Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").

The terms used are not gender-specific.

As of: October 15, 2025

Controller
Overview of Processing Activities
Applicable Legal Bases
Security Measures
Transmission of Personal Data
International Data Transfers
General Information on Data Storage and Erasure
Rights of Data Subjects
Provision of the Online Offering and Web Hosting
Use of Cookies
Contact and Request Management
Online Marketing
Amendment and Update
Definitions of Terms

Controller

Corneliu Rusu
Gastfeldstraße, 61
28201, Bremen, Germany

Email address: snipklas@gmail.com

Overview of Processing Activities

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

Types of Data Processed

Inventory data.
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.
Reach measurement.
Tracking.
Conversion measurement.
Audience building.
Organizational and administrative procedures.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online offering and user-friendliness.
Information technology infrastructure.

Applicable Legal Bases

Applicable legal bases according to 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 requirements may apply in your or our country of residence or domicile. If, in individual cases, more specific legal bases are relevant, 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 his or her 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 party or in order to take steps at the request of the data subject prior to entering into a contract.
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 Federal Data Protection Act (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 and for transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Security Measures

In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection 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 access, input, disclosure, assurance of availability, and their separation. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the erasure of data, and responses to data breaches. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by privacy-friendly default settings.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transmission of Personal Data

In the course of our processing of personal data, it may happen that the data is transmitted or disclosed to other bodies, companies, legally independent organizational units, or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

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, this will only 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 protection ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the Standard Contractual Clauses serve as additional security. Should there be any changes within the framework of 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.

We will inform you for each individual service provider 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 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, express consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found on the information portal of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General Information on Data Storage and Erasure

We erase personal data that we process in accordance with legal provisions as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing has ceased 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 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 apply specifically to certain processing activities.

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

Retention and erasure 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 records, 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 relevant for taxation, e.g., time sheets, operational cost sheets, calculation documents, price markings, but also payroll documents, insofar as they are not already accounting records, and cash register tapes (§ 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 experiences and common industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Start of the period at the end of the year: If a period does not explicitly start on a specific date and is at least one year long, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the triggering event is the time the termination becomes effective or any other termination of the legal relationship.

Rights of 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 Art. 15 to 21 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 Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where personal data concerning you are 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 data concerning you is being processed, and to access this 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 the law, 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 provisions, you have the right to demand that data concerning you be erased immediately, or alternatively, to demand a restriction of the processing of the data in accordance with the legal provisions.
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 in accordance with the legal requirements, or to request its transmission to another controller.
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.

Provision of the Online Offering and Web Hosting

We process users' 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 dwell time, 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, involved persons). 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.
Storage and erasure: Erasure according to the information in the section "General Information on Data Storage and Erasure".
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures, and services:

Provision of 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 "web hoster"); Legal bases: Legitimate interests (Art. 6(1)(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". The server log files may include the address and name of the retrieved web pages and files, the date and time of retrieval, the amount of data transferred, a message about successful retrieval, 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 utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Erasure 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 erasure until the final clarification of the respective incident.
Hetzner: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hetzner.com; Privacy policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

Use of Cookies

The term "cookies" refers to functions that store and read information on users' end devices. Cookies can also be used for various purposes, such as the functionality, security, and comfort of online offerings, as well as the creation of analyses of visitor flows. We use cookies in accordance with legal regulations. For this purpose, we obtain the prior consent of users where necessary. If consent is not required, 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, storing settings and 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 using 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: Regarding 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, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about 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 notes on revocation and objection (opt-out): Users can revoke their given consent at any time and also declare an objection to processing in accordance with the legal requirements, including through the privacy settings of their browser.

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

Further information on processing activities, procedures, and services:

Processing of cookie data based on consent: We use a consent management solution in which users' consent to the use of cookies or to the procedures and providers mentioned within the consent management solution is obtained. This procedure is used to obtain, log, manage, and revoke consents, particularly regarding the use of cookies and comparable technologies used to store, read, and process information on users' end devices. Within this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option to manage and revoke their consents. The declarations of consent are stored to avoid repeated queries and to be able to prove consent in accordance with legal requirements. Storage is server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information about the providers of consent management services is available, the following general information applies: The duration of the storage of the consent is up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g., concerning categories of cookies and/or service providers), and information about the browser, system, and end device used; Legal bases: Consent (Art. 6(1)(a) 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, residential 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, as well as information concerning them, such as authorship or creation time); Usage data (e.g., page views and dwell time, 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, involved persons).
Data subjects: Communication partners.
Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
Storage and erasure: Erasure according to the information in the section "General Information on Data Storage and Erasure".
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 inquiry. This generally includes information such as name, contact information, and possibly other information that is communicated to us and is necessary 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 inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Online Marketing

We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used, by means of which the user's data relevant for the presentation of the aforementioned content is stored. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, as well as information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

In addition, the IP addresses of the users are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear data of the users (such as email addresses or names) are stored in the context of the online marketing procedure, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the user, but only the information stored in their profiles.

The information in the profiles is usually stored in cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure, and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, it is possible to assign clear data to the profiles, primarily if the users are, for example, members of a social network whose online marketing procedure we use and the network connects the user profiles with the aforementioned data. We ask you to note that users can make additional agreements with the providers, for example, by giving consent during registration.

We generally only receive access to summarized information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a contract conclusion with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is the permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Notes on revocation and objection:

We refer to the privacy policies of the respective providers and the objection options (so-called "opt-out") specified for the providers. If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are offered collectively for respective areas:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://youradchoices.ca/.

c) USA: https://optout.aboutads.info/.

d) Cross-regional: https://optout.aboutads.info.

Types of data processed: Usage data (e.g., page views and dwell time, 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, involved persons).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest/behavioral profiling, use of cookies); Audience building; Marketing; Profiles with user-related information (creation of user profiles). Conversion measurement (measuring the effectiveness of marketing measures).
Storage and erasure: Erasure according to the information in the section "General Information on Data Storage and Erasure". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users' devices for a period of two years).
Security measures: IP masking (pseudonymization of the IP address).
Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures, and services:

Google Ads and Conversion Measurement: Online marketing procedure for the purpose of placing content and advertisements within the service provider's advertising network (e.g., in search results, in videos, on websites, etc.), so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e., whether users have interacted with the ads and used the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
Google AdSense with personalized ads: We integrate the Google AdSense service, which allows personalized ads to be placed within our online offering. Google AdSense analyzes user behavior and uses this data to display targeted advertising that is tailored to the interests of our visitors. We receive financial compensation for each ad impression or other use of these ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
Google AdSense with non-personalized ads: We use the Google AdSense service to display non-personalized ads in our online offering. These ads are not based on individual user behavior, but are selected based on general characteristics such as the content of the page or your approximate geographical location. We receive compensation for the display or other use of these ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

Amendment and Update

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing we carry out 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 organizations in this privacy policy, we ask you to note that the addresses may change over time and to verify the information before contacting them.

Definitions of Terms

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

Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unique assignment and communication.
Content data: Content data includes information generated during the creation, editing, and publication of content of all kinds. This category of data can 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 but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, phone numbers, postal addresses, and email addresses, as well as communication tools like social media handles and instant messaging identifiers.
Conversion Measurement: Conversion measurement (also referred to as "visitor action evaluation") is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can track whether the ads we placed on other websites were successful.
Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include information on file size, creation date, the author of a document, and change histories. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used for tracking and verifying operations.
Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information showing how users use applications, which features they prefer, how long they stay on certain pages, and the paths they take through an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, 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.
Profiles with user-related information: The processing of "profiles with user-related information," or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to create performance reports.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, operators of online offerings can, for example, recognize at what time users visit their websites and what content they are interested in. This allows them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
Tracking: "Tracking" is when the behavior of users can be traced across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offerings used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
Controller: The "controller" is 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" is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is very broad and covers virtually any handling of data, be it collecting, evaluating, storing, transmitting, or erasing.
Audience Building: Audience building (or "custom audiences") is when target groups for advertising purposes, e.g., display of advertisements, are determined. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where they viewed the products. "Lookalike audiences" (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are usually used for the purposes of creating custom audiences and lookalike audiences.

Privacy Policy

Preamble

The terms used are not gender-specific.

As of: October 15, 2025

Controller
Overview of Processing Activities
Applicable Legal Bases
Security Measures
Transmission of Personal Data
International Data Transfers
General Information on Data Storage and Erasure
Rights of Data Subjects
Provision of the Online Offering and Web Hosting
Use of Cookies
Contact and Request Management
Online Marketing
Amendment and Update
Definitions of Terms

Controller

Corneliu Rusu
Gastfeldstraße, 61
28201, Bremen, Germany

Email address: snipklas@gmail.com

Overview of Processing Activities

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

Types of Data Processed

Inventory data.
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.
Reach measurement.
Tracking.
Conversion measurement.
Audience building.
Organizational and administrative procedures.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online offering and user-friendliness.
Information technology infrastructure.

Applicable Legal Bases

Consent (Art. 6(1)(a) GDPR) - The data subject has given consent to the processing of his or her 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 party or in order to take steps at the request of the data subject prior to entering into a contract.
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.

Security Measures

Transmission of Personal Data

International Data Transfers

General Information on Data Storage and Erasure

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

Retention and erasure 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 records, 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 relevant for taxation, e.g., time sheets, operational cost sheets, calculation documents, price markings, but also payroll documents, insofar as they are not already accounting records, and cash register tapes (§ 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 experiences and common industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of 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 Art. 15 to 21 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 Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where personal data concerning you are 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 data concerning you is being processed, and to access this 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 the law, 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 provisions, you have the right to demand that data concerning you be erased immediately, or alternatively, to demand a restriction of the processing of the data in accordance with the legal provisions.
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 in accordance with the legal requirements, or to request its transmission to another controller.
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.

Provision of the Online Offering and Web Hosting

Types of data processed: Usage data (e.g., page views and dwell time, 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, involved persons). 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.
Storage and erasure: Erasure according to the information in the section "General Information on Data Storage and Erasure".
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures, and services:

Provision of 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 "web hoster"); Legal bases: Legitimate interests (Art. 6(1)(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". The server log files may include the address and name of the retrieved web pages and files, the date and time of retrieval, the amount of data transferred, a message about successful retrieval, 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 utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Erasure 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 erasure until the final clarification of the respective incident.
Hetzner: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hetzner.com; Privacy policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

Use of Cookies

Storage duration: Regarding 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, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about 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.

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

Further information on processing activities, procedures, and services:

Processing of cookie data based on consent: We use a consent management solution in which users' consent to the use of cookies or to the procedures and providers mentioned within the consent management solution is obtained. This procedure is used to obtain, log, manage, and revoke consents, particularly regarding the use of cookies and comparable technologies used to store, read, and process information on users' end devices. Within this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option to manage and revoke their consents. The declarations of consent are stored to avoid repeated queries and to be able to prove consent in accordance with legal requirements. Storage is server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information about the providers of consent management services is available, the following general information applies: The duration of the storage of the consent is up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g., concerning categories of cookies and/or service providers), and information about the browser, system, and end device used; Legal bases: Consent (Art. 6(1)(a) GDPR).

Contact and Request Management

Types of data processed: Inventory data (e.g., full name, residential 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, as well as information concerning them, such as authorship or creation time); Usage data (e.g., page views and dwell time, 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, involved persons).
Data subjects: Communication partners.
Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
Storage and erasure: Erasure according to the information in the section "General Information on Data Storage and Erasure".
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 inquiry. This generally includes information such as name, contact information, and possibly other information that is communicated to us and is necessary 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 inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Online Marketing

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

Notes on revocation and objection:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://youradchoices.ca/.

c) USA: https://optout.aboutads.info/.

d) Cross-regional: https://optout.aboutads.info.

Types of data processed: Usage data (e.g., page views and dwell time, 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, involved persons).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest/behavioral profiling, use of cookies); Audience building; Marketing; Profiles with user-related information (creation of user profiles). Conversion measurement (measuring the effectiveness of marketing measures).
Storage and erasure: Erasure according to the information in the section "General Information on Data Storage and Erasure". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users' devices for a period of two years).
Security measures: IP masking (pseudonymization of the IP address).
Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures, and services:

Google Ads and Conversion Measurement: Online marketing procedure for the purpose of placing content and advertisements within the service provider's advertising network (e.g., in search results, in videos, on websites, etc.), so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e., whether users have interacted with the ads and used the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
Google AdSense with personalized ads: We integrate the Google AdSense service, which allows personalized ads to be placed within our online offering. Google AdSense analyzes user behavior and uses this data to display targeted advertising that is tailored to the interests of our visitors. We receive financial compensation for each ad impression or other use of these ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
Google AdSense with non-personalized ads: We use the Google AdSense service to display non-personalized ads in our online offering. These ads are not based on individual user behavior, but are selected based on general characteristics such as the content of the page or your approximate geographical location. We receive compensation for the display or other use of these ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

Amendment and Update

Definitions of Terms

Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unique assignment and communication.
Content data: Content data includes information generated during the creation, editing, and publication of content of all kinds. This category of data can 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 but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, phone numbers, postal addresses, and email addresses, as well as communication tools like social media handles and instant messaging identifiers.
Conversion Measurement: Conversion measurement (also referred to as "visitor action evaluation") is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can track whether the ads we placed on other websites were successful.
Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include information on file size, creation date, the author of a document, and change histories. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used for tracking and verifying operations.
Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information showing how users use applications, which features they prefer, how long they stay on certain pages, and the paths they take through an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, 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.
Profiles with user-related information: The processing of "profiles with user-related information," or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to create performance reports.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, operators of online offerings can, for example, recognize at what time users visit their websites and what content they are interested in. This allows them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
Tracking: "Tracking" is when the behavior of users can be traced across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offerings used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
Controller: The "controller" is 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" is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is very broad and covers virtually any handling of data, be it collecting, evaluating, storing, transmitting, or erasing.
Audience Building: Audience building (or "custom audiences") is when target groups for advertising purposes, e.g., display of advertisements, are determined. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where they viewed the products. "Lookalike audiences" (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are usually used for the purposes of creating custom audiences and lookalike audiences.

Privacy Policy

Preamble

Table of Contents

Controller

Overview of Processing Activities

Types of Data Processed

Categories of Data Subjects

Purposes of Processing

Applicable Legal Bases

Security Measures

Transmission of Personal Data

International Data Transfers

General Information on Data Storage and Erasure

Rights of Data Subjects

Provision of the Online Offering and Web Hosting

Use of Cookies

Contact and Request Management

Online Marketing

Amendment and Update

Definitions of Terms

Privacy Policy

Preamble

Table of Contents

Controller

Overview of Processing Activities

Types of Data Processed

Categories of Data Subjects

Purposes of Processing

Applicable Legal Bases

Security Measures

Transmission of Personal Data

International Data Transfers

General Information on Data Storage and Erasure

Rights of Data Subjects

Provision of the Online Offering and Web Hosting

Use of Cookies

Contact and Request Management

Online Marketing

Amendment and Update

Definitions of Terms