Personal Data Protection Policy

Last updated: Oct. 2026

1. What does the Personal Data Protection Policy cover?

  • The purpose of this policy is to explain what data we process, why we process it, and what we do with it.
  • Our company utilizes technical measures for data security.
  • Our company discloses personal data solely to protect your interests and to fulfill legal obligations.
  • We take data protection seriously and never sell lists or email addresses. We make every effort to store and process your personal data securely. We do not disclose personal data to third parties without your consent.
  • We do not use your personal data for automated decision-making within the meaning of Art. 22 GDPR.

2. Who we are and contact details

Software Enthusiasts GmbH
Headquarters: Schillerstraße 12, 85521 Ottobrunn
Email: info@nuntio.tech

3. Explanation of terms used in this policy

  • Data Controller – The controller responsible for processing personal data within the meaning of Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR") is Software Enthusiasts GmbH.
  • Data subject within the meaning of the GDPR – an identified or identifiable natural person (who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person). The data subject may be the person requesting a service provided by the controller, as well as any other natural person whose personal data is transmitted to the controller (for example, a customer or prospective customer, a user of the controller's website, etc.).
  • Processing of personal data means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
  • Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
  • A personal data breach or a security breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
  • Pursuant to the provisions of the GDPR, in the relationship between Software Enthusiasts GmbH and you, you are a data subject and Software Enthusiasts GmbH assumes the role of the controller.

4. What personal data do we process?

We collect the personal data requested in the "Contact" section, or your email address provided to us when sending a message via the "Contact" section.

5. Why and how do we process your data?

We process your email address to transmit the information requested on the website, to provide you with a response to your message, to communicate with you, and to conduct our legitimate business activities.

We process the content of messages transmitted via the website https://nuntio.tech/, to our email address, or through other channels, as this content is necessary to respond to you personally and offer solutions tailored to your specific situation. The collection of this personal data and the text of your messages on the website https://nuntio.tech/ and sent to our email address takes place as a result of an action on your part when you decide to send us a message. The processing of this data is carried out in accordance with Art. 6(1)(f) GDPR, i.e., to safeguard the legitimate interests of Software Enthusiasts GmbH taking into account our business purpose.

6. What is the legal basis for processing your personal data?

The processing of your personal data submitted via messages in the "Contact" section is based on Art. 6(1)(f) GDPR, i.e., on the legitimate interests of Software Enthusiasts GmbH taking into account our business purpose.

The storage and archiving of the personal data submitted by you is carried out by Software Enthusiasts GmbH in accordance with Art. 6(1)(f) GDPR, i.e., to fulfill the legal obligations of Software Enthusiasts GmbH.

Should we enter into a contract following discussions with you, it will contain a personal data protection notice setting out all legal bases on which your personal data will be processed step by step: service delivery, storage, archiving, erasure, etc.

Cooperation with processors and third parties
If, within the scope of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, this is done solely on the basis of legal permission (e.g., if the transfer of data to third parties, such as payment service providers, is required for contract performance pursuant to Art. 6(1)(b) GDPR), you have consented, a legal obligation requires it, or on the basis of our legitimate interests (e.g., when engaging agents, web hosts, etc.). If we commission third parties to process data on the basis of a so-called "data processing agreement", this is done pursuant to Art. 28 GDPR.

7. On the purposes for which we process personal data

We process your data for the purposes outlined in Section 5.

Our purposes for processing your personal data are:

  • actual;
  • current;
  • legitimate


We will inform you before processing your personal data for secondary purposes:

  • if we originally collected your data for a primary purpose;
  • if our secondary purpose is incompatible with the primary purpose.

8. How long do we retain your data?

  • We limit the retention period of your personal data to the point in time when the purposes for which we requested your personal data are achieved, as well as to fulfill the legal obligations of Software Enthusiasts GmbH.
  • We review the necessity of further retaining your personal data on an annual basis. We analyze the collected and processed data to filter, sort, and retain processing only for data for which the processing purpose remains current.
  • Should we enter into a contract as a result of your message, it will contain a personal data protection notice informing you of all legal bases on which your personal data will be processed step by step: service delivery, storage, archiving, erasure, etc.

9. Do we share your personal data?

  • Our company does not share your personal data unless a contract has been concluded and sharing is required for contract execution, or specific legal obligations apply to Software Enthusiasts GmbH that require disclosure of your personal data.
  • We remind you that we guarantee strict confidentiality of your personal data and the messages you send us; preserving your privacy is an essential value for us.

10. Do we transfer your personal data outside the EU or the EEA?

Transfers to third countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of utilizing third-party services or disclosing/transferring data to third parties, this will only take place if it is done to fulfill our (pre-)contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we process data in a third country only if the specific requirements of Art. 44 et seq. GDPR are met. This means, for example, that processing is carried out based on specific guarantees, such as the officially recognized determination of a data protection level corresponding to the EU or compliance with officially recognized special contractual obligations (so-called "Standard Contractual Clauses").

11. Is your personal data secure?

We protect your data through:

  • through appropriate technical measures;
  • through appropriate organizational measures;
  • an appropriate level of security;
  • with measures against unauthorized processing;
  • with measures against unlawful processing;
  • measures against accidental or unlawful loss;
  • with measures against accidental or unlawful destruction;

 

If we can assume with reasonable certainty that a security breach has occurred in the processing of your personal data, then:
– we will report the security incident to our company's management.
– a designated person will immediately analyze:
A. whether the security breach could have adverse effects on you;
B. inform the relevant personnel at Software Enthusiasts GmbH;
C. determine the extent to which it is necessary to notify the supervisory authority of the security incident;
D. determine whether it is necessary to notify you of the security incident.
– we will investigate the security incident.
– we will attempt to prevent the incident from resulting in:
A. accidental or unlawful destruction of data;
B. accidental or unlawful loss of control over data;
C. accidental or unlawful loss of access to data;
D. accidental or unlawful alteration of data;
E. unauthorized disclosure of personal data;
F. unauthorized access to personal data.
– we will make every effort to mitigate the immediate risk of damage.
– we will notify the competent supervisory authority without undue delay and, where feasible, within 72 hours of the security incident, unless the breach is unlikely to result in a risk to your rights and freedoms (Art. 33 GDPR).
– we will inform you of the security breach:
A. if the breach is likely to result in a high risk to your rights and freedoms;
B. without undue delay;
C. through appropriate communication channels, for example by email, on our website, etc.
– we are not required to inform you directly if (Art. 34 para. 3 GDPR):
A. we have implemented appropriate technical and organizational protection measures that were applied to the personal data affected, in particular those that render the personal data unintelligible to any person who is not authorized to access it;
B. we have taken subsequent measures ensuring that the high risk to the rights and freedoms of data subjects is no longer likely to materialize;
C. it would involve disproportionate effort. In such a case, we will instead inform you via a public communication (e.g., on our website).

12. What rights do you have regarding your personal data?

Pursuant to the GDPR, as a data subject, you benefit from a series of rights, namely:

  • The right of access to personal data: the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to that data.
  • The right to rectification: the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you and/or the completion of incomplete personal data.
  • The right to erasure ("right to be forgotten"): the right to obtain the erasure of personal data concerning you without undue delay under the circumstances provided for in the GDPR.
  • The right to restriction of processing: the right to obtain the restriction of processing in certain circumstances.
  • The right to data portability: the right to receive the personal data concerning you and to transmit that data to another controller.
  • The right to object: the right to object at any time to the processing of personal data concerning you under the conditions laid down in the GDPR.
  • The right not to be subject to a decision based solely on automated processing—including profiling—which produces legal effects concerning you or similarly significantly affects you.
  • The right to lodge a complaint with a supervisory authority (Art. 77 GDPR), particularly in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that your data has not been processed in accordance with legal provisions. The competent supervisory authority for Software Enthusiasts GmbH is: Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany, lda.bayern.de.

The rights mentioned above are not absolute. Exceptions apply; therefore, each request received is analyzed so we can determine whether it is justified or not. To the extent that the request is justified, we will facilitate the exercise of your rights. If the request is unfounded or a statutory ground applies, we will reject it, but inform you of the reasons for refusal as well as your right to lodge a complaint with the supervisory authority and seek a judicial remedy before the competent courts.

13. How do you exercise your rights?

  • We invite you to communicate with us regarding the exercise of your rights for the protection of your personal data.
  • Please submit your request in text form (e.g., by email or by post) so that we can analyze the content of your request and verify your identity.
  • Your request should contain a description of the right you wish to exercise.
  • If we have reasonable doubts concerning your identity, we may request additional information necessary to confirm your identity (Art. 12 para. 6 GDPR), such as a copy of proof of identity (ID card or passport). You may redact any information on the document that is not required for identification.
  • The use of information from your identity document:
    – is limited to the activity of confirming your identity;
    – will not result in any storage of your personal data beyond what is necessary for this purpose.
  • If, despite all efforts, we are unable to identify you and you do not provide us with additional information for identification, we are not obliged to comply with your request.
  • You can submit your data protection request to the following address:
    – email address: info@nuntio.tech
    – directly to our headquarters.
  • You will receive our response to your data protection requests directly at the contact address officially provided to us: email.
  • Please note that Software Enthusiasts GmbH will respond to your requests via the same communication channel you used to send them (post, email, etc.), unless you specify otherwise in the request.
  • We have implemented policies to ensure that any request regarding the protection of your personal data is effective and processed within the statutory timeframes.
  • We will respond to your request within 1 month of receiving it. However, this period may be extended by 2 months according to law, depending on various aspects such as the complexity of the request, a high volume of received requests, or the inability to identify you within a reasonable time. Should we be unable to respond within the 1-month period, we will notify you within that timeframe of the extension and the reasons for it.
  • However, should your requests be manifestly unfounded or excessive, in particular because of their repetitive character, then:
    – we will either refuse to act on the request;
    – or charge a reasonable fee, taking into account the administrative costs of providing the information or taking the action requested.

For further details, you can consult all of the following legal acts:

  • Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR).
  • Federal Data Protection Act (BDSG).
  • Telecommunications Digital Services Data Protection Act (TDDDG).

14. Hosting

Our website is hosted by HostEurope GmbH. This service provider operates data centers in France and Germany. The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services, and technical maintenance services, which we utilize for the purpose of operating this online offer. In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta- and communication data of customers, interested parties, and visitors to this online offer on the basis of our legitimate interests in the efficient and secure provision of this online offer pursuant to Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

15. Collection of Access Data and Log Files

We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR. Access data includes the name of the retrieved web page, file, date and time of retrieval, volume of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address, and the requesting provider.

Log file information is stored for a maximum of 7 days for security reasons (e.g., to investigate abuse or fraudulent activities) and is deleted thereafter. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been conclusively resolved.

16. Links to Other Websites

This privacy policy applies exclusively to our own website. The web pages on this website may contain links (references) to third-party websites. Our privacy policy does not extend to these websites. When leaving our website, we recommend that you carefully read the privacy policies of each website that collects personal data.

17. Cookies, Analytics, and Third-Party Content

This website uses cookies or comparable technologies that are strictly necessary for the provision of the website and its security features (Section 25 (2) TDDDG). 

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool "Real Cookie Banner". Details on how "Real Cookie Banner" works can be found at https://devowl.io/rcb/data-processing/.

The legal bases for processing personal data in this context are Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for concluding a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we cannot manage your consents.

The fonts used on this website are hosted locally on our own server, so that no connection to third-party font providers (e.g. Google Fonts) is established when you visit our website.