Legal

Privacy policy

Draft. This policy describes the services ZK Futures actually uses; it is still being reviewed. Die deutsche Fassung steht unten.

1. Controller

ballmüller solutions – Görkem Ballmüller, Regattastraße 23, 12527 Berlin, Germany
Phone: +49 30 16635771 · Email: info@ballmüllersolutions.de
More details in the imprint.

2. What ZK Futures is

ZK Futures is a testnet demo of a crypto exchange for perpetual futures. Every balance in it is play money without monetary value: you cannot deposit or withdraw real funds, and nothing on the site is an offer to trade.

3. Hosting and server logs

The site and its databases run on Microsoft Azure (Microsoft Ireland Operations Ltd.) in the Germany West Central (Frankfurt) region; Azure Front Door delivers the pages and defends against attacks. When a page is accessed we process technically necessary data such as IP address, time, requested address and user agent; we delete these access logs after 30 days. We record application errors with Azure Application Insights. Legal basis: Art. 6(1)(f) GDPR (secure and stable operation).

4. Fonts and scripts from other servers

The pages load the fonts Inter, Orbitron and Fira Code from Google Fonts (Google Ireland Ltd.), the trading terminal also the chart library TradingView Lightweight Charts from unpkg.com and Telegram's Mini App script from telegram.org, which lets the terminal run inside Telegram. These servers receive your IP address. Legal basis: Art. 6(1)(f) GDPR (consistent presentation and a working terminal).

5. Local storage, cookies and consent

Technically necessary, the terminal keeps your session (a signed token and your account id) and your consent choice in your browser's local storage (§ 25(2) TDDDG). Non-essential services run only with your consent (§ 25(1) TDDDG, Art. 6(1)(a) GDPR): we use Google Consent Mode v2 with the default "denied". You can withdraw your consent at any time with effect for the future by deleting the site data for zkfutures.com in your browser; the banner then appears again.

6. Analytics

With your consent we use Google Tag Manager and Google Analytics 4 (Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland) to measure under a pseudonym how the site is used; cookies are set and usage data such as pages viewed and device and browser information are processed. Google is certified under the EU-US Data Privacy Framework. Without your consent Google Tag Manager may still load in a restricted mode that sets no cookies and stores no identifier; Google then receives only cookieless signals (that a page was viewed, its address, device and browser type) and your IP address for technical reasons. Legal basis: our legitimate interest in measuring the site's reach (Art. 6(1)(f) GDPR).

7. Visitor counting and error reports without cookies

We also count page views ourselves, without cookies and without storing anything in your browser: a checksum of IP address and user agent with a key that changes daily and is held only in memory; only daily totals such as views per source are stored. Errors in the browser (error text, page, browser) are reported to Azure Application Insights. Legal basis: Art. 6(1)(f) GDPR.

8. Account and play-money trading data

The terminal starts a guest account with a random id. If you sign in with a crypto wallet (Sign-In with Ethereum), your wallet address becomes your account id; we check the signature and store no key. If you sign in through Telegram, we receive your Telegram user id and user name from Telegram. Under the account id we store your play-money balance, positions, orders, trades and funding payments in an Azure SQL database in Germany West Central. Legal basis: Art. 6(1)(b) GDPR (providing the demo you use).

9. Market data and the sanctions check

Prices come from public market-data interfaces; no personal data is sent to them. To block access from comprehensively sanctioned jurisdictions we look up the country of your IP address in an offline database (MaxMind GeoLite2) on our own server; the result is not stored. Legal basis: Art. 6(1)(c) and (f) GDPR.

10. Transfers to third countries

Some recipients also process data outside the EU/EEA, for example Google, Telegram and the operator of unpkg.com (Cloudflare). We base such transfers on an adequacy decision (EU-US Data Privacy Framework) or the European Commission's standard contractual clauses under Art. 46 GDPR.

11. Storage period

We store personal data only as long as necessary for the purposes above or as statutory retention obligations require; the data are then deleted or anonymised.

12. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21), and you can withdraw a consent at any time with effect for the future (Art. 7(3)). A message to the contact details in section 1 is enough.

13. Right to lodge a complaint

You may complain to a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59–61, 10555 Berlin, Germany.

14. Changes

Changes to ZK Futures or to the law may make changes to this policy necessary. The version published here applies.