Legal

Privacy Policy

Last updated: November 2026

This privacy policy explains how I process personal data when you visit this website, when you contact me, and when I contact businesses by email. It applies under the EU General Data Protection Regulation (GDPR) and, for recipients in the United Kingdom, the UK GDPR.

1. Controller

Alexander Klaczynski
Germany
Email: info@alexanderklaczynski.com

I have not appointed a data protection officer, as I am not legally required to do so. For any privacy question, please contact me at the email address above.

2. Hosting of this website

This website is hosted by [Hosting provider — name and address, please verify]. When you visit the website, the hosting provider automatically processes technical data that your browser transmits: IP address, date and time of access, the page requested, browser type and version, operating system and the referring website.

Purpose and legal basis: delivering the website and ensuring its security and stability. The legal basis is my legitimate interest in a secure and functioning website (Art. 6(1)(f) GDPR).

I have concluded a data processing agreement with the hosting provider (Art. 28 GDPR). Data may be processed in the USA. Transfers are safeguarded by [the EU-US Data Privacy Framework / Standard Contractual Clauses of the European Commission — please verify which applies].

Log data is stored only for as long as necessary for the purposes stated above and is then deleted by the hosting provider.

3. Cookies and tracking

This website does not use analytics, advertising or tracking tools, and no data is shared with advertising networks. Only cookies that are technically necessary to deliver the website may be set. These do not require consent (Section 25(2) of the German Telecommunications Digital Services Data Protection Act, TDDDG).

4. Contacting me by email

If you email me, I process your email address, your name and the content of your message to answer your enquiry. The legal basis is Art. 6(1)(b) GDPR where your enquiry relates to a potential business relationship, and otherwise my legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR).

My emails are handled through Google Workspace, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. I have concluded a data processing agreement with Google. Data may also be processed by Google LLC in the USA; Google LLC is certified under the EU-US Data Privacy Framework, and transfers are additionally covered by Standard Contractual Clauses.

I delete correspondence once it is no longer needed, unless statutory retention obligations apply (for example, under German tax and commercial law, business correspondence may have to be kept for six to ten years).

5. Business outreach by email

If you received an email from me, this section explains how I obtained your details and how I use them.

What data I process

Your name, job title, business email address, company name, company website, industry, company size and country, as well as any correspondence with you. I do not process special categories of personal data.

Where the data comes from

From Apollo.io, a commercial database of business contact information operated from the USA, and from publicly available sources such as company websites and public company registers.

Why I process it

To contact businesses with a short series of no more than three emails about the possibility of licensing their operational data through a data partnership programme, to answer replies, and, if you ask me to, to send you information and a registration link for the programme.

Legal basis

My legitimate interest in contacting businesses about an offer that relates to their professional activity (Art. 6(1)(f) GDPR and UK GDPR). In weighing this interest against yours, I have taken into account that I only contact people in their professional role at companies, that I process only business contact details, that the number of emails is limited, and that you can object at any time with a one-word reply. I comply with the applicable rules on electronic marketing in the recipient's country, such as the UK Privacy and Electronic Communications Regulations, the Irish ePrivacy Regulations and the US CAN-SPAM Act.

Recipients

Your data is stored and emails are sent using Google Workspace (see section 4). I do not sell your data and I do not pass it on to the data partnership programme or any other third party. If your company decides to apply, it registers directly with the programme, which then processes your data under its own privacy policy.

Transfers outside the EU and UK

Google may process data in the USA (see section 4). Apollo.io is based in the USA; data received from Apollo.io was transferred to me in accordance with its own privacy terms.

No tracking

My emails do not contain tracking pixels or tracked links. I do not record whether or when you open an email.

How long I keep the data

If you do not reply, I delete your details no later than six months after my last email. If you reply, I keep the correspondence for as long as needed to deal with your enquiry, and beyond that only where statutory retention obligations apply. If you object, I keep only your email address on a suppression list so that you are never contacted again (Art. 6(1)(f) GDPR).

Your right to object

You can object at any time, without giving reasons, to the use of your data for this kind of business outreach (Art. 21(2) and (3) GDPR). Simply reply "no" to any of my emails or write to info@alexanderklaczynski.com. You will not receive any further emails from me.

6. Your rights

You have the right to:

access the personal data I hold about you (Art. 15 GDPR),
have inaccurate data corrected (Art. 16 GDPR),
have your data erased (Art. 17 GDPR),
restrict processing (Art. 18 GDPR),
receive your data in a portable format (Art. 20 GDPR),
object to processing based on legitimate interests (Art. 21 GDPR).

To exercise any of these rights, email info@alexanderklaczynski.com.

7. Right to lodge a complaint

You can lodge a complaint with a data protection supervisory authority. The authority responsible for me is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestraße 2–4, 40213 Düsseldorf, Germany.

You can also contact the authority in your country, for example the Information Commissioner's Office (ICO) in the United Kingdom or the Data Protection Commission in Ireland.

8. Automated decision-making

I do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.

9. Security

This website is delivered over an encrypted connection (TLS). Emails are sent through Google's infrastructure with standard transport encryption.

10. Changes to this policy

I may update this policy if my processing changes or the law requires it. The current version is always available on this page.