1) Information on the Collection of Personal Data and the Controller’s Contact Details
1.1 Below, we provide information about how we handle your personal data. Personal data means any data by which you can be personally identified.
Please carefully consider which personal data you share with us via WhatsApp. As long as you are logged into your WhatsApp account and interact with our WhatsApp profile, WhatsApp can track this. We expressly point out that WhatsApp stores the data of its users (e.g. personal information, IP address, communications data), may also use this data for business purposes and shares it with affiliated companies of the Meta group. Further information on WhatsApp’s processing of data can be found in WhatsApp’s Privacy Policy: https://www.whatsapp.com/legal/privacy-policy-eea
We have no influence over the collection and further processing of data by WhatsApp. Furthermore, we are unable to determine the extent to which, the location at which or the duration for which personal data is stored by WhatsApp, the extent to which WhatsApp complies with existing deletion obligations, what analyses and links WhatsApp makes using the data, or to whom WhatsApp discloses the data. If you wish to prevent WhatsApp from processing personal data that you transmit to us, please contact us by another means. Our full contact details can be found in the legal notice within our WhatsApp profile.
1.2 The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) is Vexara Teknoloji Ltd., Cevizli Mah. Zühal Cad. , Ritim Istanbul AVM, A Ticari Blok Apt. No:46/50, 34846 Maltepe, Türkiye, Tel.: +90 507 451 38 32, Email: privacy@vexara.ltd.
The controller responsible for the processing of personal data is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data.
Insofar as the data that you transmit to us via WhatsApp is also or exclusively processed by WhatsApp (WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland), WhatsApp considers itself to act as a processor pursuant to Art. 28 GDPR in this context.
The data processing terms can be viewed in WhatsApp’s Data Processing Agreement for WhatsApp Business: https://www.whatsapp.com/legal/business-data-processing-terms?lang=de
As part of what WhatsApp describes as processing on behalf of a controller, personal data may also be transferred to WhatsApp LLC, 1 Meta Way, Menlo Park, California 94025, USA, and to other affiliated companies of the Meta group in the USA.
For data transfers to the USA, WhatsApp LLC and all other US companies of the Meta group have joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

2) Data Protection Officer
You can contact the Data Protection Officer of WhatsApp Ireland Ltd., as the operator of WhatsApp, using the online contact form provided at https://www.whatsapp.com/contact/forms/4363383090404717/

3) Data Processing When You Contact Us
3.1 Calendly
We use the services of the following provider to offer an online appointment-booking function: Calendly, LLC, BB&T Tower, 271 17th St NW, Atlanta, GA 30363, USA
For the purpose of arranging appointments, first and last name and email address (and, where applicable, the telephone number if a telephone appointment is requested) are collected pursuant to Art. 6(1)(b) GDPR and transmitted to the provider pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in effective customer management and efficient appointment administration, and are stored there for the purpose of organising the appointment.
After the appointment has taken place or the agreed appointment period has expired, your data will be deleted by the provider.
We have concluded a Data Processing Agreement with the provider that ensures the protection of the data of visitors to our pages and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
3.2 Google Calendar
We use the services of the following provider to offer an online appointment-booking function: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Data may also be transferred to: Google LLC, USA
For the purpose of arranging appointments, first and last name and email address (and, where applicable, the telephone number if a telephone appointment is requested) are collected pursuant to Art. 6(1)(b) GDPR and transmitted to the provider pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in effective customer management and efficient appointment administration, and are stored there for the purpose of organising the appointment.
After the appointment has taken place or the agreed appointment period has expired, your data will be deleted by the provider.
We have concluded a Data Processing Agreement with the provider that ensures the protection of the data of visitors to our pages and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
3.3 If you contact us via WhatsApp in connection with a specific transaction (for example, an order you have placed), we store and use the mobile phone number you use on WhatsApp and—if provided—your first and last name pursuant to Art. 6(1)(b) GDPR in order to process and respond to your enquiry. On the basis of the same legal basis, we may ask you via WhatsApp to provide further data (order number, customer number, address or email address) so that we can assign your enquiry to a specific transaction.
If you use our WhatsApp contact for general enquiries (for example, about our range of services, availability or our website), we store and use the mobile phone number you use on WhatsApp and—if provided—your first and last name pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in providing the requested information efficiently and promptly.
Your data will always be used solely to respond to your enquiry via WhatsApp. It will not be disclosed to third parties.
Please note that WhatsApp Business gains access to the address book of the mobile device that we use for this purpose and automatically transfers telephone numbers stored in the address book to a server of its parent company, WhatsApp LLC, in the USA and may also make them available to other affiliated companies of the Meta group.
To operate our WhatsApp Business account, we use a mobile device whose address book contains only the WhatsApp contact details of users who have also contacted us via WhatsApp.
This ensures that every person whose WhatsApp contact details are stored in our address book has already consented, upon first using the app on their device and accepting the WhatsApp Terms of Service, to the transmission of their WhatsApp telephone number from the address books of their chat contacts pursuant to Art. 6(1)(a) GDPR. The transmission of data relating to users who do not use WhatsApp and/or have not contacted us via WhatsApp is therefore excluded.

4) Data Processing for Contract Performance
If your contact via WhatsApp serves as the basis for a contract with us for the delivery of goods and/or the provision of services, we will additionally process the data that you transmit to us in this context as follows if a contract is concluded:
4.1 We transmit your payment data to the commissioned financial institution as part of payment processing, insofar as this is necessary for processing the payment. The legal basis for the disclosure of data in this case is Art. 6(1)(b) GDPR.
4.2 In the case of contracts for the delivery of goods, we disclose the personal data that we collect to the transport company commissioned with delivery as part of contract performance, insofar as this is necessary to deliver the goods.
If, on the basis of a corresponding contract, we owe you updates for goods with digital elements or for digital products, we process the contact details that you provided when placing the order (name, address, email address) in order to inform you personally of forthcoming updates within the period prescribed by law, using an appropriate means of communication (such as by post or email), as part of our statutory information obligations pursuant to Art. 6(1)(c) GDPR. Your contact details will be used strictly for the purpose of notifying you about updates that we are obliged to provide and will be processed by us for this purpose only to the extent necessary for the respective information.

5) Tools and Other Matters
Google Forms
We use the services of the following provider to conduct surveys or provide online forms: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland
In addition to data being transmitted to the aforementioned provider location, data may also be transmitted to: Google LLC, USA
The provider enables us to design and analyse surveys and online forms. In addition to the personal data that you enter in the forms, information about your operating system, browser, the date and time of your visit, the referrer URL and your IP address is also collected, transmitted to the provider and stored on the provider’s servers.
The information that you enter in the forms is stored under password protection to ensure that access by third parties is excluded and that only we can analyse the data for the respective purpose specified in the form.
Where personal data is processed as necessary for the performance of a contract with you (this also applies to processing operations necessary in order to take steps prior to entering into a contract), Art. 6(1)(b) GDPR serves as the legal basis. If you have given us consent to process your data, the processing is carried out on the basis of Art. 6(1)(a) GDPR. Consent that has been given may be withdrawn at any time with effect for the future.
We have concluded a Data Processing Agreement with the provider that ensures the protection of the data of visitors to our pages and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
Further information on Google’s data protection provisions can be found here: https://business.safety.google/intl/de/privacy/

6) Rights of the Data Subject
6.1 RIGHT TO OBJECT
IF, AS PART OF A BALANCING OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, FURTHER PROCESSING REMAINS RESERVED IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FUNDAMENTAL FREEDOMS, OR IF THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING. YOU MAY EXERCISE YOUR OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.
6.2 Applicable data protection law grants you comprehensive data subject rights (rights of access and intervention) vis-à-vis the controller with regard to the processing of your personal data, about which we inform you below:
- Right of access pursuant to Art. 15 GDPR;
- Right to rectification pursuant to Art. 16 GDPR;
- Right to erasure pursuant to Art. 17 GDPR;
- Right to restriction of processing pursuant to Art. 18 GDPR;
- Right to notification pursuant to Art. 19 GDPR;
- Right to data portability pursuant to Art. 20 GDPR;
- Right to withdraw consent previously given pursuant to Art. 7(3) GDPR;
- Right to lodge a complaint pursuant to Art. 77 GDPR.

7) Duration of Personal Data Storage
The duration for which personal data is stored is determined by the respective legal basis, the purpose of processing and—where applicable—additionally by the respective statutory retention period (e.g. retention periods under commercial and tax law).
Where personal data is processed on the basis of express consent pursuant to Art. 6(1)(a) GDPR, the data concerned will be stored until you withdraw your consent.
If statutory retention periods apply to data processed in connection with legal or similar obligations on the basis of Art. 6(1)(b) GDPR, this data will be routinely deleted after the retention periods expire, provided that it is no longer required for the performance or initiation of a contract and/or we no longer have a legitimate interest in continuing to store it.
Where personal data is processed on the basis of Art. 6(1)(f) GDPR, this data will be stored until you exercise your right to object pursuant to Art. 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.
Where personal data is processed for direct marketing purposes on the basis of Art. 6(1)(f) GDPR, this data will be stored until you exercise your right to object pursuant to Art. 21(2) GDPR.
Unless otherwise indicated by the other information in this statement concerning specific processing situations, stored personal data will otherwise be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.

Copyright notice: This Privacy Policy was prepared by the specialist lawyers of IT-Recht Kanzlei and is protected by copyright (https://www.it-recht-kanzlei.de)

Last updated: 17 August 2026, 10:49:32