Data Protection Declaration

1) Information on the Collection of Personal Data and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Savvas Apostolidis, Tegernseer Landstraße 65, 82024 Taufkirchen, Germany, Phone.: 015901300401, e-mail: info@tradelista.com. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) Data Collection When You Visit Our Website

2.1 When using our website for information 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 (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:

• Our visited website
• Date and time at the moment of access
• Amount of data sent in bytes
• Source/reference from which you came to the page
• Browser used
• Operating system used
• IP address used (if applicable: in anonymized form)

Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.

3) Hosting, Database & File Storage

3.1 Vercel

For the hosting of our website and the display of the page content, we use the system of the following provider: Vercel Inc, 340 S Lemon Ave #4133, Walnut, CA 91789, USA

All data collected on our website is processed on the provider's servers. We have concluded an order processing agreement with the provider, ensuring the protection of our site visitors' data and prohibiting unauthorised disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

3.2 Supabase

For our database, user account authentication and the storage of files you upload (e.g. trade screenshots), we use the system of the following provider: Supabase, Inc., United States. Your account data, trading records, notes and uploaded screenshots are processed on this provider's infrastructure. We have concluded an order processing agreement with the provider, ensuring the protection of your data and prohibiting unauthorised disclosure to third parties.

For data transfers to the United States, the provider relies on Standard Contractual Clauses approved by the European Commission, which ensure an adequate level of data protection.

3.3 Optional MetaTrader 4 / 5 synchronisation

If you choose to install our Expert Advisor "TradeListaSync" in your own MetaTrader terminal, it transmits data about each trade after that trade has been closed to your TradeLista account. The transmission is started by software running on your own computer, is authenticated with the API key of the trading account you created in TradeLista, and is encrypted in transit (HTTPS).

The following fields are transmitted, and no others: the traded instrument (symbol), position size (lot), entry and exit price, the initial stop loss and take profit, the trade result including swap and commission, the closing date and time together with your computer’s current UTC offset, how long the position was held, the direction of the trade (buy/sell), the trade’s ticket number, and the API key identifying which of your trading accounts the trade belongs to.

The Expert Advisor reads only your closed trade history. It does not transmit your MetaTrader login, your password, your investor password, your account balance, open positions, or any personal details held by your broker, and it cannot place, modify or close trades. Processing takes place in order to provide the journalling function you have requested pursuant to Art. 6 (1) point b GDPR. You can stop it at any time by removing the Expert Advisor from your chart; deleting the trading account in TradeLista deletes the trades synchronised through it.

4) Cookies

In order to make your visit to our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called "session cookies"), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called "persistent cookies"). In the latter case, you can find the duration of the storage in the overview of the cookie settings of your web browser.

If personal data is also processed by individual cookies set by us, the processing is carried out either in accordance with Art. 6 (1) point b GDPR for the performance of the contract, in accordance with Art. 6 (1) point a GDPR in the case of consent given or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.

You can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

Please note that the functionality of our website may be limited if cookies are not accepted.

5) Contacting Us

When you contact us (e.g. via contact form or e-mail), 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 responding to your request or for establishing contact and for the associated technical administration.

The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.

6) Data Processing When Opening a Customer Account and for Contract Processing

Pursuant to Art. 6 (1) point b GDPR, personal data will continue to be collected and processed to the extent required in each case if you provide us with this data when opening a customer account. The data required for opening an account can be found in the input mask of the corresponding form on our website. Deletion of your customer account is possible at any time and can be done by sending a message to the above address of the person responsible. After deletion of your customer account, your data will be deleted, provided that all contracts concluded via it have been fully processed, no legal retention periods are opposed and no legitimate interest on our part in the continued storage exists.

7) Processing of Data for the Purpose of Order Handling

7.1 To fulfill the contract, we work with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transferred to these service providers in accordance with the following information.

7.2 Use of an Email Dispatch Service Provider

For the dispatch of emails — e.g. account confirmation emails, password reset emails, subscription and contract-related confirmations, as well as messages you send us via the contact form — we use the system of the following provider: IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany

The provider processes the data required for dispatch (in particular your email address, your name and the content of the respective email) on our behalf on servers within the European Union. We have concluded an order processing agreement with the provider, ensuring the protection of our customers' data and prohibiting unauthorised disclosure to third parties. The legal basis for this processing is Art. 6 (1) point b GDPR insofar as the emails serve the initiation or performance of a contract, and otherwise Art. 6 (1) point f GDPR on the basis of our legitimate interest in reliable email communication with our customers and site visitors.

7.3 Use of Payment Service Providers

- Stripe

Online payment methods from the following provider are available on this website: Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland

If you select a payment method of the provider for which you make an advance payment (e.g. credit card payment), your payment data provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) point b GDPR. In this case, your data will only be passed on for the purpose of processing payment with the provider and only to the extent necessary for this purpose.

7.4 Electronic termination option for continuing obligations with consumers

Consumers who have concluded contracts on this website for continuing obligations for which payment is required (e.g., subscription contracts) have the option of terminating these contracts via an electronic button in accordance with the applicable notice periods. Pressing the button leads to a confirmation page on which the consumer can provide more detailed information on the termination, clearly identify himself and subsequently declare his termination electronically. The collection of personal data and its transmission to us is carried out in accordance with Art. 6 (1) point b GDPR and only to the extent necessary for the proper processing of the termination. Pursuant to Art. 6 (1) point b GDPR, the provided personal data will also be used to confirm receipt of the termination declaration and the termination date by electronic means in text form. The additional legal basis for such processing is Art. 6 (1) point c GDPR. We are legally obliged to provide an electronic termination option for consumer contracts concluded by means of electronic commerce regarding continuing obligations for which payment is required.

7.5 Electronic Withdrawal Function for Distance Contracts

Consumers who conclude contracts on this website for which a statutory right of withdrawal exists have the option to declare their withdrawal via an electronic withdrawal function, in accordance with the applicable withdrawal provisions.

When using the withdrawal function, in addition to details identifying the specific contract being withdrawn from, other personal information—such as the consumer's first name, last name, and email address—must be provided or confirmed.

The collection of this information and its transmission to us is carried out in accordance with Art. 6 (1) point b of the GDPR, and only to the extent necessary for the proper processing of the withdrawal request. Furthermore, and also based on Art. 6 (1) point b of the GDPR, the provided personal data is used to confirm receipt of the withdrawal declaration via email. An additional legal basis for this processing is Art. 6 (1) point c of the GDPR. We are legally obligated to provide an electronic cancellation function for remunerated distance contracts concluded with consumers.

8) Tools and Miscellaneous

This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box.

Using the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted.

The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point f GDPR based on our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.
Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.
Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.

9) Rights of the Data Subject

9.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:

• Right of access by the data subject pursuant to Art. 15 GDPR;
• Right to rectification pursuant to Art. 16 GDPR;
• Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
• Right to restriction of processing pursuant to Art. 18 GDPR;
• Right to be informed pursuant to Art. 19 GDPR;
• Right to data portability pursuant to Art. 20 GDPR;
• Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
• Right to lodge a complaint pursuant to Art. 77 GDPR.

9.2 RIGHT TO OBJECT

IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.

10) Duration of Storage of Personal Data

The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).

If personal data is processed on the basis of express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.

If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.

When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

If personal data is processed for the purpose of direct marketing based on Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.

Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.