{"id":3204,"date":"2026-05-03T16:54:51","date_gmt":"2026-05-03T16:54:51","guid":{"rendered":"https:\/\/twinlake.de\/privacy-policy\/"},"modified":"2026-05-04T20:46:51","modified_gmt":"2026-05-04T20:46:51","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/twinlake.de\/en\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"\t\t
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Privacy Policy<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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1. Privacy at a Glance<\/b><\/h4>
General Information<\/h5>

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. For detailed information on data protection, please refer to our privacy policy listed below this text. <\/p>

Data Collection on This Website<\/h5>

Who is responsible for data collection on this website?<\/strong><\/p>

Data processing on this website is carried out by the website operator. You can find the operator’s contact details in the “Information on the Responsible Party” section of this privacy policy. <\/p>

How do we collect your data?<\/strong><\/p>

Your data is collected in part by you providing it to us. This may include data you enter into a contact form, for example.
Other data is collected automatically or with your consent when you visit the website through our IT systems. This primarily includes technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website. <\/p>

What do we use your data for?<\/strong><\/p>

Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders, or other order requests. <\/p>

What rights do you have regarding your data?<\/strong><\/p>

You have the right at any time to receive information free of charge about the origin, recipient, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority. <\/p>

You can contact us at any time regarding this and any other questions about data protection.<\/p>

Analysis Tools and Third-Party Tools<\/h5>

When you visit this website, your browsing behavior may be statistically analyzed. This is primarily done using analysis programs.
Detailed information about these analysis programs can be found in the following privacy policy. <\/p>

2. Hosting<\/strong><\/h4>

We host the content of our website with the following provider:<\/p>

External Hosting<\/h5>

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, but is not limited to, IP addresses, contact requests, meta and communication data, contractual data, contact details, names, website access, and other data generated via a website.
External hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and \u00a7 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time. <\/p>

Our host(s) will only process your data to the extent necessary to fulfill its performance obligations and will follow our instructions regarding this data.
We use the following host(s):<\/p>

united-domains GmbH
Gautinger Stra\u00dfe 10
82319 Starnberg<\/p>

For details, please refer to the privacy policy of united-domains: https:\/\/www.united-domains.de\/unternehmen\/datenschutz\/<\/p>

Data Processing Agreement<\/h5>

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the service processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR. <\/p>

Microsoft 365<\/h5>

We use services from Microsoft. For customers in the European Union, these are generally provided contractually by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland (hereinafter “Microsoft”). <\/p>

In particular, Microsoft 365 is used (including Exchange Online, Outlook, Teams, SharePoint\/OneDrive).
Through these services, we process personal data for purposes such as internal and external communication (email, chats, video calls), document storage and editing, and the automation of internal processes. Processed data includes, in particular, names, email addresses, the content of messages or inquiries, and technical metadata such as timestamps, IDs, and log data. <\/p>

The legal basis, insofar as the processing serves the fulfillment of a contract or the implementation of pre-contractual measures, is Art. 6(1)(b) GDPR. Otherwise, processing is based on our legitimate interest in an efficient, secure, and low-failure IT and communication infrastructure in accordance with Art. 6(1)(f) GDPR. If corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and \u00a7 25(1) TDDDG; consent can be revoked at any time.
The use of Microsoft services is based on the applicable Microsoft license terms, in particular the Microsoft Online Subscription Agreement, the Microsoft Product Terms, and the Microsoft Products and Services Data Protection Addendum (DPA), which regulates data processing in accordance with Art. 28 GDPR. Microsoft operates the so-called EU Data Boundary for European customers. Nevertheless, a transfer of personal data to the USA or other third countries cannot be completely ruled out and, in these cases, is based in particular on the standard contractual clauses of the EU Commission. Microsoft Corporation is also certified under the “EU-US Data Privacy Framework” (DPF). Further information can be found at: https:\/\/privacy.microsoft.com\/en-us\/privacystatement, Microsoft Products and Services DPA, and the DPF entry. <\/p>

3. General Information and Mandatory Information<\/strong><\/h4>
Privacy<\/h5>

The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.
We would like to point out that data transmission over the internet (e.g., when communicating by email) may have security vulnerabilities. Complete protection of data from access by third parties is not possible. <\/p>

Information on the Responsible Party<\/strong><\/p>

The party responsible for data processing on this website is:<\/p>

Twinlake Advisory GmbH
Weidenlohstr. 18
82239 Alling
Email: info@twinlake.de <\/p>

The responsible party is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g., names, email addresses, etc.).<\/p>

Storage Duration<\/h5>

Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial retention periods); in the latter case, deletion will occur after these reasons cease to apply. <\/p>

General Information on the Legal Basis for Data Processing on This Website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, if special categories of data pursuant to Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information in your device (e.g., via device fingerprinting), data processing is additionally carried out on the basis of Section 25(1) TDDDG. Consent can be revoked at any time. If your data is required for contract fulfillment or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if it is necessary to fulfill a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following sections of this privacy policy. <\/p>

Data Protection Officer<\/h5>

We have appointed a data protection officer.
Nathanael Bauch
Lindpaintnerstra\u00dfe 15
81247 Munich<\/p>

Email: datenschutz@twinlake.de<\/p>

Note on data transfer to third countries that are not secure under data protection law and transfer to US companies that are not DPF-certified
We use, among other things, tools from companies based in third countries that are not secure under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to and processed in these countries. We point out that in third countries that are insecure under data protection law, a level of data protection comparable to that of the EU cannot be guaranteed. <\/p>

We point out that the USA, as a secure third country, generally has a level of data protection comparable to that of the EU. Data transfer to the USA is permissible if the recipient holds certification under the “EU-US Data Privacy Framework” (DPF) or has suitable additional guarantees. Information on transfers to third countries, including the data recipients, can be found in this privacy policy. <\/p>

Recipients of Personal Data<\/h5>

In the course of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is necessary for contract fulfillment, if we are legally obliged to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6(1)(f) GDPR, or if another legal basis permits the disclosure of data. When using data processors, we only disclose personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded. <\/p>

Revocation of Your Consent to Data Processing<\/h5>

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation. <\/p>

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)
If data processing is based on Art. 6(1)(e) or (f) GDPR, you have the right at any time to object to the processing of your personal data on grounds relating to your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves the establishment, exercise, or defense of legal claims (objection pursuant to Art. 21(1) GDPR).
If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object, your personal data will subsequently no longer be used for direct marketing purposes (objection pursuant to Art. 21(2) GDPR). <\/p>

Right to Lodge a Complaint with the Competent Supervisory Authority<\/h5>

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or place of the alleged infringement. The right to lodge a complaint is without prejudice to other administrative or judicial remedies. <\/p>

Right to Data Portability<\/h5>

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of data to another controller, this will only be done to the extent that it is technically feasible. <\/p>

Information, Correction, and Deletion<\/h5>

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to correction or deletion of this data. You can contact us at any time regarding this and any other questions about personal data. <\/p>

Right to Restriction of Processing<\/h5>

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases: <\/p>

\u2022 If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the audit, you have the right to request the restriction of the processing of your personal data.
\u2022 If the processing of your personal data was\/is unlawful, you can request the restriction of data processing instead of deletion.
\u2022 If we no longer need your personal data, but you need it for the exercise, defense, or establishment of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
\u2022 If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data. <\/p>

If you have restricted the processing of your personal data, this data \u2013 apart from its storage \u2013 may only be processed with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.<\/p>

SSL or TLS Encryption<\/h5>

For security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http:\/\/” to “https:\/\/” and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties. <\/p>

Objection to Promotional Emails<\/h5>

We hereby object to the use of contact data published as part of the imprint obligation for sending unsolicited advertising and informational materials. The operators of this website expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as spam emails. <\/p>

4. Data Collection on This Website<\/strong><\/h4>
Cookies<\/h5>

Our website uses so-called “cookies.” Cookies are small data packets and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted after your visit. Permanent cookies remain stored on your device until you delete them yourself or automatic deletion is carried out by your web browser.
Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for advertising purposes.
Cookies that are necessary to carry out the electronic communication process, to provide certain functions you have requested (e.g., for the shopping cart function), or to optimize the website (e.g., cookies for measuring web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG); consent can be revoked at any time.
You can set your browser so that you are informed about the setting of cookies and only allow cookies on a case-by-case basis, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.
You can find out which cookies and services are used on this website in this privacy policy. <\/p>

Consent with Cookiebot<\/h5>

Our website uses consent technology from Cookiebot to obtain your consent to the storage of certain cookies on your device or to the use of certain technologies and to document this in a data protection-compliant manner. The provider of this technology is Usercentrics A\/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter “Cookiebot”).
When you enter our website, a connection to Cookiebot’s servers is established to obtain your consent and other declarations regarding cookie use. Cookiebot then stores a cookie in your browser to be able to assign the consents you have given or their revocation to you. The data collected in this way is stored until you request us to delete it, delete the Cookiebot cookie yourself, or the purpose for data storage no longer applies. Mandatory legal retention obligations remain unaffected.
Cookiebot is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR. <\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t

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