I. 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:

• Next Level Underwriting
• Werkstr. 12
• 24955 Harrislee
• Germany
• info@nl-underwriting.com
• www.nl-underwriting.com

II. Name and address of the Data Protection Officer

• The Data Protection Officer of the controller is:
• Christian Krützfeldt
• Werkstr. 12
• 24955 Harrislee
• Germany
• Phone: +49 461 16063-0
• E-Mail: christian@balticfinance.com

III. General information on data processing

1. Scope of the processing of personal data

We only process personal data of our users to the extent that it is necessary to provide a functional website as well as our contents and services. Generally, the personal data of our users will only be processed when we have obtained the prior consent of the user. An exception applies in such cases in which the prior consent cannot be obtained for practical reasons and the data processing is permitted by legal provisions.

2. Legal basis for the processing of personal data

When we obtain consent from a data subject for the purposes of processing of personal data, Art. 6 (1) (a) of the EU General Data Protection Regulation (GDPR) provides the legal basis for such processing.

Where processing of personal data is necessary for the performance of a contract to which the data subject is party, Art. 6 (1) (b) GDPR provides the legal basis. This also applies to processing that is necessary to carry out pre-contractual measures.

Where processing is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) (c) GDPR provides the legal basis.

Where processing of personal data is necessary in order to protect the vital interests of the data subject or of another natural person, Art. 6 (1) (d) GDPR provides the legal basis.

Where 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, Art 6 (1) (f) GDPR provides the legal basis for such processing.

3. Data erasure and duration of storage

The personal data of the data subject will be erased or blocked as soon as the purpose of the storage no longer applies. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

IV. Provision of the website and creation of logfiles

1.Description and scope of data processing

Every time you visit our website, our system automatically collects data and information from the computer system of the calling computer.

The following data are collected:

Information about the browser type and version

The operating system of the user

The Internet service provider of the user

The IP address of the user

Date and time of access

Websites from which the user’s system reaches our website

Websites accessed by the user’s system through our website

The data are also stored in the logfiles of our system. These data are not stored together with other personal data of the user.

2. Legal basis for data processing

The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (f) GDPR

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user’s computer. For this purpose the IP address of the user must remain stored for the duration of the session.

The data are stored in logfiles to ensure correct functioning of the website. Furthermore the data help us to optimize the website and to guarantee the security of our IT systems. The data are not analysed for marketing purposes in this context.

Our legitimate interest in data processing pursuant to Art. 6 (1) (f) GDPR also lies in these purposes.

4. Duration of storage

The personal data will be erased as soon as they are no longer necessary in relation to the purposes for which they were collected. When data are collected for the provision of the website, this will be the case when the the session has ended.

When data are stored in logfiles, they will be erased after seven days, at the latest. Further storage is possible. In this case the IP addresses of the users will be erased or anonymized so that it is no longer possible to track the visiting client.

5 .Possibility of objection and elimination

The collection of data for the provision of the website and the storage of data in logfiles is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

V. Rights of the data subject

1. Right of access

You can request the controller to confirm whether personal data concerning yourself are being processed by us.

Where that is the case, you can request the controller to provide access to the following information:

the purposes of the processing;

the categories of personal data concerned;

the recipients or categories of recipient to whom your personal data have been or will be disclosed;

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 your personal data or restriction of processing of your personal data or to object to such processing;

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, pursuant to Art. 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether your personal data are transferred to a third country or to an international organisation. In this context, you can request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR relating to the transfer.

2. Right to rectification

You have the right to obtain from the controller rectification and/or completion if the processed personal data concerning yourself are inaccurate or incomplete. The controller shall make the rectification without delay.

3. Right to restriction of processing

You have the right to obtain from the controller restriction of processing of your personal data where one of the following applies:

if you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;

the processing is unlawful and you oppose the erasure of the personal data and request 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 you for the establishment, exercise or defence of legal claims, or

you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override yours.

Where processing of your personal data has been restricted such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If processing is restricted according to the above-mentioned conditions, you shall be informed by the controller before the restriction of processing is lifted

4. Right to erasure

a) Obligation to erase

You have the right to obtain from the controller the erasure of your personal data without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

You withdraws consent on which the processing is based according to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR, and where there is no other legal ground for the processing.

You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.

The personal data have been unlawfully processed.

The personal data have to 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 Art. 8 (1) GDPR.

b) Information to third parties

Where the controller has made the personal data public and is obliged pursuant to Art. 17 (1) GDPR 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 controllers which are processing the personal data that you as data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

c) Exceptions

The right to erasure shall not apply to the extent that processing is necessary

for exercising the right of freedom of expression and information

for compliance with a legal obligation which requires processing under Union or member state law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

for reasons of public interest in the area of public health in accordance with Art. 9 (2) (h) and (i) as well as Art. 9 (3) GDPR;

for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 (1) GDPR, in so far as the right referred to in paragraph a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

for the establishment, exercise or defence of legal claims.

5. Right to information

If you exercised your right to rectification, erasure or restriction of processing towards the controller, the controller shall be obliged to inform all recipients to whom your personal data have been disclosed about such rectification, erasure or restriction of processing unless this proves impossible or involves disproportionate effort.

You have the right to receive information on such recipients from the controller.

6. Right to data portability

You shall have the right to receive your personal data, which you provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where

the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR, and

the processing is carried out by automated means.

In exercising this right, you shall also have the right to have the personal data transmitted directly from one controller to another, where technically feasible. Freedoms and rights of other persons may not be adversely affected in that respect.

The right to data portability shall not apply to 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.

7. Right to object

You shall have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data based on Art. (6) (1) (e) or (f) GDPR; including profiling based on those provisions.

The controller shall no longer process the personal data unless the controller demonstrates 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.

Where your personal data are processed for direct marketing purposes, you shall have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

In the context of the use of information society services – and notwithstanding the Directive 2002/58/EC – you may exercise your right to object by automated means using technical specifications.

8. Right of withdrawal of consent

You shall have the right to withdraw your declaration of consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

9. Automated individual decision-making, including profiling

You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects for you or similarly significantly affects you. This shall not apply if the decision

is necessary for entering into, or performance of, a contract between you and the controller,

is 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

is based on your explicit consent

However, such decisions may not be based on special categories of personal data referred to in Art. 9 (1) GDPR, unless Art. 9 (2) (a) or (g) GDPR applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.

In the cases referred to in sections (1) and (3), the data controller 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 to contest the decision.

10. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall 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 place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and outcome of the complaint including the possibility of a judicial remedy pursuant to Art. 78 GDPR.