Privacy Policy

01

General Information

We take the protection of your personal data seriously. This Privacy Policy explains how we process personal data when you visit our website, contact us through our contact form or communicate with us by email.

Personal data means any information relating to an identified or identifiable natural person.

02

Controllers and Joint Controllership

This website is jointly operated by:

Etonec Consulting GmbH and Etonec Digital Services GmbH jointly determine the purposes and essential means of processing personal data in connection with the operation of this website and the collection and initial handling of website inquiries. They act as joint controllers under Article 26 GDPR for these activities.

The companies allocate their responsibilities as follows:

• Etonec Digital Services GmbH manages the technical operation of the website and the relationships with hosting and other service providers.
• Etonec Digital Services GmbH receives and initially handles contact-form submissions. Only its authorized personnel have access to the submissions.
• Both companies jointly determine the purposes of the website and the collection and handling of inquiries.
• Etonec Digital Services GmbH acts as the primary contact point for data protection inquiries and requests.

Individuals may exercise their data protection rights against either company.

Inquiries may be forwarded to the company whose services are relevant to the request. Any subsequent processing by that company for its own business purposes may take place under its separate responsibility.

The companies document their respective responsibilities in an arrangement pursuant to Article 26 GDPR. The essential elements of that arrangement are described above.

03

Website Hosting and Technical Access Data

Our website is hosted using Cloudflare Pages, a service provided by Cloudflare.

When you visit our website, technical information may be processed to deliver the requested content, maintain website security and ensure reliable operation.

Depending on the technical configuration, this may include:

• IP address
• Date and time of access
• Requested pages and resources
• Browser and operating-system information
• Referring website
• Technical request and response information

The legal basis is Article 6(1)(f) GDPR. Our legitimate interests are the secure, reliable and efficient operation of the website, including protection against technical attacks and misuse.

Technical access data are retained only for as long as necessary for these purposes, subject to the hosting provider's applicable retention settings and legal obligations.

04

Contact Form

You can contact us through the contact form on our website.

When you submit an inquiry, we process the information you provide, which may include your name, company, email address and message.

We use Google Forms to collect inquiries. Responses are stored in Google Forms and a linked Google Sheets spreadsheet and can only be accessed by authorized personnel of Etonec Digital Services GmbH.

Etonec Digital Services GmbH initially processes the inquiries and may selectively forward them to Etonec Consulting GmbH where they concern its services.

The legal basis is:

• Article 6(1)(b) GDPR, where processing is necessary to take steps at your request before entering into a contract or to perform a contract with you.
• Article 6(1)(f) GDPR, for other business inquiries. Our legitimate interest is responding to inquiries and maintaining business relationships.

Contact-form submissions are generally deleted after 24 months of inactivity, unless a longer retention period is necessary due to an ongoing business relationship, applicable legal obligations or the establishment, exercise or defense of legal claims.

05

Communication by Email

When you communicate with us by email, we process your contact details, the contents of your message and relevant communication metadata to handle and respond to your inquiry.

We use Google Workspace for business email and collaboration.

Depending on the nature of the communication, the legal basis is Article 6(1)(b) GDPR or Article 6(1)(f) GDPR. Our legitimate interest is maintaining business communications and responding to inquiries.

Correspondence is retained for as long as necessary for the relevant purpose and applicable legal obligations.

06

Recipients and Service Providers

Depending on the processing activity, personal data may be disclosed to or processed by:

• Cloudflare, for website hosting and infrastructure services
• Google, for Google Forms, Google Sheets and Google Workspace
• Etonec Consulting GmbH or Etonec Digital Services GmbH, where relevant to handling an inquiry
• Professional advisers, where necessary
• Public authorities, where disclosure is legally required

Where external service providers act as processors on our behalf, appropriate data-processing agreements are concluded in accordance with Article 28 GDPR.

We do not sell personal data.

07

International Data Transfers

The use of Cloudflare and Google services may involve processing or transfers of personal data outside the European Economic Area, including the United States.

Where such transfers take place, the applicable requirements of Chapter V GDPR are observed.

Depending on the relevant recipient and transfer, safeguards may include an adequacy decision of the European Commission, including the EU-US Data Privacy Framework for certified recipients, or the European Commission's Standard Contractual Clauses.

You may contact us for further information about the applicable safeguards.

08

Cookies and Similar Technologies

We do not use website analytics or marketing tracking tools.

Our website does not directly embed external videos, social media feeds or comparable third-party content.

Technologies necessary for providing and securing the website may be used where applicable.

Where storing information on, or accessing information from, a user's device requires consent under § 25 TDDDG, we obtain consent before using the relevant technology.

09

External Links

Our website may contain links to third-party websites, including professional networks, external publications and other online services.

When you follow an external link, the respective third party may process personal data under its own privacy policy.

10

Retention and Deletion

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, unless longer retention is required by law or justified by other applicable legal grounds.

Ordinary inactive contact-form inquiries are generally deleted after 24 months. Other data are deleted when no longer required for their respective purposes, subject to applicable retention obligations.

11

Your Data Protection Rights

Subject to the applicable legal requirements, you have the following rights:

• Access (Article 15 GDPR): Request information about personal data we process concerning you.
• Rectification (Article 16 GDPR): Request correction of inaccurate personal data.
• Erasure (Article 17 GDPR): Request deletion of personal data.
• Restriction of processing (Article 18 GDPR): Request restriction of processing.
• Data portability (Article 20 GDPR): Receive your personal data in a structured, commonly used and machine-readable format where the relevant conditions are met.
• Objection (Article 21 GDPR): Object to processing based on legitimate interests for reasons relating to your particular situation.
• Withdrawal of consent (Article 7(3) GDPR): Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal.

To exercise your rights, please contact office@etonec-ds.com.

You may exercise your rights against either joint controller.

12

Right to Lodge a Complaint

You have the right to lodge a complaint with a competent data protection supervisory authority under Article 77 GDPR.

A relevant supervisory authority is:

13

Provision of Personal Data

You are not legally or contractually required to provide personal data merely to browse our website. Certain technical information is necessary to deliver website content.

Providing sufficient contact details and information about your inquiry is necessary for us to respond. Without this information, we may be unable to process your request.

14

Automated Decision-Making

We do not use automated decision-making, including profiling, within the meaning of Article 22 GDPR in connection with this website.

15

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our website, processing activities or applicable legal requirements.

The current version is available on this website.