SDIS Global AG, of Gartenstrasse 22, 4052 Basel, Switzerland ("SDIS"), is committed to protecting the confidentiality and privacy of information entrusted to it. 

This Privacy Statement describes SDIS' policy regarding the collection, use and disclosure of personal data you provide when accessing and otherwise using the Aurora System. This Privacy Statement applies solely to your access and use of SDIS' Aurora System.

Personal data means any information relating to you which allows us or any third party to identify you, whether directly or indirectly.

This Privacy Statement forms an integral part of SDIS' Terms of Use, and the provisions thereof, including (without limitation), the provisions regarding disclaiming of warranties, limitation on liability, governing law and dispute resolution, apply to this Privacy Statement ("Terms of Use"). 

Unless otherwise stated, any defined terms used herein shall have the meaning assigned to them in the Terms of Use. 

Your consent

By acknowledging your consent to use the Aurora System, you also consent to: 

The collection, storage, processing, transfer, disclosure and other uses of your personal data, all as described in this Privacy Statement;

To the transfer of such personal data outside of the country where you reside in and outside the European Economic Area (EEA) and other regions with comprehensive data protection laws, to other countries worldwide for storage, processing and use by us as part of our allowing the access and use of the Aurora System; and

The placing of cookies on your computer or internet-enabled device, as described below.

What personal data do we collect?

We may collect the following categories of personal data:

When you create a User Account, you will be asked to provide your name, home address, zip code, email address, telephone number, passport or other recognized personal ID card numbers and details, and credit card details.

Personal data about your use of the Aurora System. Such data may include your IP address (which may tell us your general location), browser and standard web server log information, and any device ID or other unique identifiers of any device you are using.

The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.

Information you provide while posting Submissions on the Forum or Feedbacks, or otherwise.

Cookies and site tracking

A cookie is a small text file, which often includes an anonymous unique identifier. When you visit an Internet site, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each Internet site can send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits an Internet site to access the cookies it has already sent to you, not the cookies sent to you by other sites. Most web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended.

As you use the Aurora System, the Aurora System uses cookies to differentiate you from other Users. 

In addition, the Aurora System uses Google Analytics, a web analysis service provided by Google Inc., which works using cookies. This helps us gather feedback in order to constantly improve the Aurora System and better serve our customers. Cookies do not allow us to gather any personal data about you and we do not generally store any personal data that you provided to us in your cookies.

By viewing, accessing and/or using the Aurora System, you agree to the placement of cookies on your computer in accordance with the terms of this Privacy Statement.

What do we use your personal data for, why and for how long?

Purposes for collecting and processing your personal data

We may use personal data we collect for the following purposes:

Facilitating the access and use of the Aurora System by you;

Improving the Aurora System and enhancing your experience with us; 

Contacting you in the event it becomes necessary to do so;

Accounting, billing and auditing, and for detecting and/or preventing any fraudulent


Protecting the rights of SDIS, of its users and of other third parties; 

Sending you communications about the Aurora System and any changes thereto. These communications are not made for marketing purposes and cannot be opted-out of; and/or for

Sending you, from time to time, marketing communications regarding the Aurora System. 

You will have the right to opt in or to opt out of such marketing communications. You will also be given the opportunity on every marketing email that we send you to indicate that you no longer wish to receive our direct marketing material.

The legal basis for collecting and processing your personal data

We shall only process your personal data where we have a legal basis to do so. Such legal basis may be one or more of the following:

You have given your consent to us processing your personal data (e.g., as set out in the Section 'Your consent' above);

Processing is necessary for the performance of the contract between us;

Processing is necessary for compliance with a legal obligation which applies to us;

Processing is necessary to protect your vital interests or those of another person; and/or

Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. 

The legal basis will depend on the reasons we process and store your personal data for.

Retaining your personal data

We shall not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

We must also consider periods for which we might need to retain personal data in order to meet our legal obligations (e.g., in relation to claims) or to deal with complaints, queries and to protect our legal rights in the event of a claim being made. 

When we no longer need your personal data, we shall take reasonable measures to securely delete or destroy it.

Sharing your personal data

We may share your personal data with the following third parties and/or in the following circumstances:

Suppliers and licensors, as required to enable the access and use of the Aurora System by you;

Service providers we are using to run our business, such as cloud services providers who host the Aurora System at data centers located in multiple locations world-wide, and marketing services providers;

Credit card companies and payment service providers, which facilitate your payments to us, and anti-fraud screening, which may require information about your method of payment to process payment or ensure the security of your payment transaction;

Government authorities, law enforcement bodies and regulators for compliance with legal obligations which apply to us;

Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in, in order to enforce our legal rights in relation to our contract with you;

Social media: You may be able to access third party social media services through the Aurora System or before your access to the Aurora System. When you are registered with your social service account, we shall obtain the personal data you choose to share with us through these social media services pursuant to their privacy settings, in order to improve and personalize your use of the Aurora System. We may also use social media plugins on the Aurora System. As a result, your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy policy of these third-party social media providers to find out more about these practices;

If we are involved in a merger, acquisition, reorganization or sale of assets, or in bankruptcy: Your personal data may be sold or transferred as part of that transaction. In any such transfer of personal data, we shall ensure the confidentiality of any personal data involved in such transactions and provide notice before personal data is transferred and becomes subject to a different privacy policy.

Protection of your personal data

We take administrative and technical measures to safeguard your personal data against loss, theft, and misuse, as well as unauthorized access, alteration, disclosure or destruction.

We processes personal data on servers located in various countries worldwide. 

We shall cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between SDIS and an individual.

SDIS shall use reasonable efforts to protect information submitted by you in connection with the Aurora System, but you hereby acknowledge and agree that your submission of such information is at your sole risk, and SDIS hereby disclaims any and all liability for any disclosure, loss or liability relating to such information in any way.

Your data protection rights

Under certain circumstances, you may have, by law, the right to:

Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 

Withdraw your consent to our processing of your data for direct marketing purposes by unsubscribing from our mailing list (see Section 'What do we use your personal data for, why and for how long?' for more details).

If you want to exercise any of these rights, you can contact us as mentioned in Section 'Contact information' below.

Please note that requests for data access, erasure, etc., are dealt with via the Aurora System. Requests to unsubscribe from our mailing list can be made by clicking on the "unsubscribe" link in any of our marketing emails addressed to you. These requests cannot be processed if made via email, due to their volume and the need to verify your identity before we can act on your request.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

This Privacy Statement should help you to better understand how we use your personal data, it explains in detail the types of personal data we collect, what we use it for and who we may share it with. If you have any further questions about this Privacy Statement or how we handle your personal data, which are not dealt with here, please contact us as mentioned in Section 'Contact information' below.

Statement towards children

We do not knowingly collect personal data from children under the age of 18. 

If we become aware that a child under the age of 18 has provided us with personal data without verification of parental consent, we shall attempt to remove such personal data from our servers and terminate the child's account as soon as possible.

External sites 

We are not responsible or liable for the practices employed by External Sites linked to the Aurora System, nor for the information or content contained therein. When you use a link to go from the Aurora System to External Sites, our Privacy Statement is no longer in effect. Your browsing and interaction on any External Site, including Internet sites which have a link on the Aurora System, is subject to that External Site's own rules and policies. 

Contact information

If you have any questions or comments about this Privacy Statement, please contact us at

Changes to this Privacy Statement

We may change this Privacy Statement at any time and from time to time without liability to SDIS or notice. Any such change will be effective as of the date it is posted on this page. 

Your continued use of the Aurora System after the effective date of any changes to this Privacy Statement, will be deemed to constitute your acceptance of any and all such changes.

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This Privacy Statement was last updated on April 4, 2019.


The system provides financial information and data to help you identify investment ideas. However, we do not advise you or guide you about this, or what products to purchase or sell – these decisions are yours only.SDIS and the system are not subject to the series, and SDIS does not hold a license for investment consultancy, investment marketing or investment portfolio management under any law. The content provided on the system is independent and not based or tailored to your personal circumstances, To your needs or for your purposes, and should not be relied on as an estimate of profitability or the suitability of an investment in a particular stock for any purpose. Past performance is not a guarantee of present or future performance. Investments may lose its full value.