+49 621 58674080info@acntcp.de
ACNTCP

Privacy policy

This is a translation for your convenience. Only the German version is legally binding.

1. Who is responsible?

ACN Tech Consulting Projektmanagement UG (haftungsbeschränkt)
Kaiserring 10-16
68161 Mannheim, Germany
represented by the Managing Director Andrei C Nedelcu
Email: info@acntcp.de
Phone: +49 621 58674080

We have not appointed a data protection officer because the law does not require us to do so (§ 38 BDSG, Art. 37 GDPR). For all questions about data protection, you can contact us directly using the details above.

2. Overview

On this page we explain which personal data ACNTCP processes when you visit our website or contact us, why we need it, how long we keep it and what rights you have. Personal data is any information that can identify you directly or indirectly, for example your name, email address or IP address.

Our principle: we only collect the data we really need for the purpose in question. We do not sell data and do not use it for advertising.

3. Legal bases

We only process your data if one of the following legal bases of the General Data Protection Regulation (GDPR) applies:

  • Consent (Art. 6(1)(a) GDPR): You have agreed. You can withdraw consent at any time with effect for the future.
  • Contract and enquiry (Art. 6(1)(b) GDPR): Processing is necessary for a contract with you or to answer your enquiry before a contract.
  • Legal obligation (Art. 6(1)(c) GDPR): A law requires it, for example the retention of business records.
  • Legitimate interest (Art. 6(1)(f) GDPR): We have a legitimate interest, for example in a secure and functioning website, and your interests do not outweigh it.

4. Hosting of the website and email

Our website runs on a server of IONOS SE, and our mailbox info@acntcp.de is also hosted by IONOS:

IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany

IONOS processes on our behalf the technically necessary data when the website is accessed (see section 5) and the emails you send us. We have concluded a data processing agreement with IONOS in accordance with Art. 28 GDPR. Processing takes place in the EU or the European Economic Area. If IONOS exceptionally uses service providers outside the EU, IONOS ensures the safeguards required by Art. 44 et seq. GDPR, such as EU standard contractual clauses.

The legal basis is our legitimate interest in a secure and reliable website and email communication (Art. 6(1)(f) GDPR), and for enquiries about an assignment also Art. 6(1)(b) GDPR. More information: https://www.ionos.de/datenschutzerklaerung

5. Server log files

Each time the website is accessed, the server automatically stores information that your browser transmits:

  • IP address
  • date and time of access
  • page accessed and amount of data transferred
  • page you came from (referrer)
  • browser and operating system

We need this data to deliver the website, find errors and defend against attacks (Art. 6(1)(f) GDPR). We do not combine it with other data. The website log files are deleted after 7 days at the latest. The logs of the email service are deleted after 28 days at the latest.

6. Encrypted transmission (TLS)

This website uses TLS encryption. You can recognise it by “https://” and the padlock symbol in your browser. This prevents third parties from reading the data you send to us.

7. No cookies, no third-party content

This website does not set cookies. It does not store any information on your device and does not read any from it (§ 25 TDDDG). A cookie banner is therefore not necessary.

The website does not load anything from other providers, such as fonts, scripts, videos or maps. All files come from our server at IONOS. For text, your browser uses the fonts already installed on your device.

8. Contact by email or phone

If you contact us by email or phone, we process your details (for example name, contact details, company and your request) to answer your enquiry and, where applicable, to prepare a quotation or contract. The legal basis is Art. 6(1)(b) GDPR if it concerns an assignment, otherwise our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR).

We delete this data once your enquiry has been dealt with and no statutory retention obligations apply (see section 12).

9. Further mailboxes and customer management via Zoho

For further mailboxes and for managing contacts and enquiries (CRM), we use services of Zoho Corporation GmbH, Trinkausstr. 7, 40213 Düsseldorf, Germany.

Your data is stored in data centres in the EU (Amsterdam and Dublin, operated via Zoho Corporation B.V.). A data processing agreement in accordance with Art. 28 GDPR is in place with Zoho. In rare cases, support staff in India may access data, for example to fix errors. EU standard contractual clauses apply to this (Art. 46(2)(c) GDPR).

The legal basis is Art. 6(1)(b) GDPR (handling your enquiry or assignment) and our legitimate interest in orderly communication (Art. 6(1)(f) GDPR). More information: https://www.zoho.com/de/privacy.html and https://www.zoho.com/privacy/sub-processors.html

10. Support from an AI assistant

ACNTCP uses an AI assistant to prepare emails and to sort incoming enquiries. The assistant may process the content of your message, for example your name, contact details and request.

  • A human decides: Andrei C Nedelcu personally reviews and approves every outgoing message and every decision. There is no automated decision-making within the meaning of Art. 22 GDPR.
  • As little data as possible: We only pass on the information needed for the task in question.
  • No training: The use of your data to train AI models is switched off.

The provider is Anysphere, Inc., San Francisco, USA (service “Grok Bot”); the AI model comes from xAI (SpaceXAI), USA. The data is processed in the USA. The provider does not act as our processor under Art. 28 GDPR, but as an independently responsible recipient under its own privacy terms: https://cursor.com/privacy

For the USA, an adequacy decision of the EU Commission (EU-US Data Privacy Framework) only exists for companies certified under it. A level of data protection equivalent to the EU is therefore not guaranteed in every case. The legal basis is our legitimate interest in handling enquiries efficiently and carefully (Art. 6(1)(f) GDPR). You can object to this processing at any time (see section 15). We will then handle your enquiry without AI support.

11. Our profiles on social networks

On our website we link to our profiles on X, TikTok, Facebook, Instagram, Threads, YouTube and LinkedIn. These are simple links: you are only taken to the platform when you click a link. No data is transferred to these platforms before that.

The privacy terms of the respective provider apply on the platforms. In the EU, X is operated by X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland: https://x.com/en/privacy. TikTok is operated by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin 2, D02 T380, Ireland. YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland: https://policies.google.com/privacy. For our Facebook, Instagram and Threads profiles, we are jointly responsible with Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland (Art. 26 GDPR), insofar as Meta provides us with statistics about the use of our pages and profiles (“Insights”). The agreement on this can be found at https://www.facebook.com/legal/terms/page_controller_addendum. The same applies to the statistics of our LinkedIn company page with LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland: https://legal.linkedin.com/pages-joint-controller-addendum. You can assert your rights with us and with the respective provider. The legal basis for our presence is our legitimate interest in informing about our services (Art. 6(1)(f) GDPR).

12. How long we keep data

We only keep personal data for as long as is necessary for the purpose in question. We then delete it unless a law requires us to retain it. In that case we block the data for any other use and delete it when the period expires:

  • 6 years: business letters and emails that prepare or carry out an assignment (§ 257 HGB, § 147 AO)
  • 8 years: accounting records such as invoices (§ 147 AO, § 257 HGB)
  • 10 years: books, annual financial statements and inventories (§ 147 AO, § 257 HGB)

The period begins at the end of the calendar year in which the document was created.

13. Who receives your data

Your data is only received by the bodies that need it for the purposes described: our host and email provider IONOS, Zoho for further mailboxes and CRM, and the AI assistant within the scope described. Beyond that, we only pass on data if a law requires us to, for example to tax authorities.

14. Your rights

You have the following rights towards ACNTCP at any time:

  • Access to the data we have stored about you (Art. 15 GDPR)
  • Rectification of incorrect data (Art. 16 GDPR)
  • Erasure of your data (Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability, meaning receiving your data in a common format (Art. 20 GDPR)
  • Withdrawal of consent with effect for the future (Art. 7(3) GDPR)

An informal message to info@acntcp.de is sufficient.

15. Your right to object (Art. 21 GDPR)

If we process your data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), you can object to this processing at any time on grounds relating to your particular situation. We will then no longer process your data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves the establishment, exercise or defence of legal claims.

An informal message to info@acntcp.de is sufficient.

16. Complaint to the supervisory authority

You can lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for ACNTCP is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg
Heilbronner Straße 35, 70191 Stuttgart
Postanschrift: Postfach 10 29 32, 70025 Stuttgart
Telefon: 0711 615541-0
E-Mail: poststelle@lfdi.bwl.de
Website: https://www.baden-wuerttemberg.datenschutz.de

17. Changes

We update this privacy policy when our website or our processes change. The version published here applies.