Privacy Policy

The data controller responsible for the processing of personal data on this website is:

Meliha Tanriverdi
c/o EWRA AI
Torstraße 105-107
10119 Berlin
Germany

Email: privacy@ewra.ai
Telephone: +49 30 80407092

We process personal data only to the extent necessary to provide a functional and secure website, to handle contact enquiries, to carry out pre-contractual measures, on the basis of consent, or to safeguard legitimate interests.

The legal bases are, in particular, Article 6(1)(a), (b) and (f) of the General Data Protection Regulation (GDPR) and, where applicable, the provisions of the Telecommunications and Digital Services Data Protection Act (TDDDG).

No automated decision-making, including profiling within the meaning of Article 22 of the GDPR, takes place on this website.

This website is provided using services from Lovable. Lovable Labs AB is based in Stockholm, Sweden.

When you visit our website, technically necessary connection and log data are processed. This may include, in particular:

• IP address
• date and time of access
• page or file accessed
• amount of data transferred
• referrer URL
• browser type and version
• operating system and
• other technically necessary connection information

The processing of this data is necessary to deliver the website and to ensure its stability and security.

Processing is carried out on the basis of Article 6(1)(f) of the GDPR. Our legitimate interest lies in the secure, reliable and efficient provision of our website, as well as in the detection and prevention of technical faults and unauthorised access.

Log data is stored only for as long as is necessary for the respective technical or security-related purpose, unless statutory retention obligations or legitimate interests require longer storage.

If you contact us by email, telephone or via a contact form provided on this website, we will process the data you provide in order to handle and respond to your enquiry.

Depending on the nature of your enquiry, this may include, in particular:

• Name
• email address
• organisation or company
• professional role or position
• the content of your message, and
• any further information you provide voluntarily

Lovable’s services are used for the technical processing and transmission of the contact form. In addition to the information you have entered, technically necessary transmission data may also be processed.

Sales enquiries

Where your enquiry is aimed at initiating or concluding a contract, processing is carried out on the basis of Article 6(1)(b) of the GDPR.

Partnership enquiries

In the case of partnership enquiries, processing is carried out, depending on the content of the enquiry, on the basis of Article 6(1)(b) of the GDPR or on the basis of our legitimate interest in assessing and processing potential business collaborations in accordance with Article 6(1)(f) of the GDPR.

Investor enquiries

We generally process investor enquiries on the basis of our legitimate interest in handling financing and investment enquiries in accordance with Article 6(1)(f) of the GDPR. Where the communication serves to prepare for a contractual relationship, Article 6(1)(b) of the GDPR may apply.

General enquiries

We process general enquiries on the basis of our legitimate interest in handling and responding to them appropriately in accordance with Article 6(1)(f) of the GDPR.

Furthermore, we have a legitimate interest in protecting our contact channels from automated spam, misuse and malicious input.

The data processed in connection with an enquiry will be deleted once the relevant communication has been concluded and there are no statutory retention obligations, contractual requirements or legitimate interests in further storage.

On your first visit to our website, you can use our privacy settings to specify whether optional services such as Web analytics with Umami Analytics or Google Maps may be enabled.

Your selection is stored locally in your browser under the key ‘ewra-consent-v1’. This enables us to take your decision into account when you visit the site again and means we do not have to ask you for your settings again on every visit.

This storage is technically necessary for the consent management you have requested. Storage on your device is carried out on the basis of Section 25(2)(2) of the TDDDG. Insofar as personal data is processed, this is done on the basis of Article 6(1)(f) of the GDPR. Our legitimate interest lies in the reliable and user-friendly management of your privacy settings.

Your selection remains stored on your device until you delete the relevant website data from your browser or change your selection via ‘Privacy settings’ in the footer of our website.

You may revoke any consent previously given at any time with future effect.

The technically necessary adjustment of our website’s layout to different screen sizes takes place without the use of cookies requiring consent.

We use Umami Analytics to analyse the usage of our website statistically.

Umami is designed for data-minimal web analytics and does not use cookies for the tracking we employ.

Depending on how our website is used, the following information in particular may be processed:

• pages visited and page paths
• time and duration of visits
• referrer or source of a request
• browser
• operating system
• device type
• screen resolution
• browser language
• approximate geographical information such as country or region, and
• interactions and events on the website, insofar as these have been technically configured for analysis

Umami uses the IP address, amongst other things, to determine approximate geographical information and to generate an anonymised session ID. According to the provider, the IP address is not stored permanently.

Sessions are identified without the use of cookies, based on technical information and a changing identifier. We do not use any functions that identify visitors across different devices by name, email address or other personal identifiers assigned by us.

Umami is only loaded on our website once you have expressly consented to web analytics.

The processing of personal data is therefore carried out on the basis of your consent in accordance with Article 6(1)(a) of the GDPR. Insofar as information is stored on or read from your device in this context, this is done on the basis of your consent in accordance with Section 25(1) of the TDDDG.

You may withdraw your consent at any time via ‘Privacy Settings’ in the footer of our website, with effect for the future.

Further information on data protection and how Umami works can be found at:
https://umami.is/docs/privacy

On our contact page, we offer the option to load a map from Google Maps.

For users in the European Economic Area, the provider is generally:

Google Ireland Limited
Gordon House
Barrow Street
Dublin 4
Ireland

The map does not load automatically when you visit the contact page. A connection to Google is only established once you have enabled Google Maps via our privacy settings or actively loaded the map using the function provided for this purpose.

When Google Maps is loaded, your IP address and technical information about your browser and device may be transmitted to Google. Google may also process further data in accordance with its own privacy policy.

It cannot be ruled out that data may be processed by Google companies or service providers outside the European Economic Area, in particular in the USA.

Processing takes place on the basis of your consent in accordance with Article 6(1)(a) of the GDPR and, insofar as information is stored on or read from your device, in accordance with Section 25(1) of the TDDDG.

You may withdraw your consent at any time via ‘Privacy Settings’ in the footer of our website, with effect for the future.

Where personal data is transferred to a third country, the transfer is carried out on the basis of the applicable data protection transfer mechanisms. This may include, in particular, an adequacy decision by the European Commission under the EU-US Data Privacy Framework, provided the relevant recipient is certified accordingly, or appropriate safeguards in accordance with Article 46 of the GDPR.

Further information on data processing by Google can be found at:
https://policies.google.com/privacy

Our website may contain links to external websites and social media platforms, in particular LinkedIn.

In the case of a standard external link, the mere display of the link on our website does not in itself establish a connection with the relevant provider. Only when you click on the link do you leave our website, and data – in particular your IP address and technical information about your browser or device – may be transmitted to the relevant provider.

The respective provider is responsible for any subsequent data processing on their own website.

Personal data is only disclosed to recipients insofar as this is necessary for the purposes described in this privacy policy, where there is a legal obligation to do so, or where you have consented to the transfer.

This may include, in particular, the following categories of recipients:

• providers of hosting and website infrastructure
• technical service providers for contact forms and communication
• providers of web analytics services
• map and external content providers, and
• other data processors and IT service providers, insofar as their use is necessary for the operation of our website

The providers used on this website include, in particular, Lovable, Umami and Google Ireland Limited.

Where service providers process personal data on our behalf, they do so as processors in accordance with the requirements of Article 28 GDPR.

When using certain service providers, it cannot be ruled out that personal data may be processed outside the European Union or the European Economic Area.

Such transfers will only take place if the conditions set out in Articles 44 et seq. of the GDPR are met.

This may be the case, in particular, if:

• there is an adequacy decision by the European Commission for the third country in question
• the recipient is certified under a recognised adequacy mechanism
• appropriate safeguards in accordance with Article 46 of the GDPR, in particular the EU Standard Contractual Clauses, are in place; or
• there is another legal basis for the transfer as provided for by law

Where a transfer to a third country is relevant for individual services, you will find further information in the relevant sections of this privacy policy.

As a general rule, we process personal data only for as long as is necessary for the respective purpose of processing.

Enquiries are generally stored for the duration of their processing. Where a pre-contractual or business relationship arises from an enquiry, the relevant data may also be stored for as long as is necessary to carry out the business relationship, to comply with statutory retention obligations, or to establish, exercise or defend legal claims.

For technical log, analytics and consent data, the retention periods described in the relevant sections apply, or the storage and deletion mechanisms technically provided for by the relevant service.

Once the relevant purpose of processing no longer applies, personal data will be deleted or anonymised, provided there are no legal or other permissible grounds for further storage.

There is generally no legal or contractual obligation to actively provide us with personal data simply by visiting our website.

However, certain technical data is processed automatically as it is necessary for the transmission and display of the website.

If you contact us, we require the information necessary to identify, process and respond to your enquiry. Without this information, it may not be possible to process your enquiry, or processing may be limited.

Optional information is, as such, provided on a voluntary basis.

Provided the legal requirements are met, you have the following rights in particular:

• Access to the personal data we process in accordance with Article 15 of the GDPR
• Rectification of inaccurate data or completion of incomplete data in accordance with Article 16 of the GDPR
• Erasure of personal data in accordance with Article 17 of the GDPR
• Restriction of processing in accordance with Article 18 of the GDPR
• Data portability in accordance with Article 20 of the GDPR; and
• Objection to processing in accordance with Article 21 of the GDPR

You may withdraw any consent you have given at any time with future effect in accordance with Article 7(3) of the GDPR. The lawfulness of the processing carried out prior to the withdrawal remains unaffected.

To exercise your rights, please contact us:
privacy@ewra.ai

Right to object under Article 21 of the GDPR

Where we process personal data on the basis of Article 6(1)(f) of the GDPR, you have the right at any time to object to the processing of your personal data on grounds relating to your particular situation.

We will then no longer process the personal data in question, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims.

Under Article 77 of the GDPR, you have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes data protection regulations.

The competent supervisory authority is, in particular:

Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59-61
10555 Berlin
Germany
Email: mailbox@datenschutz-berlin.de
Telephone: +49 30 13889-0

You may also contact another supervisory authority competent under Article 77 of the GDPR, regardless of the above.

We take appropriate technical and organisational measures to protect personal data against loss, manipulation, unauthorised access and other unlawful processing.

Our security measures are reviewed and adapted in line with technological developments and taking into account the nature, scope and purpose of the processing, as well as the risks associated with it.

Data transmitted via our website is encrypted using HTTPS/TLS.

We may amend this privacy policy if the services used, our data processing or the legal requirements change.

The current version is available on this website.