Privacy Policy

1. Controller

Andre Witte
Herzogstraße 4
41747 Viersen
Germany

Email: info@calpager.com
Phone: +49 152 55426037

2. Data Protection Officer

A Data Protection Officer has not been appointed as the legal requirements pursuant to § 38 BDSG (German Federal Data Protection Act) are currently not met.

For data protection enquiries please contact: info@calpager.com

3. Collection and Storage of Personal Data

3.1 Upon Registration

We collect the following data during registration:

• Email address (mandatory)
• Name (first and last name)
• Address (street, postal code, city, country)
• Company data and VAT ID where applicable for business customers
• Payment information (processed directly by the payment provider)

3.2 During Use of the Service

• Usage data (login times, IP addresses, browser type, operating system)
• Calendar data and appointments
• Customer data (as entered by the user)
• Technical log data (server logs)

3.3 Automatically Collected Data

When visiting our website, the following data is automatically collected:

• IP address (stored anonymised)
• Date and time of access
• Page visited / URL
• Referrer URL
• Browser and operating system used

4. Legal Basis for Data Processing

Purpose	Legal Basis
Contract fulfilment and account management	Art. 6(1)(b) GDPR
Invoicing and tax obligations	Art. 6(1)(c) GDPR
Service improvement and bug fixing	Art. 6(1)(f) GDPR (legitimate interest)
Analytics cookies and marketing	Art. 6(1)(a) GDPR (consent)
IT security and abuse prevention	Art. 6(1)(f) GDPR (legitimate interest)

5. Disclosure of Data to Third Parties

5.1 We only share your data with third parties in the following cases:

• Data processors: Hosting provider, payment provider and email service provider that process data on our behalf (Art. 28 GDPR).
• Legal obligation: Where we are legally required to do so (e.g. to tax authorities or by court order).

5.2 Transfer to third countries (outside the EEA) only takes place where an adequacy decision of the EU Commission exists or appropriate safeguards pursuant to Art. 46 GDPR are in place (e.g. EU Standard Contractual Clauses).

6. Retention Periods

Data Category	Retention Period
Contract data	Duration of the contractual relationship + statutory retention periods (6–10 years)
Invoice data	10 years (§ 147 AO, § 257 HGB)
Usage data / server logs	90 days
Consent records	3 years after revocation or end of contract (proof obligation)

7. Your Rights as a Data Subject

You have the following rights vis-à-vis the controller:

• Access (Art. 15 GDPR) – information about the data stored about you
• Rectification (Art. 16 GDPR) – of inaccurate or incomplete data
• Erasure (Art. 17 GDPR) – unless statutory retention obligations apply
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR) – receipt of your data in a common, machine-readable format
• Objection (Art. 21 GDPR) – to processing based on legitimate interests
• Withdrawal of consent (Art. 7(3) GDPR) – at any time with effect for the future

You may exercise your rights by email to info@calpager.com.

Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your data. The competent supervisory authority is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestraße 2-4
40213 Düsseldorf
https://www.ldi.nrw.de

8. Cookies and Tracking

8.1 Technically Necessary Cookies

We use technically necessary cookies for the operation of the service (e.g. session cookies, CSRF protection). These cookies are required for functionality and cannot be deactivated.

8.2 Analytics and Marketing Cookies

Analytics cookies (e.g. for measuring page views) and marketing cookies are only set with your explicit consent. You may revoke your consent at any time via the cookie banner or in your privacy settings.

8.3 Cookie Management

You may also manage or delete cookies through your browser settings. Please note that deactivating technically necessary cookies may impair the functionality of the service.

9. Data Security

9.1 All data transmissions are encrypted with TLS 1.2 or higher.

9.2 Passwords are hashed and salted using Argon2id.

9.3 We perform regular backups and security audits.

9.4 Access to personal data is restricted to authorised personnel (need-to-know principle).

10. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy as needed to adapt it to changed legal requirements or changes to the service. The current version is always available on the privacy page of our website.

11. Contact

For data protection enquiries:
info@calpager.com