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GDPR information
Privacy Policy
This policy explains what personal data is processed when you use this website, why it is processed, how long it is kept, and what rights you have.
This privacy notice covers elgodesign.com, including www.elgodesign.com, and the portfolio demos operated by Elgo Design at fieldform.elgodesign.com and shineright.elgodesign.com. Section 09 describes the specific demo features.
Controller
Oleh Iashchuk
Trading as Elgo Design
c/o POSTFLEX PFX-122-373
Emsdettener Straße 10
48268 Greven
Germany
Email: [email protected]
Website hosting and Cloudflare
The website is hosted on a virtual server in Nuremberg, Germany, by Hetzner Online GmbH, Industriestraße 25, 91710 Gunzenhausen, Germany.
When you visit the site, the server processes the technical data needed to deliver it. This can include your IP address, date and time, requested URL, HTTP method and version, status code, volume of transferred data, referrer where available, browser and operating-system information, and connection data.
This processing supports delivery, stability, security, fault diagnosis, and defence against harmful access. Its legal basis is Article 6(1)(f) GDPR, reflecting our legitimate interests in reliable website operation and protection against abuse. Hetzner processes data under the Article 28 GDPR agreement for our customer account, covering the VPS and managed email.
We use Cloudflare, Inc., USA, to deliver, cache and protect our main website and both portfolio demos through its Free proxy/CDN service. Cloudflare also supplies DNS and domain services. Requests first reach Cloudflare and are then forwarded to our website server or answered from its cache. Processing includes IP addresses, requested URLs, timestamps, browser and connection information, and technical security data. Our legitimate interest is reliable, fast and secure website delivery; the legal basis is Article 6(1)(f) GDPR. Where Cloudflare processes data on our behalf, its data-processing agreement incorporated into its contractual terms applies. Section 11 explains international transfers.
Cached website content is kept according to the applicable cache settings and may be replaced, purged or evicted earlier. This cache lifetime is not a deletion deadline for request, security or reporting data. Retention of those datasets depends on the relevant service, the time needed to investigate delivery faults or abuse, the nature and sensitivity of the data, and applicable legal or contractual requirements. Data needed for a specific incident can be kept while that incident and related claims are addressed. Cloudflare describes these determining criteria in section 11 of its privacy notice. Dashboard history and browser reporting-policy lifetimes do not establish one universal Cloudflare deletion period.
Email authentication reports (DMARC)
Our domain configuration requests aggregate email-authentication reports to Cloudflare. Receiving mail providers send summaries of authentication results, sending-server IP addresses, domains and message counts. Depending on the report, technical identifiers may relate to individuals; we do not treat the reports as necessarily anonymous. Processing helps detect domain impersonation and check email authentication. The legal basis is Article 6(1)(f) GDPR, based on our legitimate interest in protecting business email and our domain against misuse. These are authentication reports, not message-content forwarding or forwarding of our mailbox into Gmail. DMARC reporting is separate from browser NEL reporting and remains enabled. The Cloudflare retention criteria and international-transfer arrangements described in sections 02 and 11 also apply to this processing.
Cloudflare Network Error Logging
Cloudflare Network Error Logging (NEL) is disabled for elgodesign.com. Browsers may still hold reporting instructions cached during earlier visits. Disabling NEL does not immediately remove those instructions; supported browsers may continue to send reports while the cached instructions remain valid. They cease to apply when they expire or are replaced or cleared. Such reports can include the affected URL, connection phase and error type and are used to diagnose availability problems. Cloudflare states that it uses the client IP only temporarily in memory during processing and does not log it in the NEL pipeline.
Server logs
Access and error logs help us keep the website secure, detect attacks, diagnose faults, and investigate incidents.
Access and error logs for the website and both portfolio demos are rotated daily. Seven archived files are retained for each log in addition to the current file. With successful daily rotation, this ordinarily corresponds to approximately seven to eight days. General Nginx logs also rotate daily, with fourteen archived files retained in addition to the current file. Older archives are removed through rotation; a file-count rotation rule is not an exact timed deletion deadline. Copies in backups follow the retention rules in section 04. Information needed for a specific security incident may be retained until the investigation and necessary legal steps are complete.
The reviewed Fail2ban, rsyslog/system, authentication and UFW firewall log rules are configured for weekly rotation with four archived files in addition to the current file. Empty files may skip rotation, so older archives can remain longer during inactivity; file counts are not guaranteed calendar deletion deadlines. Processing supports operational security, detection of abusive access and investigation of technical faults. The legal basis is Article 6(1)(f) GDPR. Provider mail-server logs for the separately managed mailbox are distinct from a VPS mail.log file.
Logs are not used for advertising, audience measurement, or profiling and are not normally combined with other sources. The legal basis is Article 6(1)(f) GDPR.
Backups
Backups support recovery after technical faults, data loss or security incidents. They may contain personal data from the systems being backed up. The legal basis is Article 6(1)(f) GDPR; our legitimate interest is operational recoverability and security.
The VPS has a daily local database-backup job configured with seven-day retention. A separate CloudPanel application backup retains the three newest copies. Automatic Hetzner Cloud server backups are disabled and CloudPanel remote backups are not configured.
One older, manually created VPS snapshot exists. A fresh recovery copy is planned and has not yet been confirmed prepared and checked. The adopted plan is to delete the older test snapshot thirty days after that preparation and check, and normally to retain future manual snapshots for at most thirty days. The replacement and deletion are planned steps, not completed changes.
The separate Hetzner webhosting service used for email has provider-managed backups retained for fourteen days. These are separate from the VPS backups.
Contact by email and AI assistance
An email link opens a draft in your configured email application. The website does not send a message through this action. Your email application or its provider may nevertheless save or synchronise the draft before sending. We receive the message when you send it yourself.
We use Hetzner Webhosting S, provided by Hetzner Online GmbH, Industriestraße 25, 91710 Gunzenhausen, Germany, to receive, send and store business emails. The Article 28 GDPR agreement for our customer account covers this managed email service. Cloudflare Email Routing into Gmail is disabled and Resend is not active. For this managed service, Hetzner states a seven-day mail-server log retention and fourteen-day provider backup retention. These periods do not describe VPS logging or our own correspondence retention.
We may process your name, email address, subject, message, attachments, technical email metadata, and any information you choose to provide.
We process the contact details and message contents provided to answer enquiries, prepare projects and deliver agreed services. Article 6(1)(b) GDPR applies where processing is necessary for a contract with you or pre-contract steps requested by you. Other enquiries and communication with company representatives rely on Article 6(1)(f) GDPR; our legitimate interest is handling business correspondence. Legal retention obligations rely on Article 6(1)(c) GDPR.
Closed enquiries that did not result in an engagement are reviewed monthly. Correspondence closed more than thirty days earlier and no longer needed is deleted during that review. This is a manual monthly review, not automatic deletion exactly on day thirty. Contracts, billing documents and other records subject to retention duties are stored separately for the applicable statutory periods; information may also be kept longer where necessary for specific legal claims.
Providing information is voluntary, but we need a way to contact you to reply.
AI assistance for planning and code
AI tools may assist technical planning and code creation. Identifiable client enquiries remain in private business records and are not submitted to external AI services. External AI assistance receives only generalised functional requirements and dummy data without a connection to identifiable individuals; the same restriction applies to project files made available to those tools. Removing names and email addresses alone does not necessarily anonymise a case. We review the outputs and make proposal, scope and project decisions ourselves.
Telephone contact
For telephone enquiries, we process the information provided and, where displayed, your telephone number and technical connection information. This supports answering enquiries, returning calls and preparing or carrying out a project. The legal basis is Article 6(1)(b) GDPR where a contract with you or pre-contract steps requested by you are involved, otherwise Article 6(1)(f) GDPR based on our legitimate interest in business communication.
Our telephone service is provided by easybell GmbH, Brückenstraße 5a, 10179 Berlin, Germany. Easybell and participating network operators process connection data to provide and bill for their telecommunications services under their legal obligations and privacy notices. We do not record calls. Call-history entries may nevertheless exist independently of recordings. Our own call notes and callback information are deleted when no longer needed for the enquiry or project, subject to legal retention duties and specific legal claims. Provider telecommunications records are separate from our own notes and call history.
Cookies and language preference
The public-facing theme does not itself set cookies for analytics, advertising, audience measurement, or profiling. WordPress may set authentication cookies for administrators when they sign in.
When you activate the language toggle, your selected language (de or en) is stored in your browser’s sessionStorage under the key elgo-language and read when a page loads. If you have not selected a language, the website checks your browser’s language preferences locally and selects German or English, with English as the fallback. This does not determine your country or location and does not contact a separate language-detection service. The automatically selected language is not saved; sessionStorage is written only when you explicitly select a language. Storage preserves your expressly selected language during the page session. It is specific to the website origin and browser-tab session and survives reloads. Browser session-restoration features may continue the session. If sessionStorage is unavailable, language switching works only in the current page’s memory. Section 25(2)(2) TDDDG applies to this exclusively functional storage and access.
Project briefing and links
The main Elgo Design website does not use separate advertising, retargeting or tracking tools to build visitor profiles. Fonts, project images and interface scripts are served locally. Infrastructure services used for delivery, security and fault diagnosis are described separately in this notice.
The project briefing assembles its summary in your browser. This feature neither submits the briefing entries to WordPress as an enquiry nor sends an email automatically. It does not deliberately persist them in cookies, localStorage or sessionStorage. The language preference is stored separately as described in section 07.
Copying the summary transfers it to your device’s clipboard. Clipboard-history or device-sync features may store it. “Open in email” passes the summary to your email application, which may save or synchronise the draft before sending. We receive it as a message when you send it yourself. The briefing is unavailable with JavaScript disabled; you can contact us directly by email instead.
Links to our portfolio demos are covered by this notice. When you open a link to another operator’s website, that destination processes the connection data needed for the visit and its own privacy notice applies.
Portfolio demos
Fieldform and Shine Right are fictional portfolio demos operated by Elgo Design. Their request and booking interfaces demonstrate a process; they do not offer a real order or appointment service. Use sample information. Ordinary page and asset delivery still involves the hosting and Cloudflare connection data described in sections 02 and 03.
Shine Right initially displays a locally hosted schematic map. External CARTO map tiles are loaded only after you explicitly choose “Enable external map”. Your browser then sends requests to CARTO’s tile-delivery infrastructure, which receives connection data, including your IP address, and the requested map areas and zoom levels. Area matching remains local; search text is not transmitted to a map provider. No Nominatim searches or device-location access are used, and the website does not save your map-activation preference.
Disabling the external map or closing it removes the external tile layer. This does not undo requests already sent, delete data already received by delivery providers, or clear the browser’s normal cache. Ordinary hosting and Cloudflare processing described elsewhere in this policy also remains applicable.
This notice applies to these owner-operated demos, not to future client websites.
Recipients
For the processing described, we use Hetzner for website infrastructure and email, Cloudflare for website delivery, security, DNS/domain services and DMARC authentication reporting, and Easybell for telephone services. Telecommunications providers also process connection data under their own statutory responsibilities. Article 28 GDPR agreements apply where providers process data on our behalf. Other disclosures to public authorities or legal and tax advisers occur only where legally required or necessary for the relevant matter. Personal data is not sold or disclosed for advertising.
Processing outside the EU or EEA
The origin hosting is located in Nuremberg, Germany. This does not keep all processing within the EU or EEA: Cloudflare uses international infrastructure and processing can involve the United States. For covered transfers to Cloudflare in the United States, Cloudflare relies on its participation in the EU-US Data Privacy Framework, an adequacy arrangement under Article 45 GDPR. Where a transfer is not covered by an applicable adequacy arrangement, its data-processing agreement provides Standard Contractual Clauses under Article 46 GDPR, including the clauses adopted in Commission Decision (EU) 2021/914. The Cloudflare data-processing agreement describes the applicable arrangements and how to obtain information about the safeguards. You may also request information using the controller contact details in section 01.
These Cloudflare transfer arrangements also concern delivery and security of Fieldform and Shine Right. The locally processed Shine Right map and searches described in section 09 do not themselves send searches, selections or device-location data to a separate map provider outside the EU or EEA.
Retention
Personal data is kept only for as long as the relevant purpose requires. It is then deleted or anonymised unless legal retention obligations, contractual duties, an ongoing dispute, or legal claims require longer storage. Sections 02 and 03 explain Cloudflare retention criteria and server-log rotation; section 04 covers backups, section 05 correspondence and section 06 telephone contact. Section 07 explains the main website’s separate language preference. Local Shine Right map searches, selections and booking entries are not deliberately retained by the demo after the page-memory state ends; ordinary delivery logs and backup copies follow their separate rules.
Your rights
Subject to the legal requirements, you may request access (Article 15 GDPR), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20), or object to processing (Article 21). Where processing relies on consent, you may withdraw it for the future under Article 7(3). Withdrawal does not affect processing that was lawful before it.
Under Article 19 GDPR, you may ask us to identify the recipients notified of rectification, erasure or restriction of processing.
To exercise your rights, contact the controller using the details in section 01.
Right to object
If we process your data under Article 6(1)(f) GDPR, you may object at any time for reasons relating to your particular situation. Following a valid objection, we stop that processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is needed to establish, exercise, or defend legal claims.
Complaint
If you believe your personal data has been processed unlawfully, you may lodge a complaint with a data protection supervisory authority under Article 77 GDPR, particularly in the Member State of your habitual residence, workplace or the place of the alleged infringement.
Security
We use appropriate technical and organisational measures to protect personal data against loss, alteration, unauthorised access, and misuse. Depending on the actual configuration, these may include HTTPS, updates, restricted administrative access, secure authentication, firewalls, limited log retention, and backup and recovery procedures. Measures are reviewed as technology and risks change.
Automated decisions
No solely automated decision-making, including profiling within the meaning of Article 22 GDPR, takes place.
Changes
We update this policy when services, processing, or legal requirements change. The current version is available on this website.
Revision: 16 October 2026.