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Data privacy

Last updated: 2026-06-12

Controller

Circular Ink UG (haftungsbeschränkt) Kreutzigerstr. 14, 10247 Berlin, Germany Email: data@circular.ink

Scope

This privacy notice covers website usage on circular.ink and related public pages.

Customer-specific operational tooling and data processing are governed separately in individual client agreements.

Philosophy

We are not in e-commerce, where tracking you across the web is the price of keeping you on the hook during a price war. Our offering is directed at a small number of people who can decide on their own whether to work with us. So we intentionally keep your footprint on these public pages minimal. In terms of analytics, we do want to know how you found us, which pages you visit, how far you scroll, what you click, and where you disengage – because those are the pointers that tell us where to improve. To create a more useful and human experience in an otherwise effectiveness-driven B2B world, we also run selected AI-supported features on public pages when you explicitly use them.

Data we process for website usage

  • Contact details you submit (for example email address in the login form).
  • Technical data needed to operate the website (for example IP address, timestamp, user agent, request metadata).
  • Booking metadata when you use the "Book a conversation" flow.
  • Product analytics events used to understand website usage and improve the service.

Purpose and legal basis (GDPR)

  • Provide and secure the website and login flow (Art. 6(1)(b), 6(1)(f) GDPR).
  • Respond to inquiries and booking requests (Art. 6(1)(b), 6(1)(f) GDPR).
  • Operate and improve website performance and reliability (Art. 6(1)(f) GDPR).
  • Comply with legal obligations (Art. 6(1)(c) GDPR), where applicable.

Subprocessors relevant for website usage

Only subprocessors required to run this website are listed here:

  • Vercel - frontend hosting and website delivery.
  • Supabase - authentication, database, and API infrastructure used by website/login flows.
  • Cal.com - meeting booking flow.
  • PostHog - product analytics and error tracking for website usage.
  • Google Gemini (Google LLC) - optional LLM processing for selected public-page workflows (for example quiz/readout). Inputs are processed only to generate the requested output and are not used for provider model training.

Data retention

  • Website and security logs are retained only as long as operationally necessary.
  • Inquiry and booking-related records are retained for the period required to process the request and for legal documentation obligations where applicable.
  • Analytics data is retained according to configured retention settings and operational necessity.

Your rights under GDPR

You have the right to request access, rectification, erasure, restriction of processing, data portability, and to object to processing where legally applicable.

You also have the right to lodge a complaint with a supervisory authority.

Competent supervisory authority (Berlin):

Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI) Alt-Moabit 59-61 10555 Berlin Germany https://www.datenschutz-berlin.de/

To exercise your rights, contact: data@circular.ink