Privacy Policy

We are very pleased that you have shown interest in our company. Data protection is of particularly high priority for the management of Drachenfels Interactive UG (haftungsbeschränkt). Use of the Drachenfels Interactive UG (haftungsbeschränkt) website is generally possible without providing any personal data. However, if a data subject wishes to make use of special services offered by our company via our website, processing of personal data may become necessary. Where the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, shall always be in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection provisions applicable to Drachenfels Interactive UG (haftungsbeschränkt). By means of this privacy policy, our company would like to inform the public of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed, by means of this privacy policy, of the rights to which they are entitled.

As the controller, Drachenfels Interactive UG (haftungsbeschränkt) has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions may in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us by alternative means as well, for example by telephone.

1. Definitions

The privacy policy of Drachenfels Interactive UG (haftungsbeschränkt) is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

In this privacy policy, we use, among others, the following terms:

personal data — Personal data means any information relating to an identified or identifiable natural person (“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, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
data subject — Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
processing — Processing is any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
restriction of processing — Restriction of processing is the marking of stored personal data with the aim of limiting its processing in the future.
profiling — Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.
pseudonymisation — Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data is not attributed to an identified or identifiable natural person.
controller or controller responsible for the processing — Controller or controller responsible for the processing is 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
processor — Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
recipient — Recipient is a natural or legal person, public authority, agency, or another body to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law are not regarded as recipients.
third party — Third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
consent — Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

2. Controller

Controller within the meaning of the General Data Protection Regulation (GDPR) is:

Drachenfels Interactive UG (haftungsbeschränkt)
Steinstraße 74c
51379 Leverkusen
Germany

Phone: +49 174 1913763
Email: Alexander.Lysek@DrachenfelsInteractive.de
Website: www.DrachenfelsInteractive.de

If you have any questions about data protection, please contact the address given above.

3. Collection of General Data and Information

The Drachenfels Interactive UG (haftungsbeschränkt) website collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server’s log files. The following may be collected:

the browser types and versions used
the operating system used by the accessing system
the website from which an accessing system reaches our website (so-called referrers)
the sub-websites accessed via an accessing system on our website
the date and time of access to the website
an Internet Protocol address (IP address)
the Internet service provider of the accessing system
other similar data and information that may serve to avert danger in the event of attacks on our information technology systems

When using this general data and information, Drachenfels Interactive UG (haftungsbeschränkt) does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website and the advertising for it, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. This anonymously collected data and information is therefore evaluated by Drachenfels Interactive UG (haftungsbeschränkt) statistically, and further with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.

4. Contact Form

If you use our contact form, the data you enter (name, email address, subject, and message) is used to process your inquiry.

Processing: Your input is transmitted to our own server in encrypted form and immediately forwarded from there to our team by email. The data is not permanently stored on the server — the only place it remains is our email inbox.

Processor: To deliver the email, we use the SMTP service of Brevo (Sendinblue SAS, 7 rue de Madrid, 75008 Paris, France). Brevo acts as a processor pursuant to Art. 28 GDPR; your data is not processed by Brevo for its own purposes. As Brevo is based within the EU, no transfer to a third country takes place.

Legal basis: Art. 6(1)(b) GDPR (processing of a pre-contractual inquiry) and Art. 6(1)(f) GDPR (legitimate interest in responding to contact inquiries).

Storage period: Your data remains in our email inbox for as long as necessary to process your inquiry and is deleted afterwards.

5. Hosting

This website is hosted on our own server (VPS). In this context, technical data such as IP addresses and access times may be processed as part of the server log files (see Section 3).

Self-Hosted Fonts

This website uses the “Inter” typeface, which is delivered as part of the website from our own server. There is no connection to Google Fonts or any other external font service, so no personal data is transmitted to third parties in this regard.

6. Cookies and Tracking

This website does not use cookies and does not use tracking. No analytics, marketing, or targeting tools are employed. A cookie consent banner is therefore not required.

7. Routine Erasure and Blocking of Personal Data

The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as provided for by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the storage purpose no longer applies, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with statutory requirements.

8. Rights of the Data Subject

a) Right of Confirmation

Each data subject shall have the right granted by the European legislator to obtain confirmation from the controller as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they may contact any employee of the controller at any time.

b) Right of Access

Each data subject shall have the right granted by the European legislator to obtain free information from the controller about their personal data stored at any time, as well as a copy of that information. Furthermore, the European directives and regulations grant the data subject access to the following information:

the purposes of the processing
the categories of personal data concerned
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
where possible, the envisaged period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period
the existence of the right to request rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing
the existence of the right to lodge a complaint with a supervisory authority
where the personal data is not collected from the data subject, any available information as to its source
the existence of automated decision-making, including profiling, referred to in Art. 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject

The data subject also has the right to obtain information as to whether personal data is transferred to a third country or to an international organisation. Where this is the case, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, they may contact any employee of the controller at any time.

c) Right to Rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller, without undue delay, the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject also has the right to have incomplete personal data completed, including by means of a supplementary statement.

If a data subject wishes to exercise this right to rectification, they may contact any employee of the controller at any time.

d) Right to Erasure (Right to Be Forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller is obliged to erase personal data without undue delay where one of the following grounds applies and processing is not necessary:

The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
The data subject withdraws the consent on which the processing was based pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
The personal data has been processed unlawfully.
The personal data must be erased to comply with a legal obligation under Union or Member State law to which the controller is subject.
The personal data was collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.

If one of the aforementioned reasons applies and a data subject wishes to request the erasure of personal data stored by Drachenfels Interactive UG (haftungsbeschränkt), they may contact any employee of the controller at any time. An employee of Drachenfels Interactive UG (haftungsbeschränkt) will ensure that the erasure request is complied with immediately.

Where the controller has made the personal data public and is obliged pursuant to Art. 17(1) GDPR to erase it, the controller shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure of any links to, or copies or replications of, that personal data, insofar as processing is not required. An employee of Drachenfels Interactive UG (haftungsbeschränkt) will arrange the necessary measures on a case-by-case basis.

e) Right to Restriction of Processing

Each data subject shall have the right granted by the European legislator to obtain restriction of processing from the controller where one of the following applies:

The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead.
The controller no longer needs the personal data for the purposes of processing, but the data subject requires it for the establishment, exercise, or defence of legal claims.
The data subject has objected to processing pursuant to Art. 21(1) GDPR pending verification of whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met and a data subject wishes to request the restriction of processing of personal data stored by Drachenfels Interactive UG (haftungsbeschränkt), they may contact any employee of the controller at any time. The employee of Drachenfels Interactive UG (haftungsbeschränkt) will arrange the restriction of processing.

f) Right to Data Portability

Each data subject shall have the right granted by the European legislator to receive the personal data concerning them, which they provided to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to which the personal data was provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, or on a contract pursuant to Art. 6(1)(b) GDPR, and the processing is carried out by automated means, provided the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible and provided this does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may contact any employee of Drachenfels Interactive UG (haftungsbeschränkt) at any time.

g) Right to Object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to their particular situation, at any time, to the processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

Drachenfels Interactive UG (haftungsbeschränkt) will no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or the processing serves the establishment, exercise, or defence of legal claims.

If Drachenfels Interactive UG (haftungsbeschränkt) processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing. This also applies to profiling, insofar as it is related to such direct marketing. If the data subject objects to Drachenfels Interactive UG (haftungsbeschränkt) regarding processing for direct marketing purposes, Drachenfels Interactive UG (haftungsbeschränkt) will no longer process the personal data for these purposes.

The data subject also has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them carried out by Drachenfels Interactive UG (haftungsbeschränkt) for scientific or historical research purposes, or for statistical purposes pursuant to Art. 89(1) GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact any employee of Drachenfels Interactive UG (haftungsbeschränkt) directly. The data subject is also free, in connection with the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.

h) Automated Individual Decision-Making, Including Profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, provided the decision (1) is not necessary for entering into or performing a contract between the data subject and the controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into or performing a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Drachenfels Interactive UG (haftungsbeschränkt) shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.

If the data subject wishes to exercise rights relating to automated individual decision-making, they may contact any employee of Drachenfels Interactive UG (haftungsbeschränkt) at any time.

Each data subject shall have the right granted by the European legislator to withdraw their consent to the processing of their personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, they may contact any employee of Drachenfels Interactive UG (haftungsbeschränkt) at any time.

Right to Lodge a Complaint with the Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority. The supervisory authority responsible for us is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW) Kavalleriestraße 2–4 40213 Düsseldorf, Germany www.ldi.nrw.de

9. Legal Basis for the Processing

Art. 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or the provision of any other service, the processing is based on Art. 6(1)(b) GDPR. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in response to enquiries about our products or services. If our company is subject to a legal obligation by which the processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance details, or other vital information had to be passed on to a doctor, hospital, or other third party. In that case, the processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations may be based on Art. 6(1)(f) GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal grounds, where processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests, fundamental rights, and freedoms of the data subject. Such processing operations are expressly permitted because they are specifically mentioned by the European legislator, who considered that a legitimate interest could be assumed where the data subject is a client of the controller (Recital 47, sentence 2 GDPR).

10. Legitimate Interests Pursued by the Controller or a Third Party

Where the processing of personal data is based on Art. 6(1)(f) GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.

11. Period for Which the Personal Data Will Be Stored

The criterion used to determine the period for which personal data is stored is the respective statutory retention period. After expiry of that period, the corresponding data is routinely deleted, provided it is no longer required for the performance of a contract or the initiation of a contract.

12. Statutory or Contractual Requirements to Provide Personal Data; Necessity for the Conclusion of a Contract; Obligation of the Data Subject to Provide the Personal Data; Possible Consequences of Failure to Provide It

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner). It may sometimes be necessary, in order to conclude a contract, for a data subject to provide us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact an employee of ours. Our employee will explain to the data subject, on a case-by-case basis, whether the provision of personal data is required by law or by contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of not providing it.

13. Existence of Automated Decision-Making

As a responsible company, we do not use automated decision-making or profiling.

14. Changes to This Privacy Policy

We reserve the right to amend this privacy policy to ensure it always complies with current legal requirements, or to reflect changes to our website. The version in effect at the time of your next visit shall apply.

Last updated: July 2026

Developed by the Legal Tech specialists at Willing & Able, who also developed the system for privacy-compliant, legally sound time tracking. The texts of the privacy policy generator were created and published by Prof. Dr. h.c. Heiko Jonny Maniero and attorney Christian Solmecke.