocation of data protection consent
You have the right to revoke your consent to the processing of personal data at any time with future effect.

11.9 Complaint to a supervisory authority
You have the right to complain about our processing of personal data to a supervisory authority responsible for data protection.

12. Routine storage, deletion and blocking of personal data
We process and store your personal data only for the period necessary to achieve the storage purpose or if this is provided for by the legal regulations to which our company is subject.

If the storage purpose no longer applies or a prescribed storage period expires, the personal data will be routinely blocked or deleted in accordance with legal regulations.

13. Duration of storage of personal data
The criterion for the duration of storage of personal data is the respective statutory retention period. After the deadline has expired, the relevant data will be routinely deleted unless it is no longer required to fulfill the contract or initiate a contract.

14. Currentness and changes to the data protection declaration
This data protection declaration is currently valid and is dated: June 2022.

Due to the further development of our websites and offers or due to changed legal or official requirements, it may become necessary to change this data protection declaration. You can access and print out the current data protection declaration at any time on the website at “www.walluta.de/privacypolicy”.

This data protection declaration was created with the support of the data protection software: audatis MANAGER.