Privacy policy.

1. Overview

This policy explains what happens to personal data when you visit ps-code.de or get in touch with us. It follows Art. 13 and 14 GDPR. In short: this website sets no cookies, stores nothing on your device, and loads nothing from third-party servers until you actively ask it to. Visits are counted in aggregate only, without cookies and without any profile of you.

2. Controller

Product Studio S&M UG (haftungsbeschränkt)
trading as Product Studio at CODE
c/o CODE Education GmbH
Donaustraße 44
12043 Berlin
Germany

Managing directors: Emin Sengül (CEO), Nikolaos Magklis (COO)

E-Mail: hello@ps-code.de

3. Data Protection Officer

We are not required to appoint one. We do not permanently employ 20 or more people on the automated processing of personal data (§ 38 (1) sentence 1 BDSG), we carry out no processing that requires a data protection impact assessment under Art. 35 GDPR, and we do not process personal data commercially for the purpose of transfer or for market or opinion research (§ 38 (1) sentence 2 BDSG). The cases in Art. 37 (1) GDPR do not apply either. For any privacy matter, write to hello@ps-code.de.

4. No cookies, no consent banner, reach measurement only

This website stores nothing on your device and reads nothing from it. There are no cookies, no local or session storage, no tracking pixels, no advertising tools and no social media plugins.

Web fonts and images are served from our own servers rather than from an external content delivery network, so no third party learns that you visited us.

Reach measurement: To see how many people read which page, we use Vercel Web Analytics, provided by our hosting provider Vercel Inc. (see section 8). The measurement script is delivered from our own domain and reports back to it, so no data flows to an additional company. Per page view the following is recorded: time, page address, referrer, filtered query parameters, approximate location at city level, device type, operating system and browser. Repeat views are grouped by a hash generated from the incoming request, which is discarded after 24 hours at the latest. No cookie is set, nothing is stored on your device, and no profile is built that would follow you across websites or sessions.

Legal basis: Art. 6 (1) (f) GDPR. Our legitimate interest is knowing which content is used, so we can maintain and improve the site. Since nothing is stored on or read from your device, § 25 TDDDG does not require consent.

Because we do not carry out any processing that requires consent under § 25 TDDDG, we do not show a consent banner. Asking for a consent we do not need would suggest you could withdraw permission that was never the legal basis for anything, which would itself be misleading. You can object to the reach measurement at any time under Art. 21 GDPR by writing to hello@ps-code.de. A content blocker in your browser also stops the measurement script from loading in the first place.

5. Server log files

When you open a page, our hosting provider records the request in a log file. This is technically unavoidable for operating a website. The following data is processed:

• IP address of the requesting device
• Date and time of the request
• The page or file requested
• Referrer URL
• Browser type and version, operating system

Purpose and legal basis: Art. 6 (1) (f) GDPR. Our legitimate interests are operating the site reliably, diagnosing faults, and detecting and defending against attacks and misuse. Without this data we could not run the service securely.

Retention: Log data is deleted automatically after 30 days at the latest, unless a specific security incident requires us to keep individual entries longer in order to investigate it.

This data is not merged with other sources and is not used to identify you as a person.

6. Contact form and e-mail

If you send us a brief through a form on this site, we process the details you enter, typically your name, e-mail address, company, the services you are interested in, budget and timeline indications and your message.

Purpose and legal basis: Art. 6 (1) (b) GDPR where your enquiry concerns entering into or performing a contract, otherwise Art. 6 (1) (f) GDPR based on our legitimate interest in answering enquiries addressed to us.

Is providing the data required? No law or contract obliges you to. Name and e-mail address are needed for us to reply at all; without them we cannot process your enquiry. Every other field is optional.

How the form is sent: Submissions go to an endpoint on this website and are forwarded from there by e-mail to our own mailbox. No external form service is involved. Our mailbox is operated by STRATO AG, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany, as a processor under Art. 28 GDPR, with servers in Germany. To keep out automated spam, the endpoint uses a hidden form field and a limit on the number of submissions per IP address; the IP address is only checked in memory for that purpose and is not stored with your enquiry.

Retention: Your enquiry stays in our mailbox for as long as it takes to handle it and for as long as statutory retention periods require, after which it is deleted.

If you write to us directly by e-mail, we process the data contained in that message on the same legal bases.

7. Booking a call (Cal.com)

Our booking form can open a scheduling calendar. That calendar is not loaded when the page opens. It is requested only after you have filled in the form and pressed the submit button, that is, after you have actively asked for it.

At that moment your browser connects to app.cal.eu and your IP address, the details you entered and technical connection data are transmitted. The calendar is provided by Cal.com, Inc., 2261 Market Street #4382, San Francisco, CA 94114, USA, through its European data residency service, under which booking data is stored in the EU. Because Cal.com, Inc. is a US company, access from outside the EU cannot be ruled out.

Legal basis: Art. 6 (1) (b) GDPR for arranging the appointment you requested. The loading of the calendar is covered by § 25 (2) no. 2 TDDDG, because it is strictly necessary to provide the service you expressly asked for.

If you do not want any data to reach Cal.com, simply write to hello@ps-code.de instead of using the booking form.

8. Hosting

This website is hosted by Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA. Vercel processes the data described in sections 4 and 5 on our behalf as a processor under Art. 28 GDPR.

9. Transfers outside the EU

Some of the providers named above are located outside the European Economic Area. We rely on the following safeguards under Chapter V GDPR:

• Vercel Inc. (USA): certified under the EU-US Data Privacy Framework, so transfers are covered by the European Commission's adequacy decision of 10 July 2023 (Art. 45 GDPR). Standard contractual clauses additionally apply through Vercel's data processing agreement.
• Cal.com, Inc. (USA): booking data is stored in the EU through the provider's European data residency service; loaded only after you actively submit the booking form.

You can request a copy of the relevant safeguards from us at hello@ps-code.de.

10. Your rights

You have the following rights regarding your personal data:

• Access (Art. 15 GDPR): confirmation of whether we process data about you, and a copy of it.
• Rectification (Art. 16 GDPR): correction of inaccurate or incomplete data.
• Erasure (Art. 17 GDPR): deletion, unless statutory retention obligations prevent it.
• Restriction (Art. 18 GDPR): restriction of processing.
• Data portability (Art. 20 GDPR): the data you provided, in a structured, commonly used, machine-readable format.
• Withdrawal of consent (Art. 7 (3) GDPR): where processing is based on consent, you can withdraw it at any time with effect for the future.

An informal e-mail to hello@ps-code.de is enough to exercise any of them.

11. Right to object

You have the right to object at any time, on grounds relating to your particular situation, to processing of your personal data based on Art. 6 (1) (f) GDPR (Art. 21 GDPR). This applies in particular to the server log files described in section 5. If you object, we will stop processing your data unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims.

Send your objection to hello@ps-code.de.

12. Right to lodge a complaint

You can lodge a complaint with a supervisory authority, in particular in the member state of your residence, place of work or the place of the alleged infringement. The authority responsible for us is the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin.

13. No automated decision-making

We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.

14. Changes to this policy

We update this policy when the processing described here changes, for example when we add or remove a service provider.