Privacy Policy

GDPR · EU 2016/679 · Datenschutzerklärung

This policy explains what personal data we collect when you use thecircleexclusive.com, why we collect it, how long we keep it, and the rights you have under the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

1. Controller

The controller responsible for processing personal data on this website is:

Kevin Bützow
The Circle
Neuer Wall 18
20354 Hamburg
Deutschland
E-Mail: info@thecircleexclusive.com

For any privacy-related request you may contact us at any time using the email address above.

2. Scope

This policy applies to the website thecircleexclusive.com and its subpages. It does not apply to third-party websites linked from our pages.

3. Data We Process

3.1 Server log data

When you access the site, our hosting provider automatically records technical data in server log files for the purpose of delivering the site and protecting it against abuse. This includes:

• IP address (typically shortened / anonymised within a short retention period)
• Date and time of the request
• URL requested, HTTP status code, and amount of data transferred
• Referring URL, browser type and version, operating system

Legal basis: Art. 6 (1) (f) GDPR: legitimate interest in operating and securing the website.

3.2 Application form (/apply)

If you submit an application, we process the following data:

• Name and age
• Email address and phone number
• City and Instagram handle
• Your current situation and the message you submit
• Consent confirmation

Purpose: reviewing your application and contacting you with a decision.
Legal basis: Art. 6 (1) (b) GDPR (pre-contractual measures at your request) and Art. 6 (1) (a) GDPR (your consent given via the privacy checkbox).
Retention: up to 12 months after submission, unless an ongoing relationship is established or legal retention obligations require longer storage.

3.3 Contact form (/contact)

If you submit the contact form, we process the following data:

• Name and email address
• City and phone number, if provided
• The message you submit
• Consent confirmation

Purpose: responding to your enquiry.
Legal basis: Art. 6 (1) (b) or (f) GDPR and Art. 6 (1) (a) GDPR (consent).
Retention: until the matter is resolved, and thereafter within applicable legal retention periods.

3.4 Email contact

If you contact us by email (info@thecircleexclusive.com), we process the information you voluntarily provide in order to respond.
Legal basis: Art. 6 (1) (b) or (f) GDPR.

4. Cookies & Tracking

This website does not use advertising, profiling, or analytics cookies. No tracking scripts (Google Analytics, Meta Pixel, TikTok Pixel, etc.) are loaded.

5. Processors & Third Parties

5.1 Hosting: Cloudflare

This website is hosted by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. When you access the site, Cloudflare processes technical data (IP address, request metadata) to deliver and secure the site. A data-processing agreement (Art. 28 GDPR) is in place. Transfers to the USA are safeguarded by the EU–US Data Privacy Framework and EU Standard Contractual Clauses. Cloudflare privacy policy: cloudflare.com/privacypolicy.

5.2 Form handling: Formspree

Our forms are processed by Formspree, Inc., 2261 Market Street #4151, San Francisco, CA 94114, USA. When you submit a form, Formspree processes your submitted data and forwards it to us by email. Transfers to the USA are safeguarded by EU Standard Contractual Clauses. Formspree privacy policy: formspree.io/legal/privacy-policy.

5.3 Email routing: Cloudflare

Email sent to our domain is routed via Cloudflare Email Routing and forwarded to our mailbox. The same safeguards as in section 5.1 apply.

5.4 Fonts

This site uses the typefaces Cormorant Garamond, Bebas Neue and Jost. These fonts are hosted directly on our own servers and are not loaded from Google or any other third party. No connection to external font servers is established, and no font-related data is transmitted to third parties when you load a page.

5.5 Social media links

Our footer links to profiles on Instagram and TikTok. These are plain text links; no social plug-ins or pixels are loaded. A connection to Meta Platforms or ByteDance is only established if you click the link.

6. International Transfers

Some processors (see section 5) are located outside the EU/EEA, including in the United States. Such transfers take place on the basis of the EU–US Data Privacy Framework (Art. 45 GDPR) and, additionally, Standard Contractual Clauses (Art. 46 GDPR).

7. Your Rights

Under the GDPR you have the following rights regarding your personal data:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure: the “right to be forgotten” (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to withdraw consent at any time (Art. 7 (3) GDPR)

To exercise these rights, contact us at info@thecircleexclusive.com.

8. Right to Lodge a Complaint

You have the right to lodge a complaint with a data-protection supervisory authority (Art. 77 GDPR). The competent authority for Hamburg is:

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
Ludwig-Erhard-Straße 22, 20459 Hamburg
datenschutz-hamburg.de

9. Security

The website is served over HTTPS using TLS encryption. Form submissions are transmitted over an encrypted connection.

10. Changes to this Policy

We may update this policy from time to time. The current version can always be found at thecircleexclusive.com/privacy.

Last updated: May 2026