Privacy Policy / Datenschutzerklärung

1. Controller

​

The controller responsible for the processing of personal data through this website is:

 

Aurelis Clavis
Sole proprietor: Adwoa Theresa Adu-Sanyah
c/o Postflex #7630
Emsdettener Str. 10
48268 Greven
Germany

​

Email: info@aurelisclavis.com

​

2. Scope of this Privacy Policy

​

This Privacy Policy explains how Aurelis Clavis collects, uses, stores and protects personal data when you:

​

• visit this website;

• use the Request Consideration form;

• upload documents or other materials;

• communicate with Aurelis Clavis by email;

• or enter into pre-contractual or contractual communications with Aurelis Clavis.

 

Personal data means any information relating to an identified or identifiable natural person.

 

This website is directed primarily towards established businesses and their authorised representatives. It is not intended for private consumer enquiries or for use by children.

 

3. General Principles of Data Processing

​

Personal data is processed only where a lawful basis exists and only to the extent reasonably necessary for the relevant purpose.

​

Depending on the circumstances, processing is based on:

​

• Article 6(1)(a) GDPR where consent has been given;

• Article 6(1)(b) GDPR where processing is necessary for pre-contractual steps or the performance of a contract;

• Article 6(1)(c) GDPR where processing is necessary to comply with a legal obligation;

• Article 6(1)(f) GDPR where processing is necessary for a legitimate interest and that interest is not overridden by the rights and freedoms of the person concerned.

 

Legitimate interests may include:

​

• operating and securing the website;

• preventing misuse and fraudulent or automated submissions;

• reviewing genuine business enquiries;

• communicating with prospective and existing clients;

• documenting business communications;

• protecting legal rights;

• and maintaining the technical stability of the website.

 

The information required by Article 13 GDPR includes the identity of the controller, processing purposes, legal bases, recipients, retention criteria, data-subject rights and information concerning international transfers. (EUR-Lex)

 

4. Website Hosting and Wix

​

This website is created and hosted using services provided by Wix.com Ltd. and its affiliated companies.

​

When you visit the website, Wix processes technical information required to deliver, operate, protect and maintain the website. This may include:

​

• IP address;

• date and time of access;

• requested page or file;

• referring website;

• browser type and version;

• operating system;

• device type;

• language and regional settings;

• screen resolution;

• session and security identifiers;

• technical error information;

• and information relating to website stability and performance.

 

To the extent Wix processes personal data of website visitors on behalf of Aurelis Clavis, Aurelis Clavis acts as controller and Wix acts as processor. Wix processes such data under its Data Processing Addendum and may engage contractually bound subprocessors where required to provide its services. (Wix Help Center) (wix.com)

​

The processing is necessary for the secure and reliable provision of the website and is based on Article 6(1)(f) GDPR.

 

Further information about Wix’s processing activities is available in the Wix Privacy Policy.

 

5. Server Log Data

​

Technical server and access data may be recorded automatically whenever the website is accessed.

​

This information is processed for the following purposes:

​

• delivery of website content;

• establishment and maintenance of secure connections;

• detection of technical errors;

• defence against attacks, spam and misuse;

• maintenance of website stability;

• and investigation of security incidents.

 

Server log data is not combined with application information for the purpose of creating personal profiles.

​

The legal basis is Article 6(1)(f) GDPR. The legitimate interest lies in the secure, stable and technically functional operation of the website.

​

Log data is retained only for as long as necessary for technical operation, security monitoring, error analysis or the investigation of suspected misuse.

Longer retention may occur where required to establish, exercise or defend legal claims or to comply with legal obligations.

 

6. Cookies and Similar Technologies

 

This website uses cookies and comparable technologies.

​

Cookies are small data files stored on or accessed through a visitor’s device. They may be necessary for website security and operation or may support optional functions such as audience measurement.

​

Essential Technologies

 

Essential cookies and technologies may be used without separate consent where they are strictly necessary to:

​

• deliver the website;

• maintain secure sessions;

• protect forms and interfaces;

• prevent attacks or fraudulent use;

• remember privacy choices;

• render website content correctly;

• and maintain technical stability.

 

The legal basis for access to or storage of information on a visitor’s device is Section 25(2) TDDDG where the technology is strictly necessary to provide a service expressly requested by the visitor.

​

Any subsequent processing of personal data is based on Article 6(1)(f) GDPR.

Wix identifies essential cookies used for purposes including security, fraud detection, rendering, API protection, system resilience and core website operation. (Wix Help Center)

 

Non-Essential Technologies

​

Non-essential cookies and comparable technologies are used only after consent has been given through the website’s cookie settings.

​

These may include technologies used for:

​

• analytics;

• traffic measurement;

• assessment of website use;

• or other optional functions.

 

The legal basis for storing or accessing information on a visitor’s device is Section 25(1) TDDDG. The legal basis for the subsequent processing of personal data is Article 6(1)(a) GDPR.

​

Consent is voluntary and may be withdrawn at any time through the cookie settings available on the website. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

​

Under Section 25 TDDDG, consent is generally required before non-essential information is stored on or accessed from a user’s device. Strictly necessary technologies are exempt from that requirement. (Gesetze im Internet)

 

7. Cookie Consent Management

 

The website provides a cookie consent interface through which visitors can:

​

• accept or reject non-essential technologies;

• select individual categories;

• review available information about cookies and providers;

• and change or withdraw previous choices.

 

The consent selection and related technical information may be stored in order to:

​

• apply the visitor’s preferences;

• prevent the consent request from appearing unnecessarily on every page;

• and document whether legally required consent was obtained.

 

The legal basis is Article 6(1)(c) GDPR where documentation is required for compliance with data-protection obligations and Article 6(1)(f) GDPR for the efficient administration of privacy preferences.

​

Wix provides a privacy and cookie system that allows visitors to accept or decline non-essential cookies, while essential cookies remain available for necessary website functions. (Wix Help Center)

 

8. Wix Analytics

​

The website may use Wix Analytics to understand how the website is used and to improve its structure, clarity and technical performance.

Depending on the visitor’s consent selection, analytics information may include:

​

• number of visits;

• pages viewed;

• approximate session duration;

• referring source;

• general device information;

• browser information;

• general geographic region;

• and interactions with website pages.

 

Where analytics requires non-essential cookies or comparable identifiers, the relevant data is collected only after consent.

The legal basis is Article 6(1)(a) GDPR together with Section 25(1) TDDDG.

 

Where Wix processes limited technical or aggregated information through essential platform technologies for security, error detection or system effectiveness, the legal basis is Article 6(1)(f) GDPR.

Wix states that traffic reports based on analytics cookies are generated only where the visitor has provided the relevant consent through the cookie banner. (Wix Help Center)

 

9. Request Consideration Form

​

When you submit the Request Consideration form, Aurelis Clavis processes the information you provide.

Depending on the form fields completed, this may include:

​

• full name;

• role within the business;

• email address;

• country;

• business name;

• website or principal digital profile;

• year the business was established;

• approximate team size;

• product category;

• details of the selected product or collection;

• current markets, channels or regions;

• intended European market or commercial direction;

• the objective for which a system is being considered;

• current business challenges;

• available catalogues, specifications, material information, pricing, production capacity, photography, research or buyer information;

• preferred timeframe;

• readiness for a five-figure private project;

• uploaded documents;

• free-text information;

• and the date and time of submission.

 

The information is processed to:

​

• review whether the business and proposed objective fall within the current Aurelis Clavis focus;

• assess product maturity, operational readiness and strategic fit;

• understand the intended commercial direction;

• communicate with the applicant;

• request relevant clarification;

• determine whether a project may be considered;

• prepare a private scope or proposal where appropriate;

• and document pre-contractual communications.

 

The legal basis is Article 6(1)(b) GDPR where the submission requests pre-contractual consideration or steps towards a possible engagement.

Where a submission does not lead to contractual discussions, processing may also be based on Article 6(1)(f) GDPR. The legitimate interest lies in reviewing genuine business applications, responding appropriately and documenting the basis of the decision.

Submission of the form does not create a contract, an entitlement to acceptance or an obligation for either party to proceed.

 

10. Form Processing Through Wix

​

The Request Consideration form is operated using Wix Forms.

Form information may be stored within the Wix website dashboard, contact system, submissions area and related technical systems. Submission notifications may also be sent to authorised recipients through Wix Automations or associated email services.

Wix Forms enables site owners to collect customised information, store form submissions and receive notifications relating to submitted forms. (Wix Help Center) (Wix Help Center)

​

Wix processes the submitted information on behalf of Aurelis Clavis in accordance with its Data Processing Addendum.

Access to submissions is limited to Aurelis Clavis and authorised service providers or collaborators who require access for the relevant purpose and are subject to appropriate confidentiality obligations.

​

11. Uploaded Files and Documents

​

The Request Consideration form may permit the upload of documents and other business materials.

Uploaded content may include:

​

• product catalogues;

• company presentations;

• product specifications;

• material information;

• price structures;

• production information;

• photographs;

• market research;

• buyer information;

• or other documents relevant to the proposed objective.

 

Uploaded files are processed only to assess the application, understand the business and product context, evaluate potential scope and carry out pre-contractual or contractual work.

​

The legal basis is Article 6(1)(b) GDPR and, where necessary, Article 6(1)(f) GDPR.

Applicants should upload only information that is necessary for the application.

 

Applicants should not upload:

​

• identity documents;

• payment-card information;

• private banking credentials;

• medical information;

• biometric information;

• information relating to criminal convictions;

• private information about employees or customers;

• or confidential third-party information that the applicant is not authorised to disclose.

 

Where uploaded materials contain personal data relating to other individuals, the person submitting the material is responsible for ensuring that the disclosure is lawful and that the relevant individuals have been informed where required.

Wix Forms supports document and file uploads and may store or transmit those files through the form and notification infrastructure. (Wix Help Center)

​

12. Spam Prevention and Website Security

​

Wix Forms may use integrated spam filters, behavioural analysis and CAPTCHA mechanisms to identify automated or suspicious submissions.

These mechanisms may process:

​

• IP address;

• browser and device information;

• interaction patterns;

• date and time;

• security indicators;

• and technical information concerning the form submission.

 

The purpose is to protect the website, form infrastructure and communication channels from spam, bots, attacks and abusive use.

The legal basis is Article 6(1)(f) GDPR. The legitimate interest lies in maintaining website security and ensuring that business applications are submitted by genuine users.

​

Wix states that its current forms include integrated spam protection and may present a CAPTCHA challenge where activity is considered suspicious. (Wix Help Center)

​

These security mechanisms do not make decisions producing legal effects or similarly significant effects concerning applicants.

 

13. Email Communication

 

When you contact Aurelis Clavis by email, the information contained in your message is processed.

 

This may include:

• your name;

• email address;

• business details;

• message content;

• attachments;

• communication history;

• and technical email metadata.

 

The data is processed to:

​

• respond to your communication;

• assess and manage a business enquiry;

• prepare or perform a contractual engagement;

• maintain business records;

• and protect or exercise legal rights.

 

The legal basis is Article 6(1)(b) GDPR where the communication concerns pre-contractual or contractual matters.

For general business correspondence, security, documentation or the defence of legal rights, the legal basis is Article 6(1)(f) GDPR.

Where legal retention duties apply, processing is based on Article 6(1)(c) GDPR.

​

Email communication may involve the processing of data by the email, hosting and IT service providers used by Aurelis Clavis.

Ordinary email communication cannot be guaranteed to be completely secure. Particularly confidential information should be transmitted only after an appropriate secure method has been agreed.

​

14. No Newsletter or Unsolicited Marketing Through the Application Form

​

The Request Consideration form is not used to subscribe applicants automatically to a newsletter or general advertising communications.

Contact details submitted through the form are used for the submitted application, related business communication and any resulting pre-contractual or contractual relationship.

​

Separate electronic marketing will be sent only where a valid legal basis exists, including consent where consent is legally required.

​

15. Recipients of Personal Data

​

Personal data is disclosed only where necessary for the relevant purpose, where legally permitted or where required by law.

Possible recipients or categories of recipients include:

​

• Wix.com Ltd. and its affiliated companies;

• Wix subprocessors involved in hosting, storage, security, forms, analytics or technical support;

• email and communication service providers;

• IT and website service providers;

• professional advisers bound by confidentiality where their involvement is necessary;

• public authorities, courts or regulators where disclosure is legally required;

• and contractual service providers whose involvement is necessary to perform an agreed engagement.

 

Aurelis Clavis does not sell personal data.

​

Aurelis Clavis does not receive referral income for transferring applicant information to external professional providers.

External lawyers, tax advisers, customs professionals, laboratories, certification providers or other regulated professionals do not receive applicant data merely because their category of service may be mentioned within an Aurelis Clavis system.

​

Any disclosure to an external professional requires a separate lawful basis and will occur only where necessary, authorised or legally required.

16. International Data Transfers

​

Because Wix operates internationally, personal data processed through the website may be transferred to and processed in countries outside the European Economic Area.

​

Wix states that visitor data is initially transferred to Wix.com Ltd. in Israel on the basis of the European Commission’s adequacy decision for Israel.

Where Wix or its subprocessors transfer personal data to another country recognised as providing an adequate level of protection, the transfer may rely on the applicable adequacy decision.

​

For transfers to other third countries, Wix states that it uses appropriate safeguards such as the European Commission’s Standard Contractual Clauses or another legally recognised transfer mechanism. (wix.com)

​

Where applicable, supplementary technical and organisational measures may also be used.

​

International transfers through other service providers are made only where a lawful transfer mechanism exists, such as:

​

• an adequacy decision;

• Standard Contractual Clauses;

• an approved certification framework;

• or another safeguard permitted under Chapter V GDPR.

 

17. Retention of Personal Data

​

Personal data is retained only for as long as necessary for the purpose for which it was collected.

​

The applicable retention period depends on:

​

• the nature of the information;

• the purpose of processing;

• whether an application leads to an engagement;

• legal retention obligations;

• limitation periods;

• security requirements;

• and the need to establish, exercise or defend legal claims.

 

Website and Security Data

​

Technical and security data is retained only for the period necessary to operate and secure the website, investigate errors or misuse and comply with technical or legal obligations.

Applications That Do Not Proceed

Application information and related communications that do not result in an engagement are generally deleted when they are no longer required for review, follow-up, documentation or the defence of legal claims.

 

As a general internal standard, such information may be retained for up to twelve months after the final communication unless:

​

• continued communication is ongoing;

• the applicant has requested later reconsideration;

• consent has been given for longer retention;

• legal claims must be protected;

• or a longer period is required by law.

 

Contractual Relationships

​

Where an engagement is entered into, relevant information is retained for the duration of the relationship and afterwards for the applicable statutory commercial, tax, accounting and limitation periods.

​

Uploaded Materials

​

Uploaded documents are deleted when they are no longer necessary for application review, project preparation, performance of the engagement, legal documentation or the defence of claims.

​

Files that contain unnecessary or unlawfully submitted personal data may be deleted earlier.

​

Consent Records

​

Records of privacy and cookie consent may be retained for as long as necessary to demonstrate compliance and to manage the visitor’s preferences.

 

18. Data Security

 

Aurelis Clavis and its processors use appropriate technical and organisational measures intended to protect personal data against:

​

• accidental or unlawful destruction;

• loss;

• alteration;

• unauthorised disclosure;

• unauthorised access;

• and other unlawful processing.

 

Measures may include:

​

• encrypted website connections;

• access restrictions;

• secure account authentication;

• role-based access;

• system monitoring;

• platform security controls;

• spam protection;

• confidentiality obligations;

• and secure deletion procedures.

 

Wix states that it maintains technical and organisational security measures designed to protect visitor data and requires its subprocessors to provide an appropriate level of protection. (wix.com)

​

No online transmission or electronic storage method can guarantee absolute security.

​

19. Obligation to Provide Personal Data

​

There is no statutory obligation to submit a Request Consideration application.

 

However, certain information is necessary for Aurelis Clavis to:

​

• identify the applicant;

• understand the business and selected product;

• assess the intended objective;

• communicate a response;

• and determine whether a possible engagement can be considered.

 

Without the required information, Aurelis Clavis may be unable to review or respond to the application.

​

Where a contractual relationship is established, further information may be required to perform the agreement or comply with legal obligations.

 

20. Automated Decision-Making

​

Aurelis Clavis does not use personal data to make decisions based solely on automated processing that produce legal effects or similarly significant effects within the meaning of Article 22 GDPR.

Applications are reviewed under human direction.

Technical spam and security filters may automatically identify, delay or block suspicious submissions. These measures serve website security and do not determine whether a genuine business application is accepted.

​

21. Special Categories of Personal Data

The website and Request Consideration form are not intended to collect special categories of personal data under Article 9 GDPR.

Applicants should not submit information concerning:

• racial or ethnic origin;

• political opinions;

• religious or philosophical beliefs;

• trade-union membership;

• genetic data;

• biometric data used for identification;

• health;

• or sex life or sexual orientation.

Where such information is received without being requested and is not necessary for a lawful purpose, it may be deleted.

22. Information Concerning Other Individuals

Where an applicant provides personal data concerning employees, representatives, customers, suppliers, business partners, photographers, designers, artisans or other individuals, the applicant must ensure that:

• the information is relevant and necessary;

• the applicant is legally permitted to disclose it;

• the disclosure does not violate confidentiality obligations;

• and the relevant person has been informed where required by data-protection law.

Aurelis Clavis may request that unnecessary third-party personal data be removed or redacted.

23. External Links

This website may contain links to external websites or services.

When you follow an external link, the relevant third party may process personal data independently and under its own responsibility.

This Privacy Policy does not govern the data-processing practices of external websites.

Aurelis Clavis is not responsible for the privacy practices or content of independent third-party services.

24. Rights of Data Subjects

Subject to the conditions of the GDPR, you may have the following rights:

Right of Access

You may request confirmation as to whether personal data concerning you is processed and obtain access to that data and the related processing information.

Right to Rectification

You may request correction of inaccurate personal data and completion of incomplete data.

Right to Erasure

You may request deletion of personal data where the legal requirements are met.

The right to erasure does not apply where processing remains necessary, including for legal obligations or the establishment, exercise or defence of legal claims.

Right to Restriction of Processing

You may request that processing be restricted where the legal requirements are met.

Right to Data Portability

Where processing is based on consent or contract and carried out by automated means, you may request personal data provided by you in a structured, commonly used and machine-readable format.

Right to Object

Where personal data is processed on the basis of Article 6(1)(f) GDPR, you may object to the processing on grounds relating to your particular situation.

Processing will cease unless compelling legitimate grounds exist that override your interests, rights and freedoms or the processing is necessary for the establishment, exercise or defence of legal claims.

Where personal data is processed for direct marketing, you may object at any time. The data will then no longer be processed for that purpose.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time with effect for the future.

Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Right to Lodge a Complaint

You have the right to lodge a complaint with a data-protection supervisory authority.

Requests concerning your rights may be sent to:

info@aurelisclavis.com

Aurelis Clavis may request information necessary to confirm the identity of the person making the request.

25. Competent Supervisory Authority

The supervisory authority responsible for data protection in North Rhine-Westphalia is:

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

Email: poststelle@ldi.nrw.de

A complaint may also be submitted to another supervisory authority, particularly in the Member State of the individual’s habitual residence, place of work or the place of the alleged infringement.

The LDI NRW provides a procedure through which individuals may submit complaints concerning possible data-protection violations. (ldi.nrw.de)

26. Changes to this Privacy Policy

This Privacy Policy may be updated where:

• the website or its functions change;

• new service providers are introduced;

• processing activities change;

• legal or regulatory requirements change;

• or clarification becomes necessary.

The version published on this website at the time of the relevant visit applies.

Material changes affecting consent-based processing will not retrospectively alter or expand an existing consent.

The current version is dated 19 July 2026.