Data Privacy

The data controller and service provider is: Trade Republic Bank GmbH, Brunnenstr. 19-21, 10119 Berlin (“Trade Republic”). You can contact the controller via datenschutz@traderepublic.com

1. Purpose and Legal Basis of our Data Processing - Legitimate interest - Art. 6 (1) lit. f GDPR

We process your personal data based on Art. 6 (1) lit. f GDPR, if we have a legitimate interest to do so. This means that our interest in processing your data is not overridden by your interests or your fundamental rights and freedoms. The purpose for which we have such a legitimate interest is to aggregate data on how many Website visitors are redirected to the app store and download the Trade Republic app, when you visit the Website on your smartphone, or are redirected to the Trade Republic website, when you visit the Website on your computer. Additionally, each time content on the Website is accessed, data is temporarily stored that may allow an identification. Temporary storage of the data is necessary to enable the provision of the website. Further storage in log files takes place to ensure the functionality of the website and the security of the IT systems.

2. Data Processing

When you just visit the Website we may process the following personal data:

• Date and time of access
• IP address
• Host name of the accessing computer
• Website from which the website was accessed
• Message as to whether the retrieval was successful
• Information about the browser type and version used

When you visit the Website and you click on the QR Code or the tracking link we track that action for the purpose mentioned in section 1 using a referral link which adds a unique identifier to the URL of the Website before you are redirected to the app store or the Trade Republic website.

3. Recipients or categories of recipients

Your personal data is transmitted to adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin, Germany (“Adjust”) when you use the QR Code. Trade Republic entered into a data processing agreement with the recipient in accordance with Art. 28 para. 3 GDPR. Under the conditions and in accordance with sections 1 and 2, we use Adjust to track whether you were transferred from the Website to the app store and downloaded our app, when visiting the Website on your smartphone, or to the Trade Republic website, when you visit the Website on your computer.

4. Transfer of personal data to third countries

We only transfer personal data to third parties outside of the European Economic Area, when at least one of the following transfer mechanisms is given to ensure an appropriate level of data protection:

• If the third country has been confirmed by the EU Commission to have an adequate level of data protection pursuant to Art. 45 (1) GDPR;
• Binding Corporate Rules have been established by the recipient;
• The EU Standard Data Protection Clauses as adopted by the European Commission have been agreed upon between us and the third party; or
• You have consented to the transfer.

You can reach out to us, if you want to receive further information on the respective transfer mechanism (possibly including copies of the respective mechanism) and the service providers we use.

5. Automated decision making

We do not make automated decisions in the meaning of Art. 22 GDPR affecting you as a regular visitor of the Website or the Recipient of a Gift.

6. Data retention

The generic but unique tracking links according to section 2 are retained for 90 days and then deleted automatically.

7. Your Privacy Rights and Contact

You have the following privacy rights:

• The right to access your personal data (Art. 15 GDPR);
• The right to rectification (Art. 16 GDPR);
• The right to deletion (Art. 17 GDPR);
• The right to restriction of processing (Art. 18 GDPR);
• A right to object to processing (Art. 21 GDPR); and
• The right to data portability (Art. 20 GDPR) within the framework of the legal requirements.

With regard to the right to access your data and the right to erasure, the restrictions pursuant to Art. 17 (3) GDPR and pursuant to local law Act must be taken into account. You have the right to revoke your consent at any time with effect for the future (Art. 7 (3) sentence 1 GDPR). However, the lawfulness of the processing carried out until the revocation is not affected by this.

In addition, there is the right to complain to the data protection supervisory authority pursuant to Art. 77 GDPR in conjunction with Section 19 German Federal Data Protection Act.

In case of general questions or if you want to exercise your privacy rights, you can reach out to our data protection team under dataprotection@traderepublic.com at any time. For a direct contact to our data protection officer, please send a letter to Trade Republic Bank GmbH, confidential - only for the Data Protection Officer, Brunnenstr. 19-21, 10119 Berlin, Germany or reach out via email to dataprotection@traderepublic.com and ask for a confidential direct contact.