Privacy Policy
1. Controller
Jaro Kaulmann
Karl-Korn-Straße 2
50678 Cologne, Germany
Email: [email protected]
Phone: +49 221 29249508
2. General Information
Your privacy matters to me. I process personal data strictly in accordance with the General Data Protection Regulation (GDPR) and applicable German data protection laws.
3. Collection and Processing of Personal Data
Website (jaro.digital):
When visiting my website, technical data automatically collected by your browser includes:
- IP address
- Browser type and version
- Operating system
- Date and time of access
- Referrer URL
This data is used solely to ensure technical functionality and for statistical purposes. It is not combined with other data sources.
Customer Portal (my.jaro.digital):
The customer portal uses login via Collection Accounts (accounts.clsw.app/privacy). Within the portal, personal data is collected and processed to handle contracts and manage invoices. This includes:
- Name
- Address
- Contact details (e.g. email address, phone number)
- Invoice and payment information
- Login credentials (username, password, if applicable)
This data is only stored as long as necessary for contract fulfillment, accounting, or legal retention obligations.
4. Legal Basis for Processing
Data processing is based on:
- Article 6(1)(b) GDPR (contract performance)
- Article 6(1)(c) GDPR (legal obligation)
- Article 6(1)(f) GDPR (legitimate interests, e.g. IT security)
5. Data Disclosure
Personal data is only shared with third parties when required for contract performance or by law (e.g. accountant, payment processor, hosting provider). All external processors are bound by data processing agreements under Article 28 GDPR.
6. Data Security
I apply appropriate technical and organizational measures to protect your data against loss, misuse, or unauthorized access, including:
- Encrypted data transmission (HTTPS)
- Secure passwords
- Regular security updates
7. Liability in Case of Data Breach
No IT system can be completely secure. I am not liable for damages resulting from unavoidable data loss, unauthorized access, or external attacks (e.g. hacking or third-party vulnerabilities), unless caused by proven intent or gross negligence on my part. In case of a verified data breach, affected individuals and authorities will be notified in accordance with Articles 33 and 34 GDPR.
8. Your Rights
You have the right to:
- Access your stored data (Art. 15 GDPR)
- Rectify inaccurate data (Art. 16 GDPR)
- Request deletion of your data (Art. 17 GDPR)
- Restrict processing (Art. 18 GDPR)
- Object to processing (Art. 21 GDPR)
- Request data portability (Art. 20 GDPR)
To exercise these rights, please contact [email protected].
9. Hosting
The website and customer portal are hosted on servers located within the European Union. Data processing
fully complies with the GDPR.
All hosting services are provided by my partner ProHosting24:
ph24
Hanauer Landstraße 328-330
60314 Frankfurt am Main
https://www.ph24.de/datenschutz/
10. Changes to This Privacy Policy
This policy may be updated from time to time to reflect legal or technical changes.
Last updated: October 2025