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") 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 Offer").

The terms used are not gender-specific.

Status: March 29, 2026

Table of Contents

Controller

Cristian Carrasco
Frauenstraße, 13
89073, Ulm, Germany

Email address: carrascocristian098@gmail.com

Legal Notice: carrascocristian.com/legal

Overview of Processing

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

Types of Data Processed

  • Inventory data.
  • Employee data.
  • Contact data.
  • Content data.
  • Usage data.

Categories of Data Subjects

  • Employees.
  • Third parties.
  • Whistleblowers.

Purposes of Processing

  • Whistleblower protection.

Relevant Legal Bases

Relevant legal bases under the GDPR: In the following, you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection requirements in your or our country of residence or seat may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Legal obligation (Art. 6 (1) (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) (f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

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

Security Measures

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

The 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, transmission, securing availability and separation of data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data and reactions to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Securing online connections with TLS/SSL encryption technology (HTTPS): In order to protect user data transmitted via our online services from unauthorized access, we use 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 transfers meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is transmitted securely and encrypted.

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transmitted to other offices, companies, legally independent organizational units or persons or disclosed to them. 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 comply with the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of 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 happens in the context of using third-party services or disclosure or transmission of data to other persons, bodies or companies (which becomes recognizable by the postal address of the respective provider or if the data transfer to third countries is explicitly mentioned in the privacy policy), this is always done in accordance with the 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. In addition, we have concluded standard contractual clauses with the respective providers, which correspond to the specifications of the EU Commission and establish contractual obligations to protect your data.

This dual safeguarding 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 act as a reliable fallback option. In this way, we ensure that your data remains appropriately protected even in the event of political or legal changes.

In the case of individual service providers, we inform you whether they are certified according to the DPF and whether standard contractual clauses are available. 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, explicit consent or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found on the information page of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there are no further legal bases for the processing. This applies to cases where the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this provision exist if legal obligations or special interests require longer storage or archiving of the data.

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

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

If several details are provided regarding the storage period or deletion periods of data, the longest period is always decisive. Data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its storage.

Storage and deletion of data: The following general periods apply to storage and archiving under German law:

  • 10 years - retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the working instructions and other organizational documents required for their understanding (§ 147 para. 1 No. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 No. 1 in conjunction with para. 4 HGB).
  • 8 years - accounting vouchers, such as invoices and cost vouchers (§ 147 para. 1 No. 4 and 4a in conjunction with para. 3 sentence 1 AO and § 257 para. 1 No. 4 in conjunction with para. 4 HGB).
  • 6 years - other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents as far as they are relevant for taxation, e.g., hourly wage slips, business accounting sheets, calculation documents, price tags, but also payroll documents as far as they are not already accounting vouchers and cash register tapes (§ 147 para. 1 No. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 No. 2 and 3 in conjunction with para. 4 HGB).
  • 3 years - data required to take into account potential warranty and damage claims or similar contractual claims and rights as well as to process related inquiries, based on past business experience and common industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Period starts at the end of the year: If a period does not explicitly start on a certain date and it is at least one year, 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 event triggering the period is the time at which the termination or other end of the legal relationship becomes effective.

Rights of Data Subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the 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 the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consents granted at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the legal requirements, to request the completion of data concerning you or the rectification of incorrect data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to request that data concerning you be deleted immediately or, alternatively, to request 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 that you have provided to us in a structured, commonly used and machine-readable format or to demand its transmission to another controller in accordance with the legal requirements.
  • Right to lodge a complaint with a supervisory authority: You have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement if you consider that the processing of personal data concerning you infringes the provisions of the 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 to 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.

Insofar as we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Definitions of Terms

In this section, you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Employees: Employees are defined as persons who are in an employment relationship, whether as workers, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee, which is established by an employment contract or an agreement. It includes the employer's obligation to pay remuneration to the employee while the employee performs their work. The employment relationship includes various phases, including the establishment in which the employment contract is concluded, the execution in which the employee performs their work activity, and the termination when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information that relates to these persons and is in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank data, working hours, vacation entitlements, health data and performance assessments.
  • Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data can include, among other things, personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, facilities or systems by enabling a unique assignment and communication.
  • Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include text, 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 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 people or organizations. 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.
  • Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data includes 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 can also include frequency of use, timestamps of activities, IP addresses, device information and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and possible problem areas within digital offers.
  • 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.
  • 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 which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, whether collecting, evaluating, storing, transmitting or deleting.

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