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Privacy policy

This page explains what personal data is processed when you visit this website, why, and what rights you have. In short: this website does not use cookies; traffic is measured only cookie-free and without profiling, using Cloudflare Web Analytics. The only data processed is what is technically required to deliver the pages, the traffic measurement and whatever you send yourself through the enquiry form.

1. Controller

Michael Engel
Rietheimer Str. 32
78050 Villingen-Schwenningen, Germany
Email: Ing.michael.engel@proton.me

No data protection officer has been appointed, as there is no legal requirement to do so.

2. Hosting and delivery by Cloudflare

This website is hosted on Cloudflare Pages and delivered through Cloudflare’s network. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. Cloudflare is a US company.

What data: When you open a page, Cloudflare necessarily receives connection data: your IP address, date and time, the requested URL, the amount of data transferred, the referring page (if your browser sends it), and your browser type and operating system.

Purpose: to deliver the website, secure the connection and fend off attacks.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is to provide the website reliably and securely.

Data processing agreement: Cloudflare processes this data on our behalf under its Customer Data Processing Addendum pursuant to Art. 28 GDPR.

Transfers to the USA: Processing may take place on servers in the USA and other countries outside the EU. Cloudflare is certified under the EU-U.S. Data Privacy Framework, so the European Commission’s adequacy decision of 10 July 2023 applies (Art. 45 GDPR). The data processing agreement additionally provides for the European Commission’s Standard Contractual Clauses (Art. 46(2)(c) GDPR).

Retention: We do not analyse or store access logs ourselves. Cloudflare determines how long it retains connection data; according to Cloudflare, this depends on the purpose of processing and legal obligations.

For details, see Cloudflare’s privacy policy: https://www.cloudflare.com/privacypolicy/

3. No cookies, no advertising, little third-party content

This website does not use cookies and does not store anything else in your browser. According to Cloudflare, Cloudflare Web Analytics uses neither cookies nor local storage. It uses no advertising networks and no tools that follow you across websites. Third-party servers are contacted for two purposes only: traffic measurement (section 5, on all pages) and the spam check in the enquiry form (section 4, on the contact page only). Both are provided by Cloudflare. Otherwise the site loads no fonts, scripts or other content from third-party servers. Videos and other external content are linked, not embedded. Light or dark mode follows your device settings.

Search: The search function runs in your browser, which fetches parts of the search index from this website as needed. This only involves the connection data described in section 2.

4. Enquiry form

On the contact page you can write to us using a form.

What data: your name, email address, your message and the language of the page you write from. Optional are an organisation and a topic selection. In addition, the connection data described in section 2 is processed.

Purpose: to answer your enquiry.

Legal basis: Art. 6(1)(b) GDPR if your enquiry aims at a contract or pre-contractual steps, otherwise Art. 6(1)(f) GDPR. Our legitimate interest is to answer enquiries.

Forwarding by email: The website itself does not store your details. A function on Cloudflare Pages receives the form and forwards it through Cloudflare Email Service as an email to our mailbox with Proton AG (provider and basis: see section 6). According to Cloudflare, message content is not stored by default; only delivery data (status, timestamps) is logged.

Retention: Nothing is stored on the website. Enquiries are deleted once they have been dealt with, after two years at the latest, unless statutory retention obligations apply.

Spam protection (Cloudflare Turnstile): The form is protected against automated submissions by Cloudflare Turnstile. Turnstile is loaded on the contact page only, from challenges.cloudflare.com, and does not read the contents of the form. According to Cloudflare, Cloudflare processes the following signals: IP address, TLS fingerprint, User-Agent, sitekey and origin. Cloudflare acts in two roles: it processes the signals as processor (Auftragsverarbeiter) to provide spam and bot protection, and as independent controller (eigener Verantwortlicher) to improve its own bot detection (see the Turnstile privacy addendum: https://www.cloudflare.com/turnstile-privacy-policy/). The provider is Cloudflare, Inc. (see section 2 on transfers to the USA). The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest is protection against spam and abuse. No consent banner is needed: access to device information is limited to what is strictly necessary to provide the form submission you request (Section 25(2) no. 2 TDDDG).

5. Cloudflare Web Analytics

We measure how often pages are viewed so that we can see which content is used and whether the site loads quickly. For this we use Cloudflare Web Analytics from Cloudflare, Inc. (address: see section 2). A small script is loaded from static.cloudflareinsights.com and sends measurements to Cloudflare.

What data: According to Cloudflare, Web Analytics collects page load and performance timing metrics, the page visited and the referring page (referrer). Cloudflare states that it does not identify individuals by IP address or browser identifier and does not track you across websites.

No cookies, no fingerprinting: According to Cloudflare, Web Analytics uses no cookies, no local storage and no fingerprinting. We build no profiles.

Retention: According to Cloudflare, unsampled data is kept for 7 days and then aggregated.

Sources: https://www.cloudflare.com/web-analytics/, https://developers.cloudflare.com/web-analytics/faq/

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is to run the website according to demand and in good technical order. You may object to this processing under Art. 21 GDPR (see section 8).

Data processing and USA: as in section 2.

6. Contact by email

If you email us, we process your email address, your name (if provided) and the content of your message in order to respond. The legal basis is Art. 6(1)(f) GDPR, or Art. 6(1)(b) GDPR for enquiries relating to a contract. We delete your message once your enquiry has been dealt with, unless statutory retention obligations apply. Emails are stored with our email provider, Proton AG, Route de la Galaise 32, 1228 Plan-les-Ouates, Switzerland, which processes them on our behalf (Art. 28 GDPR). The European Commission has recognised Switzerland as providing an adequate level of data protection (adequacy decision 2000/518/EC, Art. 45 GDPR).

Articles link to sources on other websites. No data is transferred to those providers unless you click a link. Once you do, their privacy policy applies. Our links are set up so that your browser does not tell the destination site which of our pages you came from (no referrer is sent).

8. Your rights

You have the right to

Right to object (Art. 21 GDPR): You may object at any time, on grounds relating to your particular situation, to processing based on Art. 6(1)(f) GDPR.

To exercise any of these rights, simply email the address above.

Right to lodge a complaint (Art. 77 GDPR): You may lodge a complaint with a data protection supervisory authority. The authority responsible for us is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg (State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg)
Postfach 10 29 32, 70025 Stuttgart, Germany
Website: https://www.baden-wuerttemberg.datenschutz.de

9. Obligation to provide data; automated decisions

You are not obliged to provide any data. Without the connection data described in section 2, however, the website cannot be delivered. No automated decision-making or profiling takes place.

10. Changes

If the website or the services used change, we will update this policy. The version published here applies.