Privacy Policy

Last updated: April 2025

1. Data Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

PPJ Ventures UG (haftungsbeschränkt)
Hohenzollernstr. 30
80801 München
Germany
Email: julius.hasenzahl@eclat-studios.com

2. General Principles

We process personal data of our users only to the extent necessary to provide a functional website and our content and services. As a rule, personal data is only processed with the user's consent, unless prior consent is not possible for factual reasons and processing is permitted by law.

This website does not use tracking tools, advertising cookies, or analytics services (such as Google Analytics). No user profiles are created.

3. Hosting and Server Infrastructure

This website and the REFAI service are operated on servers located in Germany. All data processed through the service remains within the European Union.

When you visit our website, the server automatically records the following information in so-called server log files:

IP address of the requesting device (anonymised)
Date and time of access
Name and URL of the file accessed
Browser and operating system used
Referrer URL (previously visited page)

This data is not merged with other data sources. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in the technically error-free presentation and optimisation of the website).

4. Processing of Lead Data in the REFAI Service

The core function of REFAI is the processing of CSV and Excel files containing contact data (lead lists). This processing takes place exclusively upon your active request (file upload) and is subject to the following principles:

Uploaded files are stored only for the duration of the processing session.
After export, all uploaded and processed data is completely and irreversibly deleted.
Contact data is not used for our own purposes (training, marketing, resale).
All data transmission is encrypted exclusively via TLS 1.3.

The legal basis is Art. 6(1)(b) GDPR (contract performance) and Art. 6(1)(f) GDPR.

5. Contact by Email

If you contact us by email, the data you provide (name, email address, message content) will be stored for the purpose of processing your enquiry. We will not pass this data on without your consent.

The legal basis is Art. 6(1)(f) GDPR. The data will be deleted once your enquiry has been fully answered and no statutory retention obligations apply.

6. Cookies

This website uses only technically necessary cookies that are required for the operation of the website. No marketing, tracking, or analytics cookies are set. Technically necessary cookies do not require consent pursuant to § 25(2) TTDSG (German Telecommunications and Telemedia Data Protection Act).

7. Disclosure to Third Parties

Your personal data will not be transferred to third parties unless this is required by law or you have expressly consented. We do not sell personal data.

8. Your Rights as a Data Subject

You have the following rights with respect to your personal data:

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 (Art. 21 GDPR)
Right to withdraw consent (Art. 7(3) GDPR)

To exercise your rights, please contact: julius.hasenzahl@eclat-studios.com

You also have the right to lodge a complaint with a supervisory authority. The competent authority for Bavaria is: Bayerischer Landesbeauftragter für den Datenschutz (BayLfD), Wagmüllerstraße 18, 80538 München, Germany.

9. Data Security

We use SSL/TLS encryption for all data transmission on this website, with the highest encryption level supported by your browser (typically 256-bit encryption).

10. Updates to This Privacy Policy

This privacy policy is currently valid as of April 2025. Due to the further development of our website and services, or changes in legal or regulatory requirements, it may be necessary to amend this privacy policy. The current version is always available on this page.