Cookie Policy

Legal notice:

SCANDIC ASSETS FZCO, LEGIER Limited Liability Company and SCANDIC TRUST GROUP Limited Liability Company act as non-operational service providers. All operational and responsible activities are carried out by SCANDIC FINANCE GROUP LIMITED, Hong Kong, Special Administrative Region of the People's Republic of China.

This cookie policy applies to the SCANDIC brand ecosystem, in particular to the following brands and services:

as well as for all structures owned or supported by SCANDIC FINANCE GROUP LIMITED, insofar as these operate online services, websites, platforms, applications or comparable digital offerings.

I. Purpose and scope of this cookie policy

1. This cookie policy provides you with comprehensive information about how and for what purposes SCANDIC FINANCE GROUP LIMITED and its cooperating companies (hereinafter collectively referred to as "SCANDIC FINANCE GROUP LIMITED" or "we") use cookies and similar technologies on all websites, mobile applications and other online services operated by us (hereinafter collectively referred to as "online services").

2. This Cookie Policy applies worldwide, regardless of the country from which you access our Online Services. In particular, it takes into account:

• the General Data Protection Regulation of the European Union,
• the Federal Data Protection Act of the Federal Republic of Germany,
• the Federal Act on Data Protection of the Swiss Confederation,
• the data protection laws of the United Kingdom of Great Britain and Northern Ireland,
• the data protection provisions of the Hong Kong Special Administrative Region of the People's Republic of China,
• as well as other applicable national and international data protection and telecommunications laws.

3. In the event of any conflict between this Cookie Policy and mandatory provisions of the law applicable in your country of residence, the mandatory legal provisions shall prevail. Otherwise, this Cookie Policy applies worldwide.

II. Responsible body for data processing

1. The data controller responsible for the processing of personal data in connection with the use of cookies on the majority of online services is:

2. For individual online services that are operated technically or organisationally by one of the cooperating companies (SCANDIC ASSETS FZCO, SCANDIC TRUST GROUP Limited Liability Company or LEGIER Beteiligungs Gesellschaft mit beschränkter Haftung), the respective company may be the data controller or, in some cases, the joint data controller together with SCANDIC FINANCE GROUP LIMITED. In this case, this will be specifically stated in the respective privacy policy of the online service concerned.

3. Data protection officer

SCANDIC FINANCE GROUP LIMITED has appointed a data protection officer for its global online services. This is:

You can contact the Data Protection Officer at any time with questions and to exercise your rights as a data subject.

III. Definitions

The following definitions apply in particular to this cookie policy:

1. Cookies

Cookies are small text files that are sent from a web server to your internet browser and stored on your device (e.g. computer, tablet, smartphone or similar device) when you visit an online service of SCANDIC FINANCE GROUP LIMITED. When you visit our online service again, the cookie and the information stored in it may be transmitted back to our server or to the server of a third-party provider.

2. Session cookies (session files)

These are cookies that are only stored for the duration of a single session (a single visit) and are automatically deleted after you finish using the service.

3. Persistent cookies

Persistent cookies remain stored on your device for a predefined period of time beyond the respective session. They enable us to recognise you when you visit again and, for example, to display your selected settings again.

4. Required (technically necessary) cookies

These cookies are essential for our online services to function properly. Without these cookies, basic functions such as navigation within the website or the security of your privacy settings cannot be provided.

5. Functional cookies

Functional cookies enable advanced functionalities and personalisation, such as remembering your language settings, displaying certain content or saving form content for the duration of a session.

6. Analytical and statistical cookies

These cookies collect information about how visitors use our online services, for example, which pages are accessed, how long visitors stay on the site, and whether error messages occur. The information obtained in this way helps us to improve our offerings in terms of technology, content, and design.

7. Marketing and tracking cookies

Marketing and tracking cookies are used to track user behaviour across multiple visits or across different online services in order to enable personalised advertising, reach measurement, conversion analysis and similar marketing measures.

8. Third-party cookies

Third-party cookies are not set directly by SCANDIC FINANCE GROUP LIMITED, but by independent third-party companies that integrate their services into our online services (e.g. analytics services, advertising networks, payment service providers, security and fraud prevention providers).

9. Personal data

Personal data is any information relating to an identified or identifiable natural person. This includes, for example, name, address, email address, telephone number, but also online identifiers (e.g. cookie identifiers, pseudonymised user IDs or your Internet Protocol address).

IV. Types, scope and purposes of the use of cookies

1. Necessary and functional cookies

We use necessary and functional cookies to:

• provide the basic functionality of our online services,
• ensure a secure and stable connection to our servers,
• save and respect your privacy settings,
• offer shopping basket or watch list functions, favourites, login sessions or similar functions,
• enable technical error detection and correction.

The legal basis for the processing of personal data using necessary cookies is our legitimate interest in the secure and technically flawless provision of our online services (Article 6(1)(f) of the General Data Protection Regulation of the European Union or corresponding provisions of other legal systems). If your country of residence does not require separate consent for technically necessary cookies, we base the use of these cookies on this legitimate interest.

2. Analytical and statistical cookies

We use analytical and statistical cookies to:

• statistically evaluate the use of our online services,
• collect reach and performance data (e.g. number of visitors, pages viewed, length of stay),
• optimise the navigation structures, content and functions of our online services,
• identify and resolve technical problems at an early stage.

The processing of personal data in the context of analytical and statistical cookies is generally based on your prior consent (Article 6(1)(a) of the European Union's General Data Protection Regulation). You can revoke your consent at any time with effect for the future (see Section VI).

3. Marketing and tracking cookies

Marketing and tracking cookies are used in particular to:

• create user profiles in order to display interest-based and personalised content and advertising to you,
• measure the effectiveness of our marketing measures and advertising campaigns (conversion tracking),
• identify returning visitors across multiple online services (cross-site tracking),
• form target group segments and optimise our marketing strategies.

The processing of personal data for marketing and tracking purposes is carried out exclusively on the basis of your consent (Article 6(1)(a) of the European Union's General Data Protection Regulation and corresponding provisions of other legal systems). No marketing or tracking cookies will be set without your prior consent, insofar as this is legally required.

4. Use of comparable technologies

In addition to traditional cookies, we may use other technologies that are functionally comparable, such as:

• local storage technologies in your browser (local storage or session storage),
• so-called tracking pixels or web beacons (small, mostly invisible image or code elements),
• device recognition technologies for fraud prevention and security.

Insofar as these technologies process personal data, the same principles apply as for the cookies described in this section.

V. Managing your consent and cookie settings

1. Cookie notice and consent banner

When you first visit an online service of SCANDIC FINANCE GROUP LIMITED, you will be informed about the use of cookies and similar technologies by a notice banner. Within this banner, you can:

• consent to all non-essential cookies,
• reject the default settings, to the extent permitted by applicable law,
• configure individual settings for individual cookie categories.

2. Revocation of your consent

You can revoke your consent at any time with future effect. The following options are available to you for this purpose:

• Using the cookie management tool provided by us, which you can usually access via a corresponding link in the footer of our online services ("Cookie settings", "Privacy settings" or similar).
• By changing the settings in your internet browser, which you can use to restrict or completely prevent the setting of cookies.

Please note that revoking your consent does not affect the legality of the processing carried out until revocation.

3. Browser settings

Most internet browsers accept cookies by default. However, you can set your browser so that:

• prevent cookies from being set in general,
• only certain types of cookies are allowed,
• you are asked before each cookie is stored,
• cookies that have already been saved are deleted.

Please refer to the help function or instructions for your browser for the exact procedure. If you deactivate all cookies, you may not be able to use certain functions of our online services or only to a limited extent.

VI. Use of web analysis services and third-party providers

1. Web analysis services

We use web analysis services from specialised service providers on our online services. These services use cookies or similar technologies to record how visitors use our online services. This may include the following data in particular:

• pages accessed,
• time and duration of the visit,
• origin of visitors (e.g. which website you came to us from),
• pseudonymised online identifiers,
• truncated Internet Protocol addresses.

If the analysis services process personal data, this is done on the basis of your consent. Where possible, Internet Protocol addresses are shortened so that a direct personal reference is excluded or greatly reduced.

2. Third-party services

Our online services may also include third-party services, for example:

• Service providers for the delivery of videos, map material or fonts,
• Social network providers (if integrated via plugins or links),
• Payment service providers,
• Security and fraud prevention providers,
• Advertising networks and technology providers for personalised advertising.

These third-party providers may set their own cookies or use similar technologies and apply their own privacy policies. We carefully select such third-party providers and require them to comply with applicable data protection laws. A specific list of the third-party providers involved, their purposes, the categories of data processed, the legal basis and the storage period can be found in the detailed cookie overview, which we make available via our cookie management tool.

VII. International data transfers

1. SCANDIC FINANCE GROUP LIMITED operates worldwide and works with service providers in various countries, including countries outside the scope of the European Union's General Data Protection Regulation. Personal data may be transferred to such countries in connection with the use of cookies and similar technologies.

2. Where data from countries in which the European Union's General Data Protection Regulation applies is transferred to countries for which there is no adequacy decision by the European Commission, we ensure that an adequate level of protection is in place, in particular by:

• concluding contracts based on the standard contractual clauses issued by the European Commission,
• additional technical and organisational measures, such as encryption and pseudonymisation,
• carefully selecting and regularly reviewing the service providers used.

3. For data transfers within the group of companies affiliated with SCANDIC FINANCE GROUP LIMITED (Hong Kong, United Arab Emirates, Ukraine, Federal Republic of Germany, Switzerland and other countries), internal agreements are in place to ensure a uniformly high level of data protection.

VIII. Storage period and deletion

1. The storage period for individual cookies depends on their purpose:

• Session cookies are deleted at the latest at the end of your session.
• Persistent cookies are stored for a predefined period of time, which is specified in the cookie overview of the respective online service (e.g. a few days, several months or a few years).

2. You can delete cookies manually at any time via your internet browser settings. In addition, many cookies offer an integrated function for automatic deletion after a certain period of time.

3. We only store personal data processed in connection with cookies for as long as is necessary to fulfil the respective purposes or as required by statutory retention obligations. The data is then deleted or anonymised in such a way that the data subject can no longer be identified.

IX. Your rights as a data subject

To the extent applicable to you, you have the following rights in particular under the relevant data protection laws:

1. Right to information

You may request information about whether we process personal data about you and, if so, what data this is, for what purposes we process it, from which sources it originates and to whom it may be transferred.

2. Right to rectification

You may request that inaccurate or incomplete personal data concerning you be corrected or completed.

3. Right to erasure

Under the legal requirements, you may request the erasure of your personal data, in particular if the data is no longer necessary for the purposes pursued or if you have effectively revoked your consent.

4. Right to restriction of processing

You may request the restriction of processing if the requirements of the applicable data protection laws are met, for example if you dispute the accuracy of the data or the processing is unlawful, but you do not wish it to be erased.

5. Right to data portability

Where applicable, you have the right to receive personal data that you have provided to us and that we process automatically on the basis of your consent or for the performance of a contract in a structured, commonly used and machine-readable format or to have this data transferred to another controller.

6. Right to object

Where we process personal data on the basis of a legitimate interest, you have the right to object to the processing at any time on grounds relating to your particular situation. We will then cease processing unless we can demonstrate compelling legitimate grounds for the processing.

7. Right to withdraw consent

You may revoke your consent to the processing of personal data at any time with effect for the future. This applies in particular to consent to the use of analytical, statistical, marketing and tracking cookies.

To exercise your rights, you can contact us at any time using the contact details provided in Section II or contact the data protection officer.

X. Right to lodge a complaint with supervisory authorities

1. If you believe that the processing of your personal data violates applicable data protection law, you have the right to lodge a complaint with a competent data protection supervisory authority. This may be, in particular, the supervisory authority at your habitual residence, at your place of work or at the registered office of SCANDIC FINANCE GROUP LIMITED.

2. Examples of competent supervisory authorities include:

• for persons within the scope of the European Union's General Data Protection Regulation: the respective national or regional data protection supervisory authority,
• for persons in the Federal Republic of Germany: the state data protection authorities of the federal states,
• for persons in the Swiss Confederation: the Federal Data Protection and Information Commissioner,
• for persons in the United Kingdom of Great Britain and Northern Ireland: the Information Commissioner's Office,
• for persons in the Hong Kong Special Administrative Region of the People's Republic of China: the Office of the Privacy Commissioner for Personal Data.

XI. Changes to this cookie policy

1. The provisions of this cookie policy in the version current at the time of your visit to our online services apply.

2. We reserve the right to supplement or amend the content of this cookie policy at any time, in particular to adapt it to changes in legislation, case law, official requirements or technical developments.

3. The current version of the cookie policy is available via our online services. We will also notify you of any significant changes, where legally required, for example by posting a notice on our online services or by obtaining your consent again.

XII. Appendix: Overview of cookie categories

The following overview describes the categories of cookies that may be used on the online services of SCANDIC FINANCE GROUP LIMITED. The specific, current list of cookies, including name, provider, purpose, category, storage period and legal basis, is provided in our cookie management tool.

1. Strictly necessary cookies

• Purpose: Ensuring technical functionality, load balancing, login and session control, storing your cookie settings.
• Storage period: Session-related or permanent (usually a few months).
• Legal basis: Legitimate interest in providing secure and functioning online services.

2. Functional cookies

• Purpose: Storage of language settings, display of individual content, convenience functions (e.g. watch lists, recently viewed content).
• Storage period: Session-related or permanent (e.g. a few days to several months).
• Legal basis: Consent, where required by law; otherwise, legitimate interest in user-friendly design.

3. Analytical and statistical cookies

• Purpose: measurement and evaluation of the use of our online services, creation of anonymous statistics, optimisation of structure, content and performance.
• Storage period: usually several months to a maximum of a few years.
• Legal basis: consent.

4. Marketing and tracking cookies

• Purpose: Formation of target groups, personalised content and advertising, measurement of campaign success, avoidance of inappropriate or repeated advertising.
• Storage period: varies depending on the provider and purpose, usually several months.
• Legal basis: consent.

5. Third-party cookies

• Purpose: Provision of third-party services (e.g. maps, videos, security and fraud prevention solutions, payment processing, social media integration).
• Storage period: Depends on the respective third-party provider.
• Legal basis: consent, plus legitimate interests in the integration of external functionalities where applicable.