Privacy Policy

In the following, we would like to inform you about how we process your data.

You can reach our Data Protection Officer at:

Joel Schulz-Andres
Gollierstr. 23 Rgb., 80339 München
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If you contact us via email, the data you provide will be stored by us to process your request.

The processed data includes:

  • Email address

We will delete the data once storage is no longer necessary or restrict processing if there are statutory retention obligations.

Data Subject Rights

As a data subject, you have the right to information, the right to rectification or erasure, the right to restriction of processing, and the right to object to the processing of your data. If you have given us consent, you can revoke it at any time with effect for the future.

Please send your objection or revocation informally to the above address of our Data Protection Officer via (E-)Mail.

Furthermore, you have the right to data portability. You also have the right to lodge a complaint with a supervisory authority about the processing.

Trial Application Form

We provide an application form through which you can request a trial. Through it we collect the following personal data:

  • Name*
  • Email address*
  • Message*

Required fields are marked with an asterisk (*).

Additionally, the following is collected when you submit the form:

  • Time of submission
  • IP address
  • Browser type and referring website address

We process this data solely to receive and respond to your trial request. The legal basis is your consent (Art. 6(1)(a) GDPR), which you grant by ticking the consent box on the form and which you may withdraw at any time with effect for the future. As you are inquiring about an offered product, the processing additionally serves to implement pre-contractual measures (Art. 6(1)(b) GDPR).

Your data will be deleted once your request has been processed, unless statutory retention periods exist.

Spam Protection (Cloudflare Turnstile)

To protect the application form against automated misuse, we use Cloudflare Turnstile, a service of Cloudflare (Cloudflare Germany GmbH, Rosental 7, c/o Mindspace, 80331 Munich, Germany). When the form is loaded, Cloudflare processes your IP address as well as information about your browser and device in order to distinguish human visitors from bots. The legal basis is our legitimate interest in preventing spam and misuse of the form (Art. 6(1)(f) GDPR). Cloudflare's safeguards for international data transfers (EU Standard Contractual Clauses and participation in the EU-US Data Privacy Framework) described under "Hosting and Content Delivery Network (CDN)" apply accordingly.

Hosting and Content Delivery Network (CDN)

Our host Cloudflare (Cloudflare Germany GmbH, Rosental 7, c/o Mindspace, 80331 Munich, Germany) collects the following data transmitted by your browser in so-called log files: IP address, the address of the previously visited website (Referer Request Header), date and time of the request, time zone difference to Greenwich Mean Time, content of the request, HTTP status code, transferred amount of data, website from which the request comes, and information about browser and operating system.

This is necessary to display our website, ensure stability and security, and increase delivery speed through the Content Delivery Network (CDN). This corresponds to our legitimate interest pursuant to Art. 6(1)(f) GDPR. A CDN is a network of globally distributed servers that can optimally deliver content to website users.

No tracking occurs and we have no direct access to this data. The log files are deleted after a maximum of 25 hours.

The processing by Cloudflare corresponds to our legitimate interest pursuant to Art. 6(1)(f) GDPR in not having to maintain server infrastructure and a Content Delivery Network on our own premises.

You have the right to object to the processing. Whether the objection is successful must be determined as part of a balancing of interests.

The data will be deleted as soon as the purpose for processing ceases to apply. Personal data is stored by Cloudflare only as long as necessary for the described purposes.

The processing of the data specified in this section is neither legally nor contractually required. The functionality of the website cannot be guaranteed without the processing.

Cloudflare has implemented compliance measures for international data transfers. These apply to all worldwide activities where Cloudflare processes personal data of natural persons in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs) and participation in the EU-US Data Privacy Framework. For more information, visit: https://www.cloudflare.com/cloudflare_customer_SCCs.pdf

Analytics

For web analytics, we use Pirsch Analytics. Pirsch Analytics is a cookie-free web analytics software that was developed according to the Privacy by Design principle. To analyze visitor flows, Pirsch Analytics uses a hashing algorithm to generate a 16-digit number as the visitor ID when the page request is received. The input values are the IP address, the user agent, the date and a salt.

The visitor's IP address is not persisted in whole or in part, and is anonymized completely and non-reversibly by the hash. The inclusion of the date and the use of one salt per website ensures that website visitors cannot be recognized for more than 24 hours and cannot be tracked across multiple websites. A rough localization (country/city) is performed via a locally integrated database.

In principle, a data processing agreement must be concluded with the host. The Bavarian State Office for Data Protection Supervision has made an exception for hosting purely static websites.
In cases where the website serves self-presentation purposes, e.g., for associations or small businesses, no personal data flows to the operator, and no tracking takes place, there is no commissioned data processing. It further states: "The fact that IP addresses, i.e., personal data, must necessarily be processed even when hosting static websites does not lead to the assumption of commissioned data processing.
This would not be appropriate. The (short-term) storage of IP addresses is rather to be attributed to the telecommunications access mediation of the website host according to the TKG and primarily serves the host's security purposes.
https://www.lda.bayern.de/media/veroeffentlichungen/FAQ_Hosting_keine_Auftragsverarbeitung.pdf
We assume that this exception applies to Cloudflare Pages.