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1. Privacy at a Glance
General Information
The following information provides an overview of how your personal data is handled when you visit this website. Personal data is any information that can be used to identify you personally. For more detailed information, please read the full privacy policy below.
Data Collection on This Website
Who is responsible for collecting data on this website?
The website operator is responsible for processing data on this website. You can find their contact details in the “Data Controller” section of this privacy policy.
How do we collect your data?
Some data is collected when you provide it to us—for example, when you enter information into a contact form.
Other data is collected by our IT systems automatically or with your consent when you visit the website. This primarily includes technical information, such as your browser, operating system, and the time you access a page. This information is collected automatically when you access this website.
What do we use your data for?
Some data is collected to ensure that the website functions correctly. Other data may be used to analyze how visitors use the website.
If this website allows you to enter into a contract or make an inquiry about one, the information you provide may also be processed to prepare offers, handle orders, or respond to other business inquiries.
What rights do you have regarding your data?
You have the right to request information, free of charge, about the source, recipients, and purposes of the personal data we hold about you. You may also request that your data be corrected or deleted.
If you have given consent to data processing, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before you withdrew your consent.
Under certain circumstances, you also have the right to request that the processing of your personal data be restricted. You may also lodge a complaint with the competent supervisory authority.
You can contact us at any time about these rights or any other questions concerning data protection.
Analytics and Third-Party Tools
When you visit this website, your browsing behavior may be analyzed statistically, primarily through analytics tools.
Further information about these tools is provided in the privacy policy below.
2. Hosting
We use MailerLite to host our website.
MailerLite
MailerLite provides email marketing and automation software as a service. When processing personal data on behalf of its customers, MailerLite acts as a data processor.
The contracting entity depends on the customer’s billing address shown on the relevant order form:
(a) For customers in the European Economic Area (EEA), the United Kingdom, or Switzerland: MailerLite Limited, a company registered in Ireland, with its registered address at 88 Harcourt Street, Dublin 2, D02 DK18, Ireland.
(b) For customers elsewhere in the world: MailerLite, Inc., a Delaware corporation, with its registered address at 548 Market St, PMB 98174, San Francisco, CA 94104-5401, USA.
MailerLite’s privacy policy explains what information it processes, how it processes that information, and for what purposes.
External Hosting
This website is hosted by an external service provider. Personal data collected through this website is stored on the hosting provider’s servers. This may include IP addresses, contact inquiries, metadata and communication data, contract information, contact details, names, website access records, and other data generated through the website.
We use external hosting to fulfill our contractual obligations to prospective and existing customers under Article 6(1)(b) of the General Data Protection Regulation (GDPR). We also have a legitimate interest in having a professional provider deliver our online services securely, quickly, and efficiently under Article 6(1)(f) GDPR.
Where consent has been requested, the relevant processing is based exclusively on Article 6(1)(a) GDPR and Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG), insofar as that consent covers storing cookies or accessing information on the user’s device—for example, through device fingerprinting—within the meaning of the TDDDG. Consent may be withdrawn at any time.
Our hosting provider processes your data only to the extent necessary to fulfill its service obligations and follows our instructions regarding that data.
Data Processing Agreement
We have entered into a data processing agreement (DPA) for the service described above. This agreement is required under data protection law and ensures that the provider processes our website visitors’ personal data only in accordance with our instructions and in compliance with the GDPR.
3. General Information and Required Disclosures
Data Protection
We take the protection of your personal data seriously. We handle your personal data confidentially and in accordance with applicable data protection laws and this privacy policy.
Various types of personal data are collected when you use this website. Personal data is information that can be used to identify you personally. This privacy policy explains what data we collect, how we collect it, and how and why we use it.
Please note that transmitting data over the internet—for example, when communicating by email—may involve security vulnerabilities. Complete protection against access by third parties cannot be guaranteed.
Data Controller
The data controller responsible for processing personal data on this website is:
Veit Wittenberger
Armonias 15
7040 Oroklini / Larnaca
Cyprus
Phone: +357 95905851
Email: veit@veitwittenberger.com
The data controller is the individual or legal entity that, alone or jointly with others, determines the purposes and means of processing personal data, such as names and email addresses.
Data Retention
Unless a more specific retention period is stated in this privacy policy, we retain your personal data until the purpose for processing it no longer applies.
If you submit a valid deletion request or withdraw your consent to data processing, we will delete your data unless we have another legally permissible reason to retain it, such as statutory retention requirements under tax or commercial law. In that case, the data will be deleted once those reasons no longer apply.
General Information on the Legal Bases for Processing Personal Data
If you have consented to data processing, we process your personal data under Article 6(1)(a) GDPR or, where special categories of personal data under Article 9(1) GDPR are involved, Article 9(2)(a) GDPR.
If you explicitly consent to the transfer of personal data to third countries, that transfer is also based on Article 49(1)(a) GDPR.
If you consent to cookies being stored or information on your device being accessed—for example, through device fingerprinting—processing is additionally based on Section 25(1) TDDDG. You may withdraw your consent at any time.
Where your data is necessary to perform a contract or take steps before entering into a contract, we process it under Article 6(1)(b) GDPR. Where processing is necessary to comply with a legal obligation, the legal basis is Article 6(1)(c) GDPR.
We may also process your data on the basis of our legitimate interests under Article 6(1)(f) GDPR. The legal bases applicable to individual processing activities are explained in the following sections.
Recipients of Personal Data
We work with various external organizations in the course of our business. This sometimes requires us to share personal data with them.
We only share personal data with external recipients where this is necessary to perform a contract, where we are legally required to do so—for example, when providing information to tax authorities—where we have a legitimate interest under Article 6(1)(f) GDPR, or where another legal basis permits the disclosure.
When using data processors, we share our customers’ personal data only on the basis of a valid data processing agreement. Where processing is carried out jointly, we enter into a joint controller agreement.
Withdrawing Your Consent
Many processing activities require your explicit consent. You may withdraw consent you have already given at any time. This does not affect the lawfulness of processing carried out before you withdrew your consent.
Right to Object in Certain Circumstances and to Direct Marketing — Article 21 GDPR
Where we process your personal data under Article 6(1)(e) or (f) GDPR, you have the right to object at any time on grounds relating to your particular situation. This also applies to profiling based on those provisions. The relevant legal basis for each processing activity is set out in this privacy policy.
If you object, we will stop processing the personal data concerned unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless processing is necessary to establish, exercise, or defend legal claims. This is your right to object under Article 21(1) GDPR.
Where your personal data is processed for direct marketing, you have the right to object at any time to processing for that purpose. This includes profiling related to direct marketing. If you object, your personal data will no longer be used for direct marketing purposes. This is your right to object under Article 21(2) GDPR.
Right to Lodge a Complaint with a Supervisory Authority
If you believe that your personal data has been processed in breach of the GDPR, you have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State where you normally live or work, or where the alleged infringement took place.
This right applies without prejudice to any other administrative or judicial remedies available to you.
Right to Data Portability
You have the right to receive data that we process automatically on the basis of your consent or in the performance of a contract in a commonly used, machine-readable format, or to have it provided to a third party.
If you request that we transfer the data directly to another controller, we will do so where technically feasible.
Access, Rectification, and Erasure
Subject to applicable law, you have the right to obtain information, free of charge, about the personal data we hold about you, its source and recipients, and the purposes for which it is processed. Where applicable, you also have the right to have that data corrected or deleted.
You may contact us at any time about these rights or any other questions concerning your personal data.
Right to Restrict Processing
You have the right to request restrictions on the processing of your personal data. You may contact us at any time to exercise this right.
This right applies in the following circumstances:
Where processing has been restricted, we may continue to store your data. Any other processing is permitted only with your consent, to establish, exercise, or defend legal claims, to protect the rights of another individual or legal entity, or for reasons of important public interest of the European Union or an EU Member State.
SSL and TLS Encryption
This website uses SSL or TLS encryption for security and to protect confidential information you send to us, such as orders or inquiries.
You can identify an encrypted connection by the “https://” prefix in your browser’s address bar. Your browser may also display a security indicator.
SSL or TLS encryption helps protect the information you transmit to us against interception by third parties during transmission.
Objection to Unsolicited Marketing Emails
We expressly object to the use of contact details published as part of our legal notice to send unsolicited advertising or promotional materials.
The website operator reserves the right to take legal action in response to unsolicited marketing communications, including spam emails.
4. Data Collection on This Website
Cookies
Our website uses cookies. Cookies are small data files that do not damage your device. They may be stored temporarily for the duration of a session—known as session cookies—or remain on your device for a longer period—known as persistent cookies.
Session cookies are automatically deleted at the end of your visit. Persistent cookies remain on your device until you delete them or your browser deletes them automatically.
Cookies may be set by us, known as first-party cookies, or by other companies, known as third-party cookies. Third-party cookies allow external services to be integrated into a website, such as payment processing services.
Cookies serve different purposes. Many are technically necessary because certain website features would not work without them, such as shopping cart functionality or video playback. Other cookies may be used to analyze visitor behavior or for advertising.
Unless another legal basis is specified, cookies required for electronic communications, for features you have requested, or for website optimization are stored on the basis of Article 6(1)(f) GDPR. The website operator has a legitimate interest in storing necessary cookies to provide services reliably and efficiently.
Where consent has been requested for storing cookies or using comparable recognition technologies, processing is based exclusively on that consent under Article 6(1)(a) GDPR and Section 25(1) TDDDG. You may withdraw your consent at any time.
You can configure your browser to notify you when cookies are set, allow them on a case-by-case basis, reject certain cookies or all cookies, or delete cookies automatically when you close your browser. Disabling cookies may limit the functionality of this website.
Details of the cookies and services used on this website are provided in this privacy policy.
Contact Form
If you send us an inquiry through a contact form, we store the information you provide, including your contact details, to respond to your inquiry and handle any follow-up questions. We do not share this data without your consent.
If your inquiry relates to the performance of a contract or is necessary to take steps before entering into a contract, processing is based on Article 6(1)(b) GDPR.
In all other cases, processing is based on our legitimate interest in handling inquiries efficiently under Article 6(1)(f) GDPR, or on your consent under Article 6(1)(a) GDPR where consent has been requested. You may withdraw consent at any time.
We retain the information you enter into the contact form until you request its deletion, withdraw your consent to its storage, or the purpose for retaining it no longer applies—for example, once your inquiry has been resolved.
Mandatory legal requirements, particularly statutory retention periods, remain unaffected.
Inquiries by Email, Telephone, or Fax
If you contact us by email, telephone, or fax, we store and process your inquiry, including any personal data it contains, such as your name and the details of your request, to respond to you. We do not share this data without your consent.
If your inquiry relates to the performance of a contract or is necessary to take steps before entering into a contract, processing is based on Article 6(1)(b) GDPR.
In all other cases, processing is based on our legitimate interest in handling inquiries efficiently under Article 6(1)(f) GDPR, or on your consent under Article 6(1)(a) GDPR where consent has been requested. You may withdraw consent at any time.
We retain the data you send us until you request its deletion, withdraw your consent to its storage, or the purpose for retaining it no longer applies—for example, once your request has been resolved.
Mandatory legal requirements, particularly statutory retention periods, remain unaffected.
5. Social Media
This website includes features provided by the Facebook social network. The service provider is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. According to Facebook, the data collected is also transferred to the United States and other third countries.
An overview of Facebook’s social plugins is available here:
Facebook Social Plugins
When a social media feature is active, a direct connection is established between your device and Facebook’s servers. Facebook then receives information that you have visited this website using your IP address.
If you click the Facebook “Like” button while logged into your Facebook account, you can link content from this website to your Facebook profile. This allows Facebook to associate your visit with your user account.
As the website operator, we do not receive information about the content of the data transmitted or how Facebook uses it. For further details, please see:
Facebook Privacy Policy
This service is used on the basis of your consent under Article 6(1)(a) GDPR and Section 25(1) TDDDG. You may withdraw your consent at any time.
Where the tool described here collects personal data on our website and transfers it to Facebook, we and Meta Platforms Ireland Limited act as joint controllers under Article 26 GDPR. This joint responsibility is limited to collecting the data and transferring it to Facebook. It does not cover Facebook’s subsequent processing.
Our respective obligations are set out in a joint controller agreement:
Meta Controller Addendum
Under this agreement, we are responsible for providing privacy information when using the Facebook tool and for implementing it on our website in compliance with data protection requirements. Facebook is responsible for the security of its products.
You may exercise your data protection rights, such as requesting access to your data, directly with Facebook in relation to data processed by Facebook. If you submit such a request to us, we are required to forward it to Facebook.
Transfers of data to the United States are based on the European Commission’s Standard Contractual Clauses. Further details are available at:
The company is certified under the EU–US Data Privacy Framework (DPF). The DPF is a framework between the European Union and the United States intended to ensure European data protection standards are upheld when personal data is processed in the United States. Certified companies commit to complying with these standards.
Further information is available here:
Data Privacy Framework — Meta
This website includes features provided by Instagram. The service provider is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
When a social media feature is active, a direct connection is established between your device and Instagram’s servers. Instagram then receives information about your visit to this website.
If you are logged into your Instagram account, clicking the Instagram button allows you to link content from this website to your Instagram profile. This allows Instagram to associate your visit with your user account.
As the website operator, we do not receive information about the content of the data transmitted or how Instagram uses it.
This service is used on the basis of your consent under Article 6(1)(a) GDPR and Section 25(1) TDDDG. You may withdraw your consent at any time.
Where the tools described here collect personal data on our website and transfer it to Facebook or Instagram, we and Meta Platforms Ireland Limited act as joint controllers under Article 26 GDPR.
This joint responsibility is limited to collecting the data and transferring it to Facebook or Instagram. It does not cover their subsequent processing.
Our respective obligations are set out in a joint controller agreement:
Meta Controller Addendum
Under this agreement, we are responsible for providing privacy information when using Facebook or Instagram tools and for implementing them on our website in compliance with data protection requirements. Facebook is responsible for the security of Facebook and Instagram products.
You may exercise your data protection rights, such as requesting access to your data, directly with Facebook in relation to data processed by Facebook or Instagram. If you submit such a request to us, we are required to forward it to Facebook.
Transfers of data to the United States are based on the European Commission’s Standard Contractual Clauses. Further details are available at:
For further information about how Instagram handles personal data, please see:
Instagram Privacy Policy
The company is certified under the EU–US Data Privacy Framework (DPF). This framework is intended to ensure European data protection standards are upheld when personal data is processed in the United States. Certified companies commit to complying with these standards.
Further information is available here:
Data Privacy Framework — Meta
6. Newsletter
Newsletter Subscription Data
To subscribe to the newsletter offered on this website, you must provide an email address and information that allows us to verify that you own that address and agree to receive the newsletter.
We do not collect any additional data unless you provide it voluntarily. We use this information exclusively to send the information you have requested and do not share it with third parties.
The information entered into the newsletter subscription form is processed exclusively on the basis of your consent under Article 6(1)(a) GDPR.
You may withdraw your consent to the storage of your data and email address, and their use for sending the newsletter, at any time—for example, by using the “Unsubscribe” link in a newsletter. This does not affect the lawfulness of processing carried out before you withdrew your consent.
The data you provide to receive the newsletter is stored by us or our newsletter service provider until you unsubscribe. It is removed from the mailing list after you unsubscribe or when the purpose for processing it no longer applies.
We reserve the right to remove or block email addresses from our mailing list at our discretion on the basis of our legitimate interests under Article 6(1)(f) GDPR.
Data stored for other purposes is not affected.
After you unsubscribe, your email address may be retained by us or our newsletter service provider on a suppression list where this is necessary to prevent further mailings. Information on this list is used only for that purpose and is not combined with other data.
This serves both your interests and our legitimate interest in complying with the legal requirements governing newsletters under Article 6(1)(f) GDPR.
Retention on the suppression list is not subject to a fixed time limit. You may object to this storage if your interests override our legitimate interest.
7. Plugins and Tools
YouTube in Privacy-Enhanced Mode
This website embeds videos from YouTube. The service is operated by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
When you visit a page containing an embedded YouTube video, a connection is established with YouTube’s servers. YouTube is informed which of our pages you have visited.
If you are logged into your YouTube account, YouTube can associate your browsing activity directly with your personal profile. You can prevent this association by logging out of your YouTube account.
We use YouTube’s privacy-enhanced mode. According to YouTube, videos viewed in this mode are not used to personalize your browsing experience on YouTube. Ads shown in this mode are also non-personalized.
In privacy-enhanced mode, cookies are not set. However, local storage items are stored in your browser. Like cookies, these may contain personal data and may be used to recognize your browser.
Further details about privacy-enhanced mode are available here:
YouTube Help — Embedded Videos and Privacy-Enhanced Mode
Activating a YouTube video may trigger additional processing activities over which we have no control.
We use YouTube in the interest of presenting our online content in an engaging way. This constitutes a legitimate interest under Article 6(1)(f) GDPR.
Where consent has been requested, processing is based exclusively on Article 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as consent covers storing cookies or accessing information on your device—for example, through device fingerprinting—within the meaning of the TDDDG. You may withdraw your consent at any time.
For further information, please see:
Google Privacy Policy
The company is certified under the EU–US Data Privacy Framework (DPF). This framework is intended to ensure European data protection standards are upheld when personal data is processed in the United States. Certified companies commit to complying with these standards.
Further information is available here:
Data Privacy Framework — Google
Vimeo with Do Not Track Enabled
This website uses plugins provided by the Vimeo video platform. The service provider is Vimeo Inc., 555 West 18th Street, New York, NY 10011, USA.
When you visit a page containing a Vimeo video, a connection is established with Vimeo’s servers. Vimeo is informed which of our pages you have visited and receives your IP address.
We have configured Vimeo so that it does not track your activity or set cookies.
We use Vimeo in the interest of presenting our online content in an engaging way. This constitutes a legitimate interest under Article 6(1)(f) GDPR.
Where consent has been requested, processing is based exclusively on Article 6(1)(a) GDPR. You may withdraw your consent at any time.
Transfers of data to the United States are based on the European Commission’s Standard Contractual Clauses and, according to Vimeo, on “legitimate business interests.” Further details are available in:
Vimeo Privacy Policy
The same policy provides further information about how Vimeo handles user data.
The company is certified under the EU–US Data Privacy Framework (DPF). This framework is intended to ensure European data protection standards are upheld when personal data is processed in the United States. Certified companies commit to complying with these standards.
Further information is available here:
Data Privacy Framework — Vimeo
Spotify
This website includes features provided by the music service Spotify. The service provider is Spotify AB, Birger Jarlsgatan 61, 113 56 Stockholm, Sweden.
Spotify plugins can be identified by the green Spotify logo on this website. An overview of Spotify’s developer tools is available here:
Spotify for Developers
When you visit this website, the plugin may establish a direct connection between your browser and Spotify’s servers. Spotify then receives information that you have visited this website using your IP address.
If you click the Spotify button while logged into your Spotify account, you can link content from this website to your Spotify profile. This allows Spotify to associate your visit with your user account.
Please note that Spotify uses Google Analytics cookies, which means your usage data may also be shared with Google when you use Spotify. Google Analytics is a tool provided by the US-based Google group to analyze user behavior.
Spotify alone is responsible for this integration. As the website operator, we have no control over this processing.
Data storage and analysis are based on Article 6(1)(f) GDPR. The website operator has a legitimate interest in providing engaging audio content.
Where consent has been requested, processing is based exclusively on Article 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as consent covers storing cookies or accessing information on your device—for example, through device fingerprinting—within the meaning of the TDDDG. You may withdraw your consent at any time.
For further information, please see:
Spotify Privacy Policy
If you do not want Spotify to associate your visit to this website with your Spotify account, please log out of your account.
8. Additional Services
OneDrive
We have integrated OneDrive into this website. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, referred to below as “OneDrive.”
OneDrive allows us to provide an upload area on our website where you can upload content. Uploaded content is stored on OneDrive’s servers.
A connection to OneDrive is also established when you access our website, allowing OneDrive to determine that you have visited it.
We use OneDrive on the basis of Article 6(1)(f) GDPR. The website operator has a legitimate interest in providing a reliable upload area.
Where consent has been requested, processing is based exclusively on Article 6(1)(a) GDPR. You may withdraw your consent at any time.
The company is certified under the EU–US Data Privacy Framework (DPF). This framework is intended to ensure European data protection standards are upheld when personal data is processed in the United States. Certified companies commit to complying with these standards.
Further information is available here:
Data Privacy Framework — Microsoft
Data Processing Agreement
We have entered into a data processing agreement (DPA) for the service described above. This agreement is required under data protection law and ensures that the provider processes our website visitors’ personal data only in accordance with our instructions and in compliance with the GDPR.
Google Drive
We have integrated Google Drive into this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Drive allows us to provide an upload area on our website where you can upload content. Uploaded content is stored on Google Drive’s servers.
A connection to Google Drive is also established when you access our website, allowing Google Drive to determine that you have visited it.
We use Google Drive on the basis of Article 6(1)(f) GDPR. The website operator has a legitimate interest in providing a reliable upload area.
Where consent has been requested, processing is based exclusively on Article 6(1)(a) GDPR. You may withdraw your consent at any time.
The company is certified under the EU–US Data Privacy Framework (DPF). This framework is intended to ensure European data protection standards are upheld when personal data is processed in the United States. Certified companies commit to complying with these standards.
Further information is available here:
Data Privacy Framework — Google
Data Processing Agreement
We have entered into a data processing agreement (DPA) for the service described above. This agreement is required under data protection law and ensures that the provider processes our website visitors’ personal data only in accordance with our instructions and in compliance with the GDPR.
ndbarkeit des TDDDG sind aus deiner Vorlage übernommen und hier nicht rechtlich oder technisch geprüft.