Privacy Policy

Protecting your personal data is important to us. In the following, we inform you in accordance with Articles 13 and 14 of the General Data Protection Regulation (GDPR) which personal data we process when you visit this website, for which purposes and on what legal basis.

1. Controller

The controller within the meaning of the GDPR is:

Pragmatic Technologies GmbH (in formation / in Gründung), Pappelallee 64, 10437 Berlin, Germany

Represented by its Managing Director, Philipp Decurtins. Email: [email protected].

2. Data protection officer

We are not legally required to appoint a data protection officer and have therefore not designated one. For any data protection questions, you can reach us at [email protected].

3. Your rights as a data subject

With regard to the personal data concerning you, you have the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object to processing (Art. 21 GDPR)
• Right to withdraw a given consent at any time with effect for the future (Art. 7 (3) GDPR)

You also have the right to lodge a complaint about the processing of your personal data with a data protection supervisory authority (Art. 77 GDPR). The authority competent for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59–61, 10555 Berlin, Germany.

4. Right to object (Art. 21 GDPR)

Insofar as we process personal data on the basis of legitimate interests (Art. 6 (1)(f) GDPR), you have the right to object to this processing at any time on grounds relating to your particular situation. We will then no longer process the data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

5. Visiting our website and server log files

When you access this website, your device's browser automatically sends information to the server of our hosting provider and stores it temporarily in so-called log files. The following is recorded in particular:

• the IP address of the requesting device
• the date and time of access
• the name and URL of the file retrieved
• the website from which access is made (referrer URL)
• the browser used and the operating system

This processing serves to ensure a smooth connection, the convenient use of the website and the evaluation of system security and stability. The legal basis is our legitimate interest in the technical provision and security of the website (Art. 6 (1)(f) GDPR).

6. Hosting and content delivery network (Cloudflare)

This website is delivered via the infrastructure and content delivery network of Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. On our behalf, Cloudflare processes, among other things, the server log data mentioned above and your IP address in order to deliver the content of our website, ensure its security (e.g. defending against attacks) and accelerate delivery.

The legal basis is our legitimate interest in the secure and efficient provision of our website (Art. 6 (1)(f) GDPR). We have concluded a data processing agreement with Cloudflare in accordance with Art. 28 GDPR. As personal data may be transferred to the USA in this context, this transfer is based on Cloudflare's certification under the EU-U.S. Data Privacy Framework (Art. 45 GDPR) and, additionally, on the European Commission's Standard Contractual Clauses (Art. 46 GDPR).

For more information, see Cloudflare's privacy policy.

7. Consent and cookies

Insofar as we use cookies or comparable technologies, or use services that store or read information on your device, we obtain your prior consent for this via a consent banner – unless this is technically necessary. The legal basis is § 25 (1) TDDDG in conjunction with Art. 6 (1)(a) GDPR. Your consent is voluntary and can be withdrawn at any time with effect for the future, for example via the settings of the consent banner. Technically necessary cookies that are required to operate the website are exempt from consent under § 25 (2) TDDDG; the associated processing is based on our legitimate interest (Art. 6 (1)(f) GDPR). You can adjust or withdraw your choice at any time via the Cookie settings button at the bottom of this page.

8. Google Analytics

This website uses – exclusively after your consent – Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Google). Google Analytics uses cookies and similar technologies to analyse the use of our website (e.g. pages visited, time spent, approximate location, device used). The information generated is generally transferred to and stored on Google servers; this may involve a transfer to Google LLC in the USA.

The legal basis is your consent pursuant to § 25 (1) TDDDG and Art. 6 (1)(a) GDPR. Processing only takes place after you have given your consent via the consent banner; you can withdraw your consent at any time with effect for the future. For the data transfer to the USA, we rely on Google's certification under the EU-U.S. Data Privacy Framework and, additionally, on the European Commission's Standard Contractual Clauses.

For more information, see Google's privacy policy.

9. Google Tag Manager

To manage the tags used on our website (such as Google Analytics), we use Google Tag Manager provided by Google Ireland Limited. Google Tag Manager serves to manage and deploy other services and does not itself set analytics or tracking cookies. However, when Tag Manager loads, a connection to Google's servers is established and your IP address is processed. Services triggered via Tag Manager that process personal data are only activated after your consent (§ 25 (1) TDDDG, Art. 6 (1)(a) GDPR).

10. YouTube videos

On individual pages we embed videos from the YouTube platform (provider: Google Ireland Limited). The videos are embedded in extended data protection mode via the youtube-nocookie.com domain. Before you give consent, no data whatsoever is transmitted to YouTube or Google – in particular, no preview image is loaded from Google servers; you initially see a neutral placeholder. A video is only loaded once you accept the External media category via our consent banner or actively click to load the specific video. Only then is a connection to YouTube's or Google's servers established and your IP address transmitted.

By activating a video – whether by consenting in the banner or by actively clicking to load it – you consent to the associated data processing by YouTube. The legal basis is your consent pursuant to § 25 (1) TDDDG and Art. 6 (1)(a) GDPR. You can withdraw your consent at any time with effect for the future, for example via the Cookie settings button. Here too, a transfer to the USA may occur, based on the EU-U.S. Data Privacy Framework and, additionally, on the Standard Contractual Clauses. For more information, see Google's privacy policy.

11. Newsletter (Brevo)

If you sign up for our newsletter, we process the data you provide (in particular your email address and, where applicable, your name) in order to send you the newsletter. Registration takes place using the double opt-in procedure: after signing up, you receive an email in which you must confirm your registration. This ensures that the registration was actually made by you.

The legal basis for sending the newsletter is your consent pursuant to Art. 6 (1)(a) GDPR. You can unsubscribe from the newsletter and withdraw your consent at any time, for example via the unsubscribe link in every newsletter email. To document the registration, we store the time of registration and confirmation as well as your IP address; the legal basis for this is our legitimate interest in being able to demonstrate that consent was duly given (Art. 6 (1)(f) GDPR).

For sending, we use the Brevo service provided by Sendinblue SAS, 17 rue Salneuve, 75017 Paris, France. Brevo processes your data on our behalf on the basis of a data processing agreement pursuant to Art. 28 GDPR within the European Union. For more information, see Brevo's privacy policy.

12. Appointment booking and demo requests

Via our website you can arrange an appointment for a product demonstration (demo) or a conversation. For scheduling and conducting the appointment, we use the following services:

• Google Calendar / appointment scheduling – Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
• Microsoft 365 Bookings – Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland

When you make a booking, we process the data you provide, in particular your name, your email address, where applicable your telephone number and company, as well as any details you share about your request and the appointment slot you select. We use this data exclusively to plan, conduct and follow up on the agreed appointment.

The legal basis is the performance of pre-contractual measures at your request and the initiation of a contractual relationship (Art. 6 (1)(b) GDPR), as well as our legitimate interest in efficient appointment organisation (Art. 6 (1)(f) GDPR). The aforementioned providers process the data as processors on the basis of agreements pursuant to Art. 28 GDPR. Insofar as data is transferred to the USA, this is based on the EU-U.S. Data Privacy Framework and, additionally, on the European Commission's Standard Contractual Clauses. For more information, see the privacy policies of Google and Microsoft.

13. Contacting us by email

If you contact us by email – for example at [email protected] – we process the data you provide (your email address, your name and the content of your message) in order to handle your request. The legal basis is Art. 6 (1)(b) GDPR insofar as your request is aimed at concluding or performing a contract, and otherwise our legitimate interest in responding to your enquiry (Art. 6 (1)(f) GDPR). We delete this data as soon as it is no longer required to achieve the purpose for which it was collected, unless statutory retention obligations prevent this.

14. Retention period

We process and store personal data only for as long as is necessary to fulfil the respective purposes or as required by statutory retention periods (e.g. commercial and tax law obligations). Once the respective purpose ceases to apply or these periods expire, the data is deleted.

15. Data security

We take appropriate technical and organisational measures to protect your data against loss, destruction, manipulation and unauthorised access. This website uses TLS/SSL encryption, recognisable by the padlock symbol in your browser and by the address bar beginning with https://. Our fonts are served locally from our own server; external font services (e.g. Google Fonts) are not used.

16. Recipients of the data

The recipients of your personal data are the service providers named in this policy, whom we engage as processors in accordance with Art. 28 GDPR and on our instructions (in particular for hosting, web analytics, newsletter delivery and appointment booking). We only pass data to other third parties where we are legally obliged to do so or where this is necessary to assert, exercise or defend legal claims. We do not sell your data.

17. International data transfers

Some of the services we use are provided by providers based or with servers in the USA (in particular Cloudflare, Google and Microsoft). Insofar as personal data is transferred to the USA or other third countries, this takes place on the basis of an adequacy decision (EU-U.S. Data Privacy Framework, Art. 45 GDPR) for correspondingly certified providers and, additionally, on the basis of the European Commission's Standard Contractual Clauses (Art. 46 GDPR). You can request a copy of the Standard Contractual Clauses at [email protected]. Our newsletter provider Brevo (Sendinblue SAS) processes your data within the European Union.

18. Obligation to provide personal data

The provision of your personal data is neither legally nor contractually required; you are not obliged to provide us with data. However, without the respective necessary data we cannot handle certain requests – for example an appointment booking, the sending of the newsletter or responding to an enquiry.

19. Automated decision-making

No automated decision-making, including profiling within the meaning of Art. 22 GDPR, takes place.

20. Changes to this privacy policy

We reserve the right to amend this privacy policy so that it always complies with current legal requirements or in order to reflect changes to our services. The current version then applies to your next visit.

This English text is a non-binding convenience translation. In the event of any discrepancy, the German version shall prevail.