Privacy Policy

1. Privacy at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the section "Notice Concerning the Data Controller" in this privacy policy.

How do we collect your data?

Some data is collected when you provide it to us. This could, for example, be data you enter in a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure error-free provision of the website. Other data may be used to analyse your user behaviour. If contracts can be concluded or initiated via the website, the transmitted data is also processed for contract offers, orders, or other enquiries.

What rights do you have regarding your data?

You have the right to receive information about the origin, recipient, and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and other questions on the subject of data protection.

Analytics Tools and Third-Party Tools

When visiting this website, your browsing behaviour may be statistically analysed. This is done primarily with so-called analytics programs. Detailed information about these analytics programs can be found in the following privacy policy.

2. Hosting and Content Delivery Networks

We host the contents of our website with the following provider:

External Hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host. This may include, but is not limited to, IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access, and other data generated via a website.

External hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast, and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act), insofar as the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Our host will only process your data to the extent necessary to fulfil its service obligations and will follow our instructions with regard to this data.

We use the following host:

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures the provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

Cloudflare

We use the service "Cloudflare". The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter "Cloudflare").

Cloudflare offers a globally distributed Content Delivery Network with DNS. Technically, the information transfer between your browser and our website is routed through Cloudflare's network. This enables Cloudflare to analyse the data traffic between your browser and our website and to act as a filter between our servers and potentially malicious traffic from the internet. Cloudflare may also use cookies or other technologies for recognising internet users, which are used solely for the purpose described here.

The use of Cloudflare is based on our legitimate interest in providing our website as error-free and securely as possible (Art. 6(1)(f) GDPR).

Data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission. Details can be found here: https://www.cloudflare.com/privacypolicy/.

The company is certified under the "EU-US Data Privacy Framework" (DPF). More information can be found at: https://www.dataprivacyframework.gov/participant/5666.

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures the provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

3. General Information and Mandatory Disclosures

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.

We would like to point out that data transmission over the internet (e.g. when communicating by email) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Notice Concerning the Data Controller

The data controller responsible for data processing on this website is:

Email: [email protected]
Phone: +49 5145 3479490

The data controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage Duration

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, deletion will take place after these reasons cease to apply.

General Information on the Legal Basis for Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, if special categories of data are processed pursuant to Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your device (e.g. via device fingerprinting), data processing is additionally carried out on the basis of Section 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act). Consent can be revoked at any time. If your data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if this is necessary to fulfil a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. The relevant legal bases in each individual case are explained in the following paragraphs of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we work with various external parties. In some cases, the transfer of personal data to these external parties is necessary. We only pass on personal data to external parties if this is necessary for the fulfilment of a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest pursuant to Art. 6(1)(f) GDPR in the transfer, or if another legal basis permits the data transfer. When using data processors, we only pass on personal data of our customers on the basis of a valid Data Processing Agreement. In the case of joint processing, a joint processing agreement is concluded.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You can revoke consent that has already been given at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have a right of complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged violation. The right of complaint exists without prejudice to any other administrative or judicial remedy.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of data to another controller, this will only be done insofar as it is technically feasible.

Access, Rectification, and Deletion

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, where applicable, a right to rectification or deletion of this data. You can contact us at any time regarding this and other questions on the subject of personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

• If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of deletion.
• If we no longer need your personal data, but you need it for the exercise, defence, or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
• If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may -- apart from its storage -- only be processed with your consent or for the assertion, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

SSL/TLS Encryption

This site uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content, such as enquiries you send to us as the site operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

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

4. Data Collection on This Website

Cookies

Our websites use so-called "cookies". Cookies are small data packets that do not cause any damage to your device. They are stored either temporarily for the duration of a session (session cookies) or permanently (persistent cookies) on your device. Session cookies are automatically deleted after your visit ends. Persistent cookies remain stored on your device until you delete them yourself or they are automatically deleted by your web browser.

Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them. Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are required to carry out the electronic communication process, to provide certain functions you have requested, or to optimise the website (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG); consent can be revoked at any time.

You can set your browser to inform you about the setting of cookies and to allow cookies only on a case-by-case basis, to exclude the acceptance of cookies for certain cases or in general, and to activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

The following table shows the cookies used on this website:

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address

This data is not merged with other data sources.

The collection of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website -- for this purpose, server log files must be collected.

Contact Form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact data you provided there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR if your enquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions -- in particular retention periods -- remain unaffected.

Enquiry by Email or Phone

If you contact us by email or phone, your enquiry including all resulting personal data (name, enquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR if your enquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.

The data you send to us via contact enquiries will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions -- in particular statutory retention periods -- remain unaffected.

Registration on This Website

You can register on this website to use additional functions on the site. We use the data entered for this purpose only for the use of the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject the registration.

For important changes, such as changes to the scope of the offer or technically necessary changes, we use the email address provided during registration to inform you in this way.

The data entered during registration is processed for the purpose of implementing the user relationship established by the registration and, where applicable, for the initiation of further contracts (Art. 6(1)(b) GDPR).

The data collected during registration is stored by us for as long as you are registered on this website and is subsequently deleted. Statutory retention periods remain unaffected.

5. Analytics & Tracking

Google Ads Conversion Tracking

We use Google Ads conversion tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

With the help of Google Ads conversion tracking, we can determine whether a user has completed certain actions. This allows us to measure the effectiveness of our advertisements and evaluate them for statistical and market research purposes.

The Google tag (gtag.js) is only loaded after you have given your consent via our cookie banner. Without your consent, no tracking takes place. Upon granting consent, the cookies _gcl_aw and _ga may be set. The storage duration is up to 2 years.

The use is based on Art. 6(1)(a) GDPR and Section 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act). Consent can be revoked at any time via the "Cookie Settings" link in the footer of our website.

Data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission and the EU-US Data Privacy Framework. Google LLC is certified under the EU-US Data Privacy Framework.

For more information, see Google's privacy policy: https://policies.google.com/privacy.

Umami Analytics

We use Umami Analytics for statistical analysis of website usage. The provider is Umami Software, Inc. Data is processed on servers in the EU (Umami Cloud).

Umami does not set cookies and does not perform cross-device tracking. When a page is loaded, your IP address is transmitted to Umami Cloud and processed to determine your approximate location (country/region). The IP address is not stored in plain text; all collected data is anonymised so that individual visitors cannot be identified.

The use is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the anonymised analysis of user behaviour to optimise our website.

For more information, see Umami's privacy policy: https://umami.is/privacy.

6. Error Analysis and Logging

Analysis of Log Files and Error Traces

We analyse log files and error traces from our systems to detect technical issues, ensure the stability of our services, and improve the user experience. This may involve the processing of technical data such as IP addresses, browser information, error messages, and timestamps.

This data is processed exclusively on our own infrastructure within the EU. No data is shared with third parties.

Processing is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the technically error-free provision and optimisation of our services.

7. Payment Providers

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data to establish, structure, and modify our contractual relationships. We collect, process, and use personal data about the use of this website (usage data) only insofar as this is necessary to enable the user to use the service or to bill for it. The legal basis for this is Art. 6(1)(b) GDPR.

The collected customer data is deleted after completion of the order or termination of the business relationship and expiry of any existing statutory retention periods. Statutory retention periods remain unaffected.

Data Transfer Upon Contract Conclusion for Services and Digital Content

We only transfer personal data to third parties if this is necessary for contract processing, for example to the credit institution entrusted with payment processing.

No further transfer of data takes place, or only if you have expressly consented to the transfer. Your data will not be passed on to third parties without your express consent, for example for advertising purposes.

The basis for data processing is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.

Payment Services

We integrate payment services from third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank details, credit card number) is processed by the payment service provider for the purpose of payment processing. The respective contractual and data protection provisions of the respective providers apply to these transactions. The use of payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment process (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent can be revoked at any time for the future.

We use the following payment service on this website:

Stripe

The provider for customers within the EU is Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter "Stripe").

Data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission. Details can be found here: https://stripe.com/de/privacy and https://stripe.com/de/guides/general-data-protection-regulation.

For details, please refer to Stripe's privacy policy at the following link: https://stripe.com/de/privacy.

8. Data Processing in the Easy Mail Archive Service

Scope and Role

This section describes data processing within the cloud service "Easy Mail Archive" (hereinafter "Service"), accessible at app.easymailarchive.com. Sections 1–7 above apply to the use of our website; this section supplements them with processing carried out within the Service.

Insofar as we archive, process, and store email data on behalf of our customers, we act as a data processor within the meaning of Art. 28 GDPR. The customer is the data controller for the email data archived on their behalf. This is governed by a Data Processing Agreement (DPA) to which the customer agrees during account setup.

For the processing of account data (registration, authentication), we act as data controller within the meaning of Art. 4(7) GDPR.

Categories of Data Processed

The following categories of data are processed within the Service:

• Account data: Email address, password (hashed), full name, company name. Legal basis: Art. 6(1)(b) GDPR (contract fulfilment).
• Archived email data: Raw email files (.eml) including content and attachments, parsed metadata (sender, recipient, subject, date), and search index. Legal basis: Art. 6(1)(b) GDPR in conjunction with Art. 28 GDPR (data processing on behalf of the controller).
• Audit log data: Logging of all user actions (searches, email access, exports, logins and logouts) with timestamps and user identifiers. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in traceability and compliance) and Art. 6(1)(c) GDPR (legal retention obligations, e.g. GoBD, HGB).
• Authentication data: Login events, two-factor authentication, SSO/OIDC session data. Legal basis: Art. 6(1)(b) GDPR (contract fulfilment) and Art. 6(1)(f) GDPR (legitimate interest in security).

How Email Data is Collected

Email data enters the Service via two methods:

• IMAP import: The Service retrieves emails from the customer's mail server. The customer configures and authorises the connection.
• SMTP journaling: The customer sets up a journal or BCC rule on their mail server that forwards emails to the Easy Mail Archive infrastructure.

In both cases, the customer initiates and controls the data transfer.

Storage, Encryption, and Tenant Isolation

All Service data is stored on the infrastructure of WIIT AG in Dusseldorf, Germany (see Section 2).

• Email content: Raw .eml files are encrypted at rest using AES-256.
• Metadata and search index: Stored unencrypted to enable queries and full-text search.
• Tenant isolation: Each customer receives their own isolated database. Access to other customers' data is technically impossible.
• Transport encryption: All data transfers are encrypted via TLS.

Sub-processors

We do not use any sub-processors for the processing of email data. All data processing takes place on our own infrastructure at WIIT AG. Transactional emails (e.g. password resets) are sent via our own mail server.

Data Retention and Deletion

Archived email data is retained for as long as the customer's account exists. The customer can delete their data from the system at any time.

Following termination of the contractual relationship, the customer has 30 days to export their archived data. After this period, all customer data is irrevocably deleted. The customer bears sole responsibility for compliance with any continuing statutory retention obligations.

Account data is deleted after the account is closed and any statutory retention periods have expired.

Data Subject Rights for Archived Emails

Individuals whose emails are archived within the Service should contact the respective customer (data controller), not Easy Mail Archive directly. We assist our customers in fulfilling data subject requests in accordance with the Data Processing Agreement.

Technical and Organisational Measures

We implement the following measures to protect the data processed:

• AES-256 encryption for email content at rest
• TLS encryption for all data transfers
• Strict tenant isolation through separate databases per customer
• Comprehensive audit logging of all user access
• Support for SSO/OIDC and two-factor authentication
• Hosting in an ISO 27001 certified data centre

9. Business Transfers and Successor Entities

The Provider is entitled to transfer the operation of the Service and the associated contractual relationships to a successor entity (UG or GmbH) in which Martin Becker holds a majority ownership interest.

In the event of such a transfer, personal data (account data, billing data, archived email data) will be transferred to the successor entity insofar as this is necessary for the continuation of the Service. The legal basis is Art. 6(1)(b) GDPR (contract fulfilment) and Art. 6(1)(f) GDPR (legitimate interest in business continuity).

The nature and scope of data processing, the technical and organisational safeguards, and the rights of data subjects remain unaffected by any such transfer.

Customers will be notified by email at least 30 days before any transfer and may terminate the contract for cause with effect from the date of transfer.