Privacy Policy
1. Privacy at a Glance
General Information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on the subject of data protection, please refer to our privacy policy below.
Data Collection on This Website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find their
contact details in the Legal Notice of this website.
How do we collect your data?
Your data is collected in part by you providing it to us — for example, data you enter in a
contact form.
Other data is collected automatically or with your consent when you visit the website through
our IT systems. This is primarily technical data (e.g. internet browser, operating system, or
time of page access). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Some data is collected to ensure the error-free provision of the website. Other data may be
used to analyze your user behavior.
What rights do you have regarding your data?
You have the right to receive information about the origin, recipient, and purpose of your
stored personal data free of charge at any time. You also have the right to request the
correction or deletion of this data. If you have given your consent to data processing, you can
revoke this consent at any time for the future. You also have the right to request the
restriction of the processing of your personal data under certain circumstances. Furthermore,
you have the right to lodge a complaint with the competent supervisory authority.
2. Hosting
We host the contents of our website with the following provider:
IONOS SE
Elgendorfer Str. 57, 56410 Montabaur, Germany
For details, please refer to IONOS's privacy policy: https://www.ionos.de/terms-gtc/datenschutzerklaerung/
Cloudflare (Content Delivery Network and Attack Protection)
Our website is delivered via the content delivery network (CDN) of Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. All requests to our website pass through Cloudflare's servers. Cloudflare delivers content faster and blocks attacks and abusive requests. In doing so, Cloudflare processes technical data such as IP address, requested page, time of the request and browser information. We also load the program library for the PDF export of our website check via Cloudflare's cdnjs service.
The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in providing our website securely, quickly and reliably. Cloudflare is certified under the EU-U.S. Data Privacy Framework. More information: https://www.cloudflare.com/privacypolicy/
3. General Information and Mandatory Disclosures
Data Protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
The use of our website is generally possible without providing personal data. Where personal data (such as name, address, or email addresses) is collected on our pages, this is always done on a voluntary basis wherever possible. This data will not be passed on to third parties without your explicit consent.
Note on the Responsible Party
The responsible party for data processing on this website is:
Pragma Code LLC
Alexander Ohl
1 Building, Giorgi Leonidze Street / 2 Galaktion Tabidze St
Tbilisi 0105, Georgia
Phone: +49 511 515 67 91 8
E-Mail: INFO@pragma-code.de
The responsible party is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).
Storage Period
Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for data processing ceases to apply. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, deletion will occur once these reasons no longer apply.
Legal Basis for Data Processing on This Website
Where you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data within the meaning of Art. 9(1) GDPR are processed. In the event of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of § 25(1) TDDDG. Consent can be revoked at any time.
4. Data Collection on This Website
Contact Form
If you send us inquiries via the contact form, your details from the inquiry form, including the contact data you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We will not share this data without your consent.
The processing of this data is based on Art. 6(1)(b) GDPR if your request relates to the performance of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested.
The data you enter in the contact form will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your inquiry has been processed). Mandatory statutory provisions — in particular retention periods — remain unaffected.
Server Log Files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
Browser type and version · Operating system used · Referrer URL · Hostname of the accessing computer · Time of the server request · IP address
This data will not be merged with other data sources. This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of their website — for this purpose, server log files must be recorded.
Cookie Notice and Local Storage
Your choice in the cookie notice ("Accept all" or "Essential only") and your colour scheme setting (light/dark) are stored in your browser's local storage (localStorage). This information does not leave your device. Storing it is strictly necessary to respect your choice (Section 25(2) No. 2 TDDDG, Art. 6(1)(f) GDPR). You can change your choice at any time via the "Cookie Settings" link in the footer.
Cloudflare Web Analytics
To understand how our website is used and how fast it loads, we use Cloudflare Web Analytics (provider: Cloudflare, Inc., see above). A small script is loaded that transmits the requested page, the referring page, browser, device type, the country derived from the IP address and loading-time metrics to Cloudflare. According to Cloudflare, no cookies or other client-side storage are used for this, and visitors are not recognised via IP address, user agent or other characteristics ("fingerprinting"). The data is evaluated in aggregated form only.
The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in measuring and improving the reach and technical quality of our website. You can object to this processing by blocking the script from static.cloudflareinsights.com in your browser (e.g. with a content blocker).
Project Requests
We receive requests submitted via our project request form or the chat assistant by email and/or as a notification via the Slack service (Slack Technologies, LLC, USA), so that we can respond quickly. The Slack message contains the information from your form. The legal basis is Art. 6(1)(b) GDPR (pre-contractual measures), otherwise Art. 6(1)(f) GDPR. The storage period is the same as for the contact form.
Appointment Booking with Calendly
On our contact page you can book an appointment with us via an embedded booking window of Calendly LLC (USA). When the contact page loads, a connection to Calendly is established, through which Calendly receives, among other things, your IP address. If you book an appointment, Calendly also processes the data you enter (e.g. name, email address, preferred time). The legal basis is Art. 6(1)(b) GDPR where the booking serves to prepare a contract, otherwise Art. 6(1)(f) GDPR (straightforward scheduling). Calendly is certified under the EU-U.S. Data Privacy Framework. More information: https://calendly.com/privacy
Free Website Check
If you request our free website check, we process the address of the website to be checked, your name, your email address and – optionally – your company name. The check runs on servers of Vercel Inc. (USA). The report is stored with Upstash, Inc. (USA) and automatically deleted after 90 days; the link in your email remains valid for that period. We send the report by email via our mail server at IONOS. Vercel and Upstash are certified under the EU-U.S. Data Privacy Framework. The legal basis is Art. 6(1)(b) GDPR (providing the requested service).
Free AI Visibility Check
For the free AI visibility check, we process your email address and the details of your company or website. The request is handled on servers of Vercel Inc. (USA) and stored in a database of Neon, Inc. (USA). To check whether AI and search systems mention your company, we send search queries containing your company name or domain to Google (Gemini), Tavily and Brave Search – your email address is not transmitted. You receive the confirmation and the result by email via the delivery service Resend (Plus Five Five, Inc., USA). To prevent abuse, we store your IP address only in truncated form and as a checksum (hash), never in plain text. Vercel and Resend are certified under the EU-U.S. Data Privacy Framework. The legal basis is Art. 6(1)(b) GDPR (providing the requested service).
Checklist and Newsletter
If you enter your email address on our homepage to receive our checklist and occasional news, we store your email address. Sign-up uses a double opt-in procedure: the sign-up only becomes active once you click the link in our confirmation email. The data is stored on our server at IONOS and is not passed on to third parties. The legal basis is your consent (Art. 6(1)(a) GDPR). You can withdraw your consent at any time – via the unsubscribe link in each of our emails or by emailing us. Your address will then be deleted completely.
Chat Assistant
The chat assistant on our website is rule-based and runs directly in your browser; no third-party AI is connected. Your chat input is not transmitted – with one exception: if you explicitly send us a request via the chat (name, email, message), it is handled like a project request (see above).
Contact via WhatsApp and AI Assistant
You can reach us via WhatsApp. For users in the EU, the service is provided by WhatsApp Ireland Limited, a Meta group company. When you message us, WhatsApp and we process your phone number, your profile name, the content of your messages and metadata such as the time sent. A transfer to Meta Platforms, Inc. in the USA cannot be ruled out; Meta Platforms, Inc. is certified under the EU-U.S. Data Privacy Framework. The legal basis is Art. 6(1)(b) GDPR where your request serves to prepare or perform a contract, otherwise Art. 6(1)(f) GDPR (fast, straightforward communication via the channel you chose).
On our main WhatsApp number, an AI assistant ("Olaf") answers messages automatically when we do not reply ourselves. It identifies itself as an AI at the start of the conversation. The assistant is a service provided by Meta in the WhatsApp Business app; your messages are processed by Meta for this purpose. It answers solely on the basis of the information we give it (services, prices, process), makes no decisions with legal effect and does not bindingly confirm orders or appointments – only we do that in person. If the assistant books a call at your request, it passes the necessary details to Calendly (see "Appointment Booking with Calendly"). We read all chats and reply in person.
Please do not send us passwords, login credentials or bank details via WhatsApp. If you prefer not to use WhatsApp, you can always reach us by email at info@pragma-code.de. We delete chat histories as soon as they are no longer needed to handle your request and no statutory retention obligations apply. More information: https://www.whatsapp.com/legal/privacy-policy-eea
5. Your Rights
Right to Access, Deletion, and Rectification
Within the scope of applicable legal provisions, you have the right at any time to receive free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to correction or deletion of this data. For this and other questions on the subject of personal data, you can contact us at any time.
Right to Restriction of Processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose.
Right to Lodge a Complaint with a Supervisory Authority
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, place of work, or place of the alleged violation.
