Last updated: 02 April 2026 Version 1.3 # 1\. Introduction In the following, we provide information about the collection of personal data when using - our website - our profile in social media . Personal data is any data that can be related to a specific natural person, such as their name or IP address. ## 1.1. Contact details The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Orbiq GmbH, Ludwig-Erhard-Str. 18 Hamburg 20459 Germany, email: . We are legally represented by Emre Salmanoglu. ## 1.2. Scope of data processing, processing purposes and legal bases We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing: - Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent. - Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services. - Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law. - Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website. ## 1.3. Data processing outside the EEA Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR). In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework. In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data. ## 1.4. Storage duration Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons. ## 1.5. Rights of data subjects Data subjects have the following rights against us with regard to their personal data: - Right of access, - Right to correction or deletion, - Right to limit processing, - **Right to object to the processing**, - Right to data transferability, - **Right to revoke a given consent at any time**. Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at . ## 1.6. Obligation to provide data Within the scope of the business or other relationship, Clients and Beneficiaries, prospective Clients and Beneficiaries or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship. Mandatory data are marked as such. ## 1.7. No automatic decision making in individual cases As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law. ## 1.8. Making contact When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations. ## 1.9. Surveys of Clients and Beneficiaries From time to time, we conduct Surveys of Clients and Beneficiaries to get to know our Clients and Beneficiaries and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our Clients and Beneficiaries and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated. # 2\. Newsletter We reserve the right to inform Clients and Beneficiaries who have already used services from us or purchased goods from time to time by e-mail or other means about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Clients and Beneficiaries can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address. Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation. Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience. We send email notifications to you and your Trust Center users with the tool Lettermint of the provider Lettermint B.V., Willemsvaart 16B, Unit 1.08, 8019 AB Zwolle, The Netherlands. The provider processes content, usage, meta/communication data and contact data exclusively within the EU. Further information is available in the provider's privacy policy at and their Data Processing Agreement at . # 3\. Data processing on our website ## 3.1. Notice for website visitors from Germany Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections. This storage and access is based on the following provisions: - Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g., to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 para. 2 no. 2 of the German Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutzgesetz, "TDDDG"). - Otherwise, this storage or access takes place on the basis of the website visitor's consent (Section 25 para. 1 TDDDG). The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR. ## 3.2. Informative use of our website During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR. These data are: - IP address - Date and time of the request - Time zone difference to Greenwich Mean Time (GMT) - Content of the request (specific page) - Access status/HTTP status code - Amount of data transferred in each case - Website from which the request comes - Browser - Operating system and its interface - Language and version of the browser software. This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days. ## 3.3. Web hosting and provision ### 3.3.1 Website Our website is hosted by Vercel. The provider is Vercel, Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy at . It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR. The legal basis of the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection. We use the content delivery network Vercel for our website. The provider is Vercel, Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy at . We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Legal basis of the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection. ### 3.3.2 Trust Center Our Trust Centers and Admin Center are hosted by Hostinger. The provider is Hostinger International Ltd., 61 Lordou Vironos Street, 6023 Larnaca, Cyprus. The servers are located in Germany. In this process, the provider processes personal data transmitted through the Trust Centers and Admin Center, such as content, usage, meta/communication data, or contact data. Further information can be found in the provider's privacy policy at https://www.hostinger.com/legal/privacy-policy. For data backup purposes, we additionally use the services of Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. The backup servers are also located in Germany. Copies of the aforementioned personal data are stored to ensure data security and recoverability. Further information can be found in the provider's privacy policy at https://www.hetzner.com/legal/privacy-policy. It is our legitimate interest to provide secure and reliable Trust Centers as well as an Admin Center and to ensure the availability and integrity of data through regular backups, therefore the legal basis for the described data processing is Art. 6(1)(f) GDPR. ## 3.4. Contact form When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations. ## 3.5. Vacant positions We publish vacant positions on our website, on pages linked to the website or on third-party websites. The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act (Bundesdatenschutzgesetz). We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application. Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 s. 1 lit. a GDPR). We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR). Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. We pass on the applicants' data to the responsible employees in the HR department, to our data processors in the area of recruiting and to the employees otherwise involved in the application process. If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant. If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receiving the application. ## 3.6. Third parties ### 3.6.1. Analytics and Website Performance Monitoring #### PostHog Analytics We use PostHog for anonymized website analytics, including page visits monitoring, user interaction heatmaps, error logging, and session replays. The provider is PostHog, Inc., 2261 Market Street #4008, San Francisco, CA 94114, USA. All data is processed and stored exclusively on EU servers located in Frankfurt, Germany (AWS eu-central-1 region), ensuring your data never leaves the EU. PostHog processes the following data in an anonymized manner: - Anonymized page view data and user interactions - Technical information necessary for error detection and website optimization - Session recordings with sensitive data automatically redacted - No personal identifiable information is collected unless you explicitly provide it The processing is based on our legitimate interest in understanding website usage patterns and improving user experience (Art. 6 para. 1 s. 1 lit. f GDPR). PostHog operates without cookies and generates only anonymous user IDs for session tracking. You can opt out of tracking at any time by enabling "Do Not Track" in your browser settings. Further information is available in PostHog's privacy policy at and their GDPR compliance documentation at . ### 3.6.2. Payment Processing For payment processing in our Trust Centers, we use the services of Polar Software ("Polar.sh"). Polar.sh acts as our Merchant of Record and handles payments, subscriptions, and international tax compliance on our behalf. During payment processing, personal data such as name, email address, billing address, payment information, and transaction data are processed. The actual payment processing is carried out through the payment service provider Stripe, Inc. Further information on data processing can be found in Polar's privacy policy at https://polar.sh/legal/privacy and in Stripe's privacy policy at https://stripe.com/privacy. It is our legitimate interest to offer our customers secure, reliable, and legally compliant payment processing including automatic tax handling, therefore the legal basis for the described data processing is Art. 6(1)(f) GDPR. For the execution of the payment transaction itself, the legal basis is Art. 6(1)(b) GDPR (contract fulfillment). # 4\. Data processing on social media platforms We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data. If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR. ## 4. LinkedIn We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: . One way to object to data processing is via the settings for advertisements: . # 5\. Changes to this privacy policy We reserve the right to change this privacy policy with effect for the future. A current version is always available here. # 6\. Questions and comments If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.

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April 2026 Release
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