Privacy Policy

1. Privacy at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. For detailed information on the subject of data protection, please refer to our privacy policy set out below.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator's contact details in the section "Information on the Responsible Party" in this privacy policy.

How do we collect your data?

Some data is collected when you provide it to us. This could, for example, be data you enter in a contact form or data submitted when booking an appointment through our scheduling tool.

Other data is collected automatically or with your consent when you visit the website by our IT systems. This is primarily technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior. In addition, we use a Customer Relationship Management system (CRM) to manage and maintain customer relationships.

What rights do you have regarding your data?

You have the right to receive information about the origin, recipient, and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and other questions on the subject of data protection.

Analytics Tools and Third-Party Tools

When visiting this website, your surfing behavior may be statistically analyzed. This is primarily done with analytics programs. These analytics programs are generally only used with your consent.

Detailed information on these analytics programs can be found in the following privacy policy.

2. Hosting

Web Hosting

This website is hosted by the following provider:

STRATO AG Pascalstraße 10 10587 Berlin, Germany

Further information can be found in STRATO's privacy policy: https://www.strato.de/datenschutz/

The personal data collected on this website is stored on the host's servers. This may include IP addresses, contact requests, meta and communication data, website access, and other data generated through a website.

The use of STRATO is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable provision of our website possible. Where corresponding consent has been obtained, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG (German Telecommunications-Telemedia Data Protection Act); consent can be revoked at any time.

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) with the above-mentioned provider. This is a contract required by data protection law, which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Content Management System (CMS)

We use the HubSpot Content Management System for managing and delivering the content of this website. The provider is HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA. The European subsidiary is HubSpot Ireland Limited, 1 Sir John Rogerson's Quay, Dublin 2, Ireland.

The data in our HubSpot account is stored on servers in the European Union (Germany). When you visit our website, your browser establishes a connection to HubSpot's servers, during which technical data (e.g., IP address, browser type, page views) is automatically collected and processed.

The use of HubSpot CMS is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the professional and efficient management of our website. Where corresponding consent has been obtained, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG; consent can be revoked at any time.

Data transfers to the USA are based on the EU-US Data Privacy Framework (DPF). HubSpot is certified under the DPF. In addition, the Standard Contractual Clauses (SCCs) of the EU Commission apply. Details can be found at: https://legal.hubspot.com/dpa

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) with HubSpot. Details can be found at: https://legal.hubspot.com/dpa

3. General Information and Mandatory Disclosures

Data Protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the Internet (e.g., communication by email) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information on the Responsible Party

The responsible party for data processing on this website is:

Peter Vogel peppereffect Provinzialstraße 41 46499 Hamminkeln, Germany

Phone: 00491637096754 Email: info@peppereffect.com

The responsible party is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data (e.g., names, email addresses, etc.).

Storage Duration

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General Information on the Legal Basis for Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data according to Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If data processing is necessary for the performance of a contract or for pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if data processing is necessary for compliance with a legal obligation, we process your data on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.

Information on Data Transfers to the USA and Other Third Countries

Our website includes tools from companies based in the USA or other third countries that are not considered secure from a data protection perspective. When these tools are active, your personal data may be transferred to and processed in these third countries. We would like to point out that no level of data protection comparable to that of the EU can be guaranteed in these countries.

Where the respective companies are certified under the EU-US Data Privacy Framework (DPF), this constitutes an appropriate basis for data transfers in accordance with the EU Commission's adequacy decision of July 10, 2023. For companies not certified under the DPF, we base the data transfer on the Standard Contractual Clauses (SCCs) of the EU Commission. These are available at: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847

We would like to point out that even with adequate safeguards, it cannot be ruled out that US authorities (e.g., intelligence services) may process, evaluate, and permanently store your data on US servers for surveillance purposes. We have no influence over these processing activities.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You may revoke any consent you have already given at any time. The lawfulness of the data processing carried out before the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged violation. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedies.

The supervisory authority responsible for us is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia) Postfach 20 04 44 40102 Düsseldorf, Germany https://www.ldi.nrw.de/

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of data to another controller, this will only be done to the extent technically feasible.

SSL/TLS Encryption

For security reasons and to protect the transmission of confidential content, such as inquiries you send to us as the website operator, this site uses SSL/TLS encryption. You can recognize an encrypted connection by the fact that the browser's address bar changes from "http://" to "https://" and by the lock icon in your browser bar.

When SSL/TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Information, Deletion, and Correction

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing and, if applicable, a right to correction or deletion of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

• If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of deletion.
• If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
• If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may — apart from its storage — only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

Objection to Unsolicited Emails

The use of contact data published in the context of the imprint obligation for sending advertising and information materials that have not been expressly requested is hereby objected to. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as spam emails.

4. Data Collection on This Website

Cookies

Our websites use so-called "cookies." Cookies are small text files and do not cause any damage to your device. They are stored either temporarily for the duration of a session (session cookies) or permanently (persistent cookies) on your device. Session cookies are automatically deleted after your visit. Persistent cookies remain stored on your device until you delete them yourself or automatic deletion by your web browser occurs.

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them. Other cookies are used to evaluate user behavior or display advertising.

Cookies that are necessary for carrying out the electronic communication process, for providing certain functions you have requested, or for optimizing the website (e.g., cookies for storing your cookie consent preferences) are stored on the basis of § 25(2) TTDSG (German Telecommunications-Telemedia Data Protection Act) in conjunction with Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing technically necessary cookies for the technically error-free and optimized provision of its services.

Cookies that are not technically necessary (e.g., cookies for analytics or advertising purposes) are only set with your express consent (§ 25(1) TTDSG in conjunction with Art. 6(1)(a) GDPR). Consent can be revoked at any time.

You can set your browser to inform you about the setting of cookies and only allow cookies on a case-by-case basis, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

Cookie Consent with HubSpot Cookie Banner

Our website uses the HubSpot cookie consent tool to obtain your consent for the storage of certain cookies on your device and to document this in compliance with data protection regulations. The provider of this technology is HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA (hereinafter "HubSpot").

When you enter our website, you will be informed via a banner about the use of cookies and asked for your consent for non-technically necessary cookies. Non-necessary cookies and tracking technologies (including HubSpot Analytics) are only activated after your express consent (opt-in). HubSpot stores a cookie in your browser to assign the consents you have given or their revocation.

The data collected is stored until you request deletion, delete the cookie yourself, or the purpose for data storage no longer applies. Mandatory legal retention obligations remain unaffected.

The use of the HubSpot Cookie Banner is carried out to obtain the legally required consents for the use of cookies. The legal basis for this is § 25(1) TTDSG in conjunction with Art. 6(1)(c) GDPR.

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• Browser type and browser version
• Operating system used
• Referrer URL
• Hostname of the accessing computer
• Time of the server request
• IP address

This data is not merged with other data sources.

The collection of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website — for this purpose, the server log files must be collected.

HubSpot CRM

We use HubSpot as a Customer Relationship Management system (CRM) on this website. The provider is HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA. The European subsidiary is HubSpot Ireland Limited, 1 Sir John Rogerson's Quay, Dublin 2, Ireland (hereinafter "HubSpot").

CRM data is hosted on servers in the European Union (Germany).

HubSpot enables us to manage existing and potential customers as well as customer contacts. With HubSpot, we are able to capture, sort, and analyze customer interactions via email, phone, or through the website. The personal data collected in this way may be used for communication with potential customers.

We use the following HubSpot features on this website:

HubSpot Forms: When you send us inquiries via the contact form, your details from the inquiry form, including the contact data you provide, are stored in our HubSpot CRM for the purpose of processing the inquiry and for follow-up questions. We do not share this data without your consent.

HubSpot Meeting Tool: Through our scheduling tool, you can book an appointment with us directly. The data you enter (e.g., name, email address, preferred appointment) is transmitted to HubSpot and stored in our CRM.

HubSpot Analytics: HubSpot uses its own tracking cookies to analyze user behavior on our website (e.g., page views, time on site, origin of the user). These cookies are only set after your consent via the cookie banner (opt-in). HubSpot analytics data is stored in our EU-hosted CRM account.

The processing of this data is based on Art. 6(1)(b) GDPR if your inquiry is related to the performance of a contract or is necessary for pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective management of customer relationships (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.

The data you submit to us will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies. Mandatory legal provisions — in particular retention periods — remain unaffected.

Data transfers to the USA are based on the EU-US Data Privacy Framework (DPF). In addition, the Standard Contractual Clauses (SCCs) of the EU Commission apply. Details: https://legal.hubspot.com/dpa

Details on HubSpot's privacy policy: https://legal.hubspot.com/privacy-policy

Data Processing Agreement: We have concluded a Data Processing Agreement (DPA) with HubSpot. This is a contract required by data protection law, which ensures that HubSpot processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Note on AI-Assisted Data Processing by HubSpot

HubSpot provides AI-powered features within its platform (under the name "Breeze AI"). These features are enabled by default in HubSpot accounts and include AI-assisted text generation, data analysis, and assistance functions for internal purposes.

We would like to point out that:

• No AI-powered chatbot or other AI-based communication tool is used on our website. Visitors do not interact with an AI system at any point.
• HubSpot's AI features may be used internally (e.g., to assist in content creation or CRM data analysis). No automated decision-making within the meaning of Art. 22 GDPR that produces legal effects concerning you or similarly significantly affects you takes place.
• For information on how HubSpot processes AI data, please visit: https://legal.hubspot.com/privacy-policy and the HubSpot AI Trust FAQs: https://www.hubspot.com/artificial-intelligence

The legal basis for the use of AI-powered features for internal data processing is Art. 6(1)(f) GDPR. We have a legitimate interest in the efficient management and analysis of our customer relationships.

Inquiries by Email, Phone, or Fax

If you contact us by email, phone, or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of handling your request. We do not share this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR if your inquiry is related to the performance of a contract or is necessary for pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested.

The data you send to us via contact inquiries will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been fully processed). Mandatory legal provisions — in particular statutory retention periods — remain unaffected.

5. Analytics Tools

Google Analytics 4

This website uses features of the web analytics service Google Analytics 4. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics 4 enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as page views, time on site, operating systems used, and the origin of the user.

Google Analytics 4 uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g., cookies or device fingerprinting). The information collected by Google about the use of this website is generally transferred to and stored on a Google server in the USA.

Google Consent Mode v2: Google Consent Mode v2 is implemented on our website. This ensures that Google Analytics does not set cookies and does not store personal data unless you have given your consent via the HubSpot Cookie Banner. The Consent Mode parameters "ad_storage," "analytics_storage," "ad_user_data," and "ad_personalization" are set to "denied" by default and are only changed to "granted" upon consent.

Please note that the Google Analytics script (gtag.js) technically establishes a connection to Google's servers when the website loads, during which your IP address is transmitted. Without your consent, however, no tracking or storage of personal data by Google Analytics takes place.

The use of this analytics tool is based on § 25(1) TTDSG in conjunction with Art. 6(1)(a) GDPR. Consent can be revoked at any time via the cookie banner.

Data transfers to the USA are based on the EU-US Data Privacy Framework (DPF). Google LLC is certified under the DPF. In addition, the Standard Contractual Clauses (SCCs) of the EU Commission apply. Details: https://privacy.google.com/businesses/controllerterms/mccs/

Browser Plugin: You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

More information on how Google Analytics handles user data can be found in Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=en

Data Processing Agreement: We have concluded a data processing agreement with Google and fully implement the requirements of the German data protection authorities when using Google Analytics.

6. Plugins and Tools

Google Web Fonts (Local Hosting)

This website uses so-called Google Web Fonts for the uniform display of fonts. Google Fonts are served locally through the HubSpot CMS (via the path /_hcms/googlefonts/). No direct connection to Google's servers is established. Your IP address is not transmitted to Google.

Further information on Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google's privacy policy: https://policies.google.com/privacy?hl=en

External Libraries (CDN)

This website uses the JavaScript library "AOS" (Animate On Scroll) for scroll animations. This library is loaded from the external CDN service unpkg.com, which is operated by Cloudflare, Inc. (101 Townsend Street, San Francisco, CA 94107, USA).

When you access a page, your browser establishes a connection to the servers of unpkg.com/Cloudflare. Your IP address is transmitted to Cloudflare in this process.

The use is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the correct display of animations on our website.

Information on data protection at Cloudflare can be found at: https://www.cloudflare.com/privacypolicy/

7. Audio and Video Conferencing

Data Processing

For communication with our customers, we use online conference tools. The specific tools we use are listed below. When you communicate with us via video or audio conference over the Internet, your personal data is collected and processed by us and by the provider of the respective conference tool.

The conference tools collect all data that you provide/use for using the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants, and other "context information" related to the communication process (metadata).

In addition, the provider of the tool processes all technical data necessary for handling online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speakers, and the type of connection.

If content is exchanged, uploaded, or otherwise made available within the tool, this is also stored on the servers of the tool providers. Such content includes, in particular, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards, and other information shared during the use of the service.

Please note that we do not have full control over the data processing operations of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider.

Purpose and Legal Basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Where consent has been requested, the relevant tools are used on the basis of this consent; consent can be revoked at any time with effect for the future.

Storage Duration

Data collected directly by us through video and conference tools is deleted from our systems as soon as you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies. Stored cookies remain on your device until you delete them. Mandatory legal retention periods remain unaffected.

We have no influence on the storage duration of your data stored by the conference tool operators for their own purposes. For details, please contact the conference tool operators directly.

Zoom

We use Zoom. The provider of this service is Zoom Video Communications, Inc., 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA.

Details on data processing can be found in Zoom's privacy policy: https://explore.zoom.us/en/privacy/

Data transfers to the USA are based on the EU-US Data Privacy Framework (DPF). Zoom is certified under the DPF. In addition, the Standard Contractual Clauses (SCCs) of the EU Commission apply.

Note on AI Features: Zoom optionally offers AI-powered features (e.g., "Zoom AI Companion" for meeting summaries). We do not currently use these features actively. Should changes occur, we will update this privacy policy accordingly.

Data Processing Agreement: We have concluded a data processing agreement with Zoom and fully implement the requirements of the German data protection authorities when using Zoom.

8. Processing of Customer and Contract Data

We collect, process, and use personal data only insofar as they are necessary for the establishment, content arrangement, or modification of the legal relationship (inventory data). This is carried out on the basis of Art. 6(1)(b) GDPR, which permits the processing of data for the fulfillment of a contract or pre-contractual measures. We collect, process, and use personal data about the use of this website (usage data) only insofar as this is necessary to enable or bill the user for the use of the service.

The collected customer data is deleted after the completion of the order or the termination of the business relationship. Statutory retention periods remain unaffected.

9. Note on the EU AI Act

peppereffect is a digital agency specializing in AI-powered marketing solutions. In the interest of transparency, we would like to point out that no AI systems are used on this website with which visitors interact directly. There is no chatbot, no automated decision-making system, and no AI-based customer communication tool on this website.

To the extent that we use AI-powered tools internally (e.g., to assist in content creation or data analysis within our CRM system), this is always done under human supervision and without automated decision-making within the meaning of Art. 22 GDPR that directly affects you as a data subject.

We continuously monitor the requirements of the EU AI Act (Regulation (EU) 2024/1689) and will adapt this privacy policy as needed.

Last updated: February 2026