Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the course of providing our services and in particular on our website (hereinafter collectively referred to as "online services").

The terms used are not gender-specific.

Last updated: August 4, 2026

Table of Contents

• Preamble
• Controller
• Overview of Processing Activities
• Applicable Legal Basis
• Security Measures
• International Data Transfers
• General Information on Data Retention and Deletion
• Rights of Data Subjects
• Provision of Online Services and Web Hosting
• Management, Organisation and Auxiliary Tools
• Amendments and Updates
• Definitions

Controller

Fabian Weiß
Kolonnenstr. 8
10827 Berlin
Germany

Email address: privacy@genfabric.dev

Legal Notice: https://genfabric.dev/impressum

Overview of Processing Activities

The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.

Types of Data Processed

• Contact data.
• Content data.
• Usage data.
• Meta, communication and procedural data.
• Log data.

Categories of Data Subjects

• Communication partners.
• Users.

Purposes of Processing

• Provision of contractual services and fulfilment of contractual obligations.
• Security measures.
• Office and organisational procedures.
• Provision of our online services and user-friendliness.
• Information technology infrastructure.

Applicable Legal Bases

Relevant legal bases under the GDPR: The following provides an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be applicable in individual cases, we will inform you of these in the privacy policy.

• Legitimate Interests (Art. 6(1)(f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include in particular the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and the transmission and automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual German federal states may apply.

Applicable legal basis under the Swiss Data Protection Act (DPA): We process your personal data in accordance with the Federal Act on Data Protection, known as the "Swiss Data Protection Act (DPA)". Personal data must be processed lawfully, in good faith and proportionately (Art. 6(1) and (2) Swiss DPA). It may only be collected for a specific purpose that is apparent to the data subject and may only be processed in a manner compatible with that purpose (Art. 6(3) Swiss DPA). Unlike the GDPR, the Swiss DPA does not, in principle, make the admissibility of processing by private controllers dependent on the selection of a specific legal basis from a legally defined catalogue. Therefore, there is generally no obligation to specify a legal basis for each processing activity in the privacy policy.

Security Measures

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of processing, as well as the different likelihoods and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability and separation thereof. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data and responses to data threats. We also take the protection of personal data into account during the development and selection of hardware, software and procedures, in accordance with the principles of data protection by design and data protection by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorised access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

International Data Transfers

Data processing in third countries: Where we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where this occurs in the context of using third-party services or the disclosure or transfer of data to other persons, entities or companies (as indicated by the postal address of the respective provider or where the privacy policy explicitly refers to data transfers to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the Standard Contractual Clauses serve as additional security. Should changes occur in connection with the DPF, the Standard Contractual Clauses serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of any political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, in particular Standard Contractual Clauses, explicit consent or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be obtained from the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

Disclosure of personal data abroad: In accordance with the Swiss DPA, we only disclose personal data abroad if adequate protection of the data subjects is ensured (Art. 16 Swiss DPA). Where the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/de/schweizerische-anerkennung-von-staaten-die-einen-angemessenen-datenschutz-gewaehrleisten), we take alternative safeguards.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of Switzerland dated 15 September 2024. In addition, we have concluded Standard Data Protection Clauses with the respective providers, which have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and establish contractual obligations for the protection of your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the Standard Data Protection Clauses serve as additional security. Should changes occur in connection with the DPF, the Standard Data Protection Clauses serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of any political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether Standard Data Protection Clauses are in place. The list of certified companies and further information on the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, including international treaties, specific guarantees, Standard Data Protection Clauses approved by the FDPIC, or binding corporate rules previously recognised by the FDPIC or a competent data protection authority of another country.

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with the legal provisions as soon as the underlying consent is withdrawn or there are no further legal grounds for processing. This applies to cases where the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where statutory obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose retention is necessary for the pursuit of legal claims or for the protection of the rights of other natural or legal persons, must be archived accordingly.

Our data protection notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

Where multiple indications regarding the retention period or deletion deadlines for a piece of data exist, the longest period shall always prevail. Data that is no longer retained for its originally intended purpose but due to legal requirements or other reasons is processed exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply to retention and archiving under German law:

• 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the working instructions and other organisational documents required for their understanding (Section 147 (1) no. 1 in conjunction with (3) AO, Section 14b (1) UStG, Section 257 (1) no. 1 in conjunction with (4) HGB).
• 8 years - Accounting records, such as invoices and cost receipts (Section 147 (1) no. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257 (1) no. 4 in conjunction with (4) HGB).
• 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation purposes, e.g. timesheets, cost allocation sheets, calculation documents, price markings, as well as payroll accounting documents insofar as they are not already accounting records, and cash register strips (Section 147 (1) no. 2, 3, 5 in conjunction with (3) AO, Section 257 (1) no. 2 and 3 in conjunction with (4) HGB).
• 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related enquiries, based on prior business experience and standard industry practice, are retained for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Retention and deletion of data: The following general periods apply to retention and archiving under Swiss law:

• 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting records and invoices, as well as all required working instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (CO)).
• 10 years - Data required to consider potential compensation claims or similar contractual claims and rights, as well as to process related enquiries, based on prior business experience and standard industry practice, are retained for the duration of the statutory limitation period of ten years, unless a shorter period of five years applies, which is relevant in certain cases (Art. 127, 130 CO). Claims for rent, lease and capital interest and other periodic payments, for the supply of food, for board and lodging, and for tavern debts, as well as for craftsmanship, retail sale of goods, medical attendance, professional work of lawyers, legal agents, procurators and notaries, and from the employment relationship of employees, are time-barred after five years (Art. 128 CO).

Commencement of period at the end of the year: Where a period does not expressly begin on a specific date and amounts to at least one year, it automatically commences at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the date on which the termination takes effect or the legal relationship otherwise ends.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

• Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw consent at any time.
• Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to access such data as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: You have the right, in accordance with the legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to request that data concerning you be erased without undue delay, or alternatively to request restriction of processing of the data in accordance with the legal requirements.
• Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
• Complaint to a supervisory authority: In accordance with the legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State of your habitual residence, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of data subjects under the Swiss DPA:

As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss DPA:

• Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed, and to receive such information as is necessary for you to exercise your rights under this Act and to ensure transparent data processing.
• Right to data disclosure or transfer: You have the right to request the disclosure of your personal data that you have provided to us in a commonly used electronic format.
• Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
• Right to object, erasure and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be erased or destroyed.

Provision of Online Services and Web Hosting

We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.

• Types of Data Processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved); Log data (e.g. log files concerning logins or data retrieval or access times.); Contact data (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or visual messages and posts as well as related information, such as details of authorship or time of creation).
• Data Subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures. Office and organisational procedures.
• Retention and Deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
• Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

• Provision of online services on rented storage space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a "web hoster"); Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR).
• Collection of access data and log files: Access to our online services is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure the utilisation and stability of the servers; Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymised. Data whose further retention is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
• Content Delivery Network: We use a "Content Delivery Network" (CDN). A CDN is a service that enables the content of an online offering, in particular large media files such as graphics or program scripts, to be delivered more quickly and securely with the help of regionally distributed servers connected via the internet; Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR).
• Calendly: Online scheduling and appointment management; Service provider: Calendly LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR); Website: https://calendly.com/de; Privacy Policy: https://calendly.com/legal/privacy-notice; Data Processing Agreement: https://calendly.com/legal/data-processing-addendum. Basis for third-country transfers: EU/EEA - Standard Contractual Clauses (https://calendly.com/legal/data-processing-addendum), Switzerland - Standard Contractual Clauses (https://calendly.com/legal/data-processing-addendum).
• Vercel: Services in the area of provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity) as well as development environments; Service provider: Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA; Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR); Website: https://vercel.com; Privacy Policy: https://vercel.com/legal/privacy-policy; Data Processing Agreement: https://vercel.com/legal/dpa. Basis for third-country transfers: EU/EEA - Standard Contractual Clauses (https://vercel.com/legal/dpa), Switzerland - Standard Contractual Clauses (https://vercel.com/legal/dpa).
• Vercel Analytics: We use Vercel Analytics, a privacy-friendly analytics service provided by Vercel Inc. (340 S Lemon Ave #4133, Walnut, CA 91789, USA). Vercel Analytics does not use cookies and does not collect personal data. Only aggregated usage statistics are recorded (e.g. page views, loading times). No attribution to individual visitors takes place. Data processing is carried out on Vercel's servers; Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR); Website: https://vercel.com/analytics; Privacy Policy: https://vercel.com/legal/privacy-policy.

Management, Organisation and Auxiliary Tools

We use services, platforms and software of other providers (hereinafter referred to as "third-party providers") for the purposes of organisation, administration, planning and the provision of our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may concern various data that we process in accordance with this privacy policy. Such data may include, in particular, master data and contact data of users, data relating to transactions, contracts, other processes and their content.

Where users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, for service optimisation or for marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

• Types of Data Processed: Content data (e.g. textual or visual messages and posts as well as related information, such as details of authorship or time of creation); Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Contact data (e.g. postal and email addresses or telephone numbers).
• Data Subjects: Communication partners. Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
• Retention and Deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
• Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

• Calendly: Online scheduling and appointment management; Service provider: Calendly LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; Legal Basis: Legitimate Interests (Art. 6(1)(f) GDPR); Website: https://calendly.com/de; Privacy Policy: https://calendly.com/legal/privacy-notice; Data Processing Agreement: https://calendly.com/legal/data-processing-addendum. Basis for third-country transfers: EU/EEA - Standard Contractual Clauses (https://calendly.com/legal/data-processing-addendum), Switzerland - Standard Contractual Clauses (https://calendly.com/legal/data-processing-addendum).

Amendments and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact information of companies and organisations in this privacy policy, please note that addresses may change over time and we ask you to verify the information before making contact.

Definitions

This section provides an overview of the terms used in this privacy policy. Where the terms are legally defined, their legal definitions shall apply. The following explanations are primarily intended to aid understanding.

• Content data: Content data encompasses information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates.
• Contact data: Contact data is essential information that enables communication with persons or organisations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the manner in which data is processed, transmitted and managed. Metadata, also known as data about data, encompasses information that describes the context, origin and structure of other data. It may include details about file size, creation date, author of a document and modification histories. Communication data records the exchange of information between users via various channels, such as email correspondence, call logs, messages on social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and reviewing operations.
• Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data encompasses a wide range of information indicating how users use applications, which features they prefer, how long they spend on certain pages and the paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings.
• Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Log data: Log data is information about events or activities recorded in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used for analysing system problems, security monitoring or creating performance reports.
• Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it be collection, analysis, storage, transmission or erasure.