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Privacy Policy

01

Privacy at a Glance

Controller

Sebastian Hepp
Max-Beer-Str. 27
10119 Berlin
Germany

Email: sebastian.hepp@ninety2seven.com
Phone: +49 172 2025067

Data We Process

  • Technical data: IP address, browser type and version, operating system, device information
  • Usage data: Pages visited, time of access, referring URLs
  • Communication data: Content of email inquiries, contact details you provide

Why We Process Data

  • Providing and maintaining this website
  • Responding to your inquiries
  • Analyzing website usage (with your consent)
  • Conducting video conferences for business communications

Your Rights

You have the right to request information about, correction, deletion, or restriction of your personal data at any time. You may also withdraw consent or lodge a complaint with a supervisory authority. Contact us using the details above.

For complete details, please read the full policy below.

02

Data Protection Overview

General Information

The following information provides an overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on the subject of data protection, please refer to our privacy policy listed below.

Categories of Data Processed

The personal data processed through this website includes:

  • Usage data: Pages visited, time of access, referring URLs, interest in our services
  • Technical data: IP address, browser type and version, operating system, host name
  • Communication data: Content of email inquiries, contact details you provide, video conference participation data

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 "Controller" section of this privacy policy.

How do we collect your data?

Your data is collected in part by you providing it to us, for example by contacting us via email or participating in a video conference.

Other data is collected automatically or with your consent when you visit the website by our IT systems. This is primarily technical data (e.g., internet browser, operating system, or time of 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 may be used to analyze your user behavior with your consent.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. 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.

03

Hosting

External Hosting

This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the hoster's servers. This may include, but is not limited to, IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access, and other data generated via a website.

The use of the hoster is for the purpose of fulfilling contracts with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of a secure, fast, and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f GDPR).

Our hoster will only process your data to the extent necessary to fulfill its service obligations and follow our instructions regarding this data.

We use the following hoster:

[HOSTING PROVIDER NAME]
[HOSTING PROVIDER ADDRESS]
04

General Information 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 is collected. Personal data is data by 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 would like to point out that data transmission over the Internet (e.g., when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.

Controller

The controller responsible for data processing on this website is:

Sebastian Hepp
Max-Beer-Str. 27
10119 Berlin
Germany

Phone: +49 172 2025067
Email: sebastian.hepp@ninety2seven.com

The controller is the natural or legal person who alone or jointly with others determines 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 stated within this privacy policy, your personal data will remain with us until the purpose for data processing 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., retention periods under tax or commercial law); in the latter case, deletion will take place after these reasons no longer apply.

Statutory Retention Periods

Where statutory retention obligations apply, data is retained as follows:

  • 6 years pursuant to § 257 para. 1 HGB (German Commercial Code) for commercial correspondence and business documents
  • 10 years pursuant to § 147 para. 1 AO (German Fiscal Code) for tax-relevant records and documentation

Data is deleted after these periods expire, unless longer retention is required for specific legal reasons.

General Information on the Legal Basis for Data Processing

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR if special categories of data are processed according to Art. 9 para. 1 GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information on your device (e.g., via device fingerprinting), data processing is additionally based on § 25 para. 1 TDDDG. Consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. Information on the relevant legal bases in each individual case 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 parties. In some cases, this also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary for the fulfillment of a contract, if we are legally obliged to do so (e.g., transfer of data to tax authorities), if we have a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR in the transfer, or if another legal basis permits the data transfer. When using processors, we only pass on personal data of our customers on the basis of a valid contract for order processing. In the case of joint processing, a joint processing 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 before 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 PARA. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; 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 PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 PARA. 1 GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, 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 INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 GDPR).

Right to Lodge a Complaint with a 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 is without prejudice to any 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 insofar as it is technically feasible.

Information, Correction, and Deletion

Within the framework of the applicable legal 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. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time.

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 for this purpose. The right to restriction of processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the review, 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 para. 1 GDPR, a balancing of your and our interests must be carried out. As long as it has not yet been determined 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 may - apart from being stored - only be processed with your consent or for the assertion, 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/TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as inquiries 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.

05

Data Collection on This Website

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
  • Host name 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 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of their website - for this purpose, the server log files must be recorded.

Retention: Server log files are stored for a maximum of 7 days for security purposes and then automatically deleted, unless longer retention is required for the investigation of specific incidents.

Contact by Email

If you contact us by email, your inquiry including all personal data arising from it (name, inquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. 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, the processing is based on our legitimate interest in the effective handling of inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.

The data you send to us via contact requests 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 your request has been processed). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

06

Cookie Consent Management

Consent Mechanism

This website uses a custom consent mechanism to comply with data protection regulations. When you first visit our website, a consent banner appears asking whether you agree to the use of analytics cookies.

How It Works

When you visit our website, the following process occurs:

  • A consent banner is displayed if you have not previously made a choice
  • No analytics cookies are placed until you explicitly click "Accept"
  • If you click "Decline", no analytics data is collected
  • Your preference is stored in your browser's local storage

Data Stored Locally

To remember your consent decision, we store a single preference value in your browser's local storage:

  • Key: n2s_analytics_consent
  • Value: "granted" or "denied"
  • Purpose: To remember your preference and avoid showing the banner on subsequent visits

This data is stored only in your browser and is not transmitted to our servers. You can clear this preference at any time by clearing your browser's local storage or site data.

Changing Your Preference

To change your cookie preference:

  • Clear your browser's local storage or site data for this website
  • Refresh the page - the consent banner will appear again
  • Make your new selection

Alternatively, you can use your browser's developer tools to manually delete the "n2s_analytics_consent" key from local storage.

Legal Basis

The consent management mechanism is implemented to obtain the legally required consent for the use of analytics cookies pursuant to Art. 6 para. 1 lit. a GDPR (consent) and Section 25 para. 1 TDDDG (German Telecommunications-Telemedia Data Protection Act).

07

Analysis Tools

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. In doing so, the website operator receives various usage data, such as page views, length of visit, operating systems used, and origin of the user. This data is assigned to the respective end device of the user. Assignment to a user ID does not take place.

Furthermore, Google Analytics allows us to record, among other things, your mouse and scroll movements and clicks. Google Analytics also uses various modeling approaches to supplement the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g., cookies or device fingerprinting). The information collected by Google about the use of this website is generally transferred to a Google server in the USA and stored there.

The use of this service is based on your consent pursuant to Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG. Consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.

IP Anonymization

We have activated the IP anonymization function on this website. This means that your IP address is shortened by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser Plugin

You can prevent the collection of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information on how Google Analytics handles user data, please see Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

Data Processing Agreement

We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

08

Video Conferencing Tools

Online Meetings

We use video conferencing tools to conduct online meetings, consultations, and business communications. Depending on the context and participant preferences, the following tools may be used:

Microsoft Teams
Provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA
Privacy Policy: https://privacy.microsoft.com/en-us/privacystatement

Zoom
Provider: Zoom Video Communications, Inc., 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA
Privacy Policy: https://explore.zoom.us/en/privacy/

Google Meet
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Privacy Policy: https://policies.google.com/privacy

Data Processed

When participating in an online meeting, the following personal data may be processed:

  • User information: Name, email address, profile picture (if provided)
  • Meeting metadata: Date, time, duration, participant IP addresses
  • Content data: Audio and video transmissions, chat messages, shared screens or documents
  • Technical data: Device information, browser type, connection quality

You can disable your camera and microphone at any time during a meeting. Participation without video is generally possible.

Recording

If an online meeting is to be recorded, this will be communicated transparently in advance and your consent will be obtained where required. The recording status is also displayed within the application.

Legal Basis

The processing of data in connection with online meetings is based on Art. 6 para. 1 lit. b GDPR insofar as the meetings are conducted within the framework of contractual relationships or pre-contractual measures. If there is no contractual relationship, the legal basis is Art. 6 para. 1 lit. f GDPR (legitimate interest in effective business communication).

Data Transfers to the USA

Microsoft, Zoom, and Google are certified under the EU-US Data Privacy Framework (DPF), ensuring an adequate level of data protection for transfers to the USA. You can verify certification status at: https://www.dataprivacyframework.gov/s/participant-search.

Additionally, EU Standard Contractual Clauses (SCCs) are in place with these providers as a supplementary safeguard.

09

Plugins and Tools

LinkedIn Link

This website contains a link to the external platform LinkedIn. When you click this link, you will be redirected to LinkedIn. We have no influence on the data collected by LinkedIn through such a visit. You can find information on this in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.

Note: This website does not embed LinkedIn plugins or widgets. Only a standard hyperlink to an external LinkedIn profile is provided. No data is transferred to LinkedIn until you actively click the link and visit the LinkedIn website.

10

Changes to This Privacy Policy

We reserve the right to amend this privacy policy to reflect changes in legal requirements or changes in our services and data processing practices. The current version is always available on this website.

Where changes affect processing based on your consent, we will seek renewed consent where required by law.

We encourage you to review this privacy policy periodically.

Last updated: December 2025