ANTI-SPAM POLICY

Last revised on July 07, 2020, effective as of August 12, 2018

We hold the privacy of our subscribers and clients in the highest regard. Consequently, we have a strong zero-tolerance spam policy in place.

1. DEFINITION OF SPAM

Spam is unsolicited (email) communications for direct marketing (mainly sent in bulk) without the subscribers’ prior consent.

2. ZERO-TOLERANCE SPAM POLICY

We do not send out unsolicited email communication unless the individual subscriber has obtained prior explicit permission.

We operate our email address database utilizing a double opt-in process via MailChimp email services.

If a recipient of double opt-in (confirmation/permission) emails does not respond, we do not send emails to such a recipient.

Our email communication via Mailchimp services includes accurate transmission data (i.e., clear identification of the sender and originating domain in the email header), contact details (i.e., valid reply-to email address), a valid physical address, and visible and non-misleading described unsubscribe/opt-out links at the bottom of every email message.

We actively maintain and update in due time our contact details to ensure that they are up-to-date, complete, comprehensive, and accurate.

We are not using misleading and deceptive email subjects and texts.

We have zero-tolerance for illegal and vulgar content.

We are actively managing and processing received unsubscribe requests in due time.

We are not utilizing email harvesting and do not use harvested email address lists and databases.

We are not using purchased, loaned, or rented email address lists and databases.

We are not collecting email addresses from the web.

3.NEWSLETTER

3.1. NEWSLETTER DATA

If you would like to receive our market risk solutions newsletters, we require a valid email address and information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected voluntarily. We only use this data to send the requested information and not pass it on to third parties.

Therefore, we will process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) GDPR. You can revoke consent to the storage of your data and email address and their use for sending the newsletter at any time, e.g., through the “unsubscribe” link in the newsletter. The data processed before we receive your request may still be legally processed.

When registering for the newsletter, the data will be used to distribute the newsletter until you cancel your subscription when said data are deleted. Data we have stored for other purposes (e.g., email addresses for the member’s area) remain unaffected.

3.2. MAILCHIMP

This website uses the services of MailChimp to send our market risk solutions newsletters. This service is provided by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service that organizes and analyzes the distribution of newsletters. If you provide data (e.g., your email address) to subscribe to our newsletter, it will be stored on MailChimp servers in the USA.

MailChimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States.

When registering for the newsletter, the data will be used to distribute the newsletter until you cancel your subscription when said data are deleted from our servers and those of MailChimp. Data we have stored for other purposes (e.g., email addresses for the member’s area) remains unaffected.

For details, see the MailChimp privacy policy at https://mailchimp.com/legal/terms/.

3.2.1 DATA PROCESSING AGREEMENT

We have entered into a data processing agreement with MailChimp, in which we require MailChimp to protect the data of our customers and not to disclose said data to third parties.