Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter referred to as “data”), the purposes for which we process it, and the scope of such processing. This privacy policy applies to all processing of personal data carried out by us, both as part of the services we provide and particularly on our websites, in mobile applications, and within external online presences such as our social media profiles (hereinafter collectively referred to as the “online offering”).

The terms used are not gender-specific.

Last updated: July 11, 2025

Table of Contents

Controller

Jeffery Reich
Jeffery Reich, acting under the name Reich
Rosenheimer Strasse 36
10781 Berlin
Germany

Authorized representative: Jeffery Reich

Email address: admin@reich-advisory.com

Imprint: imprint.reich-advisory.com

Overview of Processing

The following overview summarizes the types of data processed and the purposes of processing, as well as the categories of Data Subjects:.

Types of Data Processed

Categories of Data Subjects:

Purposes of Processing

Applicable Legal Bases

Legal bases under the GDPR:
Below is an overview of the legal bases of the General Data Protection Regulation (GDPR) on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence. If more specific legal bases are applicable in individual cases, we will inform you of these in the privacy policy.

National data protection regulations in Germany:
In addition to the data protection regulations of the GDPR, national regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG), which contains special provisions on access rights, the right to erasure, the right to object, processing of special categories of personal data, processing for other purposes, and data transfers and automated decision-making including profiling. State data protection laws may also apply.

Note on applicability of GDPR and Swiss FADP:
This privacy notice serves both to fulfill our information obligations under the Swiss Federal Act on Data Protection (FADP) and the GDPR. Therefore, for clarity and broader applicability, the terminology of the GDPR is used. For example, instead of the FADP term “processing of personal data,” we use “processing of personal data” and “legitimate interest” rather than “overriding interest.” The legal meaning under Swiss law remains unchanged.

Security Measures

We implement appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, implementation costs, nature, scope, and context of the processing, and the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

These measures include ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, transmission, availability, and separation of data. We also have procedures in place to ensure the exercise of data subject rights, deletion of data, and response to data threats. Furthermore, we consider data protection principles in the development and selection of hardware, software, and procedures, according to the principle of data protection by design and by default.

Securing online connections via TLS/SSL encryption (HTTPS): To protect the data of users transmitted via our online services, we use TLS/SSL encryption technology. SSL and TLS are foundational for secure data transmission on the internet. These technologies encrypt information exchanged between the website or app and the user’s browser (or between two servers), protecting it from unauthorized access. TLS, being the more advanced version, ensures data transfers meet high security standards. When a website is secured via SSL/TLS, the URL begins with “HTTPS,” indicating a secure and encrypted connection.

Transfer of Personal Data

As part of our processing of personal data, it may happen that data is transferred to other entities, companies, legally independent organizational units, or individuals, or disclosed to them. These recipients may include, for example, service providers tasked with IT responsibilities or providers of services and content integrated into a website. In such cases, we comply with legal requirements and enter into appropriate agreements or contracts that serve to protect your data with the recipients.

International Data Transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this occurs in the context of using services from third parties or disclosing/transferring data to other persons or companies (recognizable by the provider’s address or where explicitly indicated in this privacy policy), we only do so in accordance with legal requirements.

Transfers to the USA: For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized by the EU Commission as a secure framework under an adequacy decision dated July 10, 2023. Additionally, we have concluded standard contractual clauses with service providers, establishing contractual obligations to protect your data according to EU standards.

This two-layer approach ensures robust protection: the DPF provides a primary safeguard, while standard contractual clauses serve as a fallback. If changes affect the DPF, these clauses remain in place to uphold data protection.

For each individual service provider, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information about the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/.

Transfers to other third countries: For other third countries, we apply equivalent safeguards, including standard contractual clauses, explicit consent, or statutory requirements. More information is available via the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal requirements once the consent is revoked or no other legal basis exists for continued processing. This includes when the purpose of the processing is fulfilled or the data is no longer necessary. Exceptions apply if legal obligations or special interests require longer storage.

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons, must be appropriately archived.

We include additional information about retention and deletion periods in sections specific to certain processing operations.

Where multiple retention periods apply, the longest duration governs. Data that is no longer needed for its original purpose but must be retained for other reasons is processed solely for those retention purposes.

Retention and Deletion of Data: The following general time periods apply to retention and archiving under German law:

Rights of Data Subjects:

According to the GDPR, you have the following rights as a data subject (Articles 15 to 21 GDPR):

Business Services

We process data of our clients, customers, and business partners (collectively “contractual partners”) in the context of contractual or comparable legal relationships, including communication and pre-contractual inquiries.

We use this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedies in the event of warranty or other performance issues. In addition, we use the data to protect our rights and for the administrative tasks associated with these obligations as well as for corporate organization. We also process the data on the basis of our legitimate interests in proper and economically efficient business operations and in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information, and rights (e.g., by involving telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the scope of applicable law, we only share contract partner data with third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about any additional forms of processing, such as for marketing purposes, within this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes before or during the data collection process—for example, in online forms, through special markings (e.g., colors) or symbols (e.g., asterisks or similar), or in person.

We delete the data after the expiration of statutory warranty and similar obligations, i.e., generally after four years, unless the data is stored in a customer account—for example, as long as it must be retained for legal archiving purposes (typically ten years for tax reasons). Data that has been disclosed to us by the contractual partner in the context of an order is deleted in accordance with the contractual requirements and generally upon completion of the order.

Additional Information on Processing Activities, Procedures, and Services:

Provision of the Online Offer and Web Hosting

We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

Additional Information on Processing Activities, Procedures, and Services:

Use of Cookies

The term “cookies” refers to functions that store information on users’ devices and retrieve it from them. Cookies can serve various purposes, such as ensuring the functionality, security, and user-friendliness of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal requirements. Where necessary, we obtain users’ prior consent. If consent is not required, we rely on our legitimate interests—this applies when storing and retrieving information is essential for providing explicitly requested content and functions. This includes, for example, saving preferences and ensuring the functionality and security of our online services. Consent can be revoked at any time. We provide clear information about the scope of usage and which cookies are employed.

Information on Data Protection Legal Bases: Whether we process personal data using cookies depends on user consent. If consent has been given, it serves as the legal basis. In the absence of consent, we rely on our legitimate interests, as described above in this section and in the context of the respective services and procedures.

Storage Duration: With regard to storage duration, the following types of cookies are distinguished:

General Information on Withdrawal and Objection (Opt-Out): Users can withdraw their consent at any time and may also object to the processing in accordance with legal requirements, including through the privacy settings of their browser.

Additional Information on Processing Activities, Procedures, and Services:

Blogs and Publishing Media

We use blogs or comparable forms of online communication and publication (hereinafter referred to as “publishing medium”). The data of readers is processed for the purposes of the publishing medium only to the extent necessary for its presentation, for communication between authors and readers, or for security reasons. For all other matters, we refer to the information provided in this privacy notice regarding the processing of visitors to our publishing medium.

Additional Information on Processing Activities, Procedures, and Services:

Contact and Inquiry Management

When contacting us (e.g., by post, contact form, email, telephone, or via social media) and in the context of existing user and business relationships, the information provided by the inquiring individuals is processed to the extent necessary to respond to the contact inquiries and any requested actions.

Additional Information on Processing Activities, Procedures, and Services:

Newsletter and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereinafter referred to as “newsletter”) only with the recipients’ consent or based on a legal basis. If the contents of the newsletter are specified during the subscription process, these contents are decisive for the user’s consent. Typically, providing your email address is sufficient to subscribe to our newsletter. However, to offer you a more personalized service, we may ask for your name for personal salutation or other information necessary for the specific purpose of the newsletter.

We may retain unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove that consent was previously given. The processing of this data is restricted to the purpose of potentially defending against legal claims. An individual deletion request is possible at any time, provided that the prior existence of consent is confirmed. In the event of a legal obligation to permanently honor objections, we reserve the right to store the email address solely for this purpose in a suppression list (so-called “blacklist”).

The logging of the subscription process is carried out on the basis of our legitimate interests for the purpose of documenting its proper execution. If we engage a service provider to send emails, this is done on the basis of our legitimate interest in having an efficient and secure delivery system.

Contents:

Information about us, our services, promotions, and offers.

Further information on processing activities, procedures, and services:

Promotional communication via email, postal mail, fax, or telephone

We process personal data for the purposes of promotional communication, which may be carried out through various channels, such as email, telephone, postal mail, or fax, in accordance with applicable legal regulations.

Recipients have the right to withdraw their consent at any time or to object to promotional communication at any time.

After a withdrawal or objection, we store the data required to prove the previous authorization for contacting or sending communications for up to three years after the end of the year in which the withdrawal or objection was made, based on our legitimate interests. The processing of this data is limited to the purpose of potentially defending against claims. Based on the legitimate interest of permanently respecting the user’s withdrawal or objection, we also store the data necessary to prevent further contact attempts (e.g., depending on the communication channel, the email address, phone number, or name).

Web analysis, monitoring, and optimization

Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous data. Using reach analysis, we can, for example, determine at what times our online offering or its functions or content are most frequently used or invite users to revisit. It also enables us to identify which areas require optimization.

In addition to web analysis, we may also use testing methods to, for example, test and optimize different versions of our online offering or its components.

Unless otherwise specified below, profiles—that is, data compiled from a usage session—may be created for these purposes, and information may be stored in and retrieved from a browser or device. The collected data includes, in particular, visited websites and the elements used there, as well as technical details such as the browser used, the computer system, and usage times. If users have consented to the collection of their location data either with us or with the providers of the services we use, processing of location data is also possible.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear personal data of users (such as email addresses or names) is stored in the course of web analysis, A/B testing, and optimization, but only pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the data stored in their profiles for the purposes of the respective processes.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we also refer you to the information on the use of cookies in this privacy policy.

Additional Information on Processing Activities, Procedures, and Services:

Presences on social networks (social media)

We maintain online presences within social networks and, in this context, process user data to communicate with active users there or to provide information about us.

We point out that user data may be processed outside the European Union in this context. This may pose risks for users, for example, because enforcing users’ rights could become more difficult.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created based on users’ behavior and resulting interests. These profiles may then be used to display advertisements within and outside the networks that presumably match users’ interests. Therefore, cookies are typically stored on users’ devices, recording usage behavior and interests. Additionally, data may also be stored in usage profiles independently of the devices used by the users—especially if they are members of the respective platforms and logged in there.

For a detailed description of the respective processing methods and the options to object (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

Even in the case of information requests and the assertion of data subject rights, we point out that these can be most effectively exercised directly with the providers. Only they have access to the user data and can take appropriate measures and provide information directly. If you still need assistance, you may contact us.

Additional Information on Processing Activities, Procedures, and Services:

Plug-ins and embedded functions as well as content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or maps (hereinafter collectively referred to as “content”).

The integration always requires that the third-party providers of this content process the users’ IP address, since they could not deliver the content to their browser without it. The IP address is therefore necessary for displaying such content or functions. We strive to use only content whose providers use the IP address solely for delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the users’ devices and may include, among other things, technical data about the browser and operating system, referring websites, time of visit, and further details about the use of our online offering. It may also be linked with such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is that consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in providing efficient, economical, and user-friendly services). In this context, we also refer you to the information on the use of cookies in this privacy policy.

Additional Information on Processing Activities, Procedures, and Services:

This privacy policy was generated with the assistance of the free tool provided by Dr. Thomas Schwenke at Datenschutz-Generator.de.