Privacy · Art. 13 GDPR

Privacy Policy

This website collects as little as possible. No cookies, no tracking, no analytics. This page says what is processed anyway, where, and which rights you have.

1. Controller

GEO Beratung – Victor Frenzel
Victor Frenzel
Brüsseler Straße 77
50672 Cologne
Germany
Email: hello@victorfrenzel.com
Phone: +49 156 79610588

A data protection officer is not required under Art. 37 GDPR and § 38 BDSG. The controller is the contact for all privacy matters.

2. What this website does not do

3. Hosting and access data

The website is served by Netlify, Inc., 101 2nd Street, San Francisco, CA 94105, USA. When you open a page, Netlify processes the data your browser transmits for technical reasons: IP address, date and time, the address requested, the amount of data transferred, browser type and operating system, and the page you came from. The server needs this data to deliver the page and to keep the service secure.

The legal basis is my legitimate interest in a secure and functioning website (Art. 6(1)(f) GDPR). I do not analyse this access data myself. A data processing agreement with Netlify is in place, including the EU Commission's standard contractual clauses; Netlify is also certified under the EU-US Data Privacy Framework. Netlify serves the site through a worldwide network of servers, including outside the EU. Netlify's own privacy statement covers how long access logs are kept: netlify.com/privacy.

4. Getting in touch

If you write to me by email, phone, WhatsApp or LinkedIn, I process your details to answer your request: your name, your contact details, the content of the message and, where you mention them, your property and your website. The legal basis is the initiation or performance of a contract (Art. 6(1)(b) GDPR), otherwise my legitimate interest in answering your request (Art. 6(1)(f) GDPR).

I keep the correspondence while the request is open and, if it becomes an engagement, for as long as commercial and tax retention rules require. Requests that do not lead to an engagement are deleted after one year at the latest.

WhatsApp and LinkedIn are third-party services. If you contact me there, the respective provider processes your data under its own terms: WhatsApp Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, and LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The link on this website transfers no data when the page loads; only your click opens the service.

5. The Self-Check

The Self-Check tells you whether AI systems can read your website. You enter your website address and your email address. I process both to check your homepage technically and to send you the result by email. If you have also ticked the Befund, I use your email address to send you, within 24 hours, the result of three questions put to an AI system.

The legal basis is the performance of the service you requested (Art. 6(1)(b) GDPR). The check runs as a function on Netlify (see section 3). The result email is sent through Brevo, a service of Sendinblue SAS, 17 rue de Salneuve, 75017 Paris, France, under a data processing agreement. Brevo may also process personal data outside the EU, in particular in the United States and in India; those transfers are covered by the European Commission’s standard contractual clauses. Brevo records whether the email is delivered and opened and whether you click a link in it; the links in the email therefore run via a Brevo address before the stated destination opens. This counting cannot be switched off when sending through the interface. Your details are not stored in any database. They exist in the result email to you and in a copy in my mailbox. I use them for nothing else, in particular for no newsletter and no follow-up without your renewed consent.

The check reads only what your website serves without a browser: the homepage, the robots.txt and the sitemap. It runs no JavaScript and does not store your page. Excerpts from your page appear in the result as evidence and nowhere else. The function's logs contain the checked domain, the duration and the result, no email address and no IP address.

6. Proposals and engagements

If I prepare a proposal for you or carry out an engagement, I process the data needed for it: company name, contact person, contact details, billing details, your website and the results of the commissioned survey. The legal basis is the contract (Art. 6(1)(b) GDPR) and the statutory retention duty for business records (Art. 6(1)(c) GDPR, § 257 HGB, § 147 AO), as a rule ten years for invoices and six years for business correspondence.

For surveys I query AI systems through their interfaces. I transmit the agreed questions, not your personal data. The name of your property is part of those questions; that is the subject of the engagement and is agreed with you beforehand.

7. External links

This website links to external sites, such as the sources of the studies cited, LinkedIn, Instagram and citravillas.com. Loading this website transfers no data to those providers. Only when you click a link do the privacy terms of the respective site apply.

8. Your rights

You have the right to access the data I process about you (Art. 15 GDPR), to rectification (Art. 16), to erasure (Art. 17), to restriction of processing (Art. 18), to data portability (Art. 20) and to object to processing based on legitimate interest (Art. 21). You may withdraw any consent you have given at any time with effect for the future.

An email to hello@victorfrenzel.com is enough. I answer within one month.

You also have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for my seat is the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia, Kavalleriestraße 2 to 4, 40213 Düsseldorf, ldi.nrw.de.

9. Security

The website is served exclusively over HTTPS. Emails to me are transmitted encrypted where your provider supports it. For confidential content, ask me for an encrypted channel first.

10. Version

This policy applies from 8 September 2026. I update it when the site's technology or the legal situation changes. The current version is always at this address.