Ioana OrcaBack

Privacy Policy

Preamble

With the following privacy policy we would like to explain to you which types of your personal data (hereinafter also referred to simply as "data") we process, for which purposes and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular 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: 17 August 2026

Table of contents

Controller

Ioana Iordache, trading as Ioana Orca
80689 Munich, Germany

Email address: ioanaorka@gmail.com

Overview of processing operations

The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects concerned.

Types of data processed

Categories of data subjects

Purposes of processing

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or establishment. Should more specific legal bases be relevant in an individual case, we will inform you of these in this privacy policy.

National data protection provisions in Germany: In addition to the data protection provisions of the GDPR, national data protection provisions apply in Germany. These include in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains, in particular, special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated decision-making in individual cases including profiling. Furthermore, the data protection laws of the individual federal states (Landesdatenschutzgesetze) may apply.

Note on the applicability of the GDPR and the Swiss FADP:This privacy policy serves to provide information both under the Swiss Federal Act on Data Protection (FADP) and under the General Data Protection Regulation (GDPR). For this reason, please note that, owing to the broader territorial scope and greater comprehensibility, the terms of the GDPR are used. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "particularly sensitive personal data" used in the Swiss FADP, the terms used in the GDPR – "processing" of "personal data", "legitimate interest" and "special categories of data" – are used. The legal meaning of the terms continues, however, to be determined in accordance with the Swiss FADP where the Swiss FADP applies.

Applicability of data protection requirements in the country of establishment:In the country in which the controller is established, national data protection provisions apply in addition to the General Data Protection Regulation (GDPR).

Security measures

In accordance with statutory requirements and taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access to, input, disclosure, availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the erasure of data and responses to threats to the data. We also take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

Securing online connections using TLS/SSL encryption technology (HTTPS): In order to protect the data of users transmitted via our online services against unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data against unauthorised access. TLS, as the further developed and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is transmitted securely and in encrypted form.

Transfer of personal data

In the course of our processing of personal data, it may occur that such data is transferred to, or disclosed to, other bodies, companies, legally independent organisational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks, or providers of services and content embedded in a website. In such cases we comply with the statutory requirements. The recipients we currently use are named in this privacy policy.

International data transfers

Data processing in third countries: Insofar as we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or this occurs in the context of using third-party services or the disclosure or transfer of data to other persons, bodies or companies (which is apparent from the postal address of the respective provider or where the privacy policy expressly refers to a data transfer to third countries), this always takes place in accordance with the statutory requirements.

For data transfers to the USA we rely on the Data Privacy Framework (DPF), which was recognised as providing an adequate level of protection by an adequacy decision of the EU Commission of 10 July 2023. Each of the US providers named in this privacy policy is certified under the DPF. We have not concluded standard contractual clauses in addition; should a provider's certification lapse, we will change the basis for the transfer and update this privacy policy accordingly.

In relation to the individual service providers we state whether they are certified under the DPF. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce athttps://www.dataprivacyframework.gov/(in English).

General information on data storage and erasure

We erase personal data that we process in accordance with the statutory provisions as soon as the underlying consents are withdrawn or no further legal bases for the processing exist. This concerns cases in which the original purpose of processing ceases to apply or the data is no longer required. Exceptions to this rule apply where statutory obligations or particular interests require longer retention or archiving of the data.

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

Our privacy policy contains additional information on the retention and erasure of data that applies specifically to certain processing operations.

Where there are several indications regarding the retention period or erasure deadlines for a given item of data, the longest period is always decisive. Data that is no longer retained for the originally intended purpose but on the basis of statutory requirements or other reasons is processed by us exclusively for the reasons that justify its retention.

Commencement of the period at the end of the year: Where a period does not expressly commence on a specific date and is at least one year in length, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the triggering event is the point at which the termination or other ending of the legal relationship takes effect.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

Business services

We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers and other cooperation partners (collectively "contractual partners"), for the purpose of initiating, performing and settling contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken upon request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular to fulfil our primary and ancillary contractual obligations. These include the provision of the agreed services, any updating and information obligations, handling warranty claims and other performance issues, processing withdrawals, terminations of continuing obligations, reversals, refunds, and handling other contract-related declarations and enquiries. Both one-off contracts and ongoing contractual relationships are covered.

We process in particular master data such as name, address and, where applicable, company, contact data such as email address and telephone number, contract and performance data such as the subject matter of the contract, contract term, order or transaction number, usage and performance data, payment and billing data, as well as communication content and histories. Where necessary, we also process data that is disclosed or transmitted to us in the course of carrying out an order.

In addition, we process the data to safeguard our rights and to comply with legal obligations. This includes in particular commercial and tax law retention obligations, documentation obligations and, where applicable, obligations of proof and accountability. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as in protecting our business operations and our contractual partners against misuse, threats to data, trade secrets and other legally protected interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisers or other vicarious agents, insofar as this is necessary for the performance of the contract or to comply with legal obligations.

Personal data is disclosed to third parties only insofar as this is necessary for the performance of the contract, for pre-contractual measures, to safeguard legitimate interests or to comply with legal obligations. We provide separate information within this privacy policy regarding any processing that goes beyond this, in particular for marketing purposes.

We inform contractual partners which data is required in the individual case at the point of collection, for example by appropriate marking in online forms or in personal contact.

The data is erased as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations prevent erasure. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the context of a specific order is erased by us after completion of the order and expiry of any retention periods, provided no further statutory or contractual storage obligations exist.

The legal basis for the processing is Art. 6(1)(b) GDPR for carrying out pre-contractual measures and performing the respective contractual relationship, as well as Art. 6(1)(c) GDPR for compliance with legal obligations. Insofar as the processing is based on legitimate interests, it takes place on the basis of Art. 6(1)(f) GDPR. Where processing is based on Art. 6(1)(f) GDPR, it serves to safeguard our legitimate interests in proper and efficient business organisation, the internal administration and documentation of business transactions, the enforcement and defence of legal claims, ensuring IT and data security, preventing misuse and fraud, as well as the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and in preserving our entrepreneurial capacity to act.

Further information on processing operations, procedures and services:

Provision of the online offering and web hosting

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

Further information on processing operations, procedures and services:

Contact and enquiry management

When you contact us (e.g. by email, post, telephone or via social media), as well as in the context of existing user and business relationships, the information provided by the enquiring person is processed insofar as this is necessary to respond to the contact enquiries and any requested measures.

Further information on processing operations, procedures and services:

Newsletter and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter "newsletter") exclusively with the consent of the recipients or on the basis of a legal permission. Insofar as the contents of the newsletter are described when signing up, these contents are decisive for the users' consent. To sign up for our newsletter, providing your email address is normally sufficient. However, in order to be able to offer you a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter, or for further information where this is necessary for the purpose of the newsletter.

Erasure and restriction of processing: We may store the email addresses of unsubscribed recipients for up to three years on the basis of our legitimate interests before erasing them, in order to be able to provide evidence of consent previously given. The processing of this data is restricted to the purpose of a potential defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The sign-up procedure is logged on the basis of our legitimate interests for the purpose of demonstrating that it was carried out properly. Insofar as we commission a service provider to send emails, this takes place on the basis of our legitimate interests in an efficient and secure sending system.

Contents:

Information about us, our services, campaigns and offers.

Further information on processing operations, procedures and services:

Web analytics and reach measurement

We use a privacy-friendly analytics service to measure the reach of our website, i.e. to see how many people visit it, which pages they look at and which sites they arrive from. We use this to understand which content is useful and which parts of the site need improving.

The service we use is cookieless. It does not store cookies or any other information on your device, it does not create profiles, it does not track you across websites or sessions, and it does not carry out A/B testing or collect location data. Your IP address and the full browser identification string are not stored: they are used only briefly, in the provider's memory, to recognise repeat requests from the same visit, and are replaced by a randomly generated value that cannot be traced back to you. What remains is aggregate data, such as the number of times a page was viewed and the sites visitors came from.

Because no information is stored on or read from your device, no consent is required for this and we do not ask for any. We process this data on the basis of our legitimate interest in understanding how our website is used. You can object to it at any time by using the contact details given above.

Further information on processing operations, procedures and services:

Presences in social networks (social media)

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

We point out that user data may be processed outside the territory of the European Union in this context. This may give rise to risks for users, because, for example, the enforcement of users' rights could be made more difficult.

Furthermore, users' data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created on the basis of users' usage behaviour and the resulting interests. These profiles may in turn be used, for example, to display advertisements within and outside the networks that presumably correspond to users' interests. For this reason, cookies are generally stored on users' computers in which usage behaviour and users' interests are stored. In addition, data may also be stored in the usage profiles independently of the devices used by the users (in particular if they are members of the respective platforms and are logged in there).

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

Also in the case of requests for access and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the latter have access to users' data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you may contact us.

Further information on processing operations, procedures and services:

Amendment and updating

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of participation on your part (e.g. consent) or other individual notification.

Insofar as we provide addresses and contact information of companies and organisations in this privacy policy, please note that addresses may change over time and we ask you to check the information before making contact.

Definitions of terms

In this section you will find an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their statutory definitions apply. The following explanations, by contrast, are intended primarily to aid understanding.

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