PRIVACY POLICY & DISCLAIMER

General
BMB Base Metals Brokerage GmbH is a BaFin registered Tied Agent (No.150029) of Toyota Tsusho Metals Ltd., which is authorised and regulated by the UK Financial Conduct Authority (Reg.No. 189983).. Mention of specific commodities should not be taken as a recommendation to buy or sell these commodities. Commodity derivative trading is risky and you should understand those risks before trading. Neither any information presented, nor any opinion expressed on this website, constitutes a solicitation to buy or sell futures or options or futures contracts, or OTC products.

Limitation of liability for internal content

The content of our website has been compiled with meticulous care and to the best of our knowledge. However, we cannot assume any liability for the up-to-dateness, completeness or accuracy of any of the pages.

Pursuant to section 7, para. 1 of the TMG (Telemediengesetz – Tele Media Act by German law), we as service providers are liable for our own content on these pages in accordance with general laws. However, pursuant to sections 8 to 10 of the TMG, we as service providers are not under obligation to monitor external information provided or stored on our website. Once we have become aware of a specific infringement of the law, we will immediately remove the content in question. Any liability concerning this matter can only be assumed from the point in time at which the infringement becomes known to us.

Limitation of liability for external links

Our website contains links to the websites of third parties (“external links”). As the content of these websites is not under our control, we cannot assume any liability for such external content. In all cases, the provider of information of the linked websites is liable for the content and accuracy of the information provided. At the point in time when the links were placed, no infringements of the law were recognisable to us. As soon as an infringement of the law becomes known to us, we will immediately remove the link in question.

Copyright

The content and works published on this website are governed by the copyright laws of Germany. Any duplication, processing, distribution or any form of utilisation beyond the scope of copyright law shall require the prior written consent of the author or authors in question.

Data protection

A visit to our website can result in the storage on our server of information about the access (date, time, page accessed). This does not represent any analysis of personal data (e.g., name, address or e-mail address). If personal data are collected, this only occurs – to the extent possible – with the prior consent of the user of the website. Any forwarding of the data to third parties without the express consent of the user shall not take place.

Privacy Policy

We are very delighted that you have shown interest in our enterprise.

Data protection is of a particularly high priority for the management of

the BMB Base Metals Brokerage GmbH . The use of the Internet pages of the

BMB Base Metals Brokerage GmbH is possible without any indication of

personal data; however, if a data subject wants to use special enterprise

services via our website, processing of personal data could become

necessary. If the processing of personal data is necessary and there is no

statutory basis for such processing, we generally obtain consent from the

data subject.

The processing of personal data, such as the name, address, e-mail

address, or telephone number of a data subject shall always be in line

with the General Data Protection Regulation (GDPR), and in accordance with

the country-specific data protection regulations applicable to the BMB

Base Metals Brokerage GmbH. By means of this data protection declaration,

our enterprise would like to inform the general public of the nature,

scope, and purpose of the personal data we collect, use and process.

Furthermore, data subjects are informed, by means of this data protection

declaration, of the rights to which they are entitled.

As the controller, the BMB Base Metals Brokerage GmbH has implemented

numerous technical and organizational measures to ensure the most complete

protection of personal data processed through this website. However,

Internet-based data transmissions may in principle have security gaps, so

absolute protection may not be guaranteed. For this reason, every data

subject is free to transfer personal data to us via alternative means,

e.g. by telephone.

1. Definitions

The data protection declaration of the BMB Base Metals Brokerage GmbH

is based on the terms used by the European legislator for the adoption of

the General Data Protection Regulation (GDPR). Our data protection

declaration should be legible and understandable for the general public,

as well as our customers and business partners. To ensure this, we would

like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following

terms:

• a)    Personal data

  Personal data means any information relating to an identified or

  identifiable natural person (“data subject”). An identifiable natural

  person is one who can be identified, directly or indirectly, in particular

  by reference to an identifier such as a name, an identification number,

  location data, an online identifier or to one or more factors specific to

  the physical, physiological, genetic, mental, economic, cultural or social

  identity of that natural person.

• b) Data subject

  Data subject is any identified or identifiable natural person, whose

  personal data is processed by the controller responsible for the

  processing.

• c)    Processing

  Processing is any operation or set of operations which is performed on

  personal data or on sets of personal data, whether or not by automated

  means, such as collection, recording, organisation, structuring, storage,

  adaptation or alteration, retrieval, consultation, use, disclosure by

  transmission, dissemination or otherwise making available, alignment or

  combination, restriction, erasure or destruction.

• d)    Restriction of processing

  Restriction of processing is the marking of stored personal data with

  the aim of limiting their processing in the future.

• e)    Profiling

  Profiling means any form of automated processing of personal data

  consisting of the use of personal data to evaluate certain personal

  aspects relating to a natural person, in particular to analyse or predict

  aspects concerning that natural person’s performance at work, economic

  situation, health, personal preferences, interests, reliability,

  behaviour, location or movements.

• f)     Pseudonymisation

  Pseudonymisation is the processing of personal data in such a manner

  that the personal data can no longer be attributed to a specific data

  subject without the use of additional information, provided that such

  additional information is kept separately and is subject to technical and

  organisational measures to ensure that the personal data are not

  attributed to an identified or identifiable natural person.

• g)    Controller or controller responsible for the processing

  Controller or controller responsible for the processing is the natural

  or legal person, public authority, agency or other body which, alone or

  jointly with others, determines the purposes and means of the processing

  of personal data; where the purposes and means of such processing are

  determined by Union or Member State law, the controller or the specific

  criteria for its nomination may be provided for by Union or Member State

  law.

• h)    Processors

  Processor is a natural or legal person, public authority, agency or

  other body which processes personal data on behalf of the controller.

• i)      Recipient

  Recipient is a natural or legal person, public authority, agency or

  another body, to which the personal data are disclosed, whether a third

  party or not. However, public authorities which may receive personal data

  in the framework of a particular inquiry in accordance with Union or

  Member State law shall not be regarded as recipients; the processing of

  those data by those public authorities shall be in compliance with the

  applicable data protection rules according to the purposes of the

  processing.

• j)      Third party

  Third party is a natural or legal person, public authority, agency or

  body other than the data subject, controller, processor and persons who,

  under the direct authority of the controller or processor, are authorised

  to process personal data.

• k)    Consent

  Consent of the data subject is any freely given, specific, informed and

  unambiguous indication of the data subject’s wishes by which he or she, by

  a statement or by a clear affirmative action, signifies agreement to the

  processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation

(GDPR), other data protection laws applicable in Member states of the

European Union and other provisions related to data protection is:

BMB Base Metals Brokerage GmbH

Neuer Wall 36

20354 Hamburg

Germany

Phone: +494038686-0

Email: datenschutz@bmbrokerage.de

Website: www.metalbrokers.de

3. Collection of general data and information

The website of the BMB Base Metals Brokerage GmbH collects a series of

general data and information when a data subject or automated system calls

up the website. This general data and information are stored in the server

log files. Collected may be (1) the browser types and versions used, (2)

the operating system used by the accessing system, (3) the website from

which an accessing system reaches our website (so-called referrers), (4)

the sub-websites, (5) the date and time of access to the Internet site,

(6) an Internet protocol address (IP address), (7) the Internet service

provider of the accessing system, and (8) any other similar data and

information that may be used in the event of attacks on our information

technology systems.

When using these general data and information, the BMB Base Metals

Brokerage GmbH does not draw any conclusions about the data subject.

Rather, this information is needed to (1) deliver the content of our

website correctly, (2) optimize the content of our website as well as its

advertisement, (3) ensure the long-term viability of our information

technology systems and website technology, and (4) provide law enforcement

authorities with the information necessary for criminal prosecution in

case of a cyber-attack. Therefore, the BMB Base Metals Brokerage GmbH

analyzes anonymously collected data and information statistically, with

the aim of increasing the data protection and data security of our

enterprise, and to ensure an optimal level of protection for the personal

data we process. The anonymous data of the server log files are stored

separately from all personal data provided by a data subject.

4. Registration on our website

The data subject has the possibility to register on the website of the

controller with the indication of personal data. Which personal data are

transmitted to the controller is determined by the respective input mask

used for the registration. The personal data entered by the data subject

are collected and stored exclusively for internal use by the controller,

and for his own purposes. The controller may request transfer to one or

more processors (e.g. a parcel service) that also uses personal data for

an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—

assigned by the Internet service provider (ISP) and used by the data

subject—date, and time of the registration are also stored. The storage of

this data takes place against the background that this is the only way to

prevent the misuse of our services, and, if necessary, to make it possible

to investigate committed offenses. Insofar, the storage of this data is

necessary to secure the controller. This data is not passed on to third

parties unless there is a statutory obligation to pass on the data, or if

the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of

personal data, is intended to enable the controller to offer the data

subject contents or services that may only be offered to registered users

due to the nature of the matter in question. Registered persons are free

to change the personal data specified during the registration at any time,

or to have them completely deleted from the data stock of the

controller.

The data controller shall, at any time, provide information upon

request to each data subject as to what personal data are stored about the

data subject. In addition, the data controller shall correct or erase

personal data at the request or indication of the data subject, insofar as

there are no statutory storage obligations. The entirety of the

controller’s employees are available to the data subject in this respect

as contact persons.

5. Subscription to our newsletters

On the website of the BMB Base Metals Brokerage GmbH, users are given

the opportunity to subscribe to our enterprise’s newsletter. The input

mask used for this purpose determines what personal data are transmitted,

as well as when the newsletter is ordered from the controller.

The BMB Base Metals Brokerage GmbH informs its customers and business

partners regularly by means of a newsletter about enterprise offers. The

enterprise’s newsletter may only be received by the data subject if (1)

the data subject has a valid e-mail address and (2) the data subject

registers for the newsletter shipping. A confirmation e-mail will be sent

to the e-mail address registered by a data subject for the first time for

newsletter shipping, for legal reasons, in the double opt-in procedure.

This confirmation e-mail is used to prove whether the owner of the e-mail

address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP

address of the computer system assigned by the Internet service provider

(ISP) and used by the data subject at the time of the registration, as

well as the date and time of the registration. The collection of this data

is necessary in order to understand the (possible) misuse of the e-mail

address of a data subject at a later date, and it therefore serves the aim

of the legal protection of the controller.

The personal data collected as part of a registration for the

newsletter will only be used to send our newsletter. In addition,

subscribers to the newsletter may be informed by e-mail, as long as this

is necessary for the operation of the newsletter service or a registration

in question, as this could be the case in the event of modifications to

the newsletter offer, or in the event of a change in technical

circumstances. There will be no transfer of personal data collected by the

newsletter service to third parties. The subscription to our newsletter

may be terminated by the data subject at any time. The consent to the

storage of personal data, which the data subject has given for shipping

the newsletter, may be revoked at any time. For the purpose of revocation

of consent, a corresponding link is found in each newsletter. It is also

possible to unsubscribe from the newsletter at any time directly on the

website of the controller, or to communicate this to the controller in a

different way.

6. Newsletter-Tracking

The newsletter of the BMB Base Metals Brokerage GmbH contains so-called

tracking pixels. A tracking pixel is a miniature graphic embedded in such

e-mails, which are sent in HTML format to enable log file recording and

analysis. This allows a statistical analysis of the success or failure of

online marketing campaigns. Based on the embedded tracking pixel, the MBH

Metalbrokers Hamburg GmbH may see if and when an e-mail was opened by a

data subject, and which links in the e-mail were called up by data

subjects.

Such personal data collected in the tracking pixels contained in the

newsletters are stored and analyzed by the controller in order to optimize

the shipping of the newsletter, as well as to adapt the content of future

newsletters even better to the interests of the data subject. These

personal data will not be passed on to third parties. Data subjects are at

any time entitled to revoke the respective separate declaration of consent

issued by means of the double-opt-in procedure. After a revocation, these

personal data will be deleted by the controller. The BMB Base Metals Brokerage GmbH automatically regards a withdrawal from the receipt of the

newsletter as a revocation.

7. Contact possibility via the website

The website of the BMB Base Metals Brokerage GmbH contains information

that enables a quick electronic contact to our enterprise, as well as

direct communication with us, which also includes a general address of the

so-called electronic mail (e-mail address). If a data subject contacts the

controller by e-mail or via a contact form, the personal data transmitted

by the data subject are automatically stored. Such personal data

transmitted on a voluntary basis by a data subject to the data controller

are stored for the purpose of processing or contacting the data subject.

There is no transfer of this personal data to third parties.

8. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the

data subject only for the period necessary to achieve the purpose of

storage, or as far as this is granted by the European legislator or other

legislators in laws or regulations to which the controller is subject

to.

If the storage purpose is not applicable, or if a storage period

prescribed by the European legislator or another competent legislator

expires, the personal data are routinely blocked or erased in accordance

with legal requirements.

9. Rights of the data subject

• a) Right of confirmation

  Each data subject shall have the right granted by the European

  legislator to obtain from the controller the confirmation as to whether or

  not personal data concerning him or her are being processed. If a data

  subject wishes to avail himself of this right of confirmation, he or she

  may, at any time, contact any employee of the controller.

• b) Right of access

  Each data subject shall have the right granted by the European

  legislator to obtain from the controller free information about his or her

  personal data stored at any time and a copy of this information.

  Furthermore, the European directives and regulations grant the data

  subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data

    have been or will be disclosed, in particular recipients in third

    countries or international organisations;

  • where possible, the envisaged period for which the personal data will

    be stored, or, if not possible, the criteria used to determine that

    period;

  • the existence of the right to request from the controller

    rectification or erasure of personal data, or restriction of processing of

    personal data concerning the data subject, or to object to such

    processing;

  • the existence of the right to lodge a complaint with a supervisory

    authority;

  • where the personal data are not collected from the data subject, any

    available information as to their source;

  • the existence of automated decision-making, including profiling,

    referred to in Article 22(1) and (4) of the GDPR and, at least in those

    cases, meaningful information about the logic involved, as well as the

    significance and envisaged consequences of such processing for the data

    subject.

  Furthermore, the data subject shall have a right to obtain information

  as to whether personal data are transferred to a third country or to an

  international organisation. Where this is the case, the data subject shall

  have the right to be informed of the appropriate safeguards relating to

  the transfer.

  If a data subject wishes to avail himself of this right of access, he

  or she may, at any time, contact any employee of the controller.

• c) Right to rectification

  Each data subject shall have the right granted by the European

  legislator to obtain from the controller without undue delay the

  rectification of inaccurate personal data concerning him or her. Taking

  into account the purposes of the processing, the data subject shall have

  the right to have incomplete personal data completed, including by means

  of providing a supplementary statement.

  If a data subject wishes to exercise this right to rectification, he or

  she may, at any time, contact any employee of the controller.

• d) Right to erasure (Right to be forgotten)

  Each data subject shall have the right granted by the European

  legislator to obtain from the controller the erasure of personal data

  concerning him or her without undue delay, and the controller shall have

  the obligation to erase personal data without undue delay where one of the

  following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes

    for which they were collected or otherwise processed.

  • The data subject withdraws consent to which the processing is based

    according to point (a) of Article 6(1) of the GDPR, or point (a) of

    Article 9(2) of the GDPR, and where there is no other legal ground for the

    processing.

  • The data subject objects to the processing pursuant to Article 21(1)

    of the GDPR and there are no overriding legitimate grounds for the

    processing, or the data subject objects to the processing pursuant to

    Article 21(2) of the GDPR.

  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal

    obligation in Union or Member State law to which the controller is

    subject.

  • The personal data have been collected in relation to the offer of

    information society services referred to in Article 8(1) of the GDPR.

  If one of the aforementioned reasons applies, and a data subject wishes

  to request the erasure of personal data stored by the BMB Base Metals Brokerage GmbH, he or she may, at any time, contact any employee of the

  controller. An employee of BMB Base Metals Brokerage GmbH shall promptly

  ensure that the erasure request is complied with immediately.

  Where the controller has made personal data public and is obliged

  pursuant to Article 17(1) to erase the personal data, the controller,

  taking account of available technology and the cost of implementation,

  shall take reasonable steps, including technical measures, to inform other

  controllers processing the personal data that the data subject has

  requested erasure by such controllers of any links to, or copy or

  replication of, those personal data, as far as processing is not required.

  An employees of the BMB Base Metals Brokerage GmbH will arrange the

  necessary measures in individual cases.

• e) Right of restriction of processing

  Each data subject shall have the right granted by the European

  legislator to obtain from the controller restriction of processing where

  one of the following applies:

  • The accuracy of the personal data is contested by the data subject,

    for a period enabling the controller to verify the accuracy of the

    personal data.

  • The processing is unlawful and the data subject opposes the erasure of

    the personal data and requests instead the restriction of their use

    instead.

  • The controller no longer needs the personal data for the purposes of

    the processing, but they are required by the data subject for the

    establishment, exercise or defence of legal claims.

  • The data subject has objected to processing pursuant to Article 21(1)

    of the GDPR pending the verification whether the legitimate grounds of the

    controller override those of the data subject.

  If one of the aforementioned conditions is met, and a data subject

  wishes to request the restriction of the processing of personal data

  stored by the BMB Base Metals Brokerage GmbH, he or she may at any time

  contact any employee of the controller. The employee of the MBH

  Metalbrokers Hamburg GmbH will arrange the restriction of the processing.

• f) Right to data portability

  Each data subject shall have the right granted by the European

  legislator, to receive the personal data concerning him or her, which was

  provided to a controller, in a structured, commonly used and machine-

  readable format. He or she shall have the right to transmit those data to

  another controller without hindrance from the controller to which the

  personal data have been provided, as long as the processing is based on

  consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of

  Article 9(2) of the GDPR, or on a contract pursuant to point (b) of

  Article 6(1) of the GDPR, and the processing is carried out by automated

  means, as long as the processing is not necessary for the performance of a

  task carried out in the public interest or in the exercise of official

  authority vested in the controller.

  Furthermore, in exercising his or her right to data portability

  pursuant to Article 20(1) of the GDPR, the data subject shall have the

  right to have personal data transmitted directly from one controller to

  another, where technically feasible and when doing so does not adversely

  affect the rights and freedoms of others.

  In order to assert the right to data portability, the data subject may

  at any time contact any employee of the BMB Base Metals Brokerage GmbH.

• g) Right to object

  Each data subject shall have the right granted by the European

  legislator to object, on grounds relating to his or her particular

  situation, at any time, to processing of personal data concerning him or

  her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This

  also applies to profiling based on these provisions.

  The BMB Base Metals Brokerage GmbH shall no longer process the personal

  data in the event of the objection, unless we can demonstrate compelling

  legitimate grounds for the processing which override the interests, rights

  and freedoms of the data subject, or for the establishment, exercise or

  defence of legal claims.

  If the BMB Base Metals Brokerage GmbH processes personal data for direct

  marketing purposes, the data subject shall have the right to object at any

  time to processing of personal data concerning him or her for such

  marketing. This applies to profiling to the extent that it is related to

  such direct marketing. If the data subject objects to the BMB Base Metals Brokerage GmbH to the processing for direct marketing purposes, the MBH

  Metalbrokers Hamburg GmbH will no longer process the personal data for

  these purposes.

  In addition, the data subject has the right, on grounds relating to his

  or her particular situation, to object to processing of personal data

  concerning him or her by the BMB Base Metals Brokerage GmbH for scientific

  or historical research purposes, or for statistical purposes pursuant to

  Article 89(1) of the GDPR, unless the processing is necessary for the

  performance of a task carried out for reasons of public interest.

  In order to exercise the right to object, the data subject may contact

  any employee of the BMB Base Metals Brokerage GmbH. In addition, the data

  subject is free in the context of the use of information society services,

  and notwithstanding Directive 2002/58/EC, to use his or her right to

  object by automated means using technical specifications.

• h) Automated individual decision-making, including

  profiling

  Each data subject shall have the right granted by the European

  legislator not to be subject to a decision based solely on automated

  processing, including profiling, which produces legal effects concerning

  him or her, or similarly significantly affects him or her, as long as the

  decision (1) is not is necessary for entering into, or the performance of,

  a contract between the data subject and a data controller, or (2) is not

  authorised by Union or Member State law to which the controller is subject

  and which also lays down suitable measures to safeguard the data subject’s

  rights and freedoms and legitimate interests, or (3) is not based on the

  data subject’s explicit consent.

  If the decision (1) is necessary for entering into, or the performance

  of, a contract between the data subject and a data controller, or (2) it

  is based on the data subject’s explicit consent, the MBMB Base Metals Brokerage GmbH shall implement suitable measures to safeguard the data

  subject’s rights and freedoms and legitimate interests, at least the right

  to obtain human intervention on the part of the controller, to express his

  or her point of view and contest the decision.

  If the data subject wishes to exercise the rights concerning automated

  individual decision-making, he or she may, at any time, contact any

  employee of the BMB Base Metals Brokerage GmbH.

• i) Right to withdraw data protection consent

  Each data subject shall have the right granted by the European

  legislator to withdraw his or her consent to processing of his or her

  personal data at any time.

  If the data subject wishes to exercise the right to withdraw the

  consent, he or she may, at any time, contact any employee of the MBH

  Metalbrokers Hamburg GmbH.

10. Data protection for applications and the application

procedures

The data controller shall collect and process the personal data of

applicants for the purpose of the processing of the application procedure.

The processing may also be carried out electronically. This is the case,

in particular, if an applicant submits corresponding application documents

by e-mail or by means of a web form on the website to the controller. If

the data controller concludes an employment contract with an applicant,

the submitted data will be stored for the purpose of processing the

employment relationship in compliance with legal requirements. If no

employment contract is concluded with the applicant by the controller, the

application documents shall be automatically erased two months after

notification of the refusal decision, provided that no other legitimate

interests of the controller are opposed to the erasure. Other legitimate

interest in this relation is, e.g. a burden of proof in a procedure under

the General Equal Treatment Act (AGG).

11. Data protection provisions about the application and use of

Google Analytics (with anonymization function)

On this website, the controller has integrated the component of Google

Analytics (with the anonymizer function). Google Analytics is a web

analytics service. Web analytics is the collection, gathering, and

analysis of data about the behavior of visitors to websites. A web

analysis service collects, inter alia, data about the website from which a

person has come (the so-called referrer), which sub-pages were visited, or

how often and for what duration a sub-page was viewed. Web analytics are

mainly used for the optimization of a website and in order to carry out a

cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600

Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the

application “_gat. _anonymizeIp”. By means of this application the IP

address of the Internet connection of the data subject is abridged by

Google and anonymised when accessing our websites from a Member State of

the European Union or another Contracting State to the Agreement on the

European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic

on our website. Google uses the collected data and information, inter

alia, to evaluate the use of our website and to provide online reports,

which show the activities on our websites, and to provide other services

concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system

of the data subject. The definition of cookies is explained above. With

the setting of the cookie, Google is enabled to analyze the use of our

website. With each call-up to one of the individual pages of this Internet

site, which is operated by the controller and into which a Google

Analytics component was integrated, the Internet browser on the

information technology system of the data subject will automatically

submit data through the Google Analytics component for the purpose of

online advertising and the settlement of commissions to Google. During the

course of this technical procedure, the enterprise Google gains knowledge

of personal information, such as the IP address of the data subject, which

serves Google, inter alia, to understand the origin of visitors and

clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access

time, the location from which the access was made, and the frequency of

visits of our website by the data subject. With each visit to our Internet

site, such personal data, including the IP address of the Internet access

used by the data subject, will be transmitted to Google in the United

States of America. These personal data are stored by Google in the United

States of America. Google may pass these personal data collected through

the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies

through our website at any time by means of a corresponding adjustment of

the web browser used and thus permanently deny the setting of cookies.

Such an adjustment to the Internet browser used would also prevent Google

Analytics from setting a cookie on the information technology system of

the data subject. In addition, cookies already in use by Google Analytics

may be deleted at any time via a web browser or other software

programs.

In addition, the data subject has the possibility of objecting to a

collection of data that are generated by Google Analytics, which is

related to the use of this website, as well as the processing of this data

by Google and the chance to preclude any such. For this purpose, the data

subject must download a browser add-on under the link

https://tools.google.com/dlpage/gaoptout and install it. This browser

add-on tells Google Analytics through a JavaScript, that any data and

information about the visits of Internet pages may not be transmitted to

Google Analytics. The installation of the browser add-ons is considered an

objection by Google. If the information technology system of the data

subject is later deleted, formatted, or newly installed, then the data

subject must reinstall the browser add-ons to disable Google Analytics. If

the browser add-on was uninstalled by the data subject or any other person

who is attributable to their sphere of competence, or is disabled, it is

possible to execute the reinstallation or reactivation of the browser

add-ons.

Further information and the applicable data protection provisions of

Google may be retrieved under

https://www.google.com/intl/en/policies/privacy/ and under

http://www.google.com/analytics/terms/us.html. Google Analytics is further

explained under the following Link https://www.google.com/analytics/.

12. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing

operations for which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a

contract to which the data subject is party, as is the case, for example,

when processing operations are necessary for the supply of goods or to

provide any other service, the processing is based on Article 6(1) lit. b

GDPR. The same applies to such processing operations which are necessary

for carrying out pre-contractual measures, for example in the case of

inquiries concerning our products or services. Is our company subject to a

legal obligation by which processing of personal data is required, such as

for the fulfillment of tax obligations, the processing is based on Art. 6

(1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect

the vital interests of the data subject or of another natural person. This

would be the case, for example, if a visitor were injured in our company

and his name, age, health insurance data or other vital information would

have to be passed on to a doctor, hospital or other third party. Then the

processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f GDPR.

This legal basis is used for processing operations which are not covered

by any of the abovementioned legal grounds, if processing is necessary for

the purposes of the legitimate interests pursued by our company or by a

third party, except where such interests are overridden by the interests

or fundamental rights and freedoms of the data subject which require

protection of personal data. Such processing operations are particularly

permissible because they have been specifically mentioned by the European

legislator. He considered that a legitimate interest could be assumed if

the data subject is a client of the controller (Recital 47 Sentence 2

GDPR).

13. The legitimate interests pursued by the controller or by a

third party

Where the processing of personal data is based on Article 6(1) lit. f

GDPR our legitimate interest is to carry out our business in favor of the

well-being of all our employees and the shareholders.

14. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data

is the respective statutory retention period. After expiration of that

period, the corresponding data is routinely deleted, as long as it is no

longer necessary for the fulfillment of the contract or the initiation of

a contract.

15. Provision of personal data as statutory or contractual

requirement; Requirement necessary to enter into a contract; Obligation of

the data subject to provide the personal data; possible consequences of

failure to provide such data

We clarify that the provision of personal data is partly required by

law (e.g. tax regulations) or can also result from contractual provisions

(e.g. information on the contractual partner).

Sometimes it may be necessary to conclude a contract that the data subject

provides us with personal data, which must subsequently be processed by

us. The data subject is, for example, obliged to provide us with personal

data when our company signs a contract with him or her. The non-provision

of the personal data would have the consequence that the contract with the

data subject could not be concluded.

Before personal data is provided by the data subject, the data subject

must contact any employee. The employee clarifies to the data subject

whether the provision of the personal data is required by law or contract

or is necessary for the conclusion of the contract, whether there is an

obligation to provide the personal data and the consequences of non-

provision of the personal data.

16. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or

profiling.

We would like to expressly point out that the transmission of data via

the Internet (e.g., by e-mail) can offer security vulnerabilities. It is

therefore impossible to safeguard the data completely against access by

third parties. We cannot assume any liability for damages arising as a

result of such security vulnerabilities.

The use by third parties of all published contact details for the

purpose of advertising is expressly excluded. We reserve the right to take

legal steps in the case of the unsolicited sending of advertising

information; e.g., by means of spam mail.

BMB Base Metals Brokerage GmbH