Privacy Policy
Last updated: Nov. 15, 2025
1. Controller
The protection of your personal data is important to us.
This website is operated by:
Controller (data controller under Art. 4(7) GDPR)
Name: Manfred (Manni) Ostermann
Address: Kirchengasse 12, 2352 Gumpoldskirchen, Austria
Email: ostermann . manfred @ gmail . com
2. Purpose and scope of data processing
We process personal data only to the extent necessary for providing this website, processing your orders, and responding to inquiries.
(a) Website access / server logs
When you visit this site, the web server (NGINX) automatically records:
- IP address
- date/time
- browser type/version
- operating system
- referring URL
These data are stored in log files for security and technical operation.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure operation).
Retention: logs are automatically deleted within 30 days.
(b) Orders & payments
If you purchase a digital product, your payment and tax data are processed by our Merchant of Record (MoR), Paddle.com Market Ltd., United Kingdom.
Paddle.com Market Ltd. acts as the seller of record, handling all payments, invoices, VAT/tax collection, and refunds.
We receive only limited information necessary to deliver the product (your name, email address, product purchased, and delivery confirmation).
Legal basis: Art. 6(1)(b) GDPR (contract performance).
Recipient: Paddle.com Market Ltd., United Kingdom.
Transfer safeguard: EU-US Data Privacy Framework and/or Standard Contractual Clauses (Art. 46 GDPR).
Paddle.com Market Ltd. Privacy Policy: https://www.paddle.com/legal/privacy
(c) Communication
If you contact us via email, we process your message, contact details, and related correspondence to respond.
Legal basis: Art. 6(1)(b) or (f) GDPR (contract initiation / legitimate interest).
Retention: messages are deleted within 6 months after final reply unless longer retention is required by law.
(d) Delivery of digital content
Purchased reports are delivered via automated email link or direct download.
For security, download logs may record IP, timestamp, and order ID.
Legal basis: Art. 6(1)(b) GDPR.
Retention: up to 90 days to verify delivery.
3. Cookies and similar technologies
This website uses only technically necessary cookies to ensure secure operation.
Necessary cookies
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
__cf_bm, cf_clearance | Cloudflare | Security, bot detection | up to 30 min |
ghost-admin-api-session | Ghost (admin only) | CMS session cookie (not set for visitors) | Session |
| – | NGINX | No cookies set for visitors | – |
No marketing or tracking cookies are used.
Therefore, no cookie banner or consent pop-up is required (Art. 5(3) ePrivacy Directive / §96(3) TKG).
4. Hosting and content delivery
This site is hosted using Ghost CMS and NGINX, served via Cloudflare CDN for performance and DDoS protection.
Cloudflare may temporarily cache content on servers outside the EU but is certified under the EU-US Data Privacy Framework.
5. Data recipients & transfers
- Paddle.com Market Ltd. (United Kingdom) - Merchant of Record, payment processing, VAT, refunds.
- Cloudflare Inc. (USA) - CDN, security, caching.
- Email provider - transmission of transactional and support emails.
- Technical host - infrastructure and backup.
All transfers outside the EU/EEA use either the Data Privacy Framework (adequacy decision, July 2023) or Standard Contractual Clauses approved by the EU Commission (Art. 46 GDPR).
6. Retention and deletion
We keep personal data only as long as necessary for the stated purpose or required by law:
- Log files: 30 days
- Transaction data: 7 years (Austrian tax retention)
- Email correspondence: 6 months after last contact
- Product delivery logs: up to 90 days
After these periods, data are deleted or anonymized.
7. Data security
We use TLS encryption (https://) for all website communication.
Servers are located within the EU and protected by technical and organizational security measures to prevent unauthorized access.
8. Your rights under GDPR
You have the following rights regarding your personal data:
- Access (Art. 15)
- Rectification (Art. 16)
- Erasure (“right to be forgotten”) (Art. 17)
- Restriction of processing (Art. 18)
- Data portability (Art. 20)
- Objection (Art. 21)
To exercise your rights, contact ostermann . manfred @ gmail . com.
If you believe your data are processed unlawfully, you may lodge a complaint with:
Austrian Data Protection Authority (DSB) - https://www.dsb.gv.at
9. Right of withdrawal & refunds
As explained in the Imprint, EU consumers normally have a 14-day right of withdrawal for digital content.
This right expires once you consent to immediate delivery and access to the digital file.
Refunds (where applicable) are handled by Paddle.com Market Ltd.
10. Updates to this policy
We may update this Privacy Policy to reflect changes in technology or law.
The current version is always available on this page.
Contact:
Manfred (Manni) Ostermann
ostermann . manfred @ gmail . com
A-2352 Gumpoldskirchen
Austria
“We respect your privacy and use no tracking cookies. All data are processed in compliance with the EU General Data Protection Regulation (GDPR).”