Privacy Policy
This is an English translation provided for convenience. In case of any discrepancy, the German version (Datenschutzerklärung) is legally binding.
Preamble
With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for which 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 services").
The terms used are not gender-specific.
Last updated: 10 October 2026
Table of contents
- Preamble
- Controller
- Overview of processing operations
- Relevant legal bases
- Security measures
- Transfer of personal data
- International data transfers
- General information on data retention and deletion
- Rights of data subjects
- Provision of the online services and web hosting
- Use of cookies and local storage
- Contact and enquiry management
- Amendments and updates
- Definitions
Controller
HFT-KSA, owner Nico Pohle
Reitzenhainer Straße 3
09322 Penig, Germany
Authorised representatives: Nico Pohle
Email address: nico.pohle@hft-ksa.de
Legal notice (Impressum): https://hft-ksa.de/impressum/?lang=en
Overview of processing operations
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects concerned.
Types of data processed
- Contact data.
- Content data.
- Usage data.
- Meta, communication and procedural data.
- Log data.
Categories of data subjects
- Communication partners.
- Users.
Purposes of processing
- Communication.
- Security measures.
- Organisational and administrative procedures.
- Feedback.
- Provision of our online services and usability.
- Information technology infrastructure.
Relevant legal bases
Relevant legal bases under the GDPR: Below 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 regulations may apply in your or our country of residence or establishment. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.
- Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legitimate interests (Art. 6(1)(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not 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 provisions of the GDPR, national data protection regulations apply in Germany. These include in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains in particular special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual German federal states may apply.
Security measures
In accordance with the legal requirements, and 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 risks of varying likelihood and severity for the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of security appropriate to the risk.
These 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, disclosure, securing of availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data and responses to threats to the data. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in line with the principle of data protection by design and by default.
Securing online connections with TLS/SSL encryption technology (HTTPS): To protect users' data transmitted via our online services against unauthorised 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 against unauthorised access. TLS, as the further developed and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by HTTPS in the URL. This serves as an indicator to users that their data is transmitted securely and in encrypted form.
Transfer of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect 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 occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies (which can be recognised by the postal address of the respective provider or where the privacy policy expressly refers to the data transfer to third countries), this is always done in accordance with the legal requirements.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.
This dual safeguard 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 serve as a reliable fallback option. In this way, we ensure that your data always remains adequately protected, even in the event of any political or legal changes.
For the individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. 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 safeguards apply, in particular standard contractual clauses, explicit consent or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
General information on data retention and deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are withdrawn or there are no further legal bases for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where 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 prosecution or to protect 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 applies specifically to certain processing operations.
Where there are several statements on the retention period or deletion deadlines for a piece of data, the longest period always applies. Data that is no longer retained for its originally intended purpose but due to legal requirements or other reasons is processed by us exclusively for the reasons that justify its retention.
Retention and deletion of data: The following general periods apply to retention and archiving under German law:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the working instructions and other organisational documents required to understand them (Section 147(1) no. 1 in conjunction with (3) AO, Section 257(1) no. 1 in conjunction with (4) HGB).
- 8 years - Accounting vouchers, such as invoices and expense receipts (Section 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO, Section 14b(1) UStG and Section 257(1) no. 4 in conjunction with (4) HGB).
- 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents insofar as they are not already accounting vouchers, and till receipts (Section 147(1) nos. 2, 3, 5 in conjunction with (3) AO, Section 257(1) nos. 2 and 3 in conjunction with (4) HGB).
- 3 years - Data required to take into account potential warranty and damage claims or similar contractual claims and rights, and to process related enquiries, based on previous business experience and common industry practice, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).
Start of the period at the end of the year: If a period does not expressly begin 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 in the context of which data is stored, the event triggering the period is the time at which the termination or other ending of the legal relationship takes effect.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time 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 those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
- Right of access: You have the right to obtain confirmation as to whether data concerning you is being processed and to access this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased without undue delay 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 in accordance with the legal requirements, or to request its transmission to another controller.
- Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR. The complaint may be lodged in particular with a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement.
Provision of the online services and web hosting
We process users' data in order to be able to provide our online services to them. For this purpose, we process the user's IP address, which is necessary to deliver 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 time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. text or image messages and posts and information relating to them, such as details of authorship or time of creation).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online services and usability; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Retention and deletion: Deletion in accordance with the information in the section "General information on data retention and deletion".
- Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
Further information on processing operations, procedures and services:
- Provision of the online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called a "web host"); Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
- Collection of access data and log files: Access to our online services is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. Server log files can be used on the one hand for security purposes, e.g. to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilisation and stability of the servers; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
- Sending and hosting of emails: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as further information relating to the sending of emails (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails on the internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot assume any responsibility for the transmission path of emails between the sender and receipt on our server; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
Use of cookies and local storage
This website currently sets no cookies for visitors and does not use any local browser storage techniques (e.g. local storage or session storage). No user-specific data is collected for tracking, analytics or advertising purposes. All features that would collect such data (e.g. analytics and tracking services, the comment function, externally loaded fonts or embedded third-party content) are disabled. For this reason, we do not use a cookie banner either.
Your language selection (English or German) is not stored on your device. It is determined solely by the address (URL) you visit; the language switcher takes you to the URL of the selected language.
Exception for administrators: Only when administrators of this website log in to the WordPress administration area does WordPress set technically necessary login cookies. These are strictly necessary to provide the service expressly requested by the administrator and therefore do not require consent under Section 25(2) no. 2 TDDDG (German Telecommunications Digital Services Data Protection Act); the legal basis for any related processing of personal data is Art. 6(1)(1)(f) GDPR. This has no effect on visitors to the website.
Should we use cookies or comparable technologies in the future, we will amend this privacy policy accordingly and, where required, obtain your consent in advance.
Contact and enquiry management
When you contact us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the information provided by the enquiring persons is processed to the extent necessary to answer the contact enquiries and any measures requested.
- Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts and information relating to them, such as details of authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via an online form). Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information in the section "General information on data retention and deletion".
- Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR).
Further information on processing operations, procedures and services:
- Contact form: When you contact us via our contact form, by email or through other communication channels, we process the personal data transmitted to us in order to respond to and handle your respective request. This usually includes information such as name, contact information and, where applicable, further information provided to us that is necessary for appropriate handling. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
Amendments and updates
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require any action on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting them.
Definitions
This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.
- Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content 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 persons or organisations. 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.
- Meta, communication and procedural data: Meta, communication and procedural data are categories containing information about the way in which data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, origin and structure of other data. It may include details of file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used to track and verify operations.
- Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data covers a wide range of information showing how users use applications, which features they prefer, how long they stay on certain pages and which paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings.
- 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. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
- 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 performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, analysis, storage, transmission or erasure.
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