Privacy policy

Who is responsible

The controller responsible for the personal data processed on this website, in the sense of Article 4(7) of the General Data Protection Regulation (GDPR), is Kagels Trading GmbH. The managing director, the commercial register entry and the VAT identification number are listed on the imprint page.

If you have a question about how your data is handled, or you want to exercise any of the rights described at the end of this page, write to us at the address below, email us, or use the contact page. We answer privacy questions ourselves.

This policy covers the English site at kagels-trading.com. Our German site at kagels-trading.de runs on different software and publishes its own privacy policy, so please read that one if you visit it.

Company

Kagels Trading GmbH

Address

Friedrichstraße 171, D-10117 Berlin, Germany

Telephone

+49 30 56825985

Email

info@kagels-trading.de

What data we collect

Everything on this site is free to read and there is nothing to buy, so we do not take payment details, we do not run accounts, and we do not ask you to register. We do not buy personal data, we do not sell it, and we do not combine what you tell us with data from anywhere else.

Personal data is collected in three situations only, set out below with the legal basis for each and how long we keep it. The general rule is that we keep nothing longer than its purpose actually requires. Separately from that, where German commercial or tax law requires a document to be kept, for example business correspondence or an accounting record, we keep it for the statutory period, which is six or ten years depending on the document (section 257 of the German Commercial Code, HGB, and section 147 of the German Fiscal Code, AO).

• Newsletter. When you subscribe we store the email address you give us and the date and time you confirmed the subscription. The legal basis is your consent, Article 6(1)(a) GDPR. The confirmation record exists so we can show, if we are ever asked, that the subscription was genuinely requested. We keep your address until you unsubscribe, at which point it is removed from the active list, although we may keep a minimal record that it opted out so that it is not added again by mistake.
• Contact form and email. When you write to us we store your message and the contact details you give us, so that we can answer. Where your enquiry is about working with us, the legal basis is Article 6(1)(b) GDPR, which covers steps taken at your request before any agreement. In every other case it is our legitimate interest in replying to people who contact us, Article 6(1)(f) GDPR. You do not have to give us your data, but without an email address we cannot answer you by email. We keep enquiries for as long as it takes to deal with the matter, and for a reasonable period afterwards in case you come back to us about the same thing.
• Server logs. When you browse the site, our hosting provider records standard technical data: the page requested, the date and time, the referring page, the browser and operating system, and the IP address the request came from. Every web server does this, and without it a page cannot be delivered to you at all. We use it to keep the site available and to detect and defend against attacks. The legal basis is our legitimate interest in a secure, working website, Article 6(1)(f) GDPR. Log data is kept only for the short period needed to run and secure the site, and is then deleted or anonymised.

Newsletter

The newsletter is free and entirely optional. Your email address is the only thing we ask for, and we use it to send you the newsletter. We do not use it for anything else and we do not pass it to anyone for their own purposes.

Signing up uses a double opt-in process: after you enter your address you receive one confirmation email, and nothing further is sent until you click the link in it. If you never click, the address is not added to the list. This protects you as much as us, because it means nobody can sign up an address that is not theirs.

You can unsubscribe at any time using the link at the bottom of every newsletter, or simply by writing to us. Unsubscribing withdraws the consent you gave under Article 6(1)(a) GDPR, which you are free to do at any point under Article 7(3) GDPR. Withdrawing it does not make anything we sent before that unlawful, it just stops anything further.

The newsletter is not sent from our own servers. It is sent through a specialist email service provider, which stores your address and the delivery data on our behalf. That provider acts only on our instructions as a processor, and is bound by a data processing agreement under Article 28 GDPR. The provider is identified by name in this section from the day the newsletter goes live, together with where it processes the data and, if that is outside the EU or the EEA, the safeguards that cover the transfer.

Cookies and analytics

This site is built to use as few cookies as possible. Cookies that are strictly necessary for the site to work are set without asking you first, which section 25(2) of the German Digital Services Data Protection Act (TDDDG) permits. Anything that is not strictly necessary is only stored on your device after you have agreed to it, and you can withdraw that agreement at any time with effect for the future.

We do not use advertising cookies. There are no advertising pixels, no retargeting tags and no cross-site tracking on this site, and we do not build advertising profiles of our readers.

Most browsers also let you block or delete cookies yourself, in their settings. If you block strictly necessary cookies, parts of this site may stop working properly.

Visitor statistics with Matomo. To understand which forecasts and articles people actually read, we use Matomo, an analytics tool that we run on our own infrastructure. The usage data stays with us rather than being handed to an outside analytics company to use for its own purposes.

Where the analytics setup stores or reads anything on your device, it does so only with your consent, under Article 6(1)(a) GDPR and section 25(1) TDDDG, and you can withdraw that consent at any time. Where it measures without storing anything on your device, the legal basis is our legitimate interest in knowing how the site is used so that we can decide what to publish next, Article 6(1)(f) GDPR, and you can object to the measurement at any time. Either way, write to us through the contact page and we will deal with it.

Matomo is configured here for the smallest sensible data footprint:

• IP addresses are shortened before they are stored, so a full address is never kept and individual visitors cannot be identified from the statistics.
• No data is passed to third parties, and none of it is used for advertising.
• You are not followed across other websites. The measurement stops at the edge of this site.

Services and third parties

A website cannot be delivered to you without some technical data reaching the companies that deliver it. We keep that list as short as we can, and the list below is the whole of it. This site carries no advertising network, no social media plugins or like buttons, no embedded videos, no comment system, no live chat, no review widgets and no affiliate tracking. Nothing on these pages loads a third party script that watches what you do.

Links out to other websites are just links. Once you follow one, this policy no longer applies and the other site's own privacy policy takes over, so it is worth a look if the site is new to you.

Data outside the EU. Where a service provider is based outside the EU or the EEA, or processes data there, we rely on the European Commission's standard contractual clauses under Article 46(2)(c) GDPR, together with the technical and organisational measures agreed with that provider. You can ask us for details of the safeguards that apply to a particular service.

These are the services involved, and what each one receives:

• Cloudflare Pages, hosting and content delivery. Provided by Cloudflare, Inc., a company based in the United States with data centres across Europe. To deliver a page to you, Cloudflare processes your connection data, including your IP address, the page requested and basic browser information. It also uses that data to protect the site against attacks. Legal basis: our legitimate interest in a fast, available and secure website, Article 6(1)(f) GDPR. Cloudflare acts as our processor under a data processing agreement in line with Article 28 GDPR, which includes the European Commission's standard contractual clauses for any transfer of data to the United States.
• Matomo, visitor statistics. Run on our own infrastructure, as described in the previous section. The data is not handed to an outside analytics company.
• Google Fonts, the typeface used in the design. The font files are loaded from Google's font servers (fonts.googleapis.com and fonts.gstatic.com), operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When a page loads, your browser requests the font directly from those servers, so Google receives your IP address and basic browser information. Google states that these requests are kept separate from any Google account and are not used for advertising. Legal basis: our legitimate interest in a consistent, readable presentation of the site, Article 6(1)(f) GDPR. Google's privacy information is at policies.google.com/privacy.
• TradingView, chart images. The charts in our forecasts are drawn by Karsten in TradingView and then published here as ordinary static images served from our own site. No live TradingView widget runs on these pages, so viewing a chart sends nothing about you to TradingView.

Your rights

If we hold personal data about you, the GDPR gives you the rights listed below, and you do not have to give a reason for using them. To use any of them, write to us through the contact page, or email info@kagels-trading.de. We may need to check who you are before we hand over personal data, which is a protection for you rather than an obstacle. There is no charge for any of this in the normal course of things.

You also have the right to complain to a data protection supervisory authority under Article 77 GDPR. You can go to the authority in the EU country where you live, where you work, or where you believe the problem happened. Because our registered office is in Berlin, the authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit). We would rather you came to us first so that we can put things right, but you are under no obligation to.

• Access (Article 15): you can ask what data we hold about you and get a copy of it.
• Correction (Article 16): if something we hold is wrong or incomplete, you can have it corrected or completed.
• Deletion (Article 17): you can ask us to delete your data, unless the law requires us to keep it.
• Restriction (Article 18): you can ask us to stop using your data while something about it is being sorted out.
• Portability (Article 20): you can ask for the data you gave us in a structured, common, machine-readable format, or ask us to send it to someone else.
• Withdrawing consent (Article 7(3)): where processing rests on your consent, you can withdraw it at any time. That stops the processing from then on and does not make what happened before unlawful.
• Objecting (Article 21): where we process your data on the basis of a legitimate interest, Article 6(1)(f) GDPR, you can object at any time on grounds relating to your particular situation. If you do, we stop, unless we can show compelling legitimate grounds that override your interests or we need the data to establish, exercise or defend legal claims. Where data is processed for direct marketing, you can object at any time without giving any reason at all, and we will stop.