Privacy Policy

1. Controller

Kragman GmbH is responsible for the processing described in this policy.

Address: Werner-von-Siemens-Strasse 2–6, 76646 Bruchsal, Germany.
E-mail for privacy enquiries and requests: info@kragman.de.
Telephone: +49 (0) 15758868224.

This policy covers the RIONGO presentation website, contact enquiries and newsletter.

2. Contact enquiries

When you use our contact form or write to us, we process the information you provide: your name, e-mail address, telephone number if supplied, subject, message and related correspondence. We use this information to answer and manage your request.

For enquiries concerning pre-contractual steps requested by you, the legal basis is Article 6(1)(b) GDPR. For general correspondence, the basis is Article 6(1)(f) GDPR: our legitimate interest in communicating with people who contact us. Processing required to fulfil a legal obligation is based on Article 6(1)(c) GDPR.

We need a reply address and sufficient information about your enquiry to answer it. You are not required to subscribe to marketing to contact us. Please provide only information necessary for your request.

Ordinary contact enquiries are retained for no more than 12 months after resolution. If specific information must be retained under a legal obligation or for an identified legal claim, it is retained for that purpose and the applicable period, with use restricted accordingly.

3. Website operation and hosting

The website is hosted through IPHost on a server located in the Republic of Moldova (outside the European Economic Area). Loading the website involves processing technical connection data, including the IP address and request information, which are required to deliver the website, diagnose faults, and protect against abuse. The legal basis is Art. 6(1)(f) GDPR: our legitimate interest in the reliable and secure operation of the website.

Backups of the database and website files are stored in an encrypted format on the servers of our provider, Hetzner Online GmbH, physically located in Germany (European Union), ensuring data security, resilience, and the capability for recovery in the event of technical incidents. Technical logs are subject to automatic rotation and overwriting. Relevant records related to an identified incident, legal obligation, or litigation are retained for as long as necessary for that specific purpose.

4. Newsletter and Mailchimp

We use Mailchimp, a service of The Rocket Science Group LLC, to manage subscriptions and send RIONGO news and promotional e-mails. For this purpose, we process your e-mail address, subscription information and any optional details you submit. The legal basis for newsletter delivery is your consent under Article 6(1)(a) GDPR.

Mailchimp open tracking is enabled for our newsletters. It uses an embedded image to register an opening when that image is loaded. The resulting information can be associated with the recipient and is used to assess newsletter engagement. An opening report is not conclusive proof that a person read the message: e-mail applications can block or automatically load images.

Newsletter delivery and recipient-level opening measurement are separate processing purposes. The legal basis for optional opening measurement is consent under Article 6(1)(a) GDPR covering that purpose; acceptance of website cookies does not provide this consent.

Each campaign contains an unsubscribe link. Using it withdraws consent to further newsletter delivery. You may also contact info@kragman.de to withdraw consent, object to direct marketing or request that opening measurement stop. Withdrawal takes effect for future processing and does not affect the lawfulness of processing carried out before withdrawal. Unsubscribing is not the same as deleting all data: minimum records may still be retained for the purposes described below.

Subscription information is kept while it is needed for the active subscription. Following withdrawal, it is removed from active marketing use. Opening records are retained only while needed to assess the relevant campaigns and are then deleted or anonymised. A minimum suppression record may be retained to respect an unsubscribe request and prevent unwanted re-subscription; it is not used for marketing. Evidence of consent may be retained where necessary to demonstrate compliance or defend a legal claim, for the relevant legal period.

Mailchimp’s information about processing is available at https://mailchimp.com/legal/data-processing-addendum/ .

5. Google reCAPTCHA v3

The contact form uses Google reCAPTCHA v3 to assess whether an interaction is likely to be automated and to reduce spam and abuse. The service analyses technical and interaction signals and returns a risk score. Processing includes the connection to Google’s service, the IP address, browser/device information and signals associated with the interaction. The service uses the _GRECAPTCHA cookie.

The purpose is to protect the contact form. Activation of this third-party service is subject to your prior consent, managed through Complianz. The legal basis for the associated consent-based personal-data processing is Article 6(1)(a) GDPR. You can withdraw that consent through the site’s cookie settings. If you do not activate reCAPTCHA, the protected form may be unavailable; you can still contact us directly at info@kragman.de without using this integration.

reCAPTCHA’s score assesses the risk of an automated submission. It is not used by Kragman GmbH to determine eligibility to purchase RIONGO products. Google explains its processing at https://policies.google.com/privacy and its cookies at https://policies.google.com/technologies/cookies .

6. Cookies and website analytics

We use the Complianz plugin to manage cookie preferences, record acceptance or refusal and control optional scripts. Consent preference data is processed to respect your choices and demonstrate compliance with applicable consent requirements. The legal basis is Article 6(1)(c) GDPR, in connection with those requirements. Technical storage strictly necessary to remember your choices is not used for advertising.

The site also uses a language preference cookie and Google reCAPTCHA as described in the Cookie Policy. We do not currently use Google Analytics, Google Ads or Meta Pixel for our own website analytics or advertising. Newsletter opening measurement is a separate activity described above.

Introducing new optional analytics or advertising tools requires updated information and consent where applicable. This policy does not grant advance permission for future tools.

7. Recipients and international processing

Data is accessible to authorized personnel and providers involved in the relevant activity: IPHost for hosting, Hetzner for backups, Mailchimp for the newsletter, Google for reCAPTCHA, and technical or email providers involved in managing the website and inquiries. Data may be disclosed to authorities when required by law and to professional advisors when necessary to defend legal rights.

Primary hosting through IPHost takes place in the Republic of Moldova (outside the European Economic Area). As of the date of this policy, Moldova does not benefit from an adequacy decision by the European Commission. To guarantee the protection of your personal data at a level equivalent to that within the EU, transfers to IPHost are based on Standard Contractual Clauses (SCCs) approved by the European Commission, concluded between Kragman GmbH and the hosting provider, accompanied by appropriate technical security measures (encryption).

The use of Mailchimp and Google also involves the possibility of data processing outside the EEA (e.g., in the USA), covered by the EU–US Data Privacy Framework and Standard Contractual Clauses. Additional information about transfer safeguards can be requested at info@kragman.de.

8. Your rights

Under the conditions set out in the GDPR, you have rights of access, rectification, erasure, restriction of processing and portability. Portability applies to automated processing based on consent or contract. A legal retention requirement or another lawful exception can limit deletion.

You may object to processing based on legitimate interests for reasons relating to your particular situation. We must stop that processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed for legal claims. You may object to direct marketing at any time without giving reasons; processing for that purpose must then stop.

You may withdraw consent at any time. Withdrawal does not affect processing lawfully carried out before withdrawal. Cookie consent can be changed through the Complianz settings; newsletter delivery can be stopped through the unsubscribe link. To request erasure, access or another data protection right, write to info@kragman.de. Changing cookie settings or unsubscribing does not automatically submit a request to erase all data held by Kragman GmbH. We normally respond within one month. If the GDPR permits an extension because of complexity or the number of requests, we inform you within that month and explain the reasons. We request additional identity information only where necessary and proportionate.

You may complain to a competent supervisory authority, particularly in the EU country where you habitually live, work or consider an infringement to have occurred. The authority for our establishment in Baden-Württemberg is the Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg: https://www.baden-wuerttemberg.datenschutz.de/ . You are not required to contact us first or to use only this authority.

9. Updates

We update this policy when processing or legal requirements change. Material changes are communicated appropriately and new consent is required where the law requires it. The date at the beginning of this document identifies the current version.