PRIVACY POLICY

Privacy Policy (Austria)

Status: February 28, 2025

I. Overview

Our Interest

Thank you for visiting or using our platform for the brokerage of financial instruments (securities, investments, etc.). Compliance with data protection regulations is not only a legal obligation for Sensus Pura Austria GmbH but also an important trust factor. This platform is operated by Sensus Pura Austria GmbH, Vienna, a company based in Austria (hereinafter also referred to as “Sensus Pura Austria” or “we”).

With this privacy policy, we inform you in detail about the processing of your personal data and your rights. Personal data is any data that can be personally assigned to you, e.g., name, email address.

We primarily process your personal data in the following situations:

• When you access and visit our platform;
• When you communicate with us by mail, email, or telephone;
• When you use our contact form;
• When you receive our newsletter;
• When registering and using our platform;
• For the establishment and fulfillment of a contractual relationship;
• When using other features of our platform;
• To fulfill our legal obligations.

We provide detailed information on how we handle your personal data in each processing situation in sections II. and III. of this privacy policy.

II. General Information

Controller

The controller within the meaning of data protection regulations is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data. The controller of this platform is:

Sensus Pura Austria GmbH Universitätsring 12/1. Stock 1010 Vienna Austria Phone: +43 1 361993838 Email: support@sensuspura.com Commercial Register Number: FN 641684 d Commercial Register Court: Commercial Court Vienna

If you have any questions or comments about our privacy policy, please feel free to contact us by email at any time.

Recipients of Your Data

Within Sensus Pura Austria, only those persons who need access to your data to fulfill our contractual and legal obligations will receive it. Service providers and vicarious agents engaged by us may also receive data for these purposes. We limit the disclosure of your personal data to what is necessary, taking into account data protection regulations.

We generally only disclose your data to third parties in the following situations:

• If you have given your explicit consent to the disclosure in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR;
• If the disclosure is legally permissible and necessary for the fulfillment of a contractual relationship with you or the implementation of pre-contractual measures in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR;
• If there is a legal obligation for the disclosure in accordance with Art. 6 para. 1 sentence 1 lit. c GDPR;
• If we are legally obliged to transmit data to government authorities (e.g., tax authorities, supervisory authorities, and law enforcement agencies);
• If the disclosure is necessary for the protection of legitimate business interests, as well as for the assertion, exercise, or defense of legal claims, and there is no reason to assume that you have an overriding legitimate interest in not disclosing your data in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR;
• If we use external service providers, so-called processors, for processing in accordance with Art. 28 GDPR, who have been obliged to handle your data carefully.

Data Transfer Outside the EU and EEA, Risk Notice

We sometimes use service providers who process your personal data outside the European Union (EU) and the European Economic Area (EEA) (in so-called third countries). Some of the service providers we use process your personal data in the USA. The EU has concluded a data privacy framework (EU-US Data Privacy Framework / EU-US Privacy Shield) with the USA, which came into force on July 10, 2023. This means that a comparable level of protection for personal data is offered in the USA as in the EU if the service provider participates in the self-certification procedure of the US Department of Commerce.

III. Special Processing Situations

Accessing and Visiting Our Platform

For the purpose of the technical provision of our platform, it is necessary for us to process certain automatically transmitted information so that our platform can be displayed to you and you can use it. This information is automatically collected each time you access our platform and stored in so-called server log files.

Communication by Mail, Email, or Telephone

If you contact us by mail, email, or telephone, your request and other personal data (e.g., name, address, email address, telephone number) will be processed for the purpose of handling your concern.

Contact Form

If you send us inquiries via the contact form, your message/communication, including the contact details you provide there (e.g., your email address, your first name, and last name), will be stored by us for the purpose of processing and answering the inquiry and for any follow-up questions, and will be processed accordingly.

Newsletter

With your consent, you can subscribe to our newsletter, with which we inform you about our current interesting news, offers and information on investment opportunities and the possibility of subscribing to financial instruments (securities, investments, etc.) as well as events from us and our partner companies.

Registration and Use of Our Platform

If you wish to use our platform to subscribe to a financial instrument (security, investment, etc.), you must register by providing your name, email address, telephone number, date of birth, and a self-chosen password.

Data Processing for the Brokerage of Financial Instruments

If you subscribe to a financial instrument (security, investment, etc.), we process the following personal data about you in the pre-contractual area and upon conclusion of the contract:

• Name, Surname
• Date of birth, Place of birth
• Residential address, Business address
• Telephone number
• Fax number
• IP address
• Nationality
• Gender
• Profession and professional function
• Educational qualification
• IBAN and BIC
• Securities deposit account number and BIC
• Tax identification number
• Status as a politically exposed person (PEP), family member of a politically exposed person, person or a known close associate within the meaning of the Anti-Money Laundering Act
• Listing on a sanctions list (UN, HMT, etc.)
• Beneficial ownership within the meaning of the Anti-Money Laundering Act
• Information on planned investment behavior
• Source of funds
• Information on income and assets and, if applicable, proof thereof
• Identity card data, passport data, driver’s license data
• Capacity as a representative of a company.

IV. Use of Cookies and Similar Technologies

General Information on Cookies

We use so-called cookies on our platform. Cookies are small text files that are stored on your computer and saved by your browser.

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Google Ads

As part of our online marketing measures, we use cookies from the “Google Ads Conversion” service, a service of Google Ireland Limited (“Google Ireland”).

Other Ads

As part of our online marketing measures, we use so-called conversion tracking technology and the retargeting functions of various ad providers.

Video Player

We embed videos on our website that are hosted on various video platforms.

Affiliates

We use cookies that allow us to recognize whether you have reached our website from the websites of our partners (affiliates) and to assign you to the respective affiliate.

Cookie Consent Tool

This website uses the cookie consent tool “clickskeks,” a service of Papoo Software & Media GmbH, Auguststr. 4, 53229 Bonn, to obtain your consent(s) for the storage of cookies on your device and to document your consent(s).

V. Information on Data Security and Storage Duration

Data Security

Your personal data is protected by us through appropriate technical and organizational measures.

Duration of Data Storage

Unless a storage period is explicitly stated in the information on special processing situations in sections II. and III., we delete your personal data as soon as the purpose or legal basis for storage ceases to apply.

VI. Your Right of Revocation

If you have given consent to the processing of personal data, you can revoke this consent at any time.

VII. Your Right to Object to Data Processing in Special Cases and to Direct Marketing

If data processing is carried out on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data at any time.

VIII. Your Other Rights

Subject to the respective legal requirements, you have the following rights:

• Information about your data processed by us (Art. 15 GDPR);
• Correction of inaccurate or incomplete personal data (Art. 16 GDPR);
• Deletion (Art. 17 GDPR) or restriction of processing (Art. 18 GDPR);
• Data portability (Art. 20 GDPR);
• Right to lodge a complaint with a supervisory authority (Art. 77 GDPR), for example, with the Austrian Data Protection Authority, Barichgasse 40-42, 1030 Vienna.

IX. Amendment of this Privacy Policy and Timeliness

Due to the further development of our platform, our offers, and our company, or due to changed legal or official requirements, we may amend or adapt our privacy policy. We will publish all changes on this website.

This privacy policy is currently valid.