Privacy Policy
Last Updated: December 28, 2025
1. Data Controller
Kolmira UG (haftungsbeschränkt)
Represented by: Frank Baisch
Address: See our Legal Notice / Impressum
Email: [email protected]
2. Scope of Data Processing
Pre-Launch Status
We are currently in waitlist phase. We collect only email addresses through MailerLite for the purpose of notifying you when the service launches. No portfolio data is collected at this time.
Waitlist
We process your email address based on your consent (Art. 6(1)(a) GDPR) to send you updates about service launch and early access invitations. You can unsubscribe at any time.
Website Logs
Technical data (IP address, device info) is processed for security and stability based on our legitimate interest (Art. 6(1)(f) GDPR).
3. Third-Party Services
We use selected service providers to operate our business. All providers are bound by Data Processing Agreements (DPA) where applicable.
| Provider | Purpose | Legal Basis | Data Location | Status |
|---|---|---|---|---|
| Cloudflare | Hosting & Security | Legitimate Interest | Global (EU-U.S. DPF) | Active |
| MailerLite | Email Marketing | Consent | EU | Active |
| Google Analytics 4 | Usage Analysis | Consent (Opt-in) | USA (EU-U.S. DPF) | Planned* |
| Stripe / PayPal | Payment Processing | Contract | Global | Planned* |
*Planned services will be activated when the paid service launches (2025). We will update this Privacy Policy and notify users before activating any new data processing services.
4. Your Rights
You have the right to access, rectify, or erase your personal data, and the right to withdraw consent at any time. For inquiries, contact [email protected]. You also have the right to lodge a complaint with the Berliner Beauftragte für Datenschutz und Informationsfreiheit.
5. Data Retention
We delete your email address once you unsubscribe or the service ends. Portfolio review data will be retained as specified in our Terms of Service when the service launches.