Privacy policy

1. Overview

This policy explains how Mikail Toprak, trading as Volition, processes personal data of visitors to topvolition.com. We are established in Germany, so the EU General Data Protection Regulation (GDPR) applies regardless of where you are located.

2. Controller

Mikail Toprak
Kirchgasse 3
71111 Waldenbuch
Germany
Email: mail@mikailtoprak.com

We have not appointed a data protection officer, as we are not required to.

3. Hosting and server logs

This website is hosted by Netlify, Inc., San Francisco, USA. When you open a page, Netlify processes technical data such as your IP address, browser and operating system, the page requested, the referring page and the time of the request. This is necessary to deliver the site and keep it secure. Legal basis: our legitimate interest in operating a secure website, Art. 6(1)(f) GDPR. Netlify processes this data on our behalf under a data processing agreement.

4. Your privacy choice

We store your choice from the privacy banner in your browser's local storage, together with the date you made it. It is not sent to us and does not identify you. After twelve months you are asked again. You can change your choice at any time with the "Cookie settings" link in the footer. Legal basis: § 25(2) no. 2 TDDDG and Art. 6(1)(c) GDPR, as we need to record your decision.

5. Google Analytics

If you accept, we use Google Analytics 4, a web analytics service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. It records which pages you visit, how you arrived, your approximate location, your device type and how you interact with the site. IP addresses are shortened. Google Analytics sets cookies (_ga and _ga_*, up to two years). Data may be transferred to Google LLC in the USA; Google is certified under the EU-US Data Privacy Framework, and standard contractual clauses apply as well.

If you do not accept, the Google tag is never loaded and none of this data is collected. Legal basis: your consent, § 25(1) TDDDG and Art. 6(1)(a) GDPR. You can withdraw consent at any time with effect for the future through "Cookie settings". Analytics data is deleted after 14 months at the latest.

6. Booking a call with Cal.com

To book a call we use Cal.com, Inc., USA. The booking calendar is embedded on our booking page only after you accept in the privacy banner; before that, no connection to Cal.com is made from our site. You can also open the calendar directly on cal.com through a link, in which case Cal.com's own privacy policy applies to that page.

When you book, Cal.com processes the details you enter, such as your name, email address, store URL, monthly revenue and any notes, and passes them to us so we can prepare and hold the call. Legal basis: steps taken at your request before entering into a contract, Art. 6(1)(b) GDPR, and your consent for loading the embed, § 25(1) TDDDG and Art. 6(1)(a) GDPR. Where data is transferred to the USA, standard contractual clauses under Art. 46(2)(c) GDPR apply.

7. Email and video

If you email us, we use your message and contact details to answer it, Art. 6(1)(b) or (f) GDPR. Before a booked call we may send you a short screen recording about your store, hosted on Loom (Loom, Inc., USA). Opening it is your choice, and Loom's own privacy policy applies to that page.

8. How long we keep data

Booking and email data is kept for as long as we are in contact about your enquiry, and afterwards only as long as statutory retention periods require. Server logs are deleted by our host on a short rolling basis.

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) and objection (Art. 21). Where processing is based on consent, you may withdraw it at any time with effect for the future (Art. 7(3)). To exercise these rights, email mail@mikailtoprak.com.

You also have the right to lodge a complaint with a supervisory authority. The authority responsible for us is the Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg.

10. Changes

We update this policy whenever the website changes the way it handles data.