Privacy Policy

Table of Contents

  1. Controller
  2. General Information
  3. SSL/TLS Encryption
  4. Hosting and Server
  5. CDN and DNS
  6. Website-Analyse
  7. Contact Forms and Appointment Booking
  8. Online Advertising and Conversion Tracking
  9. Video consultation
  10. Speech Processing
  11. AI-Assisted Summarization
  12. Email Delivery
  13. Customer Portal
  14. Accounting
  15. Internal Communication (Telegram)
  16. Data backup
  17. Transfer to Third Countries
  18. Storage Duration and Deletion
  19. Your Rights
  20. Right to Lodge a Complaint
  21. Changes to This Privacy Policy
1. Controller

The controller responsible for data processing on this website is:

Rusi Kolev
Kolev Architektenküchen
Hauptstr. 39
61239 Ober-Mörlen

Phone: 06002 4213585
Contact: Via our Kontaktformular
Website: https://kolev-kuechen.de

If you have any questions about data protection, you can reach us at any time via our Kontaktformular.

2. General Information

In this privacy policy, we address you informally, as you are accustomed to from our communication. This does not affect your statutory rights.

This privacy policy explains what personal data we collect on our website and in the course of our kitchen planning services, what we use it for, and what rights you have.

We process your data in accordance with the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and the Telecommunications Digital Services Data Protection Act (TDDDG).

As we use AI tools for processing consultation conversations (speech recognition, summarization, analysis of design preferences), we have conducted a Data Protection Impact Assessment pursuant to Art. 35 GDPR. This is reviewed at least annually. Upon request, we are happy to inform you about the results.

Cookie-Free Website

This website does not use any cookies—neither tracking cookies, advertising cookies, nor cookies that are not technically necessary. Our analytics tool (section 6) and our advertising measurement tool (section 8) also operate entirely without cookies. We do not use device fingerprinting. Solely for the purpose of advertising attribution, if you access our website via a meta or Google ad, we store the respective click ID (fbclid or gclid) in your browser’s session storage for the duration of your current browser session. Immediately after recording, we remove the click ID from the address bar (history.replaceState) so that it is not visible when sharing the URL, clicking on external links (referrer header), or in your browser history. This information is only transmitted to our server when you submit the questionnaire and is automatically deleted at the end of your browser session (at the latest when you close the tab). No data is transmitted without submitting the questionnaire.

A cookie consent banner is therefore not required according to Section 25 Paragraph 2 of the German Telemedia Act (TDDG), since, apart from the click ID storage described above, no access to users’ devices occurs beyond what is technically necessary for providing the service. The click ID storage is covered by your explicit consent in the questionnaire (Section 8) and serves solely to associate your visit with an advertisement.

3. SSL/TLS Encryption

For security reasons, this website uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that your browser’s address bar changes from “http://” to “https://” and displays a lock icon in the browser bar.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. Hosting and Server

Provider: Netcup GmbH, Karlsruhe, Germany

Our website and all associated services — video consultation, automation, and database — run on our own server in Germany.

Legal basis: Art. 6 para. (1) f GDPR (legitimate interest in the reliable provision of our website).

DPA: Data Processing Agreement pursuant to Art. 28 GDPR concluded with Netcup.

Server Log Files

Each time our website is accessed, the following technical data is automatically collected:

  • IP address of the requesting device
  • Date and time of access
  • Name and URL of the page accessed
  • Volume of data transferred
  • Browser type and version
  • Operating system

This data is used exclusively to ensure uninterrupted operation and is automatically deleted after 14 days.

5. CDN and DNS

Provider: Cloudflare, Inc., USA

To ensure our website loads quickly and securely, we use Cloudflare as a Content Delivery Network and DNS service. Cloudflare processes technically necessary connection data (IP address, requested URL) in the process. The processing by Cloudflare is technically necessary for delivering the website and is therefore permissible without consent pursuant to § 25 para. 2 no. 2 TDDDG.

Should Cloudflare, in exceptional cases (e.g., during a DDoS protection check), set a technically necessary security cookie, this serves exclusively to protect the website and falls under § 25 para. 2 no. 2 TDDDG (strictly necessary access).

Legal basis: Art. 6 para. (1) f GDPR (legitimate interest in the secure and efficient delivery of our website).

Third-country transfer: Cloudflare is certified under the EU-US Data Privacy Framework (adequacy decision pursuant to Art. 45 GDPR). Additionally, Standard Contractual Clauses pursuant to Art. 46 para. 2 lit. c GDPR have been agreed upon as a legal fallback.

DPA: A Data Processing Agreement has been concluded with Cloudflare.

Datenschutz: https://www.cloudflare.com/de-de/privacypolicy/

6. Website analysis

We use privacy-friendly, self-hosted web analytics software.

  • No Cookies: The software sets no cookies and stores no personal data.
  • Kein Tracking: Es werden keine individuellen Nutzerprofile erstellt.
  • Selbst gehostet: Alle Daten verbleiben auf unserem eigenen Server in Deutschland.

Die Software erfasst ausschließlich aggregierte, anonyme Nutzungsstatistiken: Seitenaufrufe, Verweildauer, Herkunftsland sowie technische Ladezeit- und Reaktionsmesswerte (sogenannte Core Web Vitals: LCP, INP, CLS, FCP, TTFB). Diese dienen der Überwachung und Optimierung der Ladegeschwindigkeit unserer Seite und enthalten keine personenbeziehbaren Informationen.

Legal basis: Art. 6 para. (1) f GDPR (legitimate interest in the anonymous analysis of user behavior). Since no personal data is stored, no consent is required.

As explained in Section 2, our website is completely cookie-free. Our analytics software supports this concept, as it operates without cookies and without personal data.

Consultation preparation: When you fill out our kitchen questionnaire and subsequently book a consultation appointment, we link the anonymous session data (pages visited, time spent, products viewed) with your form data in order to prepare for your initial consultation. This linking occurs exclusively for customers with a confirmed consultation appointment — not for general website visitors. The combined data is used internally for consultation preparation only and is subject to the deletion periods stated in Section 18. Legal basis: Art. 6 para. (1) f GDPR (legitimate interest in qualified consultation preparation for the appointment initiated by you).

7. Contact Forms and Appointment Booking
7.1 Contact Form

When you use our contact form, we collect the following data:

  • Name
  • Email Address
  • Phone Number (optional)
  • Your message

Purpose: Processing your inquiry.
Legal basis: Art. 6 para. (1) b DSGVO (vorvertragliche Maßnahmen).

7.2 Küchenplanungs-Fragebogen

To ensure we can optimally prepare your consultation, we ask you to provide some information in advance via an online form (self-hosted):

  • Name, E-Mail, Telefonnummer, Postleitzahl
  • Angaben zu deinem Küchenprojekt: Küchenform, Projekttyp (Neubau oder Renovierung), Kücheninsel (ja/nein), besondere Wünsche

Zweck: Vorbereitung und Durchführung der Küchenberatung.
Legal basis: Art. 6 para. (1) b GDPR (performance of a contract and pre-contractual measures).

7.3 Appointment Booking

For appointment scheduling, we use self-hosted booking software. All booking data is stored exclusively on our own server in Germany.

To check availability, we synchronize appointment metadata (date, time, booking reference) with Google Calendar. Your name, email address, and phone number are not transmitted to Google. The synchronization is carried out via Google. Google LLC (USA) is certified under the EU-US Data Privacy Framework (Art. 45 GDPR). Additionally, Standard Contractual Clauses (SCCs) have been agreed upon.

Legal basis: Art. 6 para. (1) b GDPR (performance of a contract and pre-contractual measures).

8. Online Advertising and Conversion Tracking
8.1 Meta Ad Measurement (server-side, cookieless)

We run ads on Facebook and Instagram. To measure whether these ads are effective, we use the Meta Conversions API (CAPI). This works exclusively server-side — no Meta Pixel (JavaScript) is used on our website, no cookie is set on your device, and no client-side tracking is carried out. All data transmission takes place via our own server.

Data processed:

  • Pseudonymised (SHA-256-hashed) contact data: email address, phone number, name, postcode
  • Event type (e.g., questionnaire submitted, appointment booked, offer delivered, order placed)
  • Upon offer acceptance: Gross order value (to optimize ad delivery)
  • Facebook Click ID (fbclid), if you arrived at our website via a Facebook or Instagram ad — this is temporarily captured in your browser when the questionnaire is submitted and transmitted to our server

Note on pseudonymisation: Before transmission, your contact data is hashed using the SHA-256 method (pseudonymised within the meaning of Art. 4 No. 5 GDPR). Meta can only match the hashed data with existing user profiles — the data nonetheless remains personal data.

Purpose: Measuring advertising effectiveness and optimising our ads.

Legal basis: Art. 6 para. (1) a GDPR (consent). Data is only transmitted to Meta if you have actively given your consent in the contact form (checkbox). Without your consent, no data will be transmitted to Meta.

Joint responsibility: We and Meta Platforms Ireland Limited are jointly responsible for this processing in accordance with Art. 26 GDPR. Under this agreement, Meta is responsible for providing the infrastructure and processing the received data. We are responsible for the lawful collection and transmission of data (including obtaining your consent). The agreement can be found at https://www.facebook.com/legal/controller_addendum. You can assert your rights against either of the two controllers.

You can withdraw your consent at any time — simply contact us via our contact form. Data already transmitted to Meta can be deleted there in accordance with Meta’s own privacy policy.

Third-country transfer: Meta Platforms, Inc. is certified under the EU-US Data Privacy Framework (adequacy decision pursuant to Art. 45 GDPR). As an additional legal safeguard, Standard Contractual Clauses have been agreed upon pursuant to Art. 46 para. 2 lit. c GDPR.

Meta Privacy Policy: https://www.facebook.com/privacy/policy/

8.1.1 Custom Audience for similar target groups (lookalike source group)

In addition to the conversion events described above, we transfer the same pseudonymized contact data (email address, phone number, first and last name, postal code and country code — each hashed using SHA-256) to Meta once a day to maintain a so-called Custom Audience. This audience is named “Kolev — Consented Leads”.

Purpose: This custom audience serves as the source group for a statistically identical target audience (so-called lookalike audience or “similar target group”). This allows us to target our advertising more precisely to people with a similar interest in high-quality architect-designed kitchens—and consequently spend less advertising budget on irrelevant reach.

Data processed: identical to section 8.1 — no additional data categories are collected or transmitted. We simply use the same pseudonymized contact details a second time for this additional purpose.

Legal basis: Art. 6 para. (1) GDPR (consent) — the same consent you gave in the advertising measurement questionnaire (checkbox). Without this consent, your data will not be used for conversion measurement or for Custom Audiences.

Joint controllership: As with conversion measurement in section 8.1, we and Meta Platforms Ireland Limited are jointly responsible pursuant to Article 26 GDPR. The same provisions from the agreement linked at https://www.facebook.com/legal/controller_addendum apply.

Data retention and revocation: As long as your marketing consent is valid, you will remain part of the Custom Audience. Upon revocation, we will remove your data immediately, but no later than 30 days, including from the Custom Audience. You can declare your revocation as described in section 8.1 via our contact form. Additionally, you can request deletion directly from Meta or hide the Custom Audience in your ad settings on Facebook and Instagram.

Third-country transfer: identical to section 8.1 (DPF pursuant to Art. 45 GDPR + SCCs pursuant to Art. 46 para. 2 lit. c GDPR).

8.2 Google Ads Offline Conversion Tracking (server-side, cookieless)

We run ads on Google Ads. To measure whether these ads are effective, we use Google Ads Offline Conversion Tracking. Here too, no Google Tag (gtag.js) is deployed on our website, no cookies are set, and no client-side tracking is carried out.

Data processed:

  • Google Click-ID (gclid), sofern du über eine Google-Anzeige auf unsere Website gekommen bist — diese wird beim Absenden des Fragebogens temporär in deinem Browser erfasst und an unseren Server übermittelt
  • Event type (e.g. questionnaire completed, appointment booked, order placed)
  • Timestamp of the event
  • Upon order placement: Gross order amount

Hinweis: Bei der Übermittlung an Google werden keine personenbezogenen Daten (Name, E-Mail, Telefonnummer) weitergegeben — ausschließlich der gclid, der Zeitstempel und der Ereignistyp. Der gclid ist jedoch eine technische Kennung, die Google einem bestimmten Anzeigenklick zuordnen kann, und stellt daher ein personenbezogenes Datum dar.

Purpose: To measure the advertising effectiveness of our Google ads.

Legal basis: Art. 6 para. (1) GDPR (consent). Data will only be transferred to Google if you have actively consented in the questionnaire (same checkbox as for Meta). Without your consent, no data will be transferred to Google.

Recipient: Google Ireland Limited, Ireland.

You can withdraw your consent at any time — simply write to us via our contact form. After withdrawal, no further data will be transmitted to Google.

Third-country transfer: Google LLC is certified under the EU-US Data Privacy Framework (adequacy decision pursuant to Art. 45 GDPR). In addition, standard contractual clauses pursuant to Art. 46 para. 2 lit. c GDPR have been agreed upon.

Speicherdauer: Der gclid wird maximal 90 Tage in unserer Datenbank gespeichert und anschließend gelöscht. Im Browser wird der Eintrag am Ende deiner Browser-Sitzung automatisch gelöscht (sessionStorage).

Google Privacy Policy: https://policies.google.com/privacy

8.3 Meta Lead Forms (Contact Form on Facebook/Instagram)

When you fill out a lead form on our Facebook or Instagram page, we receive the data you enter there.

Data processed:

  • First and Last Name
  • Email Address
  • Phone Number
  • Budget information (selection field in the form)
  • Source of the request (campaign and ad name)

Purpose: Processing your request, inviting you to an initial consultation, pre-filling our online questionnaire with the information you have already provided.

Legal basis: Art. 6 para. (1) b GDPR (performance of pre-contractual measures at the request of the data subject). You actively filled out a contact form to receive information about our services.

Data source: Meta Platforms Ireland Limited — the data is retrieved from our server via the Meta Marketing API (Art. 14 para. 2 lit. f GDPR).

Joint responsibility: Meta and we are jointly responsible for the collection of data via the lead form in accordance with Article 26 of the GDPR. You can find the agreement at https://www.facebook.com/legal/controller_addendum.

Recipients: The data is processed exclusively internally. It will not be shared with third parties. There is no tracking or transmission to advertising networks – separate consent is required for this (see section 8.1).

Data retention period: If you complete our questionnaire, the lead data will be transferred to your customer profile and the original data will be deleted. If you do not complete the questionnaire, the lead data will be automatically deleted after a maximum of 90 days.

Third-country transfer: Lead data is transferred from Meta (Ireland/USA) to our server in Germany. Meta is certified under the EU-US Data Privacy Framework (Art. 45 GDPR). In addition, Standard Contractual Clauses (SCCs) pursuant to Art. 46 para. 2 lit. c GDPR apply.

Your rights: You can request information, deletion or objection at any time – write to us via our contact form.

8.4 PDF retrieval measurement during the initial consultation

If you contacted us via a meta-lead form on Facebook or Instagram, you will receive one or more guides and reference documents as PDFs via email—for example, the guide “The Five Most Expensive Mistakes When Buying a Kitchen” or a reference case study of a completed project. These links contain a pseudonymous token (32 characters, hexadecimal) generated specifically for you, so we can track whether you actually accessed the guide.

What we store:

  • The slug of the retrieved PDF (e.g.,   denkfehler-leitfaden)
  • The lead token in the URL (no real name, no email address)
  • Timestamp of the retrieval
  • Your browser’s user agent and referrer
  • Optional UTM parameters
  • An internal link between the token and your request record — the token is connected server-side to your meta lead entry, even if it is not in plain text in the URL.
  • Once you have completed the questionnaire, include a cross-reference to your consultation entry with the date of assignment — solely so that the PDF download is visible in the preparation note for the initial consultation.

What we do NOT save:

  • your IP address (neither in plaintext nor hashed)
  • Cookies or similar storage content on your device
  • PDF content or reading behavior data.

Purpose: We use this information exclusively internally to improve the preparation for your initial consultation. If you have read the guide before the initial consultation, this will be incorporated into the preparation notes for the architect—you arrive informed, and the conversation proceeds to the next stage.

Legal basis: Art. 6 para. (1) f GDPR — legitimate interest in efficient and customer-centric consultation preparation. Data will not be shared with third parties.

Storage period: The PDF retrieval data is technically linked to your lead record and follows its lifecycle. If you do not contact us within 7 days of receiving the guide, the entire record—including the PDF retrieval information—will be automatically deleted. If you come for an initial consultation, the PDF retrieval information will be retained for as long as your lead record itself—that is, until the conclusion of your consultation or until the regular deletion of your file in accordance with Section 18 of this Privacy Policy. It will not be independently transferred to subsequent accounting or contract data; these are subject exclusively to the general retention periods specified in Section 18. Upon your explicit request, we will also delete the PDF retrieval information prematurely at any time (see “Objection” below and Section 19).

Right to object: You can object to the processing of your data at any time by using the unsubscribe link in any email from us or by contacting us via our contact form. After you object, further PDF downloads will no longer be tracked; any data already stored will be deleted upon your request.

Cookieless Promise: This measurement does not change our strict cookie-free practice as outlined in Section 2 of this Privacy Policy. Neither cookies nor localStorage content will be stored on your device. The lead token travels exclusively within the URL of the PDF download link and, once downloaded, is internally linked to your data record, not to your browser.

8.5 Kolev Planungsjournal — Newsletter-Abonnement (Double Opt-In)

We invite you to subscribe to our Kolev Planning Journal. Published quarterly (four issues per year), the journal contains articles on all aspects of architect-designed kitchens—materials, reference projects, common planning mistakes, and selected industry updates. Subscription is voluntary, free of charge, and independent of any consultation request.

How the registration process works (double opt-in):

  1. You click on the registration link that we provide at the end of our initial consultation correspondence.
  2. You will land on a confirmation page and confirm that you want to subscribe to the journal.
  3. We will send you a separate confirmation email with a unique confirmation link (valid for 72 hours).
  4. Your subscription will only be activated after you click on this link. Until then, you will not receive any newsletter emails.

This two-stage registration process complies with the practice required by the Federal Court of Justice (BGH, judgment of 10.02.2011 — I ZR 164/09 “Double-Opt-In”).

What we store:

  • Email address (necessary for sending)
  • First name (for personal address)
  • Language preference (de or en)
  • Time of your registration (click on the registration link)
  • Time of your confirmation (click on the confirmation link)
  • Time of the last journal sent to you
  • A pseudonymous unsubscribe token (32 characters, hexadecimal) generated for you — it travels as a query string in every journal issue and allows you to unsubscribe with one click.
  • An internal link to your consultation lead record, if your registration originated from a previous initial consultation correspondence.

What we do NOT save:

  • your IP address (neither in plaintext nor hashed)
  • Cookies or similar storage content on your device
  • Reading, clicking, or dwell time behavior within the journal emails
  • Tracking pixels, web beacons or similar open/click trackers
  • Inhalte oder Antworten auf E-Mails (bis du uns aktiv schreibst)

Purpose: We use this information solely to send you the planning journal in your chosen language, to correctly formulate your salutation, and to enable you to unsubscribe smoothly if necessary.

Legal basis: Art. 6 para. (1) In accordance with the GDPR, your explicit consent to receive the newsletter is required. This consent is separate from any potential consultation request and can be revoked at any time without giving reasons, without affecting the lawfulness of the processing carried out until the revocation (Art. 7 para. 3 GDPR). Your data will not be transferred to third parties.

Storage period: Your registration data will be stored as long as you maintain your subscription. Upon unsubscription, your data record will be immediately set to “unsubscribed” status—we will no longer send you any further issues. For verification purposes, we retain the unsubscription time along with your email address for six months to be able to demonstrate to supervisory authorities that your withdrawal of consent has been processed (legitimate interest, Art. 6 para. 1 lit. f GDPR). After this period, the data record will be permanently deleted. Unconfirmed subscriptions are automatically removed after 72 hours.

Unsubscribe: You’ll find an unsubscribe link in every issue of the journal. A single click removes you from the mailing list—no follow-up questions, no confirmation loop. Alternatively, you can contact us via our contact form or write directly to[email protected].

Shipping provider: Shipping is handled by Amazon Web Services (AWS SES, Frankfurt region) — the same data processor we use for our other email communications (see section 12). No additional data is shared.

Cookieless Promise: Subscribing to our newsletter does not change our strict cookie-free practice as outlined in Section 2 of this Privacy Policy. Neither cookies nor localStorage content will be stored on your device. The unsubscribe token travels exclusively within the URL of the unsubscribe link and is bound to your data record server-side, not to your browser.

9. Video Consultation (self-hosted)

For our initial consultations, we use self-hosted video conferencing software. This runs entirely on our own server in Germany.

Data processed:

  • Audio and video stream during the consultation
  • IP address (connection log)
  • Recording of the session (MP4 file), if you consent

No third parties: All data is processed and stored exclusively on our own server. No data is transmitted to third parties for the video consultation itself.

Recording: We record the consultation session in order to subsequently provide you with a high-quality summary and precise kitchen planning. For this reason, we ask for your consent at the time of booking (checkbox). Without your consent, no recording will take place.

You can withdraw your consent at any time — even during the session. In that case, we will stop the recording immediately and delete any data already recorded. The video consultation can also take place without a recording — your consent to recording is not a prerequisite for the consultation.

At the start of the recording, we will remind you of this once more.

Legal basis:

  • Conducting the consultation: Art. 6 para. (1) b GDPR (performance of a contract)
  • Recording: Art. 6 para. (1) a GDPR (consent)

Retention period: The recording will be deleted 6 months after your project is completed. For non-clients, deletion occurs 3 months after the consultation.

10. Speech Processing

The audio recording of your consultation session is automatically converted into text using AI-based speech recognition software (transcription). Prior to transmission, only the audio channel is extracted and converted into a compressed format. Video data is not transmitted to the speech recognition service.

Provider: OpenAI, Inc., USA

Data processed: Audio content of the consultation session.

Purpose: Creation of a written session summary as the basis for your kitchen planning.

Legal basis: Art. 6 para. (1) a GDPR (consent). Your consent to the recording (Section 9) also covers the subsequent transcription, as this is a necessary step in project processing.

Note: The audio data is processed exclusively for transcription purposes. In accordance with OpenAI’s API usage terms, the transmitted audio data is not stored and is immediately deleted after processing (Zero Data Retention). OpenAI does not use your data to train its models.

DPA: Data processing agreement concluded with OpenAI.

Third-country transfer: OpenAI is certified under the EU-US Data Privacy Framework (adequacy decision pursuant to Art. 45 GDPR). As an additional legal safeguard, Standard Contractual Clauses have been agreed upon pursuant to Art. 46 para. 2 lit. c GDPR.

11. AI-Assisted Summary

After your consultation, your data goes through the following steps:

  1. Recording of the consultation session on our own server (Section 9)
  2. Speech recognition: Audio is converted into text (Section 10)
  3. AI summary: Transcript is analysed (this section)
  4. Email delivery: You receive a summary by email (Section 12)
  5. Client portal: Project information is made available in the portal (Section 13)

The written session transcript is processed using an AI language model in order to:

  • create an internal summary for the kitchen planning
  • compose a personalised email summary for you
  • extract relevant details: material preferences, appliance preferences, room dimensions

As part of the summary, the AI creates a structured profile of your consultation preferences (so-called profiling pursuant to Art. 4 No. 4 GDPR). This includes assessments of your design style, communication behaviour, and budget framework. This information is stored as an internal working aid and is used exclusively for personal consultation by Rusi. All decisions regarding offers, pricing, and project design are made personally by Rusi — no automated decision-making within the meaning of Art. 22 GDPR takes place that produces legal effects or similarly significantly affects you.

For continuous quality improvement, we store corrections to AI drafts exclusively in anonymised form. Personal details (names, addresses, specific project details) are removed in the process.

Provider: Amazon Web Services (AWS) — operated in the Frankfurt region

Data processed: Transcript text and questionnaire responses.

Data residency: All data is processed exclusively within the EU (Frankfurt). No data is transferred to third countries.

AWS is a US-based company. In addition to the contractual guarantees (AWS Data Processing Addendum with Standard Contractual Clauses), AWS has committed to reviewing governmental access requests under EU law and, where unfounded under EU law, to challenge them.

Legal basis: Art. 6 para. (1) f GDPR (legitimate interest in efficient and high-quality project processing). The balancing of our legitimate interest against your rights comes out in favour of processing, as only conversation content already recorded with your consent is processed, and the summary serves your immediate benefit.

Note: The AI service guarantees that customer data is not used for training AI models.

DPA: Covered by the AWS Data Processing Agreement (applies to all AWS services).

All AI-generated content — summaries, email drafts, offer texts, and design proposals — is personally reviewed and approved by Rusi before being passed on to you.

12. Email Dispatch

For sending project-related emails, we use a service from Amazon Web Services (AWS). This includes consultation summaries, offers, and invoices.

Provider: Amazon Web Services (AWS)

Data processed: Email address and email content.

Legal basis: Art. 6 para. (1) b GDPR (performance of a contract).

DPA: Covered by the AWS Data Processing Agreement.

Emails are processed exclusively within the EU. No data is transferred to third countries.

We send exclusively project-related emails via this service — no advertising and no newsletters.

13. Client Portal

For project tracking, we provide a personal client portal. It is operated on our own server in Germany — all data remains with us.

Data processed: Project progress, task status, and uploaded files (mood boards, drafts, renders).

Access: You receive a personalised, individual access link. No user account is required. Access is logged (IP address, timestamp).

Legal basis: Art. 6 para. (1) b GDPR (performance of a contract).

14. Accounting

For creating offers, order confirmations, and invoices, we use accounting software.

Provider: Haufe-Lexware GmbH & Co. KG, Freiburg, Germany

Data processed: Name, address, email address, and invoice data.

Purpose: Creation and management of business documents as well as accounting.

Payment: Payment is made exclusively by bank transfer. We do not use any external payment service providers (no PayPal, no Stripe).

Legal basis:

  • Art. 6 para. (1) b GDPR (performance of a contract)
  • Art. 6 para. (1) c GDPR (statutory retention obligations pursuant to HGB and AO)

DPA: Data processing agreement concluded with Haufe-Lexware.

15. Internal Communication (Telegram)

For internal project coordination, we use the messaging service Telegram.

Provider: Telegram, United Arab Emirates

Data processed: In Telegram, we use exclusively highly reduced data:

  • Last name and internal project number (e.g. “Müller (E-1234)”)
  • Project progress and content summaries

Not processed via Telegram: Email addresses, phone numbers, postal codes, scoring data, and full names are never sent via Telegram.

Legal basis: Art. 6 para. (1) f GDPR (legitimate interest in efficient internal communication).

Third-country transfer: Telegram is headquartered in the United Arab Emirates. No adequacy decision from the EU Commission exists for the UAE. The transfer is based on Art. 49 para. 1 subpara. 2 GDPR (compelling legitimate interests). The transfer concerns a limited number of data subjects (exclusively active consultation clients) and is not carried out on a mass scale. We have assessed the necessity and determined that the interests of the data subjects are adequately protected through strict data minimisation. The following protective measures are in place:

  • Strenge Datenminimierung: nur Nachname und interne Projektnummer
  • Email addresses, phone numbers, and postal codes are never sent via Telegram
  • Use within a closed, private group with exclusively internal access
  • Regular review of whether continued use remains necessary
16. Data backups

For data security, we store encrypted backups on offsite storage in Germany.

Provider: Hetzner Online GmbH, Germany

Data processed: Database backups (client data, project data) and files.

Legal basis: Art. 6 para. (1) f GDPR (legitimate interest in data security).

Third-country transfer: No — Hetzner data centres are located exclusively within the EU. No third-country transfer takes place.

Storage: Backups follow a rolling retention policy. Deleted data may still be contained in backups until the next rotation.

Encryption: All backups are encrypted client-side before upload and transmitted via a secure connection.

AVV: Data processing agreement concluded with Hetzner Online GmbH in accordance with Art. 28 GDPR.

17. Transfer to third countries

In the context of our services, personal data is transferred to recipients in third countries (outside the EU/EEA). The following table provides an overview:

Service Country Legal basis
Cloudflare USA EU-US Data Privacy Framework (Art. 45 GDPR) + SCCs
Google USA (via Ireland) EU-US Data Privacy Framework (Art. 45 GDPR) + SCCs
OpenAI USA EU-US Data Privacy Framework (Art. 45 GDPR) + SCCs
Meta USA (via Ireland) EU-US Data Privacy Framework (Art. 45 GDPR) + SCCs + consent
Telegram UAE Art. 49 para. 1 subpara. 2 GDPR + data minimisation

The EU-US Data Privacy Framework (DPF) is the adequacy decision of the EU Commission dated 10 July 2023 pursuant to Art. 45 GDPR. All mentioned US providers are certified under the DPF, thus ensuring an adequate level of data protection. In addition, we have agreed Standard Contractual Clauses (SCCs) pursuant to Art. 46 para. 2 lit. c GDPR with all US providers — as an additional safeguard in the event that the adequacy decision should cease to apply.

Note: Amazon Web Services (AWS) is a US-based company; however, data processing takes place exclusively within the EU. No data is transferred to third countries for these services.

18. Storage period and deletion

We store your personal data only for as long as is necessary for the respective purpose or as required by statutory retention periods.

Data category Retention period Basis
Session recordings (clients) 6 months after project completion Consent
Session recordings (non-clients) 3 months after the consultation Consent
Transcripts and AI summaries Project duration + 12 months Consent
Non-converted enquiries 6 months after last contact Legitimate interest
Consultation preparation (briefings) Project duration + 12 months Legitimate interest
Contact details (on business documents) 10 years after last invoice Statutory (§ 147 AO)
Invoices, order confirmations 10 years Statutory (§ 147 AO, § 257 HGB)
Quotes without order placement 6 years Statutory (§ 257 HGB)
Mood boards and design drafts Project duration + 24 months Legitimate interest
Client portal data Project duration + 24 months Legitimate interest
Telegram messages (internal) Project duration + 12 months Legitimate interest
AI quality data Regularly anonymized Legitimate interest
Meta conversion logs (local) 30 days Legitimate interest

Project completion is defined as the point in time when the final invoice has been paid in full. If no contract is concluded, project completion is defined as 6 months after the last contact.

After the retention period expires, your data will be deleted unless statutory retention obligations prevent this. Deleted data may still be contained in encrypted backups until the next rotation.

19. Your rights

You have the following rights with regard to your personal data:

  • Right of access (Art. 15 GDPR): you can find out at any time which data we have stored about you.
  • Right to rectification (Art. 16 GDPR): you can request the correction of inaccurate data.
  • Right to erasure (Art. 17 GDPR): you can request the deletion of your data, unless statutory retention obligations prevent this.
  • Restriction of processing (Art. 18 GDPR): you can request that we restrict the processing of your data.
  • Data portability (Art. 20 GDPR): you can receive your data in a structured, machine-readable format.
  • Right to object (Art. 21 GDPR): you can object at any time to the processing of your data that is based on legitimate interest (Art. 6 para. 1 lit. f GDPR).
  • Withdrawal of consent (Art. 7 para. 3 GDPR): you can revoke a given consent (e.g. for recording or advertising measurement) at any time with effect for the future.

Note on AI processing: No automated individual decision-making within the meaning of Art. 22 GDPR takes place at our company. All AI-generated content is personally reviewed by Rusi before being passed on to you. Should this change in the future, you have the right to human review, to present your point of view, and to contest the decision.

To exercise your rights, please use our contact form.

20. Right of appeal

You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:

The Hessian Commissioner for Data Protection and Freedom of Information (HBDI) Gustav-Stresemann-Ring 1 65189 Wiesbaden https://datenschutz.hessen.de

21. Änderungen dieser Datenschutzerklärung

We update this Privacy Policy as needed — for example, when the legal situation changes or we introduce new services.

Stand: 25. April 2026