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Privacy Policy

Privacy Policy

Last updated: September 26, 2025

Table of Contents

 

Controller

Thomas Mustermann
Schöne Aussicht 1
18678 Berlin

Authorized representatives: Thomas Mustermann

Email address: mustermann@gmail.com

Overview of Processing Activities

The following overview summarizes the types of data processed, the purposes of their processing, and refers to the data subjects.

Types of Data Processed

  • Inventory data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Log data.

Categories of Data Subjects

  • Service recipients and clients.
  • Prospective customers.
  • Communication partners.
  • Users.
  • Business and contractual partners.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Feedback.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Business processes and business management procedures.

Relevant Legal Bases

Relevant Legal Bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or registered office. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

 
  • Consent (Art. 6(1)(a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on the applicability of GDPR and Swiss FADP: This privacy notice serves to provide information under both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that for broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "special categories of personal data" used in the Swiss FADP, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are employed. However, the legal meaning of the terms will continue to be determined by the Swiss FADP within its scope of application.

Security Measures

In accordance with legal requirements, and taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, disclosure, assurance of availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or disclosing/transferring data to other persons, entities, or companies (which becomes apparent from the postal address of the respective provider or when explicitly mentioned in the privacy policy), this will always be done in compliance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.

This dual safeguarding ensures comprehensive protection for your data: The DPF forms the primary level of protection, while the Standard Contractual Clauses serve as additional security. Should there be any changes to the DPF, the Standard Contractual Clauses will act as a reliable fallback option. This way, we ensure that your data remains adequately protected even in the event of any political or legal changes.

For each individual service provider, we will inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information about the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, corresponding security measures apply, in particular Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found on the EU Commission's information page: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consents are revoked or there are no other legal bases for the processing. This applies to cases where the original purpose of processing no longer exists or the data is no longer required. Exceptions to this rule exist when legal obligations or special interests require a longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for the prosecution of legal claims or the protection of the rights of other natural or legal persons must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing activities.

If multiple retention periods or deletion deadlines are specified for a piece of data, the longest period always applies. Data that is no longer retained for its originally intended purpose, but due to legal requirements or other reasons, will be processed exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply for retention and archiving under German law:

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents required for their understanding (§ 147 Abs. 1 Nr. 1 i.V.m. Abs. 3 AO, § 14b Abs. 1 UStG, § 257 Abs. 1 Nr. 1 i.V.m. Abs. 4 HGB).
  • 8 years - Accounting documents, such as invoices and expense receipts (§ 147 Abs. 1 Nr. 4 and 4a i.V.m. Abs. 3 Satz 1 AO and § 257 Abs. 1 Nr. 4 i.V.m. Abs. 4 HGB).
  • 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents, insofar as they are relevant for taxation, e.g., hourly wage slips, operating cost allocation sheets, calculation documents, price markings, but also payroll accounting documents, insofar as they are not already accounting documents, and cash register receipts (§ 147 Abs. 1 Nr. 2, 3, 5 i.V.m. Abs. 3 AO, § 257 Abs. 1 Nr. 2 u. 3 i.V.m. Abs. 4 HGB).
  • 3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and common industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of the Data Subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right, in accordance with legal requirements, to obtain the completion of the data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to demand that data concerning you be erased without delay, or alternatively, to demand a restriction of the processing of the data in accordance with legal requirements.
  • Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller in accordance with legal requirements.
  • Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

Business Services

We process data of our contractual and business partners, e.g., customers and prospective customers (collectively referred to as "contractual partners"), in the context of contractual and similar legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractually), for example, to answer inquiries.

We use this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedies in case of warranty and other performance disruptions. Furthermore, we use the data to protect our rights and for the purpose of the administrative tasks associated with these obligations as well as for business organization. Moreover, we process the data based on our legitimate interests in proper and business-oriented management as well as in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., for the involvement of telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the scope of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about further forms of processing, for example for marketing purposes, within this privacy policy.

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually ten years). Data disclosed to us by the contractual partner in the context of an order will be deleted according to the specifications of the order, generally after the end of the order.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or phone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and business management procedures.
  • Retention and Deletion: Deletion according to the information in the "General Information on Data Storage and Deletion" section.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures, and services:

  • Online shop, order forms, e-commerce, and service fulfillment: We process our customers' data to enable them to select, purchase, or order the chosen products, goods, and related services, as well as their payment and provision, delivery, or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out the delivery or execution for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such within the order or comparable acquisition process and includes the information necessary for delivery, provision, and billing, as well as contact information to be able to consult with you if necessary; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Provision of the Online Offering and Web Hosting

We process user data to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.

  • Types of data processed: Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Log data (e.g., log files concerning logins or data retrieval or access times.).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Retention and Deletion: Deletion according to the information in the "General Information on Data Storage and Deletion" section.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures, and services:

  • Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files." The server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, a message about successful access, the browser type and version, the user's operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure the stability and utilization of the servers; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Use of Cookies

The term "cookies" refers to functions that store information on users' end devices and read information from them. Cookies can also be used for various purposes, such as for the functionality, security, and convenience of online offerings, as well as for creating analyses of visitor flows. We use cookies in accordance with legal regulations. For this, we obtain the prior consent of the users when necessary. If consent is not necessary, we rely on our legitimate interests. This applies when the storage and reading of information is essential to provide expressly requested content and functions. This includes, for example, the storage of settings as well as ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about its scope and which cookies are used.

Notes on data protection legal bases: Whether we process personal data with the help of cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.

General information on withdrawal and objection (opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

  • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Contact and Request Management

When contacting us (e.g., by post, contact form, email, telephone, or via social media) as well as within existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to answer the contact requests and any requested measures.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., textual or visual messages and posts and the information concerning them, such as authorship or creation time); Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via an online form). Provision of our online offering and user-friendliness.
  • Retention and Deletion: Deletion according to the information in the "General Information on Data Storage and Deletion" section.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further information on processing activities, procedures, and services:

  • Contact form: When contacting us via our contact form, by email, or other communication channels, we process the personal data transmitted to us to answer and handle the respective request. This generally includes information such as name, contact information, and any other information provided to us that is necessary for proper handling. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Newsletter and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or on a legal basis. If the contents of the newsletter are specified as part of the registration, these contents are decisive for the consent of the users. For registration for our newsletter, it is normally sufficient to provide your email address. However, to offer you a personalized service, we may ask for your name for a personal address in the newsletter or for further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address for this purpose alone in a blocklist (so-called "blocklist").

The logging of the registration process is based on our legitimate interests for the purpose of proving its proper conduct. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Contents:

Information about us, our services, promotions, and offers.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g., by email or post).
  • Legal bases: Consent (Art. 6(1)(a) GDPR).
  • Right to object (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably email.

Further information on processing activities, procedures, and services:

  • Measurement of open and click rates: The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server or, if we use a dispatch service provider, from its server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to the individual newsletter recipients and stored in their profiles until deleted. The evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of open and click rates and the storage of the measurement results in the users' profiles  ; Legal bases: Consent (Art. 6(1)(a) GDPR).

Created with the free Privacy Policy Generator from Dr. Thomas Schwenke