Privacy policy




Below is the privacy policy for the website www. jubileeace.com. is responsible for data processing via the designated website:


Jubilee Ace Ltd. 


Sea Meadow House  


Blackburne Highway 


(PO Box 116)  


road town  


Tortola  


British Virgin Islands  


E-mail: [email protected]  


(hereinafter referred to as JUBILEE ACE)  


For the assertion of rights within the scope of data protection or if you have questions regarding the use, collection or processing of your personal data, please contact our data protection officer:


Mr Andrew Dawson 


Sea Meadow House  


Blackburne Highway  


(PO Box 116)  


road town  


Tortola 


British Virgin Islands  


[email protected]  


For the assertion of the rights specified in this data protection declaration or in the event of questions regarding the use, collection or processing of personal data, the customer shall contact the above-mentioned data protection officer.


Security and protection of your personal data 


We consider it our primary responsibility to maintain the confidentiality of the personal data you provide and to protect it from unauthorized access. We therefore apply the utmost care and the most modern security standards to ensure maximum protection of your personal data.  


As a company under private law, we are subject to the provisions of the European Data Protection Regulation (DSGVO) and the regulations of the new Federal Data Protection Act (BDSG-neu). We have taken technical and organisational measures to ensure that the regulations on data protection are observed both by us and by our external service providers.  


Lawfulness of the processing 


The processing of personal data is lawful only if there is a legal basis for the processing. The legal basis for the processing may be, according to Article 6 (1) p.1  


lit. a - f DSGVO in particular:  


  • a.The data subject has given his/her consent to the processing of personal data relating to him/her for one or more specified purposes;              

  • b.the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;               

  • c.the processing is necessary for compliance with a legal obligation to which the controller is subject               

  • d.processing is necessary in order to protect the vital interests of the data subject or of another natural person               

  • e.the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller               

  • f.the processing is necessary in order to protect the legitimate interests of the controller or of a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child               


Information on the collection of personal data 


In the following we inform about the collection of personal data when using our website. Personal data are e.g.  B. Name, address, e-mail addresses, user behaviour.  


I.Access data 


If you use the website for informational purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser sends to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website and to ensure its stability and security:  


  • –IP address               

  • –Date and time of the request               

  • –Time zone difference to Greenwich Mean Time (GMT)               

  • –Content of the request (concrete page)               

  • –Access status/HTTP status code               

  • –Amount of data transmitted in each case               

  • –Website from which the request comes               

  • –Browser               

  • –Operating system and its interface               

  • –Language and version of the browser software.               


After a technical evaluation these data will be deleted immediately. In accordance with Art. 6 Para. 1 S. 1 lit. f DSGVO, this data collection serves to safeguard our predominant legitimate interests in the correct presentation of our website offer within the framework of a balancing of interests, as well as compliance with the EU basic data protection regulation in terms of security and confidentiality.  


II.Use of cookies 


In addition to the data mentioned above, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard disk in accordance with the browser you are using and through which certain information is transmitted to the site that sets the cookie. Cookies cannot run programs or deliver viruses to your computer. They serve to make the Internet offer as a whole more user-friendly and effective.  


Our website uses the following types of cookies, the scope and function of which are explained below:  


a)Transient cookies are automatically deleted when you close the browser. These include in particular the session cookies. These store a so-called Session-ID, with which different requests of your browser can be assigned to the common session. This allows your computer to be recognized when you return to our website. The session cookies are deleted when you log out.  


b)Persistent cookies are automatically deleted after a specified period of time, which may vary depending on the cookie. You can delete the cookies in the security settings of your browser at any time.  


You can configure your browser settings according to your preferences and refuse to accept cookies. You can prevent the use of HTML5 storage objects by setting your browser to private mode. We also recommend that you regularly delete your cookies and browser history manually. Please note that by disabling cookies you may not be able to use all the features of this website.  


III.Data processing with regard to customers on conclusion of contract and payment 


If you purchase the offered arbitrage software via our website, we process the following personal data:  


First form of address,  


Second name,  


Third address,  


Fourth phone number,  


5.e-mail address,  


JUBILEE ACE will use this data exclusively for the purpose of the execution of the contract and the communication with the customers necessary in this respect. This includes the initiation, conclusion, processing, warranty and, if necessary, the reversal of the contract. The data will be stored until the contract is fully executed. As far as commercial and fiscal retention periods exist, the duration of the storage can be up to 10 years.  


This data processing is based on Art. 6 para. 1 sentence 1 lit. b DSGVO for the execution of the contract. The legal basis for the further storage for tax and commercial law reasons is the necessity according to law in accordance with Art. 6 Paragraph 1 S. 1 lit. c DSGVO.  


IV.Data processing with regard to sales partners 


We require the following personal data from you for the conclusion and implementation of a contract as a sales partner:  


Title, surname, first name, address, date of birth, e-mail address, telephone number, fax number, IBAN and BIC, company name, tax number, VAT ID number.  


This information is required for the establishment and execution of the contract as a sales partner, in particular for the processing of commission payments. The legal basis for the processing of these data is Art. 6 para. 1 sentence 1 lit. b DSGVO.  


As a sales partner you have access to the back office. In this back office you will receive an overview of the orders that have been initiated by you. For this purpose, the following information about the persons who have prompted you to order is displayed:  


Order number, order date, career position, last name, first name, e-mail, net value of orders from the previous month, time of last online activity.  


This information is required for the calculation and traceability of commission claims. The legal basis for the processing of these data is Art. 6 para. 1 sentence 1 lit. b DSGVO.  


You can also see a team overview in the back office. There you will receive information about the sales partners you have recruited in your downline. The following information is displayed: Career position, surname, first name, net value of orders placed in the previous month, time of last online activity.  


This information is required for the calculation and traceability of commission entitlements. The legal basis for the processing of these data is Art. 6 para. 1 sentence 1 lit. b DSGVO.  


V.Data transmission 


JUBILEE ACE will only disclose personal data to the extent necessary to perform the contract or to protect the legitimate interests of JUBILEE ACE. JUBILEE ACE uses external service providers (processors) for the execution of the contract. Separate commissioned data processing contracts were concluded with the service providers to ensure the protection of personal data.  


For payment processing, the customer's payment data, namely first name, surname, address, e-mail address, telephone number, are forwarded to the respective payment provider. In addition, the data protection regulations of the respective payment provider apply. This data processing is carried out to carry out the contractual relationship with you as a customer or on the basis of the consent you have given. The legal basis for this data processing is Art. 6 para. 1 sentence 1 lit. a or lit. b DSGVO.  


In order to calculate the difference commission of the sales partners from your Up-Line, the above mentioned information about your orders as well as your team overview will also be displayed to the sales partners in whose Down-Line you are. For this purpose the sales partners from your Up-Line receive the following information:  


Career position, surname, first name, e-mail, net value of orders placed in the previous month, time of last online activity. This information is necessary to calculate and track the difference commission of your Up-Line. The legal basis for the processing of these data is Art. 6 para. 1 sentence 1 lit. b DSGVO.  


For payment processing, the payment data of the sales partners, namely first name, surname, address, e-mail address, telephone number, date of birth, IBAN and BIC are forwarded to credit institutions or payment intermediaries.  


The data transfer to the named service providers is carried out for the purpose of implementing the contractual relationship with you as a sales partner. The legal basis for this data processing is Art. 6 para. 1 sentence 1 letter b DSGVO.  


VI.Contact 


If you contact us by e-mail or via our contact form, the data you provide (your e-mail address, name, surname) will be stored by us to answer your questions. We delete the data arising in this connection after storage is no longer necessary, e.g. when your request has been dealt with. Otherwise, the processing will be restricted if there are legal obligations to keep records.  


The legal basis for this data processing is Art. 6 para. 1 sentence 1 letter a DSGVO.  


VII.Children 


Our offer is basically directed at adults. Persons under 18 years of age should not transmit any personal data to us without the consent of their parents or legal guardians.  


VIII. rights of the data subject 


(1)Revocation of consent 


If the processing of personal data is based on a granted consent, you have the right to revoke this consent at any time. The revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.  


You can contact us at any time to exercise your right of revocation.  


(2)Right to confirmation 


You have the right to request confirmation from the data controller as to whether we are processing personal data concerning you. You can request confirmation at any time using the contact details given above.  


(3)Right of access 


If personal data is processed, you can request information about this personal data and  


about the following information at any time:  


  • a.the processing purposes;               

  • b.the categories of personal data processed;               

  • c.the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients in third countries or international organisations;              

  • d.if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration;               

  • e.the existence of a right of rectification or erasure of personal data relating to you or of a right to have the processing limited by the controller or to object to such processing               

  • f.the existence of a right of appeal to a supervisory authority               

  • g.if the personal data are not collected from the data subject, all available information on the origin of the data;               

  • h.the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) DPA and, at least in these cases, meaningful information on the logic involved and the scope and intended consequences of such processing for the data subject.               


If personal data are transferred to a third country or to an international organisation, you have the right to be informed of the appropriate safeguards pursuant to Article 46 DSGVO in connection with the transfer. We provide a copy of the personal data that is the subject of the processing. We may charge a reasonable fee based on administrative costs for any additional copies you request. If the application is submitted electronically, the information shall be provided in a standard electronic format unless otherwise specified by the applicant. The right to receive a copy under paragraph 3 shall not adversely affect the rights and freedoms of others.  


(4)Right of rectification 


You have the right to ask us to correct any incorrect personal data concerning you without delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.  


(5)Right of cancellation ("right to be forgotten") 


You have the right to request the controller to delete personal data relating to you immediately and we are obliged to delete personal data immediately if any of the following reasons apply:  


  • a.The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.               

  • b.The data subject withdraws the consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) of the DPA and there is no other legal basis for the processing.               

  • c.The data subject lodges an objection to the processing pursuant to Article 21(1) DPA and there are no overriding legitimate reasons for the processing, or the data subject lodges an objection to the processing pursuant to Article 21(2) DPA.               

  • d.The personal data were processed unlawfully.               

  • e.The deletion of personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.               

  • f.The personal data were collected in relation to information society services offered in accordance with Article 8(1) of the DSGVO.               


Where the controller has made the personal data public and is obliged to delete them in accordance with paragraph 1, the controller shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that a data subject has requested them to delete all links to those personal data or copies or replications thereof.  


The right of cancellation ("right to be forgotten") does not exist insofar as the processing is necessary:  


  • –on the exercise of the right to freedom of expression and information;               

  • –to comply with a legal obligation imposed on the controller under Union or national law to which the controller is subject or to carry out a task carried out in the public interest or in the exercise of official authority vested in the controller;               

  • –for reasons of public interest in the field of public health in accordance with Article 9(2)(h) and (i) and Article 9(3) of the DSGVO               

  • –for archiving, scientific or historical research purposes in the public interest or for statistical purposes pursuant to Article 89 paragraph 1 of the DSGVO, in so far as the law referred to in paragraph 1 is likely to render impossible or seriously prejudice the attainment of the objectives of such processing, or               

  • –to assert, exercise or defend legal claims.               


(6)Right to restrict processing 


You have the right to ask us to limit the processing of your personal data if one of the following conditions is met:  


  • a.the accuracy of the personal data is contested by the data subject, for a period of time which allows the controller to verify the accuracy of the personal data,               

  • b.the processing is unlawful and the data subject refuses the deletion of the personal data and instead requests the restriction of the use of the personal data;               

  • c.the controller no longer needs the personal data for the purposes of the processing, but the data subject needs them for the purpose of asserting, exercising or defending legal claims, or               

  • d.the data subject has lodged an objection to the processing pursuant to Article 21 paragraph 1 DPA, as long as it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.               


Where processing has been restricted in accordance with the above conditions, such personal data, apart from being stored, shall be processed only with the consent of the data subject or for the purpose of pursuing, exercising or defending legal claims or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.  


In order to exercise the right to limit processing, the data subject may at any time contact us at the contact details given above.  


(7)Right to data portability 


You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format and you have the right to transfer such data to another responsible party without interference from the responsible party to whom the personal data has been provided, provided that:  


  • a.the processing is based on a consent pursuant to Article 6 paragraph 1 letter a or Article 9 paragraph 2 letter a or on a contract pursuant to Article 6 paragraph 1 letter b DSGVO and               

  • b.the processing is carried out using automated procedures.              


When exercising the right to transfer data in accordance with paragraph 1, you have the right to obtain that personal data be transferred directly from one controller to another controller to the extent technically feasible. The exercise of the right of data transferability is without prejudice to the right of erasure ("right to be forgotten"). This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.  


(8)Right of objection 


You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is carried out on the basis of Article 6 paragraph 1 letters e or f of the DPA, including profiling based on these provisions. The controller shall no longer process the personal data unless he can demonstrate compelling legitimate reasons for processing that outweigh the interests, rights and freedoms of the data subject, or the processing is carried out in order to pursue, exercise or defend legal claims.  


Where personal data are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is related to such direct marketing. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.  


In the context of the use of information society services, you may exercise your right of objection by means of automated procedures using technical specifications, without prejudice to Directive 2002/58/EC.  


You have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out for the purposes of scientific or historical research or for statistical purposes, as referred to in Article 89(1), except where such processing is necessary for the performance of a task carried out in the public interest.  


You can exercise the right of objection at any time by contacting the person responsible for the matter.  


(9)Right of appeal to a supervisory authority 


They shall also have, without prejudice to any other administrative or judicial remedy, the right to complain to a supervisory authority, in particular in the Member State of their residence, place of employment or place of the alleged infringement, if the data subject considers that the processing of personal data relating to him or her is in breach of this Regulation.  


(10)Right to an effective judicial remedy 


Without prejudice to any available administrative or extrajudicial remedy, including the right to appeal to a supervisory authority pursuant to Article 77 of the DPA, they shall have the right to an effective judicial remedy if they consider that their rights under this Regulation have been infringed as a result of the processing of their personal data contrary to this Regulation.  



Status of the privacy policy: 20.01.2020