Privacy policy

Draft: This is an internal, unreviewed English translation draft of the German legal texts. It has not been legally reviewed or approved and is not yet in use.

Draft as of: November 7, 2026

1. Overview and scope

This privacy policy informs you about which personal data we process when you visit this website and when you contact us, for what purposes, on what legal basis and for how long. It also explains your rights.

"Personal data" means any information relating to an identified or identifiable person, for example a name, an email address or an IP address.

This privacy policy applies to the website close-crm-partner.com. It does not apply to websites of other providers that we link to.

In brief: This website does not use any analytics or tracking tools and no cookies. In your browser, we only store your choice in the "Privacy settings" banner (section 8). The website does not embed any third-party content and does not load any web fonts. There is no newsletter. Data is only transferred to third parties when you follow a link to another provider, for example to the booking calendar at Calendly.

2. Controller

The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is:

CRM Kraft LLC
Florida Limited Liability Company
7901 4th St. N, Ste. 300
St. Petersburg, FL 33702
USA

Registered with the Florida Department of State (Division of Corporations), Document Number L23000258039
Represented by: Justus Kraft (Authorized Member)
Phone: +49 174 5444423
Email: justus@crm-kraft.de

You can contact us at any time using these contact details with any questions about data protection and to exercise your rights.

3. Data protection officer

We have not appointed a data protection officer because, in our assessment, there is no legal obligation to do so. Please send your data protection inquiries directly to the contact details above.

4. Overview: purposes, legal bases and retention periods

In each case, our legitimate interest under Art. 6(1)(f) GDPR is to operate the website securely and reliably and to respond efficiently to inquiries from prospective and existing clients.

5. Hosting and server log files

This website is hosted by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. The servers are located in Germany. Hetzner processes the data on our behalf (data processing under Art. 28 GDPR).

Each time the website is accessed, the server automatically processes the following data in so-called server log files:

• IP address of the requesting device
• date and time of access
• page or file requested (URL)
• referrer (the previously visited page, if your browser transmits it)
• user agent (browser type and version, operating system)
• HTTP status code
• amount of data transferred

Purpose: delivering the website, ensuring security and stability, detecting and defending against attacks, and error analysis.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in the technically error-free and secure provision of the website.

Retention period: The log files are stored for 7 days with the full IP address and then deleted automatically. They are not combined with other data sources or evaluated for analytics or marketing purposes.

6. Domain name resolution (DNS)

So that your browser can find this website under its domain name, we use a DNS provider (depending on the domain, among others Cloudflare (DNS only, without delivering content), Namecheap, IONOS or Spaceship). In a DNS lookup, the DNS provider usually only receives the request from your DNS resolver (usually that of your internet service provider) for the IP address of the website, but no website content and no data that you enter on the website.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the availability of the website). Some of these providers are based in the USA (section 14).

7. SSL/TLS encryption

For security reasons, this website uses SSL/TLS encryption. You can recognize an encrypted connection by "https://" and the lock icon in your browser's address bar. This prevents third parties from reading data that you transmit to us.

8. Cookies and storage in the browser (Section 25 TDDDG, German Telecommunications Digital Services Data Protection Act)

We do not set any cookies. We store your choice in the "Privacy settings" banner in your browser's local storage (localStorage, key "ck_partner_en_consent_v1", with date and version) so that we do not have to ask you again. This information stays in your browser and is not transmitted to us or to third parties. It remains stored until you delete it in your browser. The legal basis is Section 25(2) no. 2 TDDDG. You can change your choice at any time via "Privacy settings" in the footer. The banner has only one optional category, "Optional services", and no such service is currently in use: regardless of your choice, no such service is loaded.

9. Fonts

This website does not load any web fonts; text is displayed using the fonts installed on your device (system fonts). Therefore, no connection to third-party font servers (for example Google Fonts) is established when you visit the website.

10. Contact by email, phone and WhatsApp; managing inquiries in Close CRM

If you contact us by email or phone, we process the data you provide (for example name, email address, phone number, company and the content of your inquiry) in order to answer your inquiry and to clarify any follow-up questions. There is no contact form on this website.

Legal basis: Art. 6(1)(b) GDPR if your inquiry relates to the performance of a contract or is necessary to take pre-contractual steps; otherwise Art. 6(1)(f) GDPR (legitimate interest in handling inquiries effectively).

Email service: For our email communication, we use Google Workspace provided by Google Ireland Limited (Ireland) or Google LLC (USA). Google processes the emails as a processor on our behalf. A transfer to the USA is possible (section 14).

WhatsApp: Our contact page links to WhatsApp (wa.me). The link is a plain external link; no data is transmitted to WhatsApp when you visit our pages. If you contact us via WhatsApp, WhatsApp provides the service to you under its own terms and privacy policy: WhatsApp Ireland Limited if you live in the European Region as defined by WhatsApp (including the EEA), otherwise WhatsApp LLC. We receive your messages in the WhatsApp Business app. We process the data you share with us there (for example your phone number and the content of your messages) to answer your inquiry, and we may transfer your contact details and your inquiry into our CRM system Close to manage it (see "Close CRM" below). The legal basis is the same as for contact by email (see above). A transfer to the USA is possible (section 14).

Close CRM: We record and handle the inquiries you send us in the CRM system Close, a service provided by Elastic Inc, USA. There, we store in particular your contact details, the history of our communication and notes on your inquiry. A transfer to the USA takes place (section 14).

Retention period: We delete your data as soon as your inquiry has been fully dealt with and no further communication is to be expected, unless statutory retention obligations prevent this or a contractual relationship is established.

11. Appointment booking with Calendly

For booking appointments online (for example a strategy call), we use the service Calendly provided by Calendly LLC, USA.

Only a link: The booking calendar is not embedded on this website. No data is transmitted to Calendly when you visit our pages. A connection to Calendly is only established when you follow the link and open calendly.com. In particular, your IP address, browser and device information and the page requested are then transmitted to Calendly, and Calendly may store cookies or similar technologies on your device (for example security cookies such as "__cf_bm" and "_cfuvid"). Calendly's privacy terms apply on calendly.com.

Services loaded by Calendly: On calendly.com, Calendly itself loads further services. In checks in November 2026, these were the payment service provider Stripe (js.stripe.com, m.stripe.com, m.stripe.network), Google (Google Analytics, Google Tag Manager, reCAPTCHA, Google Sign-In, Google Fonts), Meta (Meta Pixel, connect.facebook.net), Segment, Sprig, Survicate, Braze (appboycdn.com), Airbrake and Amazon CloudFront. In the process, technical data such as your IP address may be transmitted to these providers and cookies or similar technologies may be set. Your choice in the "Privacy settings" banner applies only to this website and does not control what is loaded on calendly.com. Calendly asks for your consent there via its own "Cookie settings"; in a check on November 5, 2026, Google Analytics, Google Tag Manager, Meta Pixel, Segment, Sprig, Survicate and Braze were only loaded there after consent was given. Calendly decides which services it uses; for details, please refer to Calendly's privacy policy.

Meta Pixel via Calendly: Through the conversion tracking integration of our Calendly account, Calendly may load the Meta Pixel on calendly.com. The provider is Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, D04 X2K5, Ireland. Data may also be transferred to Meta Platforms, Inc., USA; Meta Platforms, Inc. is certified under the EU-U.S. Data Privacy Framework (adequacy decision of the European Commission of July 10, 2023, Art. 45 GDPR). The pixel is used to measure whether an appointment is booked (conversion measurement), including for advertising on Meta; Meta may link the data to your Meta account. We and Meta Platforms Ireland Ltd. are joint controllers for the collection and transmission of the data via the pixel (Art. 26 GDPR); Meta's Controller Addendum applies (facebook.com/legal/controller_addendum (opens in a new tab)). Meta is solely responsible for any further processing (facebook.com/privacy/policy (opens in a new tab)). The legal basis is the consent you give on calendly.com (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). You can withdraw it at any time with effect for the future via the "Cookie settings" on calendly.com.

Legal bases: For services and cookies on calendly.com that require consent, the legal basis is the consent you give there (Art. 6(1)(a) GDPR and Section 25(1) TDDDG). You can withdraw it at any time with effect for the future via the "Cookie settings" on calendly.com and delete the cookies that have been set in your browser.

Booking an appointment: If you book an appointment, we process the data you provide (for example name, email address, phone number if applicable, company, the selected time slot, and your information about your request) in order to schedule and hold the appointment (Art. 6(1)(b) GDPR). Calendly processes this data as a processor on our behalf.

Third country: Calendly is based in the USA; a transfer to the USA takes place (section 14).

Retention period: We store booking data with Calendly for as long as necessary to hold and follow up on the appointment; it is then deleted unless statutory retention obligations prevent this. Information on the retention period of cookies set by Calendly and by the services loaded by Calendly is provided by the respective providers.

12. No analytics tools, no tracking, no newsletter

We do not use any analytics or audience measurement tools, tracking pixels or advertising tools on this website. We do not create user profiles. We do not offer a newsletter. For the services that Calendly loads on calendly.com, see section 11.

13. Recipients of personal data

We only pass on your data if this is necessary for the purposes stated, if there is a legal basis, or if you have given your consent. Recipients or categories of recipients are:

Beyond this, we only pass on data if we are legally obliged to do so (for example to authorities) or if this is necessary to establish, exercise or defend legal claims. We do not sell personal data.

14. Transfers to third countries and retention period

Some of the providers mentioned are based in the USA or may process data in the USA. CRM Kraft LLC itself is based in the USA; your data is therefore also processed by us in the USA.

For transfers to the USA, where the respective recipient is certified under the EU-U.S. Data Privacy Framework (DPF), we rely on the adequacy decision of the European Commission of July 10, 2023 (Art. 45 GDPR). Where there is no certification, we use the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR). You can request a copy of the safeguards using the contact details in section 2.

Where no specific retention period is stated in this privacy policy, we only store personal data for as long as is necessary for the respective purpose. We then delete it unless statutory retention obligations (for example under commercial or tax law) prevent this. In that case, we restrict the processing and delete the data once the period has expired.

15. Your rights

Under the GDPR, you have the following rights:

• Access (Art. 15 GDPR): You can request information on whether and which personal data we process about you, and receive a copy.
• Rectification (Art. 16 GDPR): You can request the rectification of inaccurate data and the completion of incomplete data.
• Erasure (Art. 17 GDPR): You can request the erasure of your data unless legal reasons prevent this.
• Restriction of processing (Art. 18 GDPR): Under certain conditions, you can request that we restrict the processing of your data.
• Data portability (Art. 20 GDPR): You can request that we provide data that you have given us and that we process automatically on the basis of your consent or a contract in a structured, commonly used and machine-readable format or, where technically feasible, transmit it to another controller.
• Objection (Art. 21 GDPR): see section 16.
• Withdrawal of consent (Art. 7(3) GDPR): You can withdraw any consent you have given at any time with effect for the future. This does not affect the lawfulness of processing carried out before the withdrawal.
• Complaint to a supervisory authority (Art. 77 GDPR): see section 17.

To exercise your rights, an informal message to justus@crm-kraft.de or to the address in section 2 is sufficient.

16. Right to object (Art. 21 GDPR)

Where we process your personal data on the basis of Art. 6(1)(f) GDPR (legitimate interests), you have the right to object to this processing at any time on grounds relating to your particular situation. We will then no longer process your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

If your data is processed for direct marketing purposes, you have the right to object to this processing at any time; your data will then no longer be processed for this purpose.

You can send your objection informally to justus@crm-kraft.de.

17. Right to lodge a complaint with a supervisory authority

If you believe that the processing of your personal data violates the GDPR, you have the right, without prejudice to any other remedy, to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). In particular, you can contact the supervisory authority in the member state of your habitual residence, your place of work or the place of the alleged infringement.

However, we would appreciate it if you contacted us directly first with any questions or complaints.

18. Obligation to provide data

You are not legally or contractually obliged to provide us with personal data. You can use the website without providing any personal information; however, the processing of server log files (section 5) is technically necessary for the website to be displayed.

If you would like to contact us or book an appointment, we need the information required for this (for example your name and an email address or phone number). Without this information, we cannot answer your inquiry or schedule an appointment with you.

19. No automated decision-making

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

20. Changes to this privacy policy

We will update this privacy policy if the website, our service providers or the legal situation change. The current version published on this page applies.