Privacy Policy

Effective Date: April 1, 2025
Last Updated: April 1, 2025

I. General Information

1. Controller

Teno Guga, acting as GUGA Solutions
Nürnberger Straße 68
10787 Berlin, Germany
Email: [email protected]

2. No Data Protection Officer Appointed

We are not legally required to appoint a Data Protection Officer under Art. 37 GDPR. However, for all data protection-related inquiries, please contact Teno Guga at the contact details provided above.

3. Transfer to Third Parties

We may transfer your personal data to third parties where necessary to provide our Website or services. If we use external service providers, these have been carefully selected and contractually bound to process data in compliance with Art. 28 GDPR. Categories of recipients include:

  • Cloud service providers (e.g., iCloud, Google Drive)
  • Email and CRM providers (e.g., Mailchimp)
  • Scheduling services (e.g., Calendly)
  • Web hosting providers (e.g., GoDaddy)
  • Communication platforms (e.g., Zoom, Microsoft Teams)

4. Transfer to Third Countries

Some of our service providers are located outside the EU/EEA. If there is no adequacy decision under Art. 45 GDPR, we ensure appropriate safeguards are in place under Art. 46 GDPR, such as Standard Contractual Clauses.

5. Retention and Deletion

Your personal data will be stored only as long as necessary to fulfill the intended purposes or as legally required (e.g., 6 to 10 years under German tax and commercial laws). Once the storage purpose no longer applies, your data will be deleted or anonymized unless longer storage is required for legal or contractual obligations.

6. Data Security

We take appropriate technical and organizational measures to ensure the security of your personal data. These measures are regularly reviewed and adjusted in line with technological progress.

However, due to the nature of the Internet, data transmissions (e.g., via email) may have security gaps. Therefore, complete protection of data against third-party access cannot be guaranteed.

II. Our Processing Activities

1. Visiting Our Website

When you access our website, the following data is automatically processed:

  • IP address
  • Date and time of request
  • Browser type and version
  • Operating system
  • Referrer URL
  • Host name of the accessing device

Legal basis: Art. 6 (1) (f) GDPR. Our legitimate interest lies in the secure and stable operation of the Website. Log files are deleted after 7 days unless further storage is required for evidentiary purposes.

2. Contact Form / Calendly Booking

When you contact us via the contact form or schedule an appointment via Calendly, we process:

  • Name
  • Email address
  • Your message or booking details

Legal basis: Art. 6 (1) (a) GDPR (consent) or Art. 6 (1) (b) GDPR (pre-contractual steps). Data is deleted after your request is fulfilled unless legal retention obligations apply.

3. Newsletter Subscription

If you subscribe to our newsletter, we process:

  • Name
  • Email address

Legal basis: Art. 6 (1) (a) GDPR (consent). You can withdraw your consent at any time by clicking the “unsubscribe” link in our newsletter.

4. Cookies and Analytics

Our website uses cookies and Google Analytics (anonymized IP). Data processed:

  • IP address (anonymized)
  • Usage data (pages visited, time spent, etc.)

Legal basis: Art. 6 (1) (a) GDPR (consent via cookie banner). You can revoke your consent at any time by changing your browser settings or adjusting cookie preferences.

5. Embedded Content (LinkedIn Posts)

Embedded content from LinkedIn may collect data such as IP address and browser details.

Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in presenting external content). Activation is voluntary via a two-click mechanism.

6. Video Meetings via Zoom or Microsoft Teams

When you participate in video meetings or webinars hosted via Zoom or Microsoft Teams, we process:

  • Name
  • Email address
  • Audio and/or video (if enabled by you)
  • Metadata (meeting ID, duration, participant list, device data, IP address)

Legal basis: Art. 6 (1) (b) GDPR (performance of contract) or Art. 6 (1) (a) GDPR (consent, if recording is enabled). Recordings, if any, will only take place with prior notice and explicit consent.

7. Submission of Application Documents

When you submit a CV or application materials for potential career opportunities, we process:

  • Name and contact details
  • Curriculum vitae and cover letter content
  • Education and work history
  • Any other information you voluntarily provide

Legal basis: Art. 6 (1) (b) GDPR (pre-contractual steps) and § 26 BDSG. If your application is unsuccessful, your data will be deleted after six months unless you consent to longer retention for future opportunities.

III. Your Rights

Under the GDPR, you have the following rights:

  • Right to 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 object (Art. 21 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to withdraw consent at any time (Art. 7 (3) GDPR)
  • Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)