Sportec Solutions AG ("Sportec Solutions") appreciates your interest in and your visit to the internet site (the "Website") of Sportec Solutions at www.sportec-solutions.de.

1. Limit on liability
The content in this Website was produced with the greatest possible care. However, Sportec Solutions assumes no guarantee for the accuracy, completeness, timeliness or other quality of the provided content. The use of the content on the Website is at the User’s own risk. Contributions for which an author is named reflect the opinion of the respective author and not always the opinion of Sportec Solutions. The mere use of the Website does not establish a contractual relationship between the User and Sportec Solutions. Liability for damages, regardless of the legal basis and type, is excluded, unless the damages are based on intentional or grossly negligent misconduct.

2. Intellectual property, copyright and protective rights
All rights are reserved. The intellectual property contained on or in this Website is protected. The User is not granted any license to use or exploit the intellectual property of Sportec Solutions in this Website. Especially the content published on this Website, such as text, images, illustrations, sound, animation and videos as well as how they are ordered are subject to German copyright law and law protecting work product as well as other protective laws. Any use or exploitation which is not permitted by German copyright law or the law governing work product requires the prior written consent of Sportec Solutions or the respective holder of the right. This applies especially for reproduction, processing, translation, storage and repetition of content in data bases or other electronic media and systems. The production of copies and downloads is only permitted for personal, private and non-commercial use. The display of this Website in third party frames is only permissible with written permission. The User is instructed that the content in the Website is subject in part to third party copyrights. If the User learns about a violation of a right, Sportec Solutions requests corresponding notification.

3. Trademarks and marking rights
All trademarks and marks of Sportec Solutions mentioned or displayed in the services are protected by law. This applies especially for trademarks, logos and emblems. All other trademarks and marks of third parties mentioned or displayed in the services are fully subject to the provisions of the respective trademark and marking right of the respective holder. Simply naming or showing in particular does not mean that such brands and trademarks are not protected by rights of third parties.

4. References and links
The Website contains links to websites of third parties ("external links"). These websites are subject to the liability of the respective operator. Sportec Solutions examined the content of the third party when first establishing the external links with regard to whether there were any violations of law. There were no apparent violations of law at that time. Sportec Solutions has absolutely no influence on the current and future design and content of the linked pages. The setting of external links does not mean that Sportec Solutions has assumed responsibility for the content behind the link. Continuous monitoring of the external links is not reasonably possible for Sportec Solutions without having specific information about violations of law. Upon learning about violations of law, however, such external links will be deleted without undue delay.

5. Services of third parties
If goods or services are offered by third parties on the Website, the User must accept the contractual terms and conditions when ordering because the terms and conditions of contract of the third party apply exclusively for the contractual relationship between the User and the third party. It is especially possible to order goods and services from partners of Sportec Solutions through the Website or to participate in their contests and other actions. Sportec Solutions is exclusively active as an intermediary in these situations. The action as an intermediary will take place, e.g. using a link which is activated on the Website in the context of the offerings by the partners and which leads to the specific offer on the own website of the partners. Questions and complaints must accordingly be directed directly to the respective partner whose terms and conditions of contract apply for the respective order or participation.

6. Data protection
The provisions on data protection (Privacy Statement) can be reviewed via the following link.

Sportec Solutions AG, Beta-Straße 1, D-85774 Unterföhring, Germany ("Sportec Solutions") collects, processes and uses personal data, which is collected and stored when visiting the website www.sportec-solutions.de (hereinafter referred to as the "Website"), in compliance with the data protection regulations applicable in the Federal Republic of Germany. This privacy policy explains what data the visitor ("user") collects on the website and how this data is processed and used. The user can contact the data protection officer at the e-mail address datenschutz@sportec-solutions.com.

1. Personal data

Personal data are all information which relate to an identified or identifiable natural person. A 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. This includes, for example, the name, personalized email addresses, the residential address, the telephone number or the date of birth.

2. Data collection, processing and use when accessing the Website

Each time a User accesses the Website, the User’s Internet browser, for technical reasons, automatically supplies the following data to Sportec Solutions’s web server:

IP address of the end device

date and time of access

name and URL of accessed page

transferred data volume

access status (data file transmitted, data file not found, etc.)

recognition data of the used browser and operating system of the User's end device

name of the User’s Internet service provider

website from which the access was made

The collection, processing and use of these data occur for the purposes of enabling the use of the Website (connection set-up), system security and technical administration of the network infrastructure. A comparison with other data sets or a transmission to third parties, even in excerpts, does not take place. The legal basis for processing is Art. 6 para. 1 b) and f) General Data Protection Regulation [“GDPR”].

3. Special provisions regarding the official social media accounts and pages of Sportec Solutions 3.1 General information regarding the visit of the official social media accounts and pages

Sportec Solutions operates official accounts or pages in and on various social networks. In this context, Sportec Solutions points out that a user uses the respective social network and the respective functions basically on his own responsibility. This applies in particular to the interactive functions offered in the respective social network (for example, commenting, sharing, rating). The respective operators of the social networks regularly collect personal data of the users on their own accounts, the IP address as well as on the end devices used by the user; cookies are used for data collection. These are small files that are stored on your end devices. What information the respective operators of the social networks receive in the course of your use and how they are used is described below specifically in relation to the social network used.

3.2 LinkedIn

Sportec Solutions uses the social network "LinkedIn" and processes personal data via its official LinkedIn account under joint responsibility together with LinkedIn. LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn"). In doing so, Sportec Solutions processes your personal data to protect its legitimate interests in providing users with up-to-date information and interaction opportunities in accordance with Art. 6 para. 1 sentence 1 f) DSGVO. For the use of the official LinkedIn account, Sportec Solutions has chosen the most data protection-friendly settings possible. Sportec Solutions and LinkedIn have concluded a joint responsibility agreement in accordance with Art. 26 (1) DSGVO. You can therefore assert your data subject rights under the GDPR (see section 9) against both Sportec Solutions and LinkedIn. We kindly ask you to note that Sportec Solutions does not have full influence on the data processing of the individual social networks despite the joint responsibility according to Art. 26 DSGVO with the operators of social networks. The corporate policy of the respective provider has a significant influence on the options of Sportec Solutions. In the event of the assertion of data subject rights, Sportec Solutions could only forward these requests to the operator of the social network. You can find out how LinkedIn processes personal data in connection with Sportec Solutions' account and how the joint responsibility between Sportec Solutions and LinkedIn is essentially structured by clicking on the following external link. LinkedIn's privacy policy can be found under the following external link.

3.3 XING

Sportec Solutions uses the social network "XING" within the scope of its official XING account. The operator of the social network and sole controller of the cross-website processing of personal data is: New Work SE, Dammtorstraße 29-32, 20354 Hamburg, Germany. Information on data protection in the context of the use of XING and opt-out options with regard to XING's cookie setting can be found under the following external links: https://privacy.xing.com/en/privacy-policy
Opt-out option: https://privacy.xing.com/en/privacy-policy/information-we-automatically-receive-through-your-use-of-xing

3.4 Facebook / Instagram

Sportec Solutions uses the social networks "Facebook" and "Instagram" within the scope of its official Facebook and Instagram page and, in this context, accesses the related services of Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Meta"). In doing so, Sportec Solutions processes your personal data in order to protect its legitimate interests in providing users with up-to-date information and interaction opportunities in accordance with Art. 6 (1) sentence 1 f) DSGVO. If you visit the official Facebook page and or Instagram page of Sportec Solutions, such a visit will cause a processing of your personal data also at Meta. The information may be used by Meta to provide Sportec Solutions, as operator of a Facebook or Instagram page, with statistical information such as gender and age distribution about the use of the respective page. In addition, Meta may show you further information or advertisements on Facebook according to your preferences. Meta provides more detailed information on this with regard to Facebook at the following link: http://de-de.facebook.com/help/pages/insights. In this case, Sportec Solutions is jointly responsible with Meta for the data processing operations within the meaning of Art. 26 DSGVO. Sportec Solutions has concluded a joint responsibility agreement with Meta pursuant to Art. 26 (1) DSGVO, the so-called Page Insights Controller Addendum. You can therefore assert your data subject rights under the GDPR (see Section 9) against both Sportec Solutions and Meta. We ask you to note that Sportec Solutions has no full influence on the data processing of the individual social networks despite the joint responsibility according to Art. 26 DSGVO with the operators of social networks. The corporate policy of the respective provider has a significant influence on the options of Sportec Solutions. In the event of the assertion of data subject rights, Sportec Solutions could only forward these requests to the operator of the social network. Meta describes in its general terms in the data usage guidelines which information Meta receives as part of your use of Facebook and Instagram and how this is used. There you will also find information on how to contact Meta, on the options to object and on the settings options for advertisements. The data usage guidelines are available at the following links: http://de-de.facebook.com/about/privacy (for Facebook), https://help.instagram.com/519522125107875 (for Instagram). In what way Meta further uses the data from the visit of Facebook and/or Instagram pages for its own purposes, to what extent activities on the Facebook and/or Instagram page are assigned to individual users, how long Meta stores this data and whether data from a visit to the Facebook and/or Instagram page is passed on to third parties, is not conclusively and clearly stated by Meta and is not known to us. When you access a Facebook and/or Instagram page, the IP address assigned to your end device is transmitted to Meta. According to information from Meta, this IP address is anonymized (for "German" IP addresses) and deleted after 90 days. Meta also stores information about the end devices of its users (for example, as part of the "login notification" function); this may enable Meta to assign IP addresses to individual users. If you as a user are currently logged into Facebook and/or Instagram, a cookie with your Facebook or Instagram identifier is located on your end device. This enables Meta to track that you have visited the Facebook and/or Instagram page of Sportec Solutions and how you have used it. This also applies to all other Facebook and/or Instagram pages. Based on this data, content or advertising can be offered tailored to you. The data collected about you in this context is processed by Meta and may be transferred to countries outside the European Union. If you want to avoid this, you should log out of Facebook or Instagram or deactivate the "stay logged in" function, delete the existing cookies on your device and close and restart your browser. In this way, Facebook and/or Instagram information through which you can be directly identified will be deleted. This will allow you to use Sportec Solutions' Facebook or Instagram page without revealing your Facebook or Instagram identifier. When you access interactive features of the page (like, comment, share, message, etc.), a Facebook or Instagram login screen will appear. After any login, you will again be recognizable to Meta as a specific user. As an alternative, you can use a different browser than usual to visit the Facebook or Instagram page of Sportec Solutions. Information on how to manage or delete information about you on Facebook can be found on the following Facebook support pages: https://de-de.facebook.com/about/privacy# or in the Instagram help area: https://help.instagram.com/811572406418223/?helpref=hc_fnav.

4. Contact and inquiry management via the social networks of Sportec Solutions.

Sportec Solutions offers contact, inquiry or application forms on selected company accounts or pages on social networks (esp. Facebook, Instagram and LinkedIn, see already under section 3.), which interested users can use to contact Sportec Solutions. When using the contact, inquiry or application forms on selected company accounts or pages on social networks of Sportec Solutions, the following data is collected:

- Date and time of access

- Websites from which the user came to the website ("referrer")

- Context information (e.g. button clicks on the pages, selections made on the pages)

- Contents of all completed text fields (e.g. contact data, such as name or address of the user, or other personal data, depending on the question and answer depicted in the specific text field)

- Files uploaded by the user.

The purpose of this data processing is to ensure the communication recorded by the user. The legal basis for the processing of the data transmitted in the context of this contact is therefore the legitimate interest of Sportec Solutions in communicating with interested users in accordance with Art. 6 para. 1 p. 1 lit. f DSGVO. If a contract is initiated via an inquiry form, the legal basis is also Art. 6 para. 1 p. 1 lit. b DSGVO. The legal basis for the processing of data in an application form may be, in addition to Art. 6 para. 1 p. 1 lit. f DSGVO, also Art. 88 DSGVO in conjunction with. § 26 BDSG. For the provision of such contact, inquiry or application forms on selected company accounts or pages in social networks, Sportec Solutions uses an external service provider: Perspective Software GmbH, Mailbox 659770, D-96035 Bamberg. We have concluded an order processing agreement with this external service provider in accordance with Art. 28 (3) DSGVO. Within the scope of the order processing relationship, this service provider stores personal data exclusively on European servers. However, there is a possibility that your data may be accessible to entities in the United States of America because the external service provider uses sub-processors located in the USA. As the European Union Commission has determined that the data protection laws of the United States do not ensure an adequate level of protection for personal data collected from data subjects in the European Union, the external service provider for data transfers to the United States provides additional measures and safeguards in accordance with the requirements of the GDPR to ensure an adequate level of protection. For example, by concluding standard contractual clauses between the external service provider and the sub-processors.

5. Social Media Plugins (where available).

Users can initially share content from our website on the services of Meta such as Facebook and Instagram, LinkedIn or XING. The legal basis for the following processing is Art. 6 para. 1 sentence 1 a) DSGVO. To share the content of our online offers via social networks, we offer so-called social media buttons. For this purpose, we use the so-called Shariff solution, which provides social media buttons that comply with data protection requirements. Through the integration of social plugins, data is usually already transmitted to the social Media Networks when a content is called up, without the user having explicitly consented to this. Among other things, an identifier is transmitted in addition to the web address of the content visited, which enables a direct link between the user of the website and their profile on the relevant platform. The providers of these platforms do not provide any specific information about which data is also transmitted. In order to prevent the unintentional transfer of data of the users of the website to the Socilal Media network and to give them the choice when using these services, we use a Shariff button to establish direct contact between the social network and the visitor only when the latter actively clicks on the share button. In this way, Shariff prevents you from leaving a digital trail on every page you visit, and the connection with the services is only established after consent has been given and the social sharing links have been provided. Alternatively, this contact establishment takes place via pure html links.

6. Limited purpose for processing and using personal data

All processing or use of personal data of the User occurs only for the purposes mentioned in this Privacy Statement and to the extent necessary to achieve the respective purpose. Personal data are not published by Sportec Solutions or disclosed to unauthorized third parties. Transmissions of personal data to government agencies and public authorities occur only in accordance with mandatory national provisions in the law or if the disclosure is necessary in the case of attacks on the network infrastructure in order to pursue rights and for purposes of criminal prosecution. The legal basis for this processing is Art. 6 para. 1 c) GDPR in conjunction with § 24 para. 1 no. 1 b) German Data Protection Act [Bundesdatenschutzgesetz, "BDSG"].

7. Storage and deletion of personal data

All stored personal data and pseudonymized usage data are deleted immediately and permanently as soon as the data are no longer needed for the purposes for which they were collected or the User demands this unless Sportec Solutions is required by law to do preserve the data. If Sportec Solutions is required on the basis of provisions in the law to preserve the data, the stored personal data and pseudonymized usage data will be permanently deleted upon expiration of the time periods for preserving data required by law.

8. Security

Sportec Solutions uses technical and organizational security measures in order to protect the personal data of the Users against accidental or intentional manipulation, loss, destruction or access by unauthorized persons. The security measures are continuously adapted in accordance with technological developments.

9. Links to other websites

The Website may contain links to other websites. This Privacy Statement applies solely to the Website of Sportec Solutions. Sportec Solutions has no influence over and does not control whether other providers comply with applicable data privacy provisions.

10. Rights of the User

The User has a right to information with regard to the stored personal data of the User. The User also has a right to have incorrect data corrected and to restriction of the processing and to have data deleted, as well as a right to object against the processing and the right for data transferability. To contact us, the user can send an e-mail to info@sportec-solutions.com. The data protection officer of Sportec Solutions can be reached at datenschutz@sportec-solutions.com; only data protection-related inquiries will be answered at this e-mail address. For all other inquiries, the e-mail address info@sportec-solutions.com is to be used. Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 18, 91522 Ansbach. Tel.: +49 981 180093-0 Fax: +49 981 180093-800 E-Mail: poststelle@lda.bayern.de.

11. Applicability, validity and timeliness of the Privacy Statement

The provisions in this Privacy Statement on collection, processing and use of the User’s data apply for the User when using the Website. This Privacy Statement is current valid and is dated as of 20 March 2023. Sportec Solutions reserves the right to amend this Privacy Statement at any time as needed with effect for the future, especially for the purposes of adaption to a further development of the Website or the implementation of new technologies.

Sportec Solutions AG
Beta-Straße 1
85774 Unterföhring
Germany

T +49 89 / 45225-0
F +49 89 / 45225-290
E info@sportec-solutions.com

Managing Directors: Christian Holzer

District Court Munich: HRB 152835
VAT ID: DE 128 230 018

1. Aim of the guideline

This Whistleblowing Policy has been developed to provide a secure and confidential way for addressees to report violations of laws, policies or ethics within the company. The purpose of the Whistleblowing Policy is to ensure the integrity, transparency and compliance of our company and to ensure that reported violations are handled appropriately.

2. Scope:

This policy applies to all employees, contractors, suppliers and other stakeholders associated with our company.

3. Reporting Violations:

a) Recipients are free to report possible violations of law, policy or ethics of which they become aware. A non-exhaustive list of offenses that are specifically covered in this regard can be found under 3.b.. This is provided that the individual raises his or her concerns in good faith and in accordance with this policy.
b) This includes in particular, but is not limited to, the following offenses:
• Corruption: bribery, acceptance of bribes, improper benefits or kickbacks.
• Financial fraud: Falsification of accounting records, financial statements or other financial records.
• Insider trading: improper use of confidential information for personal gain in trading stocks or other securities.
• Theft or misappropriation of company assets.
• Violation of competition law: Unfair competition, abuse of a dominant market position or cartelization.
• Money laundering: concealment of the origin of illegally acquired funds.
• Violation of labor law: discrimination, bullying, harassment or violation of employee rights.
• Violation of environmental regulations: Illegal disposal, pollution, or violations of environmental laws.
• Violation of consumer protection: misleading advertising, product tampering, or sale of unsafe products.
• Violation of privacy policies: Misuse, theft or improper handling of personal data.
• Violation of supply chain standards: Exploitation of workers, child labor, forced labor, or violations of social and environmental standards along the supply chain.
• Violation of human rights: Aiding or condoning human rights abuses in connection with the company's business activities.
• Violation of occupational safety and health regulations: neglect of workplace safety or non-compliance with health standards.
• Violation of tax laws: tax evasion, misrepresentation on tax returns or other tax violations.
• Violation of ethics policies: Violations of corporate ethics, integrity or codes of conductc)
c) Explicitly not covered are exclusively personal, work-related complaints. This is understood to mean a complaint about a matter relating to an addressee's current or former employment that has a personal impact on the person concerned but does not have a wider impact on the company. In particular, this includes interpersonal conflicts between the addressees of the Policy, decisions by the Company regarding the hiring, transfer, compensation or promotion of an addressee, as well as decisions regarding the terms and conditions of employment or regarding the suspension or termination of an employment relationship, provided and to the extent that these are not at the same time violations subject to criminal penalties or fines or violations of federal and state laws. In such cases, notification to the immediate supervisor is requested.
d) Violations may be reported in writing through the following reporting channel: Whistleblowing
Online: Reporting by dialing into the whistleblowing link located on the website. Whistleblowers have the option of submitting reports anonymously and in encrypted form via a secure online connection. Access to this link is protected by appropriate security measures. In particular, there is the option of anonymous reporting via an encrypted portal.
e) The confidentiality of the whistleblower is protected. The identity of the whistleblower will not be disclosed unless the whistleblower expressly consents or this is required by law.
f) If requested by the whistleblower, a face-to-face meeting will be facilitated. A reasonable place and time will be arranged to receive the report confidentially, at which time the identity of the whistleblower will be disclosed to the Responsible Officer in the Legal Department.

4. Data protection:

a) GDPR-compliant processing: All personal data, both that of the whistleblower and any accused persons, will be processed in accordance with the provisions of the General Data Protection Regulation (GDPR), insofar as personal data is involved.
b) Data economy: Only those personal data are collected that are necessary for processing the report and investigating the reported incident.
c) Access restriction: access to personal data will be limited to authorized persons responsible for processing the reports and investigating the allegations. These persons are subject to strict confidentiality obligations.
d) Storage period: Personal data will be stored only for as long as necessary to process the report and to comply with legal retention periods

5. Responsibility within the company:

Within the company, the "most appropriate" person is determined to receive and follow up on the notifications. This is primarily the legal department as the point of contact for compliance issues. In times of absence of the employees of the legal department, the mentioned group of persons is represented by employees of the human resources department.

6. Duty of the company:

a) Notification of receipt and outcome: Within seven days, the Company will acknowledge to the whistleblower that the report has been received. Within three months, whistleblowers must be informed of actions taken, the status of the internal investigation and its outcome. If the report was received anonymously via the online reporting channel, the notification can be made there despite the anonymity.
b) The company will investigate all reported violations objectively, impartially and in a timely manner and take appropriate measures to take appropriate corrective action based on the results of the investigation to remedy the violation and prevent further violations. The whistleblower shall be informed of this process on a regular basis. If the report is received anonymously, the investigation of the facts shall be based on the information provided.
c) Duty to provide information: The company shall provide employees with easily understandable and easily accessible information describing and informing them about the possibilities of the reporting process. This will be done in particular by providing instructions for employees. This includes not only the company's employees per se, but also suppliers, service providers and business partners.
d) Data retention: All documents related to whistleblowing reports and investigations are retained in accordance with the company's applicable data protection regulations and retention policies.
e) Duty to maintain the identity of the whistleblower: By reporting through the online system, it is possible to protect the identity of the whistleblower to the best extent possible. In the case of an anonymous report, communication is possible without the processor being able to identify the reporter. However, this only applies as far as the report does not contain any conclusions about the identity.

7. Protection against retaliation:

The Company expressly disclaims any retaliation against whistleblowers who report violations under this Policy. Any form of retaliation will be considered a violation of the Policy and may result in sanctions.

8. Consequences of False Reporting:

Protection for a whistleblower exists only if, at the time of the report, the whistleblower had reasonable grounds to believe that the facts reported were true and that the information provided concerned violations that fall within the scope of this Policy and the Whistleblower Protection Act. In the event of intentional false reports or intentional reporting of facts that do not belong to the designated scope of application, the Company reserves the right to take disciplinary action against the reporting person.

9. Final Clause:

Only the German version of the guideline shall be authoritative; the english version is for information purposes only.