LEGAL / #02
PRIVACY POLICY
1. Overview
The protection of personal data is important to us. This privacy policy explains what data we collect, how we use it, and what rights apply. All services are directed exclusively at business clients (B2B). Where personal data of contact persons at client companies is processed, this occurs in the context of pre-contractual or contractual B2B communication. Responsible party: Torben Glamm, Hamburg, Germany. Contact: hello@torbenglamm.com
2. Data We Collect
When you visit this website, our hosting provider automatically collects and stores information in server log files that your browser transmits. This includes: IP address, date and time of request, pages visited, browser type and version, operating system. If you use contact forms or booking forms on this site, we collect the data you voluntarily provide (name, email address, message content) in order to process your request.
3. Legal Basis
Data processing is based on Art. 6 Abs. 1 lit. b GDPR (contract performance or pre-contractual measures), Art. 6 Abs. 1 lit. f GDPR (legitimate interests), and — where you have given consent — Art. 6 Abs. 1 lit. a GDPR.
4. Data Storage and Deletion
We store your data only as long as necessary for the respective purpose or as required by legal retention obligations. Contact inquiries are deleted after 3 years unless a contractual relationship has been established.
5. Hosting
This website is hosted via Base44 (base44.com). When you visit the site, technical data (IP address, access time, browser type) is processed by the hosting provider. Base44's privacy policy applies: https://base44.com/privacy
6. Tracking & Third-Party Services
This website uses the following third-party tracking and analytics services. All are loaded via Google Tag Manager (GTM) and only activated after your consent. — Google Tag Manager (Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland): Used to manage and deploy tracking scripts. GTM itself does not collect personal data but loads the services below. Privacy policy: https://policies.google.com/privacy — Google Analytics / Google Ads (Google Ireland Ltd.): Used to analyze website traffic and measure advertising effectiveness. Data may be transferred to Google servers in the USA. Google is certified under the EU-US Data Privacy Framework. Legal basis: Art. 6 Abs. 1 lit. a GDPR (consent). Privacy policy: https://policies.google.com/privacy — Meta Pixel (Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland): Used to measure the effectiveness of advertising on Facebook and Instagram and to build custom audiences. Data may be transferred to Meta servers in the USA. Meta is certified under the EU-US Data Privacy Framework. Legal basis: Art. 6 Abs. 1 lit. a GDPR (consent). Privacy policy: https://www.facebook.com/privacy/policy — LinkedIn Insight Tag (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland): Used to track conversions from LinkedIn advertising campaigns and to enable retargeting. Data may be transferred to LinkedIn servers in the USA. LinkedIn is certified under the EU-US Data Privacy Framework. Legal basis: Art. 6 Abs. 1 lit. a GDPR (consent). Privacy policy: https://www.linkedin.com/legal/privacy-policy You can withdraw your consent at any time with future effect by adjusting your cookie preferences or by using the opt-out tools provided by each service.
7. Your Rights (Art. 15–21 GDPR)
You have the following rights regarding your personal data: — Access (Art. 15 GDPR): request a copy of the data we hold about you — Rectification (Art. 16 GDPR): correct inaccurate data — Erasure (Art. 17 GDPR): request deletion where no legal obligation requires retention — Restriction (Art. 18 GDPR): restrict processing in certain circumstances — Data portability (Art. 20 GDPR): receive your data in a structured, machine-readable format — Objection (Art. 21 GDPR): object to processing based on legitimate interests — Withdrawal of consent (Art. 7 Abs. 3 GDPR): where processing is based on consent, you may withdraw it at any time without affecting prior processing To exercise these rights, contact: hello@torbenglamm.com Supervisory authority for complaints (Art. 77 GDPR): Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit https://datenschutz.hamburg.de
8. GDPR & EU AI Act — Responsibility and Liability Allocation
Torben Glamm, as the operator of this website and provider of all associated services, is solely responsible for compliance with the General Data Protection Regulation (GDPR / DSGVO) as well as the EU Artificial Intelligence Act (EU AI Act, Regulation (EU) 2024/1689) with regard to the Provider's own systems, tools, and infrastructure. Clients cannot hold Torben Glamm liable for their own obligations under GDPR or the EU AI Act that arise from the client's independent operation, use, or deployment of software, systems, or AI tools — including those developed by the Provider on behalf of the client. Once a software system or AI application is handed over, put into operation, or otherwise brought under the client's control, the responsibility for GDPR-compliant operation and compliance with the EU AI Act (including classification, registration, and documentation obligations) transfers entirely to the client as the operator. Torben Glamm explicitly excludes any liability for: the client's own data processing activities, the client's use of third-party AI services, and any regulatory non-compliance arising from the client's independent operational decisions. The Provider will advise on applicable requirements upon request within the scope of the project agreement. Such advice does not constitute legal counsel and does not create a compliance obligation on the part of the Provider.
9. Changes to This Policy
We reserve the right to update this privacy policy at any time. The current version is always available on this page. Last updated: June 2026.
10. Newsletter — Maison Insider
You can subscribe to the Maison Insider newsletter ("Letters from the Atlantic") on the Maison and Building Maison pages. We store your e-mail address to send you these letters. Subscription requires a confirmed double opt-in. You can unsubscribe at any time using the link in every letter. Your newsletter subscription is separate from a Revenue Diagnostic submission — submitting a diagnostic does NOT subscribe you to the newsletter. The newsletter is currently processed through our hosting platform; a dedicated newsletter provider (Brevo) is in preparation and will be disclosed here once active.