com works

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Privacy Policy

Last updated: 26-10-22

1. Who is responsible

The controller responsible for processing personal data on this website under the EU General Data Protection Regulation (GDPR) is:

Jana Pelchen
COM Works
Karl-Marx-Allee 98
10243 Berlin, Germany
Email: jana@com-wrks.com

2. Overview

I process personal data only to the extent necessary to provide a functioning website, respond to enquiries and run my business. Below I explain what data is processed, for what purpose, on what legal basis, and what rights you have.

3. Hosting and server log files

This website is built with and hosted by Framer B.V., Rozengracht 207B, 1016 LZ Amsterdam, the Netherlands. When you visit the website, Framer automatically collects information that your browser transmits. This includes your IP address, the date and time of access, the page requested, the referrer URL, and your browser and operating system.

This data is needed to deliver the website, keep it secure and stable, and detect misuse. The legal basis is my legitimate interest in a secure and functioning website (Art. 6(1)(f) GDPR).

I have a data processing agreement with Framer under Art. 28 GDPR. Framer uses sub-processors, including cloud infrastructure providers, some of which are based in the USA. Any transfers to the USA are based on the EU-U.S. Data Privacy Framework and/or the EU Standard Contractual Clauses.

4. Cookies

This website does not use tracking or marketing cookies. Only technically necessary storage is used, for example to remember that you have closed the information notice shown on your first visit (§ 25(2) TDDDG, Art. 6(1)(f) GDPR). No consent is therefore required.

5. Web analytics (Framer Analytics)

This website uses Framer Analytics, a service provided by Framer B.V. (address above), to understand how visitors use the site, for example which pages are visited, how often, and from which referring websites. Framer Analytics does not use cookies and does not create persistent identifiers. To count daily unique visitors, your IP address and browser information are combined with a secret key that changes daily and is then deleted, so the data cannot be traced back to you. The legal basis is my legitimate interest in understanding and improving my website (Art. 6(1)(f) GDPR).

6. Contacting me

If you contact me by email or via the contact form, I process the data you provide, such as your name, email address, company and message, in order to respond to your enquiry. The legal basis is Art. 6(1)(b) GDPR if your enquiry relates to a contract or potential contract, and otherwise my legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR).

Contact form submissions are processed and stored by Framer B.V. and forwarded to my email address.

My email is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Google Workspace), under a data processing agreement. Data may also be processed in the USA. Those transfers are based on the EU-U.S. Data Privacy Framework and Standard Contractual Clauses.

7. Booking appointments (Google Calendar)

This website links to my appointment booking page, provided by Google Calendar (Google Workspace, Google Ireland Limited, address above). No data is sent to Google until you click the link. When you book, I process your first name, surname, email address and the chosen time slot in order to schedule and hold the meeting. Calls take place via Google Meet.

The legal basis is Art. 6(1)(b) GDPR, as the booking serves to initiate a business relationship, and otherwise my legitimate interest in efficiently organising appointments (Art. 6(1)(f) GDPR). Google processes this data on my behalf under a data processing agreement. Transfers to the USA are based on the EU-U.S. Data Privacy Framework and Standard Contractual Clauses.

8. Customer relationship management (HubSpot)

I use HubSpot to manage contacts, enquiries and client relationships. If you contact me or we work together, your contact details (such as name, email address, company, position) and our correspondence may be stored in HubSpot. The provider is HubSpot Ireland Ltd., 1 Sir John Rogerson’s Quay, Dublin 2, Ireland. Its parent company is HubSpot, Inc., USA. HubSpot is not integrated into this website and does not track visitors.

The legal basis is Art. 6(1)(b) GDPR for the initiation and performance of contracts, and otherwise my legitimate interest in efficiently managing business contacts (Art. 6(1)(f) GDPR). I have a data processing agreement with HubSpot. Transfers to the USA are based on the EU-U.S. Data Privacy Framework and Standard Contractual Clauses.

9. Meeting transcription (Wispr Flow)

With the consent of the participants, I use Wispr Flow to transcribe online meetings and create meeting notes. The provider is Wispr AI, Inc., 444 Townsend Street, San Francisco, CA 94107, USA. Audio and transcripts, including the names and statements of participants, are processed by Wispr on servers in the USA.

The legal basis is the consent of the participants (Art. 6(1)(a) GDPR). I inform all participants before or at the start of a meeting, and I do not transcribe if anyone objects. Consent can be withdrawn at any time. I have a data processing agreement with Wispr that includes the EU Standard Contractual Clauses. Wispr does not use the meeting data to train AI models.

10. Retention

I delete personal data as soon as it is no longer needed for the purposes stated above, unless statutory retention obligations apply. For business correspondence and accounting records, these are generally 6 to 10 years under German commercial and tax law.

11. Fonts

The fonts on this website are hosted by Framer. No connection is made to Google or other font providers when you visit this site.

12. Links to LinkedIn and other websites

This website contains simple links to my LinkedIn profile and other external websites. No data is sent to these providers until you click a link. After that, their own privacy policies apply.

13. Your rights

You have the right to:

  • access the personal data I hold about you (Art. 15 GDPR)

  • have inaccurate data corrected (Art. 16 GDPR)

  • have your data deleted (Art. 17 GDPR)

  • restrict processing (Art. 18 GDPR)

  • receive your data in a portable format (Art. 20 GDPR)

  • withdraw consent at any time, with effect for the future (Art. 7(3) GDPR)

To exercise any of these rights, email jana@com-wrks.com.

Right to object (Art. 21 GDPR): Where I process your data based on legitimate interests (Art. 6(1)(f) GDPR), you have the right to object at any time, on grounds relating to your particular situation. I will then stop processing your data unless I can show compelling legitimate grounds that override your interests, or the processing serves to establish, exercise or defend legal claims.

14. Right to lodge a complaint

You have the right to complain to a data protection supervisory authority. The authority responsible for me is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), www.datenschutz-berlin.de.

15. Changes to this policy

I may update this privacy policy if the website or the legal requirements change. The current version is always available on this page.