Privacy Policy

1. Privacy at a Glance

General Information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data with which you can be personally identified. 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 "Notice on the Responsible Party" section of this privacy policy.

How do we collect your data?

On the one hand, your data is collected when you communicate it to us. This can be, for example, data that you enter when registering for an account or contacting us by email.

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 the page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure the error-free provision of the website. Other data can be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders, or other contract inquiries.

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 a right to demand the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. 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.

2. Hosting and Content Delivery Networks (CDN)

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

Hetzner

The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (hereinafter "Hetzner").

Details can be found in Hetzner's privacy policy: https://www.hetzner.com/legal/privacy-policy/.

The use of Hetzner is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable presentation of our website. If a corresponding consent was requested, the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG (formerly TTDSG), insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Data Processing Agreement (DPA)

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

Cloudflare

We use the "Cloudflare" service. 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 transfer of information between your browser and our website is routed through Cloudflare's network. This enables Cloudflare to analyze data traffic between your browser and our website and to serve as a filter between our servers and potentially malicious traffic from the internet. In doing so, Cloudflare may also use cookies or other technologies for the recognition of internet users, which, however, are used solely for the purpose described here.

We also use Cloudflare R2 object storage for encrypted database backups and related operational storage. Where configured, this processing takes place with EU jurisdiction pins so that stored objects remain in the European Union.

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

Data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission. Details and further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/.

The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA designed to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information can be obtained from the provider under the following link: https://www.dataprivacyframework.gov/participant/5666.

Data Processing Agreement (DPA)

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

3. General Notes and Mandatory Information

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 are collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We point out that data transmission over the Internet (e.g., when communicating via email) may have security gaps. Complete protection of data from access by third parties is not possible.

Notice on the Responsible Party (Data Controller)

The responsible party for data processing on this website is:

Lötz Develop by Roland Theisen

Im Brunnenfeld 8A

66706 Perl, Germany

Phone: +491744281529

Email: info@letzdevelop.com

The responsible party is the natural or legal person who alone or jointly with others decides on 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 specified within this privacy policy, your personal data will remain with us until the purpose for processing the data 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 retention periods); in the latter case, deletion will take place after these reasons cease to apply.

General Notes 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 according to Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is additionally based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access information in your terminal device (e.g., via device fingerprinting), data processing is additionally based on § 25(1) TDDDG. Consent can be revoked at any time.

If your data is required for the fulfillment of a contract or 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 it is required to fulfill 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. Information on the respective legal bases in individual cases is provided in the following paragraphs of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we work with various external bodies. In some cases, it is also necessary to transfer personal data to these external bodies. We only pass on personal data to external bodies if this is necessary within the scope of contract fulfillment, 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 passing it on, or if another legal basis permits the transfer of data. When using processors, we only pass on our customers' personal data on the basis of a valid contract on data processing (DPA). In the case of joint processing, a joint controllership 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 you have already given at any time. The legality of the data processing carried out up to the revocation remains unaffected by the revocation.

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

IF DATA PROCESSING IS BASED ON ART. 6(1)(e) OR (f) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE, OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a 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 to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment 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 the data to another controller, this will only be done to the extent that it is technically feasible.

Information, Rectification, and Erasure

Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipient, and the purpose of data processing and, if applicable, a right to correction 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 to do this. The right to restriction of processing exists in the following cases:

If you contest the accuracy of your personal data stored by us, we usually 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 unlawful, you can request the restriction of data processing instead of deletion.

If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request 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 is not yet clear 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 – apart from its storage – may only be processed with your consent or for the establishment, exercise, or defense 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 or TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize 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.

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

4. Data Collection on This Website

Cookies

Our internet pages use so-called "cookies". Cookies are small data packages and do not cause any damage to your terminal device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your terminal device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your terminal device until you delete them yourself or until 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. On this website, cookies are used primarily for authentication and session management via Auth.js (NextAuth). These session cookies are technically necessary so that you can stay signed in and use protected areas of the platform. Other cookies may be set by payment providers during checkout.

Cookies that are required to carry out the electronic communication process, to provide certain functions you desire (e.g., Auth.js session cookies for login), or to process payments (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR or Art. 6(1)(b) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and secure provision of its services. If consent to the storage of cookies and comparable recognition technologies was requested, processing takes place exclusively on the basis of this consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); the consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

If other cookies and services are used on this website, you can find this out in this privacy policy.

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

Hostname 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 optimization of its website – for this purpose, the server log files must be recorded.

Inquiry by Email, Phone, or Fax

If you contact us by email, phone, or fax, your inquiry including all personal data resulting from it (name, inquiry) will be stored and processed by us for the purpose of processing 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 inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this was requested; consent can be revoked at any time.

The data sent to us by you via contact inquiries 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 completion of your request). 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 purpose of using 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 in the scope of the offer or in the case of technically necessary changes, we will use the email address provided during registration to inform you in this way.

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

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

Registration and sign-in on this website use email and password credentials via Auth.js (NextAuth). Optionally, when enabled by the operator, you may also sign in with Google Sign-In (OAuth). In that case, Google transmits basic account data (such as your name, email address, and profile image) to us so we can create or authenticate your account. Use of Google Sign-In is voluntary; you can always register with email and password instead. Google's processing of your data is governed by Google's privacy policy: https://policies.google.com/privacy.

Google Sign-In (Optional OAuth)

If Google Sign-In is enabled, authentication is handled by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When you choose "Continue with Google", you are redirected to Google to authenticate. We receive an OAuth token and profile information required to create or link your QResponse account. Legal basis: Art. 6(1)(b) GDPR (performance of the user contract) and, where applicable, Art. 6(1)(a) GDPR (your choice to use this login method). Data transfer to the USA may occur; Google is certified under the EU-US Data Privacy Framework where applicable.

5. Plugins and Tools

Google Fonts (Local Hosting)

This site uses so-called Google Fonts, provided by Google, for the uniform display of fonts. The Google Fonts are installed locally. A connection to Google servers does not take place.

Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google's privacy policy: https://policies.google.com/privacy?hl=en.

Nuntly (Transactional Emails)

We use the email delivery service Nuntly on this website. The provider is Nuntly (Olivier Bazoud), 5 Villa Verges, 92320 Châtillon, France (hereinafter "Nuntly").

Nuntly is used to reliably transmit transactional, platform-related emails to our registered users (e.g., system updates, confirmation links, security alerts, and subscription details). For this purpose, personal data such as your email address, system notification contents, and associated delivery metadata (e.g., timestamps, delivery status) are transmitted to and processed on Nuntly's infrastructure.

As Nuntly is an EU-based provider, all core email data, message contents, and routing logs are hosted and processed strictly within the territory of the European Union (AWS EU regions in Frankfurt/Dublin). Nuntly does not transfer transactional email contents or recipient records to third countries such as the USA.

The use of Nuntly is based on Art. 6(1)(b) GDPR (performance of our contractual obligations under our platform terms) and Art. 6(1)(f) GDPR (our legitimate interest in ensuring secure, automated, and legally compliant delivery of system-critical email traffic).

For more details on Nuntly's data protection practices, please refer to Nuntly’s privacy policy: https://nuntly.com/legal/privacy-policy.

Data Processing Agreement (DPA)

We have entered into a Data Processing Agreement (DPA) with Nuntly. This contract guarantees that Nuntly processes all customer and transaction data exclusively in accordance with our instructions and in strict compliance with European GDPR standards.

IP2Location (Scan Geolocation)

When someone scans a QR code managed through QResponse, we may resolve the approximate geographic location of the scan (country, region, and city) from the visitor's IP address. This supports routing rules and scan analytics for our business customers. We do not use this data for advertising profiling of end visitors.

For this purpose we use the geolocation service IP2Location.io provided by Hexasoft Development Sdn. Bhd. (hereinafter "IP2Location"). The visitor's IP address is transmitted to IP2Location's API so that country/region/city metadata can be returned. We store the resulting location fields with the scan event; we do not store a full reverse-geolocation profile beyond what is needed for analytics and routing.

Processing is based on Art. 6(1)(f) GDPR (legitimate interest in providing location-aware QR routing and aggregate scan analytics for our customers) and, where the scan relates to a customer contract, Art. 6(1)(b) GDPR.

Further information: https://www.ip2location.io/ and the provider's privacy documentation at https://www.ip2location.com/privacy-policy.

6. eCommerce and Payment Providers

Processing of Customer and Contractual Data

We collect, process, and use personal customer and contractual data for the establishment, structuring of content, and amendment of our contractual relationships. We collect, process, and use personal data about the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill the user. The legal basis for this is Art. 6(1)(b) GDPR.

The collected customer data will be 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 Transmission upon Conclusion of Contract for Services and Digital Content

We transmit personal data to third parties only if this is necessary within the scope of contract processing, for example, to the credit institution commissioned with payment processing.

A further transmission of the data does not take place or only takes place if you have expressly consented to the transmission. Your data will not be passed on to third parties without 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 fulfillment 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) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. 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 services / payment service providers within the scope of 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/privacy and https://stripe.com/guides/general-data-protection-regulation.

Details on this can be read in Stripe's privacy policy under the following link: https://stripe.com/privacy.