Privacy Policy

Who We Are

We are Phiture GmbH (hereinafter: “Phiture”), a leading mobile growth consultancy. Our registered office is located at:

Managing Director: Moritz Daan
Company Registration: HRB 165786 B, Amtsgericht Charlottenburg (Berlin)

Data Protection Officer

We have appointed DataGuard as our external data protection officer. You can contact them at:

General Information on Data Processing

Scope of processing of personal data

In principle, we process our users' personal data only to the extent necessary to provide a functioning website and our content and services. The processing of personal data of our users is only carried out with the consent of the user. An exception applies in those cases where prior consent cannot be obtained for real reasons and the processing of the data is permitted by law.

Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing operations of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis.

In the processing of personal data required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

Insofar as processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.

Data erasure and storage time

The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage ceases to apply. In addition, data may be stored if provided for by the European or national legislator in Union regulations, laws or other provisions to which the data controller is subject. The data will also be blocked or deleted when a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

Provision of the website and creation of log files

Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.

The following data is collected here:

• Information about the browser type and version used
• The user's operating system
• The Internet service provider of the user
• The IP address of the user
• Date and time of access
• Websites from which the user's system accesses our website
• Websites that are accessed by the user's system via our website

The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

Legal basis for data processing

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.

Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the delivery of the website to the user's computer. For this purpose, the user's IP address must be stored for the duration of the session.

The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR.

Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the users' IP addresses are deleted or alienated so that an assignment of the calling client is no longer possible.

Possibility of objection and removal

The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for the user to object.

Use of cookies

Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user visits a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables a unique identification of the browser when the website is called up again.

Legal basis for data processing

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.

Purpose of data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.

The user data collected through technically necessary cookies is not used to create user profiles.

These purposes also constitute our legitimate interest in the processing of personal data pursuant to Art. 6 para. 1 lit. f GDPR.

Duration of storage, possibility of objection and removal

Cookies are stored on the user's computer and transmitted by the user to our site. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website in full.

Contact form and e-mail contact

Description and scope of data processing

A contact form is available on our website which can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask will be transmitted to us and stored. This data is:

• Name
• Email address
• Phone number (optional)
• Company name
• Message

At the time the message is sent, the following data is also stored:

• The IP address of the user
• Date and time of registration

Your consent is obtained for the processing of the data during the sending process and reference is made to this privacy policy.

Alternatively, contact via the e-mail address provided is possible. In this case, the user's personal data transmitted by e-mail will be stored.

The data is not passed on to third parties in this context. The data is used exclusively for processing the conversation.

Legal basis for data processing

The legal basis for the processing of data is Art. 6 para. 1 lit. a GDPR if the user has given his consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact aims at the conclusion of a contract, then the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

Purpose of data processing

The processing of personal data from the input mask serves us solely to process the establishment of contact. In the case of contact by e-mail, this also includes the necessary legitimate interest in processing the data.

The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the relevant facts have been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

Possibility of objection and removal

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.

All personal data stored in the course of making contact will be deleted in this case.

Rights of the data subject

If personal data is processed by you, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

Right to information

You may request confirmation from the controller as to whether personal data concerning you is being processed by us.

Right to rectification

You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you is incorrect or incomplete. The controller must make the correction immediately.

Right to restriction of processing

You may request the restriction of the processing of personal data concerning you under certain conditions.

Right to erasure

You may demand that the controller delete the personal data concerning you without delay, and the controller is obliged to delete this data without delay if certain legal grounds apply.

Right to data portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format.

Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions.

Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.