Privacy Policy

In the following, we would like to inform you about what happens to your personal data when you visit our website and use the services offered on the website. 

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(1) Name and contact details of the responsible body

The person responsible for the processing of personal data on this website is:

Steady Protocol (Europe) GmbH
represented by the managing director Anna Muheim
Neuer Wall 10
20354 Hamburg
Germany

E-Mail: hey@steadyprotocol.io
Web: www.steadyprotocol.io 

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(2) Purpose and legal basis of data processing 

1. Accessing the website

When you access our website, information is automatically provided to the server of our website, depending on the browser used on your device. The website is hosted by an external service provider, so that the data is stored on the hoster's servers. We will not use the information to draw conclusions about your person. The following information is automatically recorded in a log file and stored there until automated deletion:

• the date and time of the call,
• Name and URL of the retrieved file/page,
• IP address and hostname of the accessing computer,
• Website from which the access was made (referrer URL),
• Browser type and version, operating system used
• and the name of your access provider.

The aforementioned information is used to provide a smooth and comfortable use of the website, to evaluate system security and stability, and for other administrative purposes. The legal basis for this data processing is Art. 6 (1) sentence 1 (f) GDPR. Our legitimate interest follows from the data collection purposes listed above. Under no circumstances will we use the collected data for the purpose of drawing conclusions about your person. Furthermore, the lawfulness of the data collection follows from Art. 6 (1) sentence 1 (b) GDPR, provided that we provide you with the information on our website at the pre-contractual and, if necessary, already at a contractual stage. In addition, we use cookies and analysis services when you visit our website. You can find more detailed explanations in this privacy policy. 

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2. Cookies

We use cookies on our site. These are small files that are automatically created by your browser and stored on your device (laptop, tablet, smartphone, etc.) and contain information about the data of your visit. However, the use of cookies does not give us direct knowledge of your identity. The cookies are used to make your use of our website more pleasant. We also use cookies to evaluate the surfing behaviour of our users. 

The legal bases for the setting of cookies are legitimate interests under Art. 6 (1) (f) GDPR and, if applicable, Your consent in accordance with Art. 6 (1) (b) GDPR. In the case of the initiation of a contract or an ongoing contractual relationship, the legal basis also follows from Art. 6 (1) sentence 1 (b) GDPR. 

When you enter our website for the first time, you have the option of customizing the setting of cookies. Most browsers are also automatically preset for the use of cookies. However, you can set your browser so that no cookies are stored on your computer at all or that a message always appears before saving whether a cookie is being created. If you disable the use of cookies, you may not be able to use all the features of our website.

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3. Contact us

If you contact us via the options provided on the website, you agree that we may store your message and the information provided to answer your enquiry. The legal basis for this data processing is your consent in accordance with Art. 6 (1) (a) GDPR and, in the case of contract initiation, Art. 6 (1) (b) GDPR. You are neither legally nor contractually obliged to provide us with this information. However, we cannot respond to your enquiry without your contact details and information. 

After your enquiry is done, the data provided will be deleted unless it is required for a following contractual relationship, or it has to be kept due to mandatory retention obligations. You can also request to delete your data at any time. You are also entitled to further rights in accordance with section 3 of this declaration.

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4. Sign up for newsletter

By subscribing to our newsletter, you agree to receive regular e-mail updates from Steady about firm news, Steady's stablecoin and current developments in the crypto market. You also agree to collecting and processing data about your usage behavior (opening and clicking on links in the email) to adapt the content of the mailings to your needs. 

Your consent is voluntary and can be revoked at any time without giving reasons via the contact options given in the legal notice (or via the ‘unsubscribe’ link in the newsletter). Please note that data processing that took place before the revocation is not affected by the revocation and is therefore lawful despite the revocation.

Registration for the newsletter takes place via the so-called double opt-in procedure. After you have registered for our newsletter via our website, we will send you an email asking you to confirm your newsletter registration so that we can be sure that no third party has registered with your email address. To be able to prove your registration, the time of registration, time of confirmation and the IP address are logged based on our legitimate interests in accordance with Art. 6 (1) (f) GDPR.

The data provided for the purpose of subscribing the newsletter and the data collected in relation to the use of the newsletter will be stored by us until you unsubscribe from the newsletter.

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5. User area

To purchase our stablecoin, you must first register on our website. To do this, you must go through the registration process on our website. You will be asked for your contact details, company name, country, state, investment range, bank and the address of your Crypto Wallet. 

If the registration process is not completed successfully, we will not save your data. If the registration process is completed successfully, an account will be created for you and the data you enter will be stored as part of the ongoing business relationship. The password you assign is encrypted and cannot be viewed by us. The legal basis for this data processing is Art. 6 (1) (b) GDPR. 

For our services we use IT service providers such as AWS (Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg) and Zoho (Zoho Corporation GmbH, Trinkausstr.7, 40213 Düsseldorf, Germany). When using the service providers, all data is stored in encrypted form on servers within the European Economic Area. No data processing takes place outside the European Economic Area, so that EU data protection standards are guaranteed. Furthermore, the service providers are obliged to take appropriate technical and organisational measures to comply with European data protection standards through contractual agreements.

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6. Social media

We operate company pages on social media platforms to inform users and visitors about our firm and to communicate with them. When you use our social media site, personal data may be collected and processed in connection with your actions and interactions with our social media site. You can view the provider responsible for the social media platforms on the respective pages of the social media platform provider in the legal notice.

The operators of the social media platforms collect personal data based on various user actions and use this data, among other things, to compile usage statistics or for use in personalised advertising. The operator of the respective social media platform is solely responsible for data collection on its platform. Further information on data processing and data protection as well as privacy settings can be found on the websites of the operator of the respective social media platform. 

If you want to assert rights regarding the platform, please contact the operator of the social media platform, as they have the power of disposal over the data stored on the platform, possess all detailed and unencrypted information and can therefore take the necessary measures and provide information. The respective contact persons can be found in the data guidelines of the operator of the social media platform. For data protection-related matters relating to us alone, please use the contact options specified in this privacy policy under point 1. 

The operators of the social media platforms provide us with usage statistics in summarized and anonymized form (so-called insights data). We have no influence on the creation of usage statistics by the operator of the social media platform. This data is collected solely by the operator of the social media platform and made available to us in aggregated form. It is not possible for us to associate you personally with this data. The aggregated statistics may contain the following data in particular Number of followers incl. growth over a defined period, reach and interaction of certain posts, actions on the company page, number of page views, post performances, shared content. We can gain knowledge about the followers of our company page based on public profile information and interaction on our social media page. Page insights allow us to analyze this data in summarized form, but not to draw any conclusions about an individual natural person. 

The data processing described above is based on our legitimate interest in communication and information (Art. 6 (1) (f) GDPR). This consists of constantly optimising our information offering and our content to be able to respond to our target group in the best possible way. If you contact us, the processing may also be justified due to a contractual relationship (Art. 6 (1) (b) GDPR). We only process and store your personal data for as long as necessary to fulfil our intentions, i.e. as long as we operate our company website or your actions on our website are active. In the case of consent, we process the data until you revoke this consent. Beyond this, the data will only be stored until the fulfilment of any statutory retention obligation. We have no influence on how and for how long the operators of the social media platforms store your data on the platform. For details, please refer to the data policy of the operator of the respective social media platform.

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(3) Rights of the persons concerned

1. Right to information, rectification, deletion as well as rights to restriction of pro-cessing or transfer of your data to another body 

You have the right to request information (Art. 15 GDPR) about your personal data and related information. In addition, you can request the rectification (Art. 16 GDPR) and erasure (Art. 17 (1) GDPR) of your personal data. You can also request that the processing of your personal data be restricted (Art. 18 GDPR). Furthermore, you have the right to receive your personal data from the controller or to have it transferred to another controller (Art. 20 GDPR).

You have the right to request information (Art. 15 GDPR) about your personal data and related information. In addition, you can request the correction (Art. 16 GDPR) and the deletion (Art. 17 para. 1 GDPR) of your personal data. You can also request that the processing of your personal data will be restricted (Art. 18 GDPR). Furthermore, you have the right to receive your personal data from the responsible body or to have it transmitted to another responsible body  (Art. 20 GDPR). 

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2. Revocation of consent to data processing

You can revoke your consent in accordance with Art. 6 (1) sentence 1 (a) GDPR at any time with immediate effect in accordance with Art. 7 (3) sentence 1 GDPR. Please note that data processing that took place before the revocation is not affected by the revocation and is therefore lawful despite the revocation. If you would like to make use of your right of revocation, a simple notification to the person listed under no. 1.

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3. Objection to profiling and direct marketing

In certain cases, you also have the right to object (Art. 21 GDPR) to the data processing. 

In particular, you have the right  to object at any time to the processing of your data (in particular in the case of so-called profiling) based on Art. 6 (1) sentence 1 (f) GDPR (data processing on the basis of a balancing of interests) or Art. 6 (1) sentence 1 (e) GDPR (data processing in the public interest) in accordance with Art. 21 (1) GDPR. We will then no longer process your personal data for these purposes, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to establish, exercise or defend legal claims. 

If your personal data is processed for direct marketing, you can also object to the processing of your data for the purpose of direct marketing at any time in accordance with Art. 21 (2) GDPR, including profiling, insofar as it is related to such direct marketing. If you object, your personal data will no longer be used for these direct marketing purposes.

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4. Right to lodge a complaint with the competent data protection supervisory authority

If you believe that we have not complied with data protection regulations when processing your data, you can submit a complaint to the supervisory authority responsible for us. The indication of the supervisory authority is not a mandatory part of the privacy policy. 

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4. Data integrity

To ensure data security on our website, we encrypt it using the SSL method in accordance with the current state of the art. We use appropriate technical and organizational measures to prevent accidental or intentional manipulation, partial or total loss, destruction or unauthorized access to your data by third parties. Our security measures are continuously improved in line with technological developments. Furthermore, all service providers commissioned by us are obliged by means of appropriate contractual agreements to take appropriate measures in accordance with the current state of the art to prevent the risks.

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5. Up-to-dateness and modification of this privacy policy

This privacy policy is currently valid and has the status of September 2024. Due to the further development of our website and offers or due to changes in legal or official requirements, it may become necessary to change this data protection declaration. The current data protection declaration can be accessed and printed by you at any time on the website.