Privacy Policy
Who is responsible
Finn Thormeier, trading as Thormeier.co, is responsible for the personal data described in this policy.
Address: Elfriedestraße 6, 10353 Berlin, Germany
Email: finn@thormeier.co
Visiting this website
Framer B.V., Netherlands, hosts this website. Framer and its infrastructure providers process technical data, including your IP address, requested pages, access times and browser information, to deliver and secure the website. The legal basis is my legitimate interest in operating a reliable, secure website (Article 6(1)(f) GDPR).
Framer also produces cookie-free usage statistics. It uses IP and browser information to create identifiers with a secret that changes daily, allowing it to count visits without persistent visitor identifiers. My legitimate interest is understanding and improving the website (Article 6(1)(f) GDPR).
Contacting me and booking a call
When you contact me or book through the Calendly link, I process your contact details, message, appointment details and information you provide to respond and arrange the call. Calendly LLC, USA, processes bookings on my behalf. My email, calendar and customer-management providers also process the relevant correspondence and appointment data.
The legal basis is Article 6(1)(b) GDPR for steps towards, or performance of, a contract with you; otherwise, Article 6(1)(f) GDPR, reflecting my interest in handling business enquiries. Providing information is voluntary, but I need sufficient contact and booking details to respond or arrange a call.
Enquiry and appointment records are deleted upon request. Business correspondence subject to section 147 AO is retained for six years from the end of the year it was sent or received, or longer where that law requires (Article 6(1)(c) GDPR). Records needed for a dispute are retained until it is resolved (Article 6(1)(f) GDPR).
Website analytics
With your consent, I use Google Analytics and Fathom to understand website use and improve its content (Article 6(1)(a) GDPR). Any nonessential storage of, or access to, information on your device also requires your consent under section 25(1) TDDDG.
Google Analytics is provided by Google Ireland Limited, Ireland. It processes page views, interactions, referral sources, device information, cookie identifiers and IP addresses to derive approximate location. User and event data are retained for 2 years.
Fathom is provided by Conva Ventures Inc., Canada. It processes page visits, referral sources, approximate location and device information, using IP and browser information to generate visitor signatures. It does not use analytics cookies.
Video
With your consent, the embedded video loads from Wistia, Inc., USA (Article 6(1)(a) GDPR and, for nonessential device storage or access, section 25(1) TDDDG). Wistia processes your IP address, browser and device data, and viewing activity such as plays, pauses and viewing duration, to deliver the video and help me understand its use. Its standard retention period for viewing-session records is two years.
International transfers
Framer's hosting providers and Google, Calendly and Wistia can process data outside the European Economic Area, including in the USA. Their published agreements provide for applicable adequacy decisions, including covered EU–US Data Privacy Framework transfers, or EU Standard Contractual Clauses. Fathom is based in Canada, whose adequacy decision covers qualifying commercial organisations.
Your rights
Subject to the GDPR's conditions, you can request access to your personal data, correction, deletion, restriction of processing, and a portable copy of data you provided. Contact finn@thormeier.co to exercise these rights.
You can withdraw consent at any time via email. Withdrawal does not affect the lawfulness of processing before withdrawal.
You can complain to a data protection authority, including the Berlin Commissioner for Data Protection and Freedom of Information: https://www.datenschutz-berlin.de.
Right to object
You may object to processing based on legitimate interests for reasons relating to your particular situation. If your data is used for direct marketing, you may object to that use at any time. Contact finn@thormeier.co.