Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes, and to what extent in the context of providing our application.

The terms used are not gender-specific.

Status: December 30, 2025

Table of Contents

Controller

Rupert Bogensperger
Leystraße 143/1, Tür 17
1020 Vienna
Austria

Email address: rb@celerity.finance

Legal Notice: celerity.finance/impressum

Overview of Processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of Processed Data

Categories of Data Subjects

Purposes of Processing

Relevant Legal Bases

Relevant legal bases under the GDPR: In the following, you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection requirements may apply in your or our country of residence or domicile. If, in individual cases, more specific legal bases are relevant, we will inform you of these in the privacy policy.

National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Austria. This includes in particular the Federal Act concerning the Protection of Personal Data (Data Protection Act – DSG). The Data Protection Act contains in particular special regulations on the right to access, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases.

Note on the validity of the GDPR and Swiss DPA: These privacy notices serve both to provide information under the Swiss Federal Act on Data Protection (Swiss DPA) and under the General Data Protection Regulation (GDPR). For this reason, please note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data" as well as "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of the validity of the Swiss DPA.

Security Measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorized access. TLS, as the further developed and more secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator for users that their data is transmitted securely and encrypted.

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to or disclosed to other places, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

International Data Transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies (which can be recognized by the postal address of the respective provider or if the privacy policy explicitly refers to data transfer to third countries), this is only done in accordance with the legal requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that correspond to the requirements of the EU Commission and define contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes occur within the framework of the DPF, the standard contractual clauses intervene as a reliable fallback option. This ensures that your data remains adequately protected even in the event of any political or legal changes.

We inform you for the individual service providers whether they are certified under the DPF and whether standard contractual clauses exist. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, appropriate security measures apply, in particular standard contractual clauses, explicit consent or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=en.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with the legal provisions as soon as the underlying consents are revoked or there are no further legal grounds for the processing. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be kept for commercial or tax law reasons or whose storage is necessary for legal prosecution or for the protection of the rights of other natural or legal persons must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there are multiple specifications regarding the retention period or deletion deadlines for a date, the longest period is always decisive. We process data that is no longer kept for the originally intended purpose but due to legal requirements or other reasons exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply to retention and archiving under Austrian law:

Start of the period at the end of the year: If a period does not explicitly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the time at which the termination or other end of the legal relationship becomes effective.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

Provision of the Online Offer and Web Hosting

We process the users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.

Further information on processing processes, procedures and services:

Newsletters and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or on the basis of a legal basis. If the contents of the newsletter are specifically described within the scope of a registration, they are decisive for the consent of the users. For the subscription to our newsletter, it is generally sufficient to provide your email address. However, in order to provide you with a personalized service, we may ask you to provide your name for personal address in the newsletter or other information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a potential defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The logging of the registration process is based on our legitimate interests for the purpose of proving its proper procedure. If we commission a service provider with the sending of emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents: Information about us, our services, promotions and offers.

Affiliate Programs and Affiliate Links

In our online offer, we integrate so-called affiliate links or other references (which may include, for example, search masks, widgets or discount codes) to the offers and services of third-party providers (collectively referred to as "affiliate links"). If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").

In order to be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary for the respective third-party providers to know that users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or other actions (e.g., purchases) serves solely the purpose of commission settlement and is cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the aforementioned assignment of affiliate links, the affiliate links can be supplemented by certain values that are part of the link or can be stored otherwise, e.g., in a cookie. The values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the users' data is processed on the basis of our legitimate interests (i.e., interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Further information on processing processes, procedures and services:

Management, Organization and Auxiliary Tools

We use services, platforms and software of other providers (hereinafter referred to as "third-party providers") for the purposes of organization, administration, planning and provision of our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

If users are referred to third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the privacy notices of the respective third-party providers.

Further information on processing processes, procedures and services:

Changes and Updates

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Definitions of Terms

In this section, you will find an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are intended primarily for understanding.

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