Privacy policy
In brief
- This website sets no cookies and uses no third-party analytics or advertising services. That is why there is no cookie banner.
- Fonts are hosted on our own server. Visiting the site makes no connection to Google Fonts or similar services.
- We only process personal data when you write to us, call us, fill in the form for a free sample, or open your personal project page as a client.
1. Controller
Lunatha Studio GmbH, represented by its managing director Jonathan Heß
Tal 44, 80331 Munich, Germany
Email: admin@lunatha.studio · Phone: +49 89 74865866
We have not appointed a data protection officer, because the legal requirements for one are not met (§ 38 BDSG).
2. Hosting and delivery of the website (Cloudflare)
The website is delivered through Cloudflare (Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA). This covers hosting (Cloudflare Pages), the content delivery network and DNS.
With every visit, Cloudflare processes technically necessary data:
- IP address
- time and requested address
- browser and device information
- referrer
This data is needed to deliver the site, protect it against attacks and find errors.
- Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is a secure and fast website.
- Transfers outside the EU: Cloudflare is certified under the EU-U.S. Data Privacy Framework (adequacy decision of the European Commission). The EU standard contractual clauses in our data processing agreement with Cloudflare apply in addition.
- Retention: Cloudflare keeps this data only as long as these purposes require and deletes it afterwards. We store no access logs ourselves.
3. "Free sample" form (Tally)
The form runs on Tally (Tally BV, Sint-Pietersnieuwstraat 11, 9000 Ghent, Belgium). According to Tally, the data is stored on servers in the EU.
Data processed:
- company, name, business email address, phone number
- ASIN and/or product link
- catalogue size and marketplaces
- your consent
- technical: the page you came from
Purposes and legal bases:
- Creating and sending your sample: Art. 6(1)(b) GDPR (pre-contractual steps at your request).
- Contact by email and phone about your sample and about our services for Amazon listings: Art. 6(1)(a) GDPR (your consent). You can withdraw your consent at any time with effect for the future; a short email is enough.
Your details are transferred from Tally to our CRM (section 4).
4. Customer management (Attio)
We manage enquiries, client and project data in the CRM Attio (Attio Ltd., United Kingdom). Attio runs on Google Cloud Platform, with Google Cloud EMEA Limited (Ireland) as hosting provider.
- Data processed: contact details, company details, communication history, call notes, status of offers and projects.
- Legal bases:
- Art. 6(1)(b) GDPR (preparing and carrying out orders)
- Art. 6(1)(f) GDPR (interest in organised client management)
- for contact about our services: Art. 6(1)(a) (consent)
- Transfers outside the EU: an adequacy decision of the European Commission exists for the United Kingdom. Any further transfers are covered by the EU standard contractual clauses in our data processing agreement with Attio.
5. Email and phone
When you email us, we process your message and contact details to answer your enquiry.
- Mailbox: Google Workspace (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). Emails with you may be visible in Attio through its Gmail connection (section 4).
- Calls are not recorded. We only note the key points.
- Legal basis: Art. 6(1)(b) or (f) GDPR.
6. Personal project pages for clients
We create personal project pages for clients and prospects. They show the listings we created and offer them for download. These pages are not indexed by search engines.
Product images: the images are stored at Hetzner (Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany). Loading them necessarily transmits your IP address to Hetzner.
Usage statistics: we record whether and when a project page was opened and which file was downloaded. This happens on the server, without cookies, without storing anything on your device and without storing your IP address. The information is noted with the project in our CRM.
- Purpose: to know whether the delivered content arrived, so we follow up at the right time.
- Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is looking after an ongoing business contact. You can object at any time (section 9).
7. Recipients and processors
We have data processing agreements under Art. 28 GDPR with all providers named here:
- Cloudflare
- Tally
- Attio
- Hetzner
Beyond that, we only pass on data where the law requires it (for example invoice data to our tax advisers or the tax authorities).
8. Retention
- Enquiries and sample requests without an order: deleted at the latest 24 months after the last contact, or earlier if you ask.
- Client and order data: kept for the duration of the business relationship, then as long as statutory retention duties apply (commercial and tax law: 6 years for business letters, 8 years for accounting vouchers, 10 years for books, inventories and annual accounts).
- After you withdraw your consent, we no longer use your contact details for offers.
9. Your rights
You have the right to:
- access (Art. 15 GDPR)
- rectification (Art. 16)
- erasure (Art. 17)
- restriction of processing (Art. 18)
- data portability (Art. 20)
- withdraw any consent with effect for the future (Art. 7(3))
Right to object (Art. 21 GDPR): where we process data on the basis of legitimate interests, you can object at any time on grounds relating to your particular situation. You can object to processing for direct marketing at any time without giving reasons.
An email to admin@lunatha.studio is enough.
Right to lodge a complaint: you can complain to a data protection supervisory authority. The authority responsible for us is the Bavarian Data Protection Authority (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA), Promenade 18, 91522 Ansbach, Germany.
10. Status
October 2026. We update this policy when our website or our service providers change.
Language
This is a translation for convenience. The German version (lunatha.studio/gdpr) is authoritative.