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Privacy Policy

How we handle and protect your data.

Privacy

Last updated: 1 March 2026

1. Controller

ascenue GmbH (operating as zwrm) Christaweg 42, 79114 Freiburg, Germany Email: privacy@zwrm.eu

2. Overview

This privacy policy explains how zwrm ("we", "us") collects, uses, and protects personal data when you use our website (zwrm.eu) and our cloud platform services.

We process personal data in accordance with the EU General Data Protection Regulation (GDPR/DSGVO) and the German Federal Data Protection Act (BDSG).

3. Data We Collect

3.1 Website Visitors

When you visit our website, we collect:

  • Server log data: IP address, browser type, referring URL, pages visited, date and time of access. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in ensuring website security and performance).
  • Contact form submissions: Name, email address, company name, and message content. Legal basis: Art. 6(1)(b) GDPR (pre-contractual measures).
  • Waitlist/demo request: Email address. Legal basis: Art. 6(1)(a) GDPR (consent).

3.2 Platform Users

When you use the zwrm platform, we additionally process:

  • Account data: Name, email, company name, billing address. Legal basis: Art. 6(1)(b) GDPR (contract performance).
  • Usage data: Deployment logs, resource consumption, API calls. Legal basis: Art. 6(1)(b) GDPR (contract performance).
  • Payment data: Processed by our payment provider. We do not store credit card numbers.

3.3 Customer Content

Your application data, databases, and files deployed on zwrm are processed solely on your behalf. We act as a data processor under Art. 28 GDPR. A Data Processing Agreement (DPA/AVV) is available on request.

4. How We Use Your Data

We use personal data to:

  • Provide and maintain the zwrm platform
  • Process your requests and communicate with you
  • Send service-related notifications
  • Ensure security and prevent abuse
  • Comply with legal obligations
  • Improve our services (aggregated, anonymized data only)

We do not sell personal data to third parties. We do not use personal data for profiling or automated decision-making.

5. Data Storage and Transfers

All personal data is stored and processed exclusively within the European Union. We do not transfer personal data to countries outside the EU/EEA.

Our infrastructure is operated by an EU-registered entity, and we are not subject to the US CLOUD Act or similar foreign data access legislation.

6. Data Retention

  • Account data: Retained for the duration of the contractual relationship, then deleted within 30 days unless legal retention obligations apply.
  • Server logs: Deleted after 90 days.
  • Contact form data: Deleted after 12 months unless a business relationship is established.
  • Billing data: Retained for 10 years as required by German tax law (§ 147 AO).

7. Sub-processors

We use a limited number of sub-processors to provide our services. All sub-processors are contractually bound to GDPR-compliant data processing. See our Trust Center for the current list.

8. Your Rights

Under GDPR, you have the right to:

  • Access your personal data (Art. 15 GDPR)
  • Rectification of inaccurate data (Art. 16 GDPR)
  • Erasure of your data (Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Object to processing (Art. 21 GDPR)
  • Withdraw consent at any time (Art. 7(3) GDPR)

To exercise these rights, contact us at privacy@zwrm.eu.

9. Cookies

Our website uses only technically necessary cookies (e.g., language preference). We do not use tracking cookies, analytics services, or advertising technologies.

10. Security

We implement appropriate technical and organizational measures to protect personal data, including encryption in transit (TLS 1.3) and at rest (AES-256), access controls, and regular security assessments.

11. Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority. The competent authority for us is:

Supervisory authority placeholder — to be filled based on registered office location

12. Changes to This Policy

We may update this privacy policy from time to time. Changes will be posted on this page with an updated "last updated" date. Material changes will be communicated via email to registered users.