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Information under Art. 13 and 14 GDPR

Privacy Policy

This Privacy Policy describes how FW Delta LLC collects, uses, and protects your personal data in accordance with the General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (FADP), and applicable national data protection laws.

We take your privacy seriously and are committed to protecting your personal information. This policy provides transparent information about our data processing activities as required by Art. 13 and Art. 14 GDPR.

Effective: July 29, 2026 Jurisdiction: EU/EEA, CH Version 2.3

01. Data Controller and Contact

The controller responsible for the processing of your personal data within the meaning of Art. 4(7) GDPR and Art. 5(i) FADP is:

Legal Entity

FW Delta LLC

30 N Gould St Ste 60388

Sheridan, WY 82801

United States

Filing ID: 2026-001873879

Contact

Fabian Weiss

Managing Member

legal@fwdelta.com

For questions about the processing of your personal data, you can write to this address directly.

02. Scope of Application

This Privacy Policy applies to the processing of personal data:

  • When you visit our website (fwdelta.com and all subdomains)
  • When you use our contact forms or send us emails
  • When you request quotes or engage our services
  • When you interact with our content on social media platforms

This policy does not apply to third-party websites linked from our site. We recommend reviewing the privacy policies of any external websites you visit.

04. Categories of Personal Data

We process the following categories of personal data:

Identity Data

Essential
  • Full name
  • Email address
  • Company name
  • Job title
  • Postal address
  • Phone number

Communication Data

Optional
  • Email correspondence
  • Contact form messages
  • Chat transcripts
  • Support tickets
  • Meeting notes

Technical Data

Essential
  • IP address (truncated before sharing)
  • Browser type and version
  • Operating system
  • Device type
  • Screen resolution
  • Language preferences

Usage Data

Optional
  • Pages visited
  • Time spent on pages
  • Click behavior
  • Referrer URL
  • Search queries
  • Session duration

Transaction Data

Optional
  • Project details
  • Payment information
  • Invoice data
  • Contract documents

Marketing Data

Optional
  • Email open rates
  • Link clicks
  • Campaign engagement
  • Communication preferences

05. Processing Purposes

We process your personal data for website operation, service delivery, analytics, marketing (with consent), and legal compliance. Each purpose has specific retention periods and legal bases.

06. Hosting Infrastructure

EU-Exclusive Infrastructure

All our servers and databases are hosted exclusively at Hetzner, in data centres in Germany (Falkenstein, Nuremberg). We do not use US-based cloud providers for storing personal data.

Hosting Provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany

We have a Data Processing Agreement (DPA) with Hetzner in accordance with Art. 28 GDPR. The ISO/IEC 27001:2022 certification is held by Hetzner for its data centres; it is not a certification of FW Delta LLC.

07. Server-Side Tracking Architecture

Privacy-First Data Proxying

Unlike conventional client-side tracking, your browser does not communicate directly with third-party services. Measurement data is collected and evaluated on our own servers in Germany. Where data is transmitted onward at all, it is filtered and pseudonymized beforehand on the server side.

Protection Measures:

IP Truncation

IP addresses are truncated before they are passed on to third-party services. This makes attribution to an individual considerably harder.

Pseudonymization

Identifiers such as email addresses are hashed with SHA-256 before transmission. Hashed data remains personal data under data protection law and is only transmitted after consent.

User-Agent Generalization

Detailed device data is reduced to general categories to prevent fingerprinting.

Cookieless Measurement

The reach measurement of our public website sets no cookies and stores no identifiers on your device. Data is only passed on to third-party services after consent.

08. Reach Measurement

To measure the use of our website, we operate our own cookieless reach measurement. It runs entirely on our own infrastructure in Germany. We do not use any third-party analytics or advertising services on our public website.

In-House, Cookieless Measurement

  • The measurement script is served from our own servers. Your browser does not communicate with third parties for this purpose.
  • No cookies are set and no identifiers are stored on your device.
  • Evaluation takes place in aggregated form. We do not build cross-device profiles and do not recognise you across other websites.
  • The measurement data is not passed on to third parties and is not used for advertising purposes.

Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in a data-minimising analysis of the use of our website.

09. Newsletter

You can subscribe to our newsletter through the signup forms on our website. The purpose of the processing is to send specialist analyses and updates from FW Delta by email. The legal basis is your consent under Art. 6(1)(a) GDPR.

Confirmation procedure (double opt-in)

After you sign up we send you an email containing a confirmation link. Your consent only takes effect once you click that link, and only then will you receive messages from us.

If you do not confirm, the address is never written to. The link is valid for seven days and can be used only once. We store the time the email was sent and the time of confirmation in order to demonstrate consent under Art. 7(1) GDPR.

What we store when you sign up

  • Email address: the address you entered.
  • Language: the language version you signed up through (German or English).
  • Signup origin: an identifier for the form the signup was submitted from.
  • Source article: the short name (slug) of the article you signed up from, where the signup came from an article.
  • Category: the topic category of that article.
  • Time of signup: the date and time of the entry.
  • Consent text: the wording shown to you at the time of signup.
  • Consent text version: an identifier that allows the wording shown to be attributed.
  • Status: the processing state of the signup.

Why we also store the source article and the consent text

Origin, source article, category, time, and the consent text with its version document when and on what basis you gave your consent. Under Art. 7(1) GDPR we must be able to demonstrate that consent was given and which wording was shown to you at the time.

Withdrawal

You may withdraw your consent at any time with effect for the future. An informal email to legal@fwdelta.com is sufficient. This does not affect the lawfulness of processing carried out before the withdrawal.

Retention

We store your signup data until you withdraw your consent. After a withdrawal the signup is deleted. We retain the record of consent beyond that for as long as we need it to meet our accountability obligation under Art. 5(2) GDPR.

10. Data Recipients

We share data with IT service providers, payment processors, professional advisors, and public authorities (when legally required). All recipients are bound by strict contractual obligations. We do not pass the data from our reach measurement on to third parties.

11. Data Retention Periods

We retain personal data only as long as necessary:

Server Access Logs

7 days, up to 30 days in part

Automatic deletion. Security-relevant logs are retained for up to 30 days.

Reach Measurement Data

Aggregated

Evaluated in aggregated form only, no long-term storage of personal data

Contact Form Inquiries

3 years

After last contact, unless contract exists

Email Correspondence

3 years

After last contact, unless contract exists

Contract Documents

10 years

Legal retention obligation

Invoices & Accounting

10 years

Legal retention requirement

Language choice (fwd-lang cookie)

12 months

Strictly necessary so the site appears in the chosen language

Marketing Consent

Until withdrawn

Active consent required

Newsletter Signups

Until withdrawn

After withdrawal the signup is deleted. The record of consent is retained beyond that to meet our accountability obligation.

Encrypted Backups

30 days

Rolling backup retention

Project Files

5 years

After completion, for warranty purposes

12. Security Measures

We implement comprehensive security measures in accordance with Art. 32 GDPR:

Transport Layer Security

TLS 1.3 encryption for all data in transit. HTTP Strict Transport Security (HSTS) enforced.

Data Encryption at Rest

AES-256 encryption for all databases and file storage. Full disk encryption on all servers.

Access Control

Role-based access control (RBAC) with least privilege. Mandatory 2FA for all admin access.

Network Security

Dedicated firewall with strict rules. Intrusion Detection System and DDoS protection.

Backup & Recovery

Encrypted backups of the production systems at regular intervals. Rolling retention of 30 days.

Security Monitoring

Automated monitoring with alerting. Response by FW Delta within the agreed service hours.

13. Automated Decision-Making

No Automated Decisions

We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you, as defined in Art. 22 GDPR.

14. Your Data Subject Rights

Under GDPR and Swiss FADP, you have the following rights:

Right of Access (Art. 15 GDPR)

You have the right to obtain information about your personal data stored by us.

Right to Rectification (Art. 16 GDPR)

You may request correction of inaccurate data or completion of incomplete data.

Right to Erasure (Art. 17 GDPR)

You may request deletion of your personal data, subject to legal retention obligations.

Right to Data Portability (Art. 20 GDPR)

You have the right to receive your data in a structured, machine-readable format (JSON).

Right to Restriction of Processing (Art. 18 GDPR)

You may request that we restrict the processing of your data, for example while the accuracy of that data is being verified.

Right to Withdraw Consent (Art. 7(3) GDPR)

You may withdraw any consent you have given at any time with effect for the future. This does not affect the lawfulness of processing carried out before the withdrawal.

Right to Object (Art. 21 GDPR)

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is carried out on the basis of Art. 6(1)(f) GDPR.

If we process your data for direct marketing purposes, you have the right to object at any time without giving reasons. We will then no longer process your data for those purposes. An objection can be sent informally to legal@fwdelta.com.

Exercise Your Rights

To exercise any of these rights, please contact us at:

legal@fwdelta.com

We will respond within 30 days. Exercising your rights is free of charge.

15. Minors' Data

Our services are directed at business clients. We do not knowingly collect data from individuals under 16 without parental consent. If you believe we have collected data from a minor, please contact us immediately.

16. Changes to This Privacy Policy

We may update this policy to reflect changes in legal requirements or technical developments. Material changes will be communicated via email or prominent website notice.

Current Version

Version 2.3

July 29, 2026

17. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority:

Germany

The state data protection authority responsible for your place of residence. An overview is maintained by the Datenschutzkonferenz.

www.datenschutzkonferenz-online.de →

Austria

Austrian Data Protection Authority

www.dsb.gv.at →

Switzerland

Federal Data Protection Commissioner (FDPIC)

www.edoeb.admin.ch →

18. Contact Information

For questions about this policy or your data, get in touch:

Fabian Weiss

Managing Member, FW Delta LLC

legal@fwdelta.com

Questions About Your Data?

We answer your data protection questions at any time.

Get in touch

We aim to respond to all inquiries within 48 hours

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