Part 1: Legal Notice (Impressum)
This website is jointly operated and represented by the following founders:
Founders & Joint Operators:
Lena Reichwein
Elbestraße 15
65604 Elz, Germany
Email: [email protected]
Sumesh Peringeth
C1702, 55 Quach Giai, District 2
Ho Chi Minh City, 70000, Vietnam]
Company in Formation Notice:
The founders operate this website as a joint partnership on behalf of Kaaluna OÜ (currently in formation in Estonia). Upon completion of the commercial registry process in Tallinn, the legal entity and data controller details will be updated accordingly.
Part 2: Privacy Policy (GDPR)
We take the protection of your personal data very seriously. This policy explains how we process data when you visit our website and sign up for our app waitlist.
1. Data Controllers
The responsible data controllers for this website under Art. 4 No. 7 GDPR are the individuals listed in the Legal Notice (Part 1) above, acting as joint controllers.
2. Collection and Processing of Personal Data
When you use this website, we collect data in two ways:
- Waitlist Subscription: If you enter your email address to join the "52 Weeks" waitlist, we collect your email address. The legal basis for this processing is your explicit consent according to Art. 6 para. 1 lit. a GDPR, verified via a Double Opt-In process.
- Server Logs & Security: When accessing our site, technical log files (IP address, browser type, timestamp) are automatically processed to ensure website stability and security. The legal basis is our legitimate interest according to Art. 6 para. 1 lit. f GDPR.
3. Data Processors & Third Parties
To operate this website efficiently, we forward data to the following service providers under strict Data Processing Agreements (DPA) within the EU:
- Cloudflare Inc.: We use Cloudflare Pages for secure web hosting and content delivery. While Cloudflare is a US company, data routing and hosting are handled in accordance with EU standard contractual clauses to ensure GDPR compliance.
- Brevo (Sendinblue GmbH): Our newsletter and waitlist software. Brevo is located in Germany/France, meaning all email addresses are stored on secure servers within the European Union and are fully protected under EU law.
4. International Data Transfers
As a global team, technical access to the waitlist administration may occasionally be performed by the co-founder located in Vietnam. To ensure full compliance with Art. 44 GDPR, all internal management and access are strictly governed by EU Standard Contractual Clauses (SCCs) to maintain the same high level of data protection outside the EU.
5. Retention Period
We store your email address only for as long as your consent is active. If you do not click the confirmation link in the Double Opt-In email, your data will be automatically deleted within 30 days. If you confirm, we store your data until you unsubscribe from the waitlist.
6. Your Rights Under GDPR
You have the following rights at any time, free of charge:
- Art. 15 GDPR: Right to access your stored data.
- Art. 16 & 17 GDPR: Right to rectify or delete your data.
- Art. 21 GDPR: Right to object to data processing.
- Right to Withdraw: You can withdraw your consent to receive emails at any time by clicking the "Unsubscribe" link at the bottom of any email.
To exercise your rights, simply send an email to [email protected].