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.
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
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.
03. Legal Basis for Processing
We process personal data only on the basis of the following legal grounds under Art. 6 GDPR:
Art. 6(1)(a) GDPR - Consent
You have given us explicit consent to process your personal data for specific purposes. You can withdraw consent at any time.
Art. 6(1)(b) GDPR - Contract Performance
Processing is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract.
Art. 6(1)(c) GDPR - Legal Obligation
Processing is necessary for compliance with legal obligations to which we are subject.
Art. 6(1)(f) GDPR - Legitimate Interest
Processing is necessary for our legitimate interests, provided your interests or fundamental rights do not override these interests.
04. Categories of Personal Data
We process the following categories of personal data:
Identity Data
- Full name
- Email address
- Company name
- Job title
- Postal address
- Phone number
Communication Data
- Email correspondence
- Contact form messages
- Chat transcripts
- Support tickets
- Meeting notes
Technical Data
- IP address (truncated before sharing)
- Browser type and version
- Operating system
- Device type
- Screen resolution
- Language preferences
Usage Data
- Pages visited
- Time spent on pages
- Click behavior
- Referrer URL
- Search queries
- Session duration
Transaction Data
- Project details
- Payment information
- Invoice data
- Contract documents
Marketing Data
- 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.
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 partAutomatic deletion. Security-relevant logs are retained for up to 30 days.
Reach Measurement Data
AggregatedEvaluated in aggregated form only, no long-term storage of personal data
Contact Form Inquiries
3 yearsAfter last contact, unless contract exists
Email Correspondence
3 yearsAfter last contact, unless contract exists
Contract Documents
10 yearsLegal retention obligation
Invoices & Accounting
10 yearsLegal retention requirement
Language choice (fwd-lang cookie)
12 monthsStrictly necessary so the site appears in the chosen language
Marketing Consent
Until withdrawnActive consent required
Newsletter Signups
Until withdrawnAfter withdrawal the signup is deleted. The record of consent is retained beyond that to meet our accountability obligation.
Encrypted Backups
30 daysRolling backup retention
Project Files
5 yearsAfter 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.comWe 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 →18. Contact Information
For questions about this policy or your data, get in touch:
Questions About Your Data?
We answer your data protection questions at any time.
Get in touchWe aim to respond to all inquiries within 48 hours