Privacy Policy

Teroxx Investment GmbH (hereinafter referred to as “Teroxx”, “we”, “us”, “our” or the “Company”) is committed to protect and respect the privacy and security of your personal data.

This Privacy Policy follows the provisions of the General Data Protection Regulation, EU 2016/679 (hereinafter referred to as “GDPR” or “the Regulation”) and includes all the relevant information regarding the processing of your personal data through our interaction with you, when visiting our websites www.teroxx.com/aif and www.teroxx.com/de/aif and when you are using our services and products. In addition, this policy informs you about your rights under the GDPR and the domestic Data Protection Law (L. 125(l)/2018).

In general, this Privacy Policy is directed to every natural person the “data subject” who is providing Teroxx personal data or personal information for the purposes stated below and Teroxx is processing such personal information in order to provide its services and products.

1. Who we are

Teroxx Investment GmbH is registered in Germany at the Amtsgericht Munich with registered no. HRB 279138, having its registered office at Adalbert-Stifter-Straße 1, 82031 Grünwald.

If you want more details regarding how we process and use your personal information, you can contact our Data Protection Officer, email: info@teroxx.com

2. Collection of personal data

a) When you roam our website;
When you visit our websites www.teroxx.com, www.teroxx.consulting and www.teroxx.finance, the browser on your device automatically sends information to the server on our websites. This information is temporarily stored in a so-called log file. Because of the use of cookies in our website we may collect some of your data by recording how you interact with our products and services. In addition, we use analysis services when you visit our website. You will find more detailed explanations under sections 7 and 8 of this Privacy Policy.

b) When contacting us for information;
If you have any questions, we offer you the opportunity to contact us using the form provided on the website. A valid email address is required so that we know who sent the request and can respond to it. Further information can be provided voluntarily.

c) When you enter in a contract with us.

When you became a user of Teroxx App we may collect some required documents and information from you in order to proceed with the provisions of our services and products. If you are an employee or have applied for employment, we collect your personal data during the recruitment process and/or throughout your employment.

d) When you open an account or use any of our products or services.
e) When you speak with a member of our customer service team.
f) When you contact us for any other reason.

We may also collect data from third parties such as Service providers, social networks, companies that process card payments provided you have granted access to your data located on these networks.

However, under no circumstances do we use the data collected for the purpose of drawing conclusions about you personally.

3. What data we collect

When you visit our website and use our products and services or you are a prospective employee or an employee of the company/, the following information may recorded and stored until the end of their retention period:

  • IP address of the requesting computer,
  • Date and time of access,
  • Name and URL of the retrieved file,
  • Website from which access is made (referrer URL),
  • The browser used,
  • If applicable, the operating system of your computer,
  • The name of your access provider,
  • Location data,
  • The type of device you use, mobile network information, mobile operating system, the type of your mobile browser you use,
  • Name and contact details (email, phone number, date of birth, house number, city, country, postal code),
  • Preferences such as Language, favourite products,
  • Identification Details and access data such as passwords, email, etc.
  • Your image through video for KYC purposes and for compliance with the relevant KYC laws and Regulations.
  • Transaction details, payments (including time, beneficiary details, currencies, time, date, account, IP address of sender and receiver, sender’s and receiver’s information) etc.
  • Historic of Sales etc.
  • Academic qualifications, professional experience and other information that you voluntarily provide to us through your CV.
  • social security number,
  • If you are employee, photographs, recordings, films, words etc.

We only use your personal data for the purposes referred in this Privacy Notice. However, if we intend to use your data for another purpose, we will ask for your prior consent.

4. Purpose of use of personal data

We use and process your personal data for the following purposes:

  • Ensuring a smooth connection of the website,
  • Ensure comfortable use of our website,
  • Evaluation of system security and stability,
  • To conduct our business activities,
  • To fulfil our contractual obligations,
  • To communicate with you,
  • To comply with the relevant KYC laws and Regulations,
  • Employment contract
  • To provide you with our products and services which require the use of personal data, and
  • For any other administrative purposes.

5. Which is the legal basis we use for processing your personal data

GDPR provides that all processing activities of personal data must be based at least on one legal basis. Teroxx use your personal data when the law allows it and process your personal data lawfully using the following legal grounds:

a) where we ask your consent and you choose freely to provide us with your consent;
b) In case where we have a contract with you and the processing is based on our contractual obligations;
c) Where we need to comply with our legal obligations.
d) Where the processing it is necessary for our legitimate interest or of a third party and your fundamental rights and interests do not override our interest or those of the third party.
e) Where we have a legitimate interest.

6. Information disclosure

Your personal data will not be transmitted to third parties for purposes other than those listed in this document. We will only pass on your personal data to third parties in order to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data.

In case where we need to transfer your personal data to a third party we will only transfer the personal data that is necessary and not the whole amount of your personal data we hold. In addition, where it is necessary to transfer your data to third countries outside EU, we will proceed with the transfer only if the conditions set out in the Regulation are met, where there is an adequacy decision, or where we use appropriate safeguards such as binding contracts with those parties.

Teroxx may transfer your personal data to United States of America (USA), in such case the transfer may be based on the EU-US Privacy Shield Framework.

7. Cookies

We use cookies on our site. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies do no damage to your end device, do not contain viruses, Trojans or other malware.

Information is stored in the cookie that results in each case in connection with the specifically used terminal device. However, this does not mean that we immediately become aware of your identity.

The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These will be deleted automatically after leaving our site.

In addition, we also use temporary cookies that are stored on your end device for a specified period of time to optimize user-friendliness. If you visit our site again to use our services, it will automatically recognize 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 you for the purpose of optimizing our offer. These cookies enable us to automatically recognize when you return to our site that you have already been with us. These cookies are automatically deleted after a defined period of time.

The data processed by cookies are necessary for the purposes mentioned in order to protect our legitimate interests and those of third parties pursuant to Art. 6 (1) (f) of the GDPR. Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies can lead to the fact that you cannot use all functions of our website.

8. Retention period

Teroxx retain your personal data for as long as it is necessary to fulfil the purposes for which the personal data are processed for. In addition, we hold your personal data in order to meet our legal obligations, to deal with potential complaints and to protect our legal rights in the event of a claim being made.

For the determination of the appropriate retention period, we always take in mind the amount, nature, and sensitivity of personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
In any case your personal data will be deleted in a secure way or will be destroyed when no longer needed.

9. Your rights as a data subject

As far as your personal data are processed during your visit to our website, you as the data subject have the following rights within the meaning of the GDPR:

9.1 Data subject access Request

You may request information from us in relation to your personal data and the processing of it. If in your case the right to information is not excluded and your personal data is processed by us, you can request information from us about the following information:

  • Purpose of the processing:
  • Categories of your personal data we process,
  • Recipients or categories of recipients to whom your personal data is disclosed, in particular recipients in third countries,
  • Duration for which your personal data will be stored,
  • The existence of a right to rectification, deletion or limitation of the processing of personal data concerning you or a right of opposition to such processing,
  • The existence of a right of appeal to a data protection supervisory authority,
  • If the personal data have not been collected from you as the data subject, the available information on the origin of the data,
  • The existence of automated decision making, including profiling and meaningful information on the logic involved, as well as the scope and intended effects of automated decision making,
  • In the case of transfer to recipients in third countries, unless the EU Commission has decided on the adequacy of the level of protection pursuant to Art. 45 para. 3 GDPR, information on the appropriate guarantees provided for the protection of personal data pursuant to Art. 46 para. 2 GDPR.

9.2 Correction and completion

If you find that we have incorrect personal data for you, you can ask us to correct this incorrect data immediately. In the case of incomplete personal data concerning you, you may request the completion.

9.3 Erasure

You have a right to erasure („right to be forgotten“), provided that the processing is not necessary to exercise the right to freedom of expression, the right to information or to fulfil a legal obligation or to perform a task which is in the public interest and one of the following reasons applies:

  • The personal data are no longer necessary for the purposes for which they were processed.
  • The basis of justification for the processing was exclusively your consent, which you have revoked.
  • You have filed an objection to the processing of your personal data, which we have made public.
  • You have objected to the processing of personal data not made public by us and there are no overriding legitimate reasons for the processing.
  • Your personal data has been processed unlawfully.
  • The deletion of personal data is necessary to fulfil a legal obligation to which we are subject.
  • There is no claim for deletion if deletion is not possible or only possible with disproportionate effort in the case of legal, non-automated data processing due to the special type of storage and your interest in deletion is low. In this case, the restriction of processing takes the place of deletion.

9.4 Restriction of processing

You may request us to restrict processing if one of the following reasons applies:

  • You deny the accuracy of your personal data. In this case, the restriction may be required for the duration that enables us to verify the accuracy of the data.
  • The processing is unlawful and instead of deletion you request the restriction of the use of your personal data.
  • We no longer need your personal data for the purposes of processing, but for asserting, exercising or defending legal claims.
  • You have filed an objection pursuant to Art. 21 (1) of GDPR. The restriction of processing may be required as long as it is not yet clear whether our justified reasons outweigh your reasons.

Restriction of processing means that personal data will only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest. Before we lift the restriction, we have a duty to inform you.

9.5 Data portability

You have a right to data transferability, provided that the processing is based on your consent, Art. 6 (1) (a) or Art. 9 (2) (a) of GDPR, or on a contract to which you are a contracting party and the processing is carried out using automated procedures.

In this case, the right to data transfer includes the following rights, provided that this does not affect the rights and freedoms of other persons:

You can ask us to receive the personal data you have provided to us in a structured, common and machine-readable format. You have the right to pass this data on to another person responsible without hindrance on our part. If technically feasible, you can request that we transfer your personal data directly to another person responsible.

9.6 Disagreement

If the processing is based on Article 6 (1) (e) of GDPR (public interest) or on Article 6 (1) (f) of GDPR (legitimate interest of the person responsible or a third party), you have the right to object at any time to the processing of personal data concerning you for reasons arising from your particular situation. This also applies to profiling based on Article 6 (1) (e) or (f) of GDPR.

After exercising the right of objection, we will no longer process your personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

You may at any time object to the processing of personal data concerning you for direct marketing purposes. This also applies to profiling in connection with such direct advertising. After exercising this right of objection, we will no longer use the personal data concerned for direct marketing purposes.

You have the option of informing our company informally of your objection by telephone, e-mail, fax or to the postal address listed at the beginning of this privacy policy.

9.7 Revocation of consent

You have the right to revoke your consent at any time with effect for the future. The revocation of the consent can be communicated informally by telephone, by e-mail, by fax or to our postal address. The legality of the data processing, which is based on the consent until receipt of the revocation, is not affected by the revocation. After receipt of the revocation the data processing, which was based exclusively on your consent, is stopped.

9.8 Lodge a complaint with the supervisory authority

If you believe that the processing of personal data concerning you is unlawful, you may contact us using the contact details provided below or directly lodge a complaint with the Data Protection Commissioner Office at http://www.dataprotection.gov.cy.

10. Data security

We use the most common SSL (Secure Socket Layer) method in connection with the highest level of encryption supported by your browser. Usually this is a 256-bit encryption.

If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. Whether a single page of our website is transmitted in encrypted form is indicated by the closed display of the key or lock symbol in the lower status bar of your browser.

We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

11. Up to date and amendment of this Privacy Policy

We reserve the right to update this privacy policy in due course in order to improve data protection and/or adapt it to changes in government practice or case law. Any changes regarding this document will be published in our website, however we encourage you to review this Privacy Notice in our website periodically.

12. Use of link buttons of so-called social networks on the homepage

Our websites contains link buttons to the websites of Facebook, Twitter and Google+ (hereinafter “social networks” or “providers”) on the basis of Art. 6 (1) (f) to make our company better known. The underlying advertising purpose is to be regarded as a legitimate interest within the meaning of the GDPR. Responsibility for data protection-compliant operation must be guaranteed by the respective provider. The integration of these plug-ins by us takes place in the way of the so-called two-click method around visitors of our web page in the best possible way to protect.

The link button to the social network Facebook, which is operated by Facebook Inc, 1601 South California Avenue, Palo Alto, CA 94304, USA, is identified by the white letter “f” on a blue background.

The link button to the microblogging service Twitter, offered by Twitter Inc, 795 Folsom St., Suite 600, San Francisco, CA 94107, USA, can be recognized by the white bird on a blue background.

The link button to the social network Google+, which is offered and operated by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, is identified by the white letter “g” and a plus sign, both on a red background.

When visiting our homepage, you will regularly find the link buttons of the social networks mentioned above. If you click on one of the buttons, you will be redirected to our corresponding site in the selected social network. If you are logged into your account at the selected social network in parallel, it can assign your visit to our presence there to your user account. Depending on the selected social network, you may also have the opportunity to follow our website and thus receive current information from us or share it with other participants of the respective social network.

The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your rights and setting options for the protection of your privacy can be found in the privacy policy (https://www.facebook.com/about/privacy/) of Facebook. Further information on the use of social networks is available for:

Facebook at http://www.facebook.com/legal/terms
Twitter at https://support.twitter.com/ and https://twitter.com/tos
Google+ at http://www.google.com/intl/de/policies/terms/

If you do not want the respective provider to be able to assign your visit to our website to your corresponding user account, please log out of this account beforehand.

13. Use of plug-ins of so-called social networks in the blog

Our websites use plug-ins and buttons from Facebook, Twitter, Google+ and LinkedIn (hereinafter referred to as “social networks” or “providers”).

You can recognize the plug-in of the social network Facebook Inc, 1601 South California Avenue, Palo Alto, CA 94304, USA, by the Facebook logo and the words “Recommend”. Details about the Facebook plug-in can be found here: http://developers.facebook.com/docs/plugins/

The plug-in of the microblogging service Twitter, both offered and operated by Twitter Inc, 795 Folsom St., Suite 600, San Francisco, CA 94107, USA, can be recognized by the white bird on blue background.

The Google +1 plug-in of the social network Google+, which is offered and operated by Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, is identified by the white letter “g” on a red background.

The plug-in of the LinkedIn social professional network, both offered and operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA, can be recognized by the inShare logo.

When you visit our blog, the embedded plug-ins are disabled by default. The plug-ins are regularly located at the end of an article and are highlighted in gray. Only when you click on one of the plug-ins there does it establish a direct connection between your browser and the server of the desired social network.

The provider of the same receives the information that you have visited our site with your IP address. If you are logged into your personal account of the selected social network in parallel, the provider of this network can assign your visit to our blog to your user account with the help of the plug-in. If you are logged in to your account and click the plug-in a second time actively, the entry that you like contents of our blog will appear on your personal pinboard or similar in your account.

If you do not want the respective provider to be able to assign your visit to our blog to your corresponding user account, please log out of this account beforehand.

14. General information on the collection and use of data by third parties

We would like to point out that, as the provider of the website and the blog, we are not aware of the content of the transmitted data or its use by the respective provider of a social network. Please also note that an entry on the pinboard or similar should not be used. of your account with one of the providers may be visible to third parties.2

For information about the content of the transmitted data and how to share entries with specific recipients only, see the respective data usage guidelines of:

Facebook at http://de-de.facebook.com/about/privacy/your-info-on-fb
Twitter at http://twitter.com/privacy/
Google + at http://www.google.com/intl/de_en/policies/privacy/
LinkedIn at http://de.linkedin.com/static?key=privacy_policy&trk=hb_ft_privacy

15. Use of Google Analytics

The website https://www.teroxx.com uses Google Analytics, a web analysis service of Google Inc. “(“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. 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.

However, if IP anonymization is activated on this website, Google will reduce your IP address within Member States of the European Union or in other countries party 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.
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 the website operator with other services relating to website and Internet use.

The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

You can also 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 (http://tools.google.com/dlpage/gaoptout?hl=en).

You can also prevent the collection by Google Analytics by clicking on the following link. An opt-out cookie is set to prevent future collection of your data when you visit this website: Disable Google Analytics.

16. Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc. “(“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. 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. However, if IP anonymization is activated on this website, Google will reduce your IP address within Member States of the European Union or in other countries party 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. 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 the website operator with other services relating to website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also 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: http://tools.google.com/dlpage/gaoptout

You can prevent the collection by Google Analytics by clicking on the following link.

An opt-out cookie is set to prevent future collection of your data when you visit this website.

Further information on terms of use and data protection can be found in the
Google Analytics Terms and Conditions or in the Google Analytics Overview. We would like to point out that the code “gat._anonymizeIp();” has been added to Google Analytics on this website to ensure anonymous collection of IP addresses (so-called IP masking).

We use the service reCAPTCHA of the company Google Inc. to protect your inquiries via internet form. (Google). The query serves to differentiate whether the input is made by a person or abusively by automated, machine processing. The query includes sending the IP address and any other data required by Google for the reCAPTCHA service to Google. For this purpose, your input will be transmitted to Google and used there. However, Google will previously reduce your IP address within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address transmitted by your browser within the scope of reCaptcha is not merged with other Google data. The deviating data protection regulations of the company Google apply to this data. For more information about Google’s privacy policy, please visit: https://policies.google.com/privacy?hl=de