Data Privacy

Version 1.0 - 17th July 2025

Introduction

General information

The following information provides a simple overview of what happens to your personal datawhen you visit this website. Personal data is all data with which youcan be personally identified. Detailed information on the subject of data protection can be found atin our privacy policy listed below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator's contact details atin the “Information on the controller” section of this privacy policy.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This may, for example, bedata that you enter in a contact form.
Other data is collected automatically or with your consent by our ITsystems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or timeof the page view). This data is collected automatically as soon as you enter this website.

For what purpose do we use your data?

Some of the data is collected to ensure that the website is provided without errors. Otherdata may be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the data transmitted will also be processed for contract offers,orders or other order inquiries.

What rights do you have regarding your data?

You have the right to obtain information about the origin, recipient and purpose of your personal data stored atat any time and free of charge. You also have the right to request the rectification orerasure of this data. If you have given your consent to data processing,you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances.You also have the right to lodge a complaint with the competent supervisory authority.You can contact us at any time if you have any further questions on the subject of data protection.

Analysis tools and third-party tools

When you visit this website, your surfing behavior may be statistically evaluated. This is done atprimarily using so-called analysis programs.Detailed information on these analysis programs can be found in the followingprivacy policy.

Hosting

We host the content of our website with the following provider:

Webflow

The provider is Webflow, Inc, 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafterWebflow). When you visit our website, Webflow collects various log files including your IPaddresses.Webflow is a tool for creating and hosting websites. Webflow stores cookies or otherrecognition technologies that are required to display the page, to provide certainwebsite functions and to ensure security (necessary cookies).Details can be found in Webflow's privacy policy:
https://webflow.com/legal/eu-privacy-policy

The use of Webflow is based on Art. 6 para. 1 lit. f GDPR. We have alegitimate interest in displaying our website as reliably as possible. If consent has been requested for, the processing is carried out exclusively on the basis of Art.6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies oraccess to information in the user's terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.Data transfer to the USA is based on the standard contractual clauses of the EU Commission.Details can be found here:
https://webflow.com/legal/eu-privacy-policy

The use of Webflow is based on Art. 6 para. 1 lit. f GDPR. We have alegitimate interest in displaying our website as reliably asThe company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). TheDPF is an agreement between the European Union and the USA, which is intended to ensure compliance withEuropean data protection standards for data processing in the USA. Every company certified to the DPF in accordance withundertakes to comply with these data protection standards. Further information on this can be obtained from the provider atunder the following link:
https://www.dataprivacyframework.gov/participant/6365

Contract processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which guaranteesthat it will only process the personal data of our website visitors in accordance with ourinstructions and in compliance with the GDPR.

General information and mandatory information

Data Privacy

The operators of these pages take the protection of your personal data very seriously. We treat yourpersonal data confidentially and in accordance with the statutory data protection regulations andthis privacy policy.When you use this website, various personal data is collected.Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains howdoes this and for what purpose. We would like to point out that data transmission over the Internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is notpossible.

Information on the responsible body

The controller responsible for data processing on this website is:

WhosClose GmbH
Zugspitzstr. 15
82049 Pullach
Pullach, Germany

Email: dp@whosclose.com

The controller is the natural or legal person who, alone or jointly with others, determinesthe purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy,your personal data will remain with us until the purpose for processing the data no longer applies. If you assert alegitimate request for erasure or withdraw your consent to data processing, your data will be erased unless we have other legally permissible grounds for storing yourpersonal data (e.g. retention periods under tax or commercial law); in the latter case, will be erased once these grounds no longer apply.

General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data onthe basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, provided that special categories of dataare processed in accordance with Art. 9 para. 1 GDPR. In the event of express consent to the transfer ofpersonal data to third countries, data processing is also carried out on the basis of Art.49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information inyour end device (e.g. via device fingerprinting), the data processing is also carried outon the basis of Section 25 (1) TDDDG. Consent can be revoked at any time. If your data is required forcontract fulfillment or for the implementation of pre-contractual measures, we process yourdata on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR.Data processing may also be carried out on the basis of our legitimate interest in accordance with Art. 6 para. 1 lit. fGDPR. Information on the relevant legal bases in each individual case is provided in the followingparagraphs of this privacy policy.

Recipients of personal data

As part of our business activities, we work together with various external bodies. This sometimes requires the transfer of personal data to these external bodies.We only pass on personal data to external bodies if this is necessary in the context of contract fulfillment, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest in the transfer in accordance with Art. 6 para. 1 lit. f GDPR or if another legal basis permits the transfer of data. When using processors, we only pass on our customers' personal data on the basis of a valid contract for order processing. In the case of joint processing, a contract is concluded for joint processing.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke your consent to at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to the collection of data in special cases and to direct marketing (Art. 21 GDPR)

If data processing is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy.
If you object, we will no longer process your personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims (objection pursuant to Art. 21 (1) GDPR).
If your personal data are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is associated with such direct marketing. If you object, your personal data will subsequently no longer be used for the purpose of direct marketing (objection pursuant to Art. 21 (2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right to lodge a complaint is without prejudice to any otheradministrative or judicial remedy.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, correction and deletion

Within the framework of the applicable legal provisions, you have the right to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, if necessary, a right to correction or deletion of this data at any time. You can contact us at any time if you have further questions on the subject of personal data.

Right to restrict processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time to do this. The right to restriction of processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored by us, we generally need time to check this. For the duration of the review, you have the right to request that the processing of your personal data be restricted.
  • If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of erasure.
  • If we no longer need your personal data, but you need it for the exercise, defense or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
  • If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data - apart from its storage - may only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from“http://” to “https://” and by the lock symbol in your browser line.If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.