• Privacy

    The following notes provide a simple overview of what happens to your personal data when you visit our website or use our app. Personal data is all data with which you can be personally identified. For detailed information on data protection, please refer to our privacy policy listed below this text.

    1. Introduction This Privacy Policy (the “Policy”) describes how SFJ Capital UG. (“SFJ” or “we/us/our”) collects, uses, stores, shares and protects the personal information derived from the use made by the user (the “User”) both of the platform accessible via the domain https://hejsfj.com (the “Website”) and our Applications (Fred & Sunny Days Ahead) (the “App”), and through the services that are specifically offered to you via the Website or the App (referred to indistinctly as the “Services”). If you have any concern or query in connection with the Policy, you can consult us at [email protected].

    2. Who is the data controller of your personal data? The personal data you provide in the User registration process, along with any data submitted during the provision of the services or that SFJ may obtain through the Website and/or the App, will be processed by SFJ Capital UG UG located at Dhauner Straße 42, 67067 Ludwigshafen am Rhein (Deutschland) with HBR number 67315 and whose contact email address is [email protected]. This Policy governs the processing of personal data. All the terms used in the Policy will have the meaning established in the Terms and Conditions of Use (https://hejsfj.com/imprint) unless they are expressly defined in this Privacy Policy.

    3. For what purpose do we process your data? The personal data will be collected and processed in the context of the Services offered through the Website and/or the App for the following purposes: (a) To manage User registration and to be able to control the development and compliance with the contractual relationship with you, in accordance with the Terms and Conditions of Use. In particular, SFJ will process the following categories of data for the purposes that are specified below: (b) To respond to queries that may be submitted by Users in connection with the App and the Website or the Services (c) To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (d) For any other business purpose stated when collecting your personal data or as otherwise set forth in applicable data privacy laws. Furthermore, and only with the consent of the User in each case, we will use their data for the following additional purposes: (a) To better know their preferences through evaluation of their profile, using the data to improve the use of the Website and/or the App, prevent fraud and improve the service. (b) If so requested, to send the User advertising or commercial information, including by electronic means, about SFJ’s products and services that may be of interest to them. (c) To process their participation in competitions and specific promotions. In addition, the User’s personal data will be processed when SFJ has to fulfill a legal obligation under tax and anti-money laundering laws. Whenever you interact with our App, Website, or Services, we automatically collect information, such as: log data (e.g., access times, hardware, software information), usage information, browsing history, browser information, screen recording of Service interaction and usage, location data (e.g., IP address, zipcode), device identification, “cookie” information, page view statistics, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. For more information on our use of Cookies, please see our Cookies Policy. Our service providers may also transmit cookies to your browser or device in certain situations, such as when you click on a link to a third party website or service. This Policy does not cover the use of cookies by any third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google’s use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

    4. What is the legitimate interest for processing the data? The legal basis for processing the data is the performance of the Terms and Conditions of Use of the Services, where the data processing is strictly necessary to be able to use the Website and the App and, therefore, to allow Users to benefit from the services made available to them. With respect to additional purposes, these are legitimized by the consent given by the User, which may be revoked at any time without affecting the provision of the Services. Specifically, Users may withdraw their consent at any time by contacting us at [email protected]. 5. How long will we keep your personal data? SFJ will keep the personal data of Users while they remain registered customers or users of the Website and/or the App, and the personal data will be retained after the termination of the contractual relationship, duly blocked, for the time necessary to answer for any liabilities that may be derived from the relationship. In some cases we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. In particular, the Personal Data required for responding to queries made and delivering electronic marketing communications will be processed for as long as the User does not revoke the consent given and, once that consent has been withdrawn, for the time necessary to answer for any liabilities that may have arisen. In any case, when the personal data is not required for the purpose for which it was obtained and until it is not finally canceled, it will be retained in a blocked form. As stated in the Terms of Use, we do not knowingly collect personal information from anyone under the age of 18; if you are an individual under 18, please do not attempt to register, use our services or send us your personal information. If we learn that we have collected personal information from anyone under the age of 18, we will delete that information as soon as possible. If you believe that someone younger than 18 years has given us his or her personal information, please contact us through [email protected].

    6. Who will your data be sent to? SFJ may communicate the personal data of Users when so required by law, for defending its legitimate rights and interests, or when necessary in accordance with the services contracted by Users. They may also be accessed by third party service providers and computer and technical support services, some of which are detailed below.

    6.1 Passing on of data for the fulfilment of the services Our systems, data and services are hosted on the Google Cloud Platform ("GCP"), whose servers are located at "Europe-west3" and "Europe-west1. Your data may be transferred internationally to servers in the United States. This international transfer of personal data is covered by the EU-USA Privacy Shield Agreement and therefore provides adequate safeguards for the protection of your personal data. More information is available at the following link: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active. To conclude, we inform you that SFJ relies on other companies to provide certain services related to the Website and/or the App, like billing or payment of Services through our platform. More information on each company is available at the following links: Google Analytics: https://policies.google.com/privacy/update RevenueCat: https://www.revenuecat.com/privacy Supabase: https://supabase.com/privacy Google Analytics (https://policies.google.com/privacy/update) For the purpose of designing our pages to meet your needs and continuously optimizing them, we use Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files which are stored on your computer and which enable an analysis of your use of the website. In this context, pseudonymised user profiles are created and cookies are used. The information generated by the cookie about your use of this website such as Browser type/version,



the operating system used, Referrer URL (the previously visited page), Host name of the accessing computer (IP address), Time of the server request On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the internet. The IP address transmitted by your browser within the framework of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de. As an alternative to the browser add-on, especially in the case of browsers on mobile devices, you can also prevent Google Analytics from recording the data by clicking on this link. An opt-out cookie is set to prevent future collection of your information when you visit this website. The opt-out cookie is valid only in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you will need to set the opt-out cookie again. You can find further information on data protection in connection with Google Analytics on the Google Analytics website.

    6.1.1 RevenueCat

    In the case of in-app payments, payment is made via RevenueCat Inc., 300 Euclid Avenue San Francisco, CA 94118, USA. to whom we pass on the information you provided during the ordering process together with the information about your order. Your data will be passed on in accordance with Article 6 Paragraph 1 Letter b GDPR exclusively for the purpose of payment processing and only to the extent that it is necessary for this. We have concluded an order processing contract with RevenueCat Inc., with which we oblige the provider to protect the data of the app users and not to pass it on to third parties. Further information on data protection by RevenueCat can be found here: https://www.revenuecat.com/privacy

    7. What are your rights as the data subject? The exercise of all these rights is free.

    7.1) Rights of the data subject 7.1.1 The applicable data protection law grants you comprehensive data subject rights (rights to information and intervention) vis-à-vis the person responsible for the processing of your personal data, about which we will inform you below: Right to information in accordance with Art. 15 GDPR: In particular, you have a right to information about your personal data processed by us, the processing purposes, the categories of personal data processed, the recipients or categories of recipients to whom your data was or will be disclosed, planned storage period or the criteria for determining the storage period, the existence of a right to correction, deletion, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if they were not collected from you by us, the existence of automated decision-making including profiling and, if applicable, meaningful information about the logic involved and the scope and intended effects of such processing on you, as well as your right to be informed which guarantees pursuant to Art. 46 GDPR when your data is forwarded to third countries exist; Right to rectification in accordance with Art. 16 GDPR: You have the right to immediate rectification of incorrect data concerning you and/or completion of your incomplete data stored by us; Right to deletion according to Art. 17 GDPR: You have the right to request the deletion of your personal data if the requirements of Art. 17 Para. 1 GDPR are met. However, this right does not apply in particular if the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims; Right to restriction of processing in accordance with Art. 18 GDPR: You have the right to request the restriction of the processing of your personal data as long as the accuracy of your data, which you dispute, is being checked, if you refuse to delete your data because of inadmissible data processing and instead request the restriction of the processing of your data if you need your data to assert, exercise or defend legal claims after we no longer need this data after the purpose has been achieved or if you have lodged an objection for reasons of your particular situation, as long as it is not yet clear whether our legitimate reasons prevail; Right to information in accordance with Art. 19 GDPR: If you have asserted the right to correction, deletion or restriction of processing against the person responsible, he is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients. Right to data portability in accordance with Art. 20 GDPR: You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request transmission to another person responsible, insofar as this is technically feasible; Right to revoke granted consent in accordance with Art. 7 Para. 3 DSGVO: You have the right to revoke your consent to the processing of data at any time with effect for the future. In the event of revocation, we will delete the data concerned immediately, unless further processing can be based on a legal basis for processing without consent. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent up to the point of revocation; Right to lodge a complaint pursuant to Art. 77 GDPR: If you believe that the processing of your personal data violates the GDPR, you have - without prejudice to any other administrative or judicial remedy - the right to lodge a complaint with a supervisory authority, in particular in the Member State where you live, work or where the alleged infringement took place.

    Contact channel To exercise your rights, please send an e-mail to [email protected].

    8. Information updating The User may update the information held by SFJ through the settings available in their account, or by writing to [email protected]. We remind you that in order for SFJ to adequately provide the Services, the User must keep their information up to date, and accordingly, agrees to regularly check the information provided to ensure it is accurate. You can ask us to stop sending you marketing emails or communications at any time. To this end, you can change the communications preferences in the settings section of your account, or contact us at [email protected]. However, this will not prevent us from sending emails and other communications related to the Services, since these are necessary to comply with the contractual relationship between us and the User.

    9. RIGHT TO OBJECT IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF A BALANCING OF INTERESTS, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING FOR REASONS RESULTING FROM YOUR PARTICULAR SITUATION WITH EFFECT FOR THE FUTURE. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP THE PROCESSING OF THE DATA INVOLVED. HOWEVER, FURTHER PROCESSING REMAINS RESERVED IF WE CAN PROVE COMPREHENSIVE REASONS FOR PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FUNDAMENTAL FREEDOMS, OR IF THE PROCESSING IS FOR THE CERTIFICATION, EXERCISE OR DEFENSE OF LEGAL CLAIMS. IF YOUR PERSONAL DATA IS PROCESSED BY US FOR DIRECT ADVERTISING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. YOU MAY OBJECT AS DESCRIBED ABOVE. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP THE PROCESSING OF THE DATA INVOLVED FOR DIRECT MARKETING PURPOSES.