Privacy Policy

1. Controller

Robin Wirsching, Am Hochmoor 10, 26160 Bad Zwischenahn, Germany. Phone: +49 171 6156617. Email: robin@robinwirsching.com.

2. General information on processing

We process personal data only to the extent necessary to provide this website securely, to handle your enquiry or to carry out pre-contractual or contractual measures. The relevant legal bases are in particular Art. 6(1) lit. b, c and f GDPR and, where required, your consent under Art. 6(1)(a) GDPR.

3. Hosting by Framer

This website is provided by Framer B.V., Rozengracht 207B, 1016 LZ Amsterdam, the Netherlands. When you visit the website, Framer processes technically necessary data, in particular your IP address, time of access, page requested, browser and device information, referrer URL and HTTP status code. This processing serves the technically secure and reliable provision of the website and is based on our legitimate interest under Art. 6(1)(f) GDPR. Where Framer processes data on our behalf, the corresponding data processing agreement applies. Framer also provides reach statistics integrated into the hosting, such as page views, referring pages, device type and country. According to Framer, this works without cookies and with anonymised data; we only see aggregated reports. The legal basis is our legitimate interest in analysing and improving our website under Art. 6(1)(f) GDPR.

3.1 Redirecting former domains via Cloudflare

If you visit one of our former addresses (robin-wirsching.de or robinwirsching.de, each also with www), you are automatically redirected to this website. The redirect and the SSL certificate required for it are provided by Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. Cloudflare processes technically necessary data such as your IP address, the address requested, time of access and browser and device information, and stores it briefly in logs. No cookies are set. Cloudflare processes the data as a processor on the basis of a data processing agreement. Data may be transferred to the USA; Cloudflare is certified under the EU-US Data Privacy Framework; EU Standard Contractual Clauses also apply. The legal basis is our legitimate interest in reliably and securely redirecting former addresses under Art. 6(1)(f) GDPR.

4. Contact by email or phone

If you contact us by email or phone, we process the information you provide in order to handle your enquiry and any follow-up questions. Business email communication runs via Google Workspace, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Depending on the context, the legal basis is Art. 6(1)(b) or (f) GDPR.

4.1 Booking an appointment on this website (Growth Check)

If you book a free Growth Check on this website, we process the data you provide: name, email address, optionally your website or company, your selections regarding your request and advertising, optionally your own description, and the selected appointment. To display available slots and complete the booking, this information is transmitted to a script (Google Apps Script) in our Google Workspace account; for technical reasons your IP address is also processed. The appointment is created in our Google Calendar and you receive a calendar invitation with a Google Meet link at the email address provided. The conversation takes place via Google Meet, during which your video and audio data and technical connection data are processed. The call is not recorded without your express consent. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, acting as a processor on the basis of a data processing agreement. Data may be transferred to the USA; Google is certified under the EU-US Data Privacy Framework. The legal basis is Art. 6(1)(b) GDPR (pre-contractual measures taken at your request). Name and email address are required for the booking; all other information is voluntary. We delete the data once it is no longer needed for initiating or carrying out a collaboration and no statutory retention obligations apply. If no collaboration results, we delete your data no later than 24 months after our last contact.

4.2 Customer management with HubSpot

To prepare, follow up and manage enquiries, we store the information from your booking (name, email address, website or company, details of your request and the appointment) in our CRM system HubSpot. We and our cooperation partner Shabasi Digital Tech (see section 4.3) have access to it. The provider is HubSpot Ireland Limited, 1 Sir John Rogerson’s Quay, Dublin 2, Ireland, whose parent company is HubSpot, Inc., USA. HubSpot processes the data as a processor on the basis of a data processing agreement. The data is stored in a data centre in the EU; access from the USA, for example by support staff or sub-processors, is nevertheless possible. HubSpot, Inc. is certified under the EU-US Data Privacy Framework; EU Standard Contractual Clauses also apply. The legal basis is Art. 6(1)(b) GDPR and our legitimate interest in handling enquiries in an orderly manner under Art. 6(1)(f) GDPR. We delete the data once it is no longer needed for these purposes and no statutory retention obligations apply. If no collaboration results, we delete your data no later than 24 months after our last contact.

4.3 Cooperation with Shabasi Digital Tech

For certain prospects and projects we work together with our cooperation partner Shabasi Digital Tech, owner Mohamed Elshabasi, Artillerieweg 35, 26129 Oldenburg, Germany. Depending on the project, one of us takes the lead and the other supports. Shabasi Digital Tech has its own access to our CRM system HubSpot and can view and edit the information from enquiries and bookings there (in particular name, contact details, company, request, appointments and project status) to the extent necessary for joint support, preparing offers and carrying out projects. For this joint support, we and Shabasi Digital Tech are joint controllers under Art. 26 GDPR. We have set out our respective obligations, in particular regarding information and handling your requests, in an agreement; we will provide you with its essential content on request. We are your first point of contact for exercising your rights (section 1), but you can also exercise them against Shabasi Digital Tech (info@shabasidigitaltech.de). The legal basis is Art. 6(1)(b) GDPR and our legitimate interest in sharing the work on enquiries and projects under Art. 6(1)(f) GDPR.

6. Google Tag Manager

We use Google Tag Manager by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Tag Manager is only loaded after you have consented to the “Analytics” or “Advertising” category in the cookie settings; before that, there is no connection to Google. When it loads, your IP address is transmitted to Google. A transfer to the USA cannot be ruled out; Google LLC is certified under the EU-US Data Privacy Framework. Tag Manager itself does not analyse usage data; it only controls the integration of other services. The legal basis is your consent under Art. 6(1)(a) GDPR and Section 25(1) TDDDG, which you can withdraw at any time with effect for the future. Via Tag Manager we currently use Google Analytics 4 and Microsoft Clarity (sections 6.1 and 6.2). Advertising and marketing services are not enabled.

6.1 Google Analytics 4

With your consent to the “Analytics” category, we use Google Analytics 4 by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, via Google Tag Manager. Google Analytics evaluates how the website is used, such as pages viewed, time spent, where visits come from, device type and approximate location at country level. For this purpose cookies are set (e.g. “_ga”) and your IP address is processed; according to Google, IP addresses of users in the EU are not stored. We have disabled Google signals, data sharing with Google for its own purposes, granular location and device data, and personalised advertising. User- and event-level data is deleted after 2 months. Google processes the data on our behalf on the basis of the Google Ads Data Processing Terms. A transfer to the USA cannot be ruled out; Google LLC is certified under the EU-US Data Privacy Framework. The legal basis is your consent under Art. 6(1)(a) GDPR and Section 25(1) TDDDG, which you can withdraw at any time via the cookie settings with effect for the future.

6.2 Microsoft Clarity

With your consent to the “Analytics” category, we use Microsoft Clarity by Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, via Google Tag Manager. Clarity records how you use the website, such as mouse movements, clicks, scrolling and pages viewed, and creates heatmaps and session recordings from this. Input in form fields and content recognised as sensitive is masked in your browser. Cookies are set and your IP address is processed. Clarity is linked to our Google Analytics account (section 6.1): evaluated Clarity data, such as a reference to the respective session recording, is combined with the Analytics data there. This only happens if you have consented to the “Analytics” category. Microsoft is an independent controller for Clarity and, under the Clarity terms of use, also uses the data for its own purposes, such as improving its products and services including advertising; for details see Microsoft’s privacy statement (privacy.microsoft.com). Data may be stored in the USA; Microsoft is certified under the EU-US Data Privacy Framework. The legal basis is your consent under Art. 6(1)(a) GDPR and Section 25(1) TDDDG, which you can withdraw at any time via the cookie settings with effect for the future.

7. International data transfers

With internationally operating service providers, processing outside the European Union or the European Economic Area cannot be ruled out. Where necessary, we base such transfers on the safeguards provided for under the GDPR, in particular adequacy decisions or standard contractual clauses.

8. Storage period

We store personal data only for as long as necessary for the respective purpose or as required by statutory retention obligations.

9. Your rights

Subject to the statutory requirements, you have in particular the right of access, rectification, erasure, restriction of processing, data portability, objection and the right to withdraw consent with effect for the future. Please use the contact details above for this. Where we process data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), you may object to this processing at any time on grounds relating to your particular situation (Art. 21 GDPR). We do not use automated decision-making, including profiling, within the meaning of Art. 22 GDPR.

10. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for our location is in particular the State Commissioner for Data Protection of Lower Saxony (Landesbeauftragte für den Datenschutz Niedersachsen).

11. Security

Data between your browser and this website is transmitted via a TLS-encrypted connection.

Last updated: November 2026. This is a courtesy translation; the German version is legally binding. Before further services are activated, such as analytics, marketing, booking or form services, this policy will be updated accordingly.