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Privacy Policy

Last updated: January 11, 2026

Preamble

With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as "data") we process for what purposes and to what extent. The 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 "online offer"). Note: This privacy policy was created with the Datenschutz-Generator.de by Dr. Thomas Schwenke.

The terms used are not gender-specific. Where terms are legally defined, their legal definitions apply.

Responsible Party

Responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) is:

Finn Hillebrandt
Am Brandberg 10
21401 Thomasburg
Deutschland
Kontakt:
E-Mail: info@gradually.ai
Telefon: +49 (0) 171 / 7344291
Impressum: Link zum Impressum
Overview of Processing

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

Types of Data Processed

  • •Inventory data (e.g. names, addresses)
  • •Contact data (e.g. email, phone numbers)
  • •Content data (e.g. text inputs, photographs, videos)
  • •Usage data (e.g. websites visited, interest in content, access times)
  • •Meta, communication and process data (e.g. IP addresses, time data, identification numbers)
  • •Contract data (e.g. subject matter, duration, customer category)
  • •Payment data (e.g. bank details, invoices, payment history)

Categories of Data Subjects

  • •Users (e.g. website visitors, users of online services)
  • •Communication partners
  • •Customers
  • •Interested parties
  • •Business and contractual partners

Purposes of Processing

✓Provision of contractual services and customer service
✓Contact requests and communication
✓Security measures
✓Range measurement and web analytics
✓Office and organizational procedures
✓Administration and answering of inquiries
✓Provision of our online offer and user-friendliness
✓IT infrastructure (operation and provision of information systems)
✓Marketing and sales promotion
Relevant Legal Bases

Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile.

Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.

Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes in particular the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG).

Security Measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

  • Ensuring the confidentiality, integrity and availability of data.
  • Control of physical and electronic access.
  • Use of encryption procedures (SSL/TLS).
  • Procedures for regular review, assessment and evaluation of the effectiveness of technical and organizational measures.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology.

Transfer of Personal Data & International Data Transfers

Transfer of Personal Data

In the context of our processing of personal data, it may happen that it is transferred to other places, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

International Data Transfers

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements.

EU-US Data Privacy Framework: Within the framework of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as safe within the framework of the adequacy decision of July 10, 2023. We inform you in the context of the data protection notes which service providers we use are certified under the Data Privacy Framework.

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with the legal provisions as soon as the underlying consents are revoked or there are no further legal grounds for the processing. This applies to cases where the original processing purpose no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations (e.g. retention obligations under tax or commercial law) require longer retention.

10 years – Retention period for books and records, annual financial statements, accounting vouchers and invoices.
6 years – Other business documents, insofar as they are relevant for taxation.
3 years – Data required to consider potential warranty and damage claims (regular limitation period).
Table of Contents
  • • Preamble
  • • Responsible Party
  • • Overview of Processing
  • • Relevant Legal Bases
  • • Security Measures
  • • Transfer of Personal Data
  • • International Data Transfers
  • • General Information on Data Retention and Deletion
  • • Rights of Data Subjects
  • • Provision of the Online Offer and Web Hosting
  • • Use of Cookies
  • • Web Analytics, Monitoring and Optimization
  • • Infrastructure and Databases
  • • AI Tools and Text Generators
  • • Newsletter and Electronic Notifications
  • • Sucuri (Web Security)
  • • Presences in Social Networks (Social Media)
  • • E-Commerce & Payment Processing
  • • Affiliate Programs and Affiliate Links
  • • VG Wort (Tracking Pixel)
  • • Testimonials (Senja)
  • • AI Chatbot (Chatbase)
  • • Contact and Inquiry Management
  • • Definitions
Your Rights as a Data Subject

As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR.

Right to Withdraw Consent

You have the right to withdraw consent at any time.

Right of Access

You have the right to obtain confirmation as to whether personal data concerning you is being processed and to access that data as well as further information and a copy of the data in accordance with the legal requirements.

Right to Rectification

You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the legal requirements.

Right to Erasure and Restriction of Processing

You have the right to request that data concerning you be deleted without undue delay, or alternatively to request restriction of processing of the data in accordance with the legal requirements.

Right to Data Portability

You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format or to request transmission to another controller in accordance with the legal requirements.

Right to Lodge a Complaint

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Contact for Privacy Questions

If you have any questions about privacy or wish to exercise your rights, you can contact us at any time:

E-Mail: info@gradually.ai

Phone: 0171/7344291

Postal Address:
Finn Hillebrandt
Am Brandberg 10
21401 Thomasburg

Definitions

In this section, you will find an overview of the terms used in this privacy policy:

Personal Data:

Any information relating to an identified or identifiable natural person.

Controller:

The natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

Processing:

Any operation or set of operations performed on personal data, whether or not by automated means.

Consent:

Any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

This privacy policy was last updated on January 11, 2026.

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