Privacy Policy

    Last updated: February 10, 2025

    Table of Contents

    Controller

    Martin Twellmeyer
    Weinmeisterstr. 12
    10178 Berlin
    Germany

    Email: martin.twellmeyer@whu.edu
    Imprint: https://www.the-negronist.com/imprint

    Overview of Processing

    The following overview summarizes the types of data processed and refers to the data subjects.

    Types of Data Processed

    • Inventory data
    • Contact details
    • Content data
    • Usage data
    • Meta/communication data
    • Log data

    Categories of Data Subjects

    • Communication partners
    • Users

    Purposes of Processing

    • Communication
    • Security measures
    • Organization and administration
    • Feedback
    • Provision of online services and user experience
    • IT infrastructure

    Security Measures

    We implement appropriate technical and organizational measures 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 likelihood of occurrence and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

    The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of, and separation of the data. We have also established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and processes in accordance with the principle of data protection by design and by default.

    SSL/TLS encryption (HTTPS): To protect user data transmitted through our online services, we use SSL/TLS encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt information transmitted between the website or app and the user's browser (or between two servers), protecting 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 indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and in encrypted form.

    International Data Transfers

    Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, this will only be done in accordance with legal requirements. Subject to explicit consent or contractually or legally required transfer, we only process or allow data to be processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de).

    Under the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the data protection level for certain companies from the USA as safe by means of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you within the privacy notices which service providers we use are certified under the Data Privacy Framework.

    General Information on Data Storage and Deletion

    We delete personal data that we process when the underlying consent is withdrawn or when there are no longer any legal grounds for processing. This applies in cases where the original purpose of processing ceases to exist or the data is no longer needed. Exceptions to this rule exist when statutory obligations or special interests require longer retention or archiving of the data.

    In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal enforcement or 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 applies to certain processing operations.

    If multiple retention periods or deletion deadlines are specified for a piece of data, the longest period always applies.

    If a period does not explicitly start on a specific date and 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 within which data is stored, the triggering event is the time when the termination or other end of the legal relationship becomes effective.

    Data that is no longer needed for its original purpose but must be retained due to legal requirements or other reasons is processed exclusively for the reasons justifying its retention.

    Additional information on processing procedures, processes, and services:

    • Data retention and deletion: 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 sheet, and the work instructions and other organizational documents necessary for their understanding (§ 147(1) No. 1 in conjunction with (3) AO, § 14b(1) UStG, § 257(1) No. 1 in conjunction with (4) HGB).
      • 8 years - Accounting documents, such as invoices and expense receipts (§ 147(1) No. 4 and 4a in conjunction with (3) sentence 1 AO and § 257(1) No. 4 in conjunction with (4) HGB).
      • 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g., hourly wage slips, plant accounting sheets, calculation documents, price labels, but also payroll accounting documents, insofar as they are not already accounting documents, and cash register tapes (§ 147(1) No. 2, 3, 5 in conjunction with (3) AO, § 257(1) No. 2 and 3 in conjunction with (4) HGB).
      • 3 years - Data necessary to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries, based on previous business experience and common industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

    Provision of Online Services and Web Hosting

    We process users' data to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user's browser or device.

    • Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta-, communication and procedural data (e.g., IP addresses, time information, identification numbers, involved persons); Log data (e.g., log files concerning logins or data retrieval or access times). Content data (e.g., text or visual messages and posts and information concerning them, such as information about authorship or time of creation).
    • Data subjects: Users (e.g., website visitors, users of online services).
    • Purposes of processing: Provision of our online services and user-friendliness; Information technology infrastructure (Operation and provision of information systems and technical devices (computers, servers etc.)). Security measures.
    • Retention and deletion: Deletion according to information in the section "General Information on Data Storage and Deletion".
    • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

    Additional information on processing procedures, processes, and services:

    • Provision of online service on rented storage space: For the provision of our online service, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called "web host"); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).
    • Collection of access data and log files: Access to our online service is logged in the form of so-called "server log files". The server log files may include the address and name of the accessed web pages and files, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and typically 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 case of abusive attacks, so-called DDoS attacks) and to ensure the load and stability of the servers; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
    • Netlify: Hosting and software for creating, providing, and operating websites and web applications; Service provider: Netlify, Inc., 44 Montgomery Street, Suite 300, San Francisco, California 94104, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.netlify.com/; Privacy Policy: https://www.netlify.com/privacy/; Data Processing Agreement: https://www.netlify.com/trust-center/privacy/privacy-shield/. Basis for third country transfers: Data Privacy Framework (DPF).

    Blogs and Publications

    We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within these privacy notices.

    • 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., text or visual messages and posts and information concerning them, such as information about authorship or time of creation); 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, time information, identification numbers, involved persons).
    • Data subjects: Users (e.g., website visitors, users of online services).
    • Purposes of processing: Feedback (e.g., collecting feedback via online form). Provision of our online services and user-friendliness.
    • Retention and deletion: Deletion according to information in the section "General Information on Data Storage and Deletion".
    • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

    Contact Management

    When contacting us (e.g., by mail, contact form, email, telephone, or via social media) as well as in the context of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to respond to the contact inquiries 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., text or visual messages and posts and information concerning them, such as information about authorship or time of creation); 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, time information, identification numbers, involved persons).
    • Data subjects: Communication partners.
    • Purposes of processing: Communication; Organization and administration procedures; Feedback (e.g., collecting feedback via online form). Provision of our online services and user-friendliness.
    • Retention and deletion: Deletion according to information in the section "General Information on Data Storage and Deletion".
    • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Performance of contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

    Additional information on processing procedures, processes, 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 respond to and process the respective inquiry. This typically includes information such as name, contact information, and any additional information provided to us and necessary for appropriate processing; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

    Plugins and Embedded Functions and Content

    We integrate functional and content elements into our online service that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can include, for example, graphics, videos, or city maps (hereinafter uniformly referred to as "content").

    The integration always requires that the third-party providers of this content process the IP address of the users, as they could not send the content to their browsers without the IP address. The IP address is therefore required for the display of this content or functionality. We strive to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain technical information about the browser and operating system, referring websites, visit time, and other details about the use of our online service, as well as being linked with such information from other sources.

    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 consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

    • 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, time information, identification numbers, involved persons).
    • Data subjects: Users (e.g., website visitors, users of online services).
    • Purposes of processing: Provision of our online services and user-friendliness.
    • Retention and deletion: Deletion according to information in the section "General Information on Data Storage and Deletion". Storage of cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods can be stored on users' devices for a period of up to two years).
    • Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

    Additional information on processing procedures, processes, and services:

    • Google Fonts (retrieved from Google server): Retrieval of fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to currentness and loading times, their uniform display, and consideration of possible licensing restrictions. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted that is necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA - When visiting our online service, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent that describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the webpage where the Google font is to be displayed). IP addresses are neither logged on Google servers nor stored, and they are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the respective browser type. The user agent is primarily logged for debugging purposes and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on Google Fonts' "Analytics" page. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on top integrations based on the number of font requests can be generated. According to Google's own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.

    Created with Privacy Policy Generator by Dr. Thomas Schwenke