Data Protection

A.     Information About the Data Controller

Name and contact information:

tick Trading Software AG
Berliner Allee 59
40212 Düsseldorf

Phone: 0211 / 781767-0
Fax: 0211 / 781767-29    
Email: info@tick-TS.de

B.      Address and contact information for the Data Protection Officer

We have appointed an external Data Protection Officer for our company. The contact information is as follows:

tick Trading Software AG
Dominik Baum 
- external data protection officer - 
Berliner Allee 59
40212 Düsseldorf

Fax: 0211/781767-29
Email: datenschutz@tick-TS.de

C.     Processing of Your Personal Data

I.              Informational Use of Our Website

When you access our website solely to browse it, so-called log files are processed by being automatically recorded by our system.

The following log files are processed automatically:

• Visited website
  • Request line (i.e., which URL is accessed)
• Time of access
  • Timestamp in CEST and the difference from CET (+0200)
• Amount of data sent in bytes
• Size of the accessed object (page, ZIP file, etc.)
• Source/link from which you reached the page
• Browser used and OS information
• Page reported by the client as the referrer (usually empty)
• Status code returned by the web server (e.g., 404 - not found)
• Operating system used
• IP address used
  • is anonymized by tick-TS before being stored 

The data is also stored in our system’s log files. The IP address is anonymized by truncation before storage, so that it can no longer be linked to a specific individual. The full IP address is not stored. The data is not stored together with any other personal data of the user.

The processing of the above-mentioned data is necessary for the operation of our website. We also store the data for the purpose of securing our information technology systems. These purposes also constitute our legitimate interest in processing the data on the legal basis of Article 6(1)(f) of the GDPR. The log files containing the anonymized IP addresses are deleted immediately after they are no longer necessary to achieve the aforementioned purposes, but no later than one month.

II.           Contact via Email

You have the option to contact us via email. We store the personal data you provide in the email. The data is not disclosed to third parties. The data is processed exclusively to handle your inquiry. The legal basis for the processing of your personal data is Article 6(1)(f) of the GDPR. The data is stored until it is no longer necessary to achieve the purpose of the conversation with you and the matter regarding your inquiry has been fully resolved.

If your email is intended to enter into a contract with us—such as for demo access—the additional legal basis for processing your personal data is Article 6(1)(b) of the GDPR. This data will be stored for as long as it is necessary to fulfill the contract. In addition, we store your data solely to comply with contractual or legal obligations (e.g., tax obligations) (Article 6(1)(c) of the GDPR).

You may withdraw your consent to the processing of your personal data at any time by notifying us via email (see section 1 above). In this case, all personal data from the conversation will be deleted, and it will not be possible to continue the conversation.

III.          Cookies

Please note the following: You can configure your settings to ensure that no cookies are stored on your computer at all, or that only certain cookies are allowed to be stored. You can select these options in your web browser settings. There, you can also view and delete stored cookies.

If you block all cookies, you may not be able to use all the features of our website.

We use a session cookie on our website.

Cookies are text files that are sent from our web server to your browser during your visit to our website and are stored by your browser on your computer for later retrieval. A cookie allows your web browser to be identified— —when you visit the website again. The session cookie we use is one that is automatically deleted by your browser immediately after you finish browsing the website.

We use this cookie to ensure the functionality of our website. Some elements of our website require that your web browser be recognized after you navigate to a different page.

The legal basis for the processing of personal data in cookies that we place on our website to ensure the functionality of our website and our services is Article 6(1)(f) of the GDPR.

Right to Object and Deletion

You can enable or restrict the transmission of cookies by changing the settings in your web browser. You can delete cookies that have already been stored by your web browser at any time. If cookies are restricted or disabled for our website, you may not be able to use all of its features.

We do not use third-party cookies. We also do not use any analytics tools that set or store corresponding tracking cookies.

IV.         Applicant Data

On our website, we provide information about job openings at our company, and you can submit your application to us via email. Depending on the candidate profiles we are seeking, we may provide a link that redirects you to an external website (Venwa GmbH, Prinz-Georg-Straße 85, 40479 Düsseldorf). We do not transfer any data to this third party ourselves. You can view Venwa GmbH’s privacy policy here: https://www.venwa.de/venwa-datenschutzerklaerung.html

tick-TS itself processes your data to handle your application process; this means your application will be reviewed by our employees responsible for the initial screening. Your data will not be shared with third parties, and we do not use your data for any other purposes.

We store your application data. If we reject your application, we will store the data only as long as necessary, for a maximum period of six months, unless you give us your consent to store your application data for a longer period so that we may contact you after this time has elapsed.

The legal basis for the processing of your data is Section 26 of the German Federal Data Protection Act (BDSG) and Article 88 of the General Data Protection Regulation (GDPR).

V.          Recipients of Personal Data

To provide our website, our IT systems, and our communication channels, we use service providers who process personal data on our behalf (so-called “processors” pursuant to Article 28 of the GDPR). These include, in particular:

•  Hosting service providers for the operation of this website,
• IT service providers for the maintenance and support of our systems,
• Email and communication service providers for handling electronic communication,
• Service providers for AI-supported processing within the framework of our ticket system (e.g., Microsoft as the operator of the Azure OpenAI Service).

These service providers process personal data exclusively in accordance with our instructions and on the basis of corresponding data processing agreements. Any further disclosure of personal data to third parties occurs only to the extent necessary to fulfill our contractual or legal obligations or if you have given your consent.

VI.         Transfer to Third Countries

If we use service providers based in a country outside the European Union (EU) or the European Economic Area (EEA), or if service providers from a third country have access to personal data, the processing of personal data takes place only in compliance with the specific requirements of Articles 44 et seq. of the GDPR. This means, in particular, that processing is based on an adequacy decision by the European Commission or appropriate safeguards (e.g., EU Standard Contractual Clauses), or that explicit consent has been provided.

VII.         Use of an AI Agent in the Ticket System

In our self-hosted ticketing system (OTOBO), our employees may use an AI agent to assist with processing individual support tickets.

In this process, the contents of the relevant tickets—and thus, where applicable, personal data (e.g., name, contact information, and the described circumstances)—are transmitted to an AI model that we operate in our own Microsoft Azure instance (Azure OpenAI Service). The server location is expressly limited to the “Germany West Central” region. Microsoft acts as a data processor in this context. No data is transferred to the add-on’s developer (Maxence).

Processing via AI does not occur routinely. Ticket content is only transmitted to the AI model if the responsible employee actively triggers this process on a case-by-case basis. If this process is not triggered, the ticket data is not transmitted to the AI model.

According to Microsoft, the inputs (“prompts”) and outputs (“completions”) processed as part of the Azure OpenAI Service

– are not made available to other customers,
– are not viewed by OpenAI or other Azure providers,
– not used to improve or train generative AI models, and
– not used to improve or third-party products without our express instruction.

Within the ticket system itself, the relevant ticket content is stored only as long as necessary to process the request, for documentation purposes, and to comply with legal retention requirements; thereafter, it is deleted or, where possible, anonymized.

The legal basis for the processing is—depending on the nature of the inquiry—Article 6(1)(b) of the GDPR (performance of a contract or implementation of precontractual measures, such as in the case of customer support inquiries) and Article 6(1)(f) of the GDPR (legitimate interest in the efficient and high-quality handling of and other inquiries). The processing of employees’ personal data in connection with internal support requests is carried out on the basis of Section 26 of the German Federal Data Protection Act (BDSG).

Access to the AI agent is restricted exclusively to employees of tick Trading Software AG.

The data subject rights described in Section D of this Privacy Policy apply to these processing operations (in particular, the right of access, rectification, erasure, restriction of processing, objection, and data portability

VIII.       Obligation to Provide Personal Data

When using our website, you are generally not required to provide personal data. However, the provision of certain data (e.g., IP address, browser information) is necessary for the technical operation of the website.

If you contact us (e.g., via email or through the ticket system) or wish to use our TradeBase MX software (including demo accounts), the provision of the personal data required for this purpose (e.g., contact information, login credentials, a description of your request) is necessary for processing your inquiry or for the conclusion and performance of the respective contract. Without this data, it is not possible to process your request or use our software.

D.     Your Rights

If your personal data is processed, you are a data subject within the meaning of the GDPR, and you have the following rights vis-à-vis us, the data controller (hereinafter: “us,” “we,” or “the data controller”):

I.            Right of Access

You may request confirmation from us as to whether we are processing personal data concerning you.

If such processing is taking place, you may request the following information from us:

• the purposes for which the personal data is processed;
• the categories of personal data being processed;
• the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
• the planned duration of storage of the personal data concerning you or, if specific details cannot be provided, the criteria for determining the storage period;
• the existence of a right to rectification or erasure of the personal data concerning you, a right to restrict processing by the controller, or a right to object to such processing;
• the existence of a right to lodge a complaint with a supervisory authority;
• all available information regarding the origin of the data, if the personal data is not collected from the data subject;
• the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and—at least in such cases—meaningful information regarding the logic involved, as well as the scope and intended consequences of such processing for the data subject.
• You have the right to request information regarding whether the personal data concerning you will be transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.

II.           Right to Rectification

You have the right to request that we rectify and/or complete the personal data concerning you if the processed personal data is inaccurate or incomplete. We will rectify the data without delay.

III.          Right to Restriction of Processing

Under the following conditions, you may request the restriction of the processing of personal data concerning you:

• if you contest the accuracy of the personal data concerning you for a period that allows us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and instead request the restriction of its use;
• we no longer need the personal data for the purposes of processing, but you need it to assert, exercise, or defend legal claims; or
• if you have objected to the processing pursuant to Article 21(1) of the GDPR and it has not yet been determined whether the controller’s legitimate grounds override your interests.

If the processing of your personal data has been restricted, such data—apart from its storage—may be processed only with your consent, or for the purpose of asserting, exercising, or defending legal claims, or to protect the rights of another natural or legal person, or for reasons of an important public interest of the Union or a Member State.

If the restriction on processing has been imposed in accordance with the above conditions, you will be notified by the controller before it is lifted.

IV.         Right to Erasure

Obligation to Erase

You may request that the controller erase the personal data concerning you without delay, and the controller is obligated to erase such data without delay if any of the following grounds apply:

• The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
• You withdraw your consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
• You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.
• The personal data concerning you has been processed unlawfully.
• The erasure of your personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
• The personal data concerning you was collected in connection with information society services offered pursuant to Article 8(1) of the GDPR.

V.           Right to Information

If you have exercised your right to rectification, erasure, or restriction of processing with the controller, the controller is obligated to notify all recipients to whom your personal data has been disclosed of such rectification, erasure, or restriction of processing, unless this proves impossible or involves disproportionate effort.

You have the right to be informed by the controller about these recipients.

VI.         Right to Data Portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that

• the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, or on a contract pursuant to Article 6(1)(b) of the GDPR, and
• the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, to the extent that this is technically feasible. The freedoms and rights of other individuals must not be infringed upon as a result.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

VII.        Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out pursuant to Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions.

The controller will no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.

If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

In connection with the use of information society services—notwithstanding Directive 2002/58/EC—you have the option to exercise your right to object using automated procedures that employ technical specifications.

VIII.       Right to Withdraw Consent Under Data Protection Law

You have the right to withdraw your consent to data processing at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent prior to withdrawal.

IX.         Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority—in particular in the Member State of your habitual residence, place of work, or the place of the alleged infringement—if you believe that the processing of your personal data violates the GDPR.

The supervisory authority to which the complaint was submitted shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 of the GDPR.

The competent supervisory authority for us is:

State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (LDI NRW)
Kavalleriestraße 2–4
40213 Düsseldorf
Germany
Website: https://www.ldi.nrw.de

X.           Use of the TradeBase MX Frontend

Scope of Personal Data Processing

To use the TradeBase MX front end, the following personal data is stored on our server: IP address, and, if applicable, real name (depending on the user name)

Legal Basis

We require your personal data to fulfill the contract with you (Art. 6(1)(b) GDPR). This includes, for example, your IP address, which our web server receives when providing the software, or your username, which is required for logging in and verifying access authorization. To secure our IT systems, we process personal data outside the scope of a contractual relationship based on our legitimate interest in the security and availability of the IT systems (Art. 6(1)(f) GDPR).

Purpose

The purpose of processing personal data is to provide the TradeBase MX front end.

Retention Period

Personal data is stored for a maximum of 60 days after a successful login.

Once this period has expired, all data records are automatically deleted, and access is deactivated.

Objection

You may object to the use of your personal data at any time and submit an objection to info@tick-TS.de or to our other contact addresses free of charge and without any formal requirements.

As soon as we receive your objection, we will delete all personal data, unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing is necessary for the establishment, exercise, or defense of legal claims.

Please note that after you submit an objection, you will likely no longer be able to use our software.

This applies to the use of TradeBase MX as well as to a demo account.

XI.         Status of the Privacy Notice

We make every effort to keep this Privacy Notice up to date. Therefore, it may change periodically and be adapted to current circumstances.

Current version: May 26, 2026