Privacy Policy

This English version is a convenience translation. In case of doubt or discrepancy, the German version is authoritative.

Preamble

With the following privacy policy we would like to explain to you which types of your personal data (hereinafter also referred to as "data") we process, for which purposes and to what extent, in the context of providing our services.

The terms used are not gender-specific.

As of: 22 July 2026

Table of contents

• Preamble
• Controller
• Overview of processing operations
• Relevant legal bases
• International data transfers
• General information on data storage and erasure
• Rights of data subjects
• Provision of the online offering and web hosting
• Contact and enquiry management
• Changes and updates
• Definitions

Controller

Tobias Huppertz
Altstr. 39
52066 Aachen
Germany

Email address: contact@huppertz.dev

Overview of processing operations

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

Types of data processed

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

Categories of data subjects

• Communication partners.
• Users.

Purposes of processing

• Communication.
• Security measures.
• Organisational and administrative procedures.
• Feedback.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.

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 provisions of the GDPR, national data protection rules may apply in your or our country of residence or domicile. Should more specific legal bases apply in individual cases, we will inform you of these in this privacy policy.

• Consent (Art. 6 (1) sentence 1 lit. 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 enquiries (Art. 6 (1) sentence 1 lit. b GDPR) - 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.
• Legal obligation (Art. 6 (1) sentence 1 lit. c GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection rules in Germany: In addition to the data protection provisions of the GDPR, national data protection rules apply in Germany. These include, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains 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, transmission, and automated individual decision-making including profiling. Furthermore, the data protection laws of the individual federal states may apply.

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 the disclosure or transfer of data to other persons, bodies or companies (which can be recognised by the postal address of the respective provider or when the privacy policy expressly refers to a data transfer to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission of 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes occur within the framework of the DPF, the standard contractual clauses step in as a reliable fallback. This way we ensure that your data remains appropriately protected even in the event of political or legal changes.

For individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US 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 transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information offered by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General information on data storage and erasure

We erase personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or no further legal bases for the processing exist. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where legal obligations or special interests require 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 legal prosecution or to protect the rights of other natural or legal persons, must be archived accordingly.

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

Where several retention periods or erasure deadlines apply to a piece of data, the longest period is always decisive.

Retention and erasure of data: The following general periods apply to 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 organisational documents required for their understanding (§ 147 (1) no. 1 in conjunction with (3) AO, § 14b (1) UStG, § 257 (1) no. 1 in conjunction with (4) HGB).
• 8 years - accounting documents, such as invoices and cost receipts (§ 147 (1) nos. 4 and 4a in conjunction with (3) sentence 1 AO and § 257 (1) no. 4 in conjunction with (4) HGB).
• 6 years - other business documents: commercial or business letters received, reproductions of commercial or business letters sent, and other documents insofar as they are relevant for taxation, e.g. time sheets, operating cost statements, calculation documents, price labelling, as well as payroll documents insofar as they are not already accounting documents, and till receipts (§ 147 (1) nos. 2, 3, 5 in conjunction with (3) AO, § 257 (1) nos. 2 and 3 in conjunction with (4) HGB).
• 3 years - data required to consider potential warranty and compensation claims or similar contractual claims and rights, and to process related enquiries, based on previous business experience and common industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Period begins at the end of the year: If a period does not expressly begin on a specific date and is at least one year long, it automatically starts at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships in the context of which data is stored, the triggering event is the effective date of termination or other ending of the legal relationship.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

• Right to object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on Art. 6 (1) lit. e or f GDPR; this also applies to profiling based on these provisions. Where your personal data is processed for the purposes of direct marketing, you have the right to object at any time to the processing of your personal data for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw any consent given at any time.
• Right of access: You have the right to request confirmation as to whether data concerning you is being processed, and to receive information about this data as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with the 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 the legal requirements.
• Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
• Complaint to 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 the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

Provision of the online offering and web hosting

We process users' data in order 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 device.

• Types of data processed: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved); log data (e.g. log files concerning logins or the retrieval of data or access times); content data (e.g. textual or pictorial messages and contributions, as well as information relating to them, such as details of authorship or time of creation).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: 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 erasure: Erasure in accordance with the section "General information on data storage and erasure".
• Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further information on processing operations, procedures and services:

• Provision of the online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called a "web host"); Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).
• Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, 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 utilisation and stability of the servers; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is exempt from erasure until final clarification of the respective incident.
• Email dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of emails. For these purposes, the addresses of the recipients and senders as well as further information regarding the email dispatch (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails on the internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of emails between the sender and receipt on our server; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).

Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the details of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.

• Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions, as well as information relating to them, such as details of authorship or time of creation); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
• Data subjects: Communication partners.
• Purposes of processing and legitimate interests: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form); provision of our online offering and user-friendliness.
• Retention and erasure: Erasure in accordance with the section "General information on data storage and erasure".
• Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 lit. b GDPR).

Further information on processing operations, procedures and services:

• Contact form: When you contact us via our contact form, by email or other communication channels, we process the personal data transmitted to us in order to answer and handle the respective matter. This usually includes details such as name, contact information and, where applicable, further information communicated to us that is required for appropriate handling. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 (1) sentence 1 lit. b GDPR), legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).

Changes and updates

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact information of companies and organisations in this privacy policy, please note that addresses may change over time and we ask you to verify the details before contacting them.

Definitions

This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations are primarily intended to aid understanding.

• Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata providing information about the content, such as tags, descriptions, author information and publication dates.
• Contact data: Contact data is essential information enabling communication with persons or organisations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Meta, communication and procedural data: Meta, communication and procedural data are categories containing information about how data is processed, transmitted and managed. Metadata, also known as data about data, comprises information describing the context, origin and structure of other data. It may include details of file size, creation date, the author of a document and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and reviewing operations.
• Usage data: Usage data refers to information capturing how users interact with digital products, services or platforms. This data comprises a wide range of information showing how users use applications, which functions they prefer, how long they stay on certain pages and via which paths they navigate through an application. Usage data may also include frequency of use, time stamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings.
• Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Log data: Log data is information about events or activities logged in a system or network. This data typically contains information such as time stamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
• Controller: "Controller" 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.
• Processing: "Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, analysis, storage, transmission or erasure.

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