Privacy policy

1. Controller

Represented by its managing director Lars Uwe Müller.
Email: [email protected]
Phone: +49 160 5204960

2. Website and hosting

We use Cloudflare Pages and Workers (Cloudflare, Inc., USA) to provide this website and process requests. This involves processing in particular your IP address, the time of access, the requested address, and browser and device information. This serves delivery, troubleshooting and the prevention of misuse on the basis of Art. 6(1)(f) GDPR. Cloudflare's global network may also process data outside the EU. Information on the transfer safeguards used and on the processing can be found in Cloudflare's privacy policy.

The database for tour requests is configured with an EU data location. In the event of errors, our application does not log names, email addresses or form entries. To limit abusive requests, we store check values and counters derived from the IP address or email address for up to 24 hours; expired entries are removed during the next clean-up run.

3. Access cookie and local media

After you unlock access, we set the cookie “__Host-p205” to recognise your tour access. It contains a signed random access identifier, no contact details, and is valid for a maximum of 90 days. It serves exclusively the access you requested (§ 25(2) no. 2 TDDDG; Art. 6(1)(b) GDPR). You can delete it in your browser; the personal email link allows renewed access until it expires.

Fonts, images and the kitchen animation are delivered with the website. Google Analytics is not used. The Meta Pixel and PostHog are only loaded with your respective consent; see sections 8 and 9. Section 7 applies to the separately launched Matterport player.

4. Tour request and email

To unlock access, we process your name, email address, phone number and your indication of the type of your interest. In addition, we process the time of the request, the landing page, any campaign information from the link you used, and the country that our hosting provider Cloudflare derives from your IP address. We do not store the IP address itself. We use this data to unlock the tour, send you your personal link and handle your enquiry about the penthouse personally. This serves pre-contractual measures on the basis of Art. 6(1)(b) GDPR. It does not include a newsletter subscription.

We use Brevo (Sendinblue SAS, France) for contact management and to send the access email. For this purpose, we transmit the request data mentioned above to Brevo. According to Brevo, customer data is stored in European data centres. Further information is available from Brevo on data storage location and in its privacy policy.

Brevo processes sending and delivery events and, in its standard configuration, also records email opens and clicks. The access email is a requested service message. Personal email correspondence takes place via our Microsoft 365 mailbox at GoDaddy. Information from Microsoft can be found in the Microsoft privacy statement.

5. Recipients and storage period

Your enquiry is handled by the persons entrusted with the sale. Technical service providers are Cloudflare, Brevo and the providers of our email mailbox. The technical copy of the request and the access link expire after 90 days. Expired database entries are removed during the next clean-up run. This period does not automatically apply to separate correspondence and to contact management in Brevo and in the mailbox.

We keep contact and correspondence data for as long as necessary to handle your enquiry. Once it has been completed and the purpose no longer applies, the data is deleted unless statutory retention obligations or legal claims prevent this. You can contact us about deletion at any time.

6. Your rights

Subject to the statutory requirements, you have the right of access, rectification, erasure, restriction of processing and data portability. You can withdraw any consent you have given with effect for the future.

Objection: Where processing is based on Art. 6(1)(f) GDPR, you can object on grounds relating to your particular situation. You can object to direct marketing at any time.

To do so, please contact the company named above. You also have the right to lodge a complaint with a data protection supervisory authority, for example the supervisory authority for Baden-Württemberg (opens in a new tab).

7. Virtual tour with Matterport

The tour is provided by Matterport, Inc. (USA). The external player is only loaded when you click “Start virtual tour”. By starting it, you consent to its embedding and the associated data processing (Art. 6(1)(a) GDPR and, where required, § 25(1) TDDDG).

In the process, connection and device data are transmitted to Matterport. Matterport describes storing settings in local storage, usage analytics of actions in the player and technical logs, using among other things truncated IP addresses and approximate location and browser information. If you are logged in to Matterport, account identifiers and session cookies may also be processed. Processing in the USA is possible.

You can remove the player at any time via “Close tour” and thereby end the embedding for the future. Processing that has already taken place remains unaffected; you can delete stored browser settings in your browser. Details, storage practices and information on international transfers can be found at Matterport Showcase and in the Matterport privacy policy.

8. Meta Pixel and advertising measurement

If you choose “Accept all” or activate the “Marketing” category, we use the Meta Pixel (ID 1577542213496921) of Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. We use it to measure page visits and successful tour unlocks and to evaluate the effectiveness of our Facebook and Instagram advertising. The legal bases are your consent under Art. 6(1)(a) GDPR and § 25(1) TDDDG. Without your consent, the pixel is not loaded.

Meta receives, among other things, the pages viewed, events, your IP address and browser information, and may link these to your Meta profile and use them for personalised advertising. We do not pass any names, email addresses or phone numbers from the request form to the pixel and do not use advanced matching. The embedding may set the cookies “_fbp” and “_fbc” for recognition and ad attribution, usually for up to 90 days. Processing by Meta in the USA is possible.

We store your decision locally in your browser under “p205-consent-v3” for up to 180 days so that we can respect it. You can change it at any time via “Privacy settings” in the page footer and withdraw your consent with effect for the future. If you withdraw consent, we stop further pixel measurement and remove the Meta cookies accessible from our domain. Data already transmitted to Meta is not recalled. To attribute a successful unlock once, we temporarily store a random event identifier in session storage after your consent; it contains no contact details and is removed after processing.

Further information on Meta's processing, storage periods, data subject rights and international data transfers can be found in Meta's privacy policy and the cookie policy. The joint controller addendum applies to the collection and transmission of event data.

9. Usage analysis with PostHog

If you consent to the “Statistics” category, we use PostHog by PostHog, Inc. We use the US service at us.i.posthog.com. We collect page views with a cleaned page path, technical browser and device information, the steps “request form opened”, “request submitted”, “tour unlocked”, “tour started” and “gallery image opened”, as well as your interactions with the page: clicked elements, click and mouse positions (for heatmaps), scroll depth, time spent per page and technical loading times. To evaluate our advertising, we also transmit campaign information from the link you used (utm parameters), the domain of the referring website and whether the link contained a Meta click identifier – but not its value. In addition, we record your visit as a pseudonymous session recording: PostHog stores the page structure and your mouse movements, clicks and scrolling so that the visit can be replayed like a video. Entries in form fields are masked in your browser and not transmitted; we do not record console output or the content of network requests. Recordings are deleted after 30 days. Other query parameters and personal access links are not transmitted; pages opened via a personal access link are neither analysed nor recorded. We do not pass on any contact identity and do not create identified personal profiles.

The integration is only loaded after your consent. So that page views within one visit belong together, PostHog stores a random visit and session identifier and the campaign information mentioned above in your browser's session storage. This data is deleted when you close the browser tab; we do not use cookies or local storage for PostHog, and visitors are not recognised across visits. When the connection is established, your IP address is technically transmitted to the provider. PostHog derives an approximate location (country, region, city) from it; the IP address itself is not stored in our analysis. Processing takes place in the USA.

The legal bases are your consent under Art. 6(1)(a) GDPR and, where required, § 25(1) TDDDG. Your choice is stored locally together with the marketing choice under “p205-consent-v3” for up to 180 days. You can withdraw your consent at any time via “Privacy settings” in the page footer. Further information on storage, international transfers and your rights can be found in PostHog's privacy policy.

10. Automated decisions and changes

Our own website code does not use automated decision-making with legal or similarly significant effects, nor profiling. If functions or service providers change, we will update this privacy information.