We, SKD SE together with our subsidiaries (hereinafter jointly referred to as “the Company”, “we” or “us”), take the protection of your personal data seriously and would like to take this opportunity to inform you about data protection in our company.

As part of our responsibility under data protection law, obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: “GDPR”) to ensure the protection of personal data of the person affected by processing (we also refer to you as the data subject hereinafter as “you”, “you” or “data subject”).

Insofar as we decide on the purposes and means of data processing either alone or together with others, this includes above all the obligation to inform you transparently about the type, scope, purpose, duration and legal basis of the processing (cf. Art. 13 and 14 GDPR). With this declaration (hereinafter: “data protection notice”), we inform you about the way in which your personal data is processed by us.

Definitions

Following the example of Art. 4 GDPR, this data protection notice is based on the following definitions:

• “Personal data” ( Art. 4 No. 1 GDPR) means any information relating to an identified or identifiable natural person (“data subject”). A person is identifiable if they can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or information relating to their physical, physiological, genetic, mental, economic, cultural or social identity. The identifiability can also be provided by linking such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photos, video or audio recordings can also contain personal data).
• “Processing” (Art. 4 No. 2 GDPR) means any operation which involves handling personal data, whether or not by automated means (i.e. using technical procedures). This includes, in particular, the collection (i.e. acquisition), recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data, or alteration of the purposes for which they were originally processed.
• “Controller” (Art. 4 No. 7 GDPR) means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• – “Third party” (Art. 4 No. 10 GDPR) means any natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data; this also includes other legal entities belonging to the group.
• – “Processor” (Art. 4 No. 8 GDPR) is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, in particular in accordance with the controller’s instructions (e.g. IT service provider). In terms of data protection law, a processor is in particular not a third party.
• – “Consent” (Art. 4 No. 11 GDPR) of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Name and Address of the Data Controller

We are the controller responsible for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR:

SKD SE

Französische Str.12

10117 Berlin

E-mail address: contact@stark-defence.com

For further information about our company, please refer to the imprint information on our website.

Contact Details of the Data Protection Officer

Our data protection officer is available at all times to answer any questions you may have and to act as your contact for data protection issues. The contact details are:

heyData GmbH

Schützenstraße 5

10117 Berlin

www.heydata.eu

datenschutz@heydata.eu

Collection and Processing of Personal Data

We collect and process personal data only insofar as this is necessary for the operation of our website and the provision of our services. The following data is automatically collected and stored in server log files each time our website is accessed:

• IP address
• Date and time of access
• Name and URL of the retrieved file
• Amount of data transferred
• Browser type and version
• Operating system
• Referrer URL (the previously visited website)

This data is processed for the following purposes:

• Ensuring the functionality of the website
• Optimization of the website
• Analysis of security incidents

Legal Basis for Data Processing

In principle, any processing of personal data is prohibited by law and is only permitted if the data processing falls under one of the following justifications:

• 6 para. 1 sentence 1 lit. a GDPR (“consent”): Where the data subject has voluntarily, in an informed and unambiguous manner, indicated by a statement or other unambiguous affirmative act that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;
• 6 para. 1 sentence 1 lit. b GDPR: If 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;
• 6 para. 1 sentence 1 lit. c GDPR: If the processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a statutory retention obligation);
• 6 para. 1 sentence 1 lit. d GDPR: Where processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• 6 para. 1 sentence 1 lit. e GDPR: If 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; or
• 6 para. 1 sentence 1 lit. f GDPR (“Legitimate interests”): Where processing is necessary for the purposes of the legitimate (in particular legal or economic) interests pursued by the controller or by a third party, except where such interests are overridden by the interests or rights of the data subject which require protection of personal data (in particular where the data subject is a minor).

Data erasure and Storage duration

For the processing operations carried out by us, we indicate below how long the data is stored by us and when it is deleted or blocked. Unless an explicit storage period is specified below, your personal data will be erased or blocked as soon as the purpose or legal basis for storage no longer applies. Your data will only be stored on our servers in Germany, subject to any disclosure in accordance with the provisions in Section 8.

However, data may be stored beyond the specified period in the event of an (impending) legal dispute with you or other legal proceedings or if storage is provided for by statutory provisions to which we are subject as the controller (e.g. Section 257 HGB (German Commercial Code), Section 147 AO (German Fiscal Code)). If the storage period prescribed by the statutory provisions expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.

Data Security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties (e.g. TLS encryption for our website), taking into account the state of the art, the implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

We will be happy to provide you with more detailed information on request. Please contact our data protection officer (see Section 3).

Cooperation with Contract Processors

As with any large company, we also use external domestic and foreign service providers to process our business transactions (e.g. for the areas of IT, logistics, telecommunications, sales and marketing). These service providers only act in accordance with our instructions and are contractually obliged to comply with data protection regulations in accordance with Art. 28 GDPR.

If your personal data is passed on by us to our subsidiaries or is passed on to us by our subsidiaries (e.g. for advertising purposes), this is done on the basis of existing order processing relationships.

Legal Obligation to transfer Certain Data

Under certain circumstances, we may be subject to a specific legal or statutory obligation to provide the lawfully processed personal data to third parties, in particular public authorities (Art. 6 para. 1 sentence 1 lit. c GDPR).

Your Rights

You can assert your rights as a data subject with regard to your processed personal data at any time by contacting us using the contact details provided at the beginning under Section 2. As the data subject, you have the right:

• to request information about your data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the purposes of processing, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of appeal, the origin of your data if it was not collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information on its details;
• in accordance with Art. 16 GDPR, to demand the immediate correction of incorrect data or the completion of your data stored by us;
• in accordance with Art. 17 GDPR, to demand the deletion of your data stored by us, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
• in accordance with Art. 18 GDPR, to demand the restriction of the processing of your data if the accuracy of the data is disputed by you or the processing is unlawful;
• in accordance with Art. 20 GDPR, to receive your data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller (“data portability”)
• in accordance with Art. 21 GDPR, to object to the processing if the processing is based on Art. 6 para. 1 sentence 1 lit. e or lit. f GDPR. This is particularly the case if the processing is not necessary for the performance of a contract with you. If it is not an objection to direct advertising, we ask you to explain the reasons why we should not process your data as we have done when exercising such an objection. In the event of your justified objection, we will examine the situation and either discontinue or adapt the data processing or point out to you our compelling reasons worthy of protection on the basis of which we will continue the processing;
• in accordance with Art. 7 para. 3 GDPR, to withdraw your consent once given (also before the GDPR came into force, i.e. before May 25, 2018) – i.e. your voluntary, informed and unequivocal declaration or other unambiguous confirmatory act that you consent to the processing of the personal data concerned for one or more specific purposes – at any time, if you have given such consent. As a result, we may no longer continue the data processing that was based on this consent in the future and
• in accordance with Art. 77 GDPR, to complain to a data protection supervisory authority about the processing of your personal data in our company, for example to the data protection supervisory authority responsible for us:

Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59-61 10555 Berlin, mailbox@datenschutz-berlin.de.

Changes to the Data Protection Notice

We reserve the right to regularly review and amend our data protection information in the context of the further development of data protection law as well as technological or organizational changes. The latest version can be found on our website. This data protection notice was last updated in April 2025.