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GDPR Compliant

Privacy Policy

This Privacy Policy describes how FW Delta LLC collects, uses, and protects your personal data in accordance with the General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (FADP), and applicable national data protection laws.

We take your privacy seriously and are committed to protecting your personal information. This policy provides transparent information about our data processing activities as required by Art. 13 and Art. 14 GDPR.

Effective: February 12, 2026 Jurisdiction: EU/EEA, CH Version 2.1

01. Data Controller and Data Protection Officer

The controller responsible for the processing of your personal data within the meaning of Art. 4(7) GDPR and Art. 5(i) FADP is:

Legal Entity

FW Delta LLC

30 N Gould St Ste 60388

Sheridan, WY 82801

United States

Filing ID: 2026-001873879

Data Protection Officer

Fabian Weiss

Data Protection Officer

fw@fwdelta.com

Our Data Protection Officer is available to answer any questions regarding the processing of your personal data.

EU Representative

As we process data of EU residents but are not established in the EU, we have appointed an EU representative in accordance with Art. 27 GDPR. Contact details are available upon request.

02. Scope of Application

This Privacy Policy applies to the processing of personal data:

  • When you visit our website (fwdelta.com and all subdomains)
  • When you use our contact forms or send us emails
  • When you request quotes or engage our services
  • When you interact with our content on social media platforms

This policy does not apply to third-party websites linked from our site. We recommend reviewing the privacy policies of any external websites you visit.

04. Categories of Personal Data

We process the following categories of personal data:

Identity Data

Essential
  • Full name
  • Email address
  • Company name
  • Job title
  • Postal address
  • Phone number

Communication Data

Optional
  • Email correspondence
  • Contact form messages
  • Chat transcripts
  • Support tickets
  • Meeting notes

Technical Data

Essential
  • IP address (anonymized)
  • Browser type and version
  • Operating system
  • Device type
  • Screen resolution
  • Language preferences

Usage Data

Optional
  • Pages visited
  • Time spent on pages
  • Click behavior
  • Referrer URL
  • Search queries
  • Session duration

Transaction Data

Optional
  • Project details
  • Payment information
  • Invoice data
  • Contract documents

Marketing Data

Optional
  • Email open rates
  • Link clicks
  • Campaign engagement
  • Communication preferences

05. Processing Purposes

We process your personal data for website operation, service delivery, analytics, marketing (with consent), and legal compliance. Each purpose has specific retention periods and legal bases.

06. Hosting Infrastructure

EU-Exclusive Infrastructure

All our servers and databases are located exclusively within the European Union (Germany, Finland). We do not use US-based cloud providers for storing personal data.

Hosting Provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany

We have a Data Processing Agreement (DPA) with Hetzner in accordance with Art. 28 GDPR. Hetzner operates ISO/IEC 27001:2022 certified infrastructure.

07. Server-Side Tracking Architecture

Privacy-First Data Proxying

Unlike conventional client-side tracking, your browser does not communicate directly with third-party services. All tracking data is first sent to our EU-based server, where it undergoes strict filtering and anonymization before any data is forwarded.

Protection Measures:

IP Anonymization

IP addresses are truncated before any processing, making re-identification impossible.

PII Scrubbing

All personal identifiers are hashed using SHA-256 before forwarding.

User-Agent Generalization

Detailed device data is reduced to general categories to prevent fingerprinting.

First-Party Cookies

All tracking cookies are set under our domain, preventing cross-site tracking.

08. Third-Party Services

With your explicit consent, we use the following services:

Google Analytics 4 (Server-Side)

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Analytics

Purpose: Website traffic analysis, conversion tracking, and performance optimization.

Safeguards:

  • IP anonymization enabled
  • Google Signals disabled
  • Standard Contractual Clauses in place

Meta Conversions API

Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland

Marketing

Purpose: Facebook and Instagram advertising campaign measurement and optimization.

Safeguards:

  • Only SHA-256 hashed data transmitted
  • No direct browser-to-Meta communication

Right to Withdraw Consent

You can withdraw your consent at any time via cookie settings. This does not affect the lawfulness of processing before withdrawal.

09. Data Recipients

We share data with IT service providers, analytics services, payment processors, professional advisors, and public authorities (when legally required). All recipients are bound by strict contractual obligations.

10. Data Retention Periods

We retain personal data only as long as necessary:

Server Access Logs

7 days

Automatic deletion for security monitoring

Website Analytics Data

14 months

Google Analytics minimum retention setting

Contact Form Inquiries

3 years

After last contact, unless contract exists

Email Correspondence

3 years

After last contact, unless contract exists

Contract Documents

10 years

Legal retention obligation

Invoices & Accounting

10 years

Legal retention requirement

Cookie Consent Records

12 months

Standard consent validity period

Marketing Consent

Until withdrawn

Active consent required

Encrypted Backups

30 days

Rolling backup retention

Project Files

5 years

After completion, for warranty purposes

11. Security Measures

We implement comprehensive security measures in accordance with Art. 32 GDPR:

Transport Layer Security

TLS 1.3 encryption for all data in transit. HTTP Strict Transport Security (HSTS) enforced.

Data Encryption at Rest

AES-256 encryption for all databases and file storage. Full disk encryption on all servers.

Access Control

Role-based access control (RBAC) with least privilege. Mandatory 2FA for all admin access.

Network Security

Dedicated firewall with strict rules. Intrusion Detection System and DDoS protection.

Backup & Recovery

Daily encrypted backups with geographic redundancy. Regular restoration testing.

Security Monitoring

24/7 automated monitoring and alerting. Real-time threat detection and response.

12. Automated Decision-Making

No Automated Decisions

We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you, as defined in Art. 22 GDPR.

13. Your Data Subject Rights

Under GDPR and Swiss FADP, you have the following rights:

Right of Access (Art. 15 GDPR)

You have the right to obtain information about your personal data stored by us.

Right to Rectification (Art. 16 GDPR)

You may request correction of inaccurate data or completion of incomplete data.

Right to Erasure (Art. 17 GDPR)

You may request deletion of your personal data, subject to legal retention obligations.

Right to Data Portability (Art. 20 GDPR)

You have the right to receive your data in a structured, machine-readable format (JSON).

Exercise Your Rights

To exercise any of these rights, please contact us at:

fw@fwdelta.com

We will respond within 30 days. Exercising your rights is free of charge.

14. International Data Transfers

Our primary infrastructure is in the EU. When using Google Analytics and Meta CAPI, data may be transferred to the USA with appropriate safeguards (Standard Contractual Clauses, EU-US Data Privacy Framework).

Important Notice

Despite safeguards, there remains a residual risk of access by US authorities when transferring to the USA. You can disable these services at any time via cookie settings.

15. Minors' Data

Our services are directed at business clients. We do not knowingly collect data from individuals under 16 without parental consent. If you believe we have collected data from a minor, please contact us immediately.

16. Changes to This Privacy Policy

We may update this policy to reflect changes in legal requirements or technical developments. Material changes will be communicated via email or prominent website notice.

Current Version

Version 2.1

February 12, 2026

17. Right to Lodge a Complaint

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

Germany

Federal Commissioner for Data Protection (BfDI)

www.bfdi.bund.de →

Austria

Austrian Data Protection Authority

www.dsb.gv.at →

Switzerland

Federal Data Protection Commissioner (FDPIC)

www.edoeb.admin.ch →

18. Contact Information

For questions about this policy or your data, contact our Data Protection Officer:

Fabian Weiss

Data Protection Officer, FW Delta LLC

fw@fwdelta.com

Questions About Your Data?

Our Data Protection Officer is available to assist you at any time.

Contact Data Protection Officer

We aim to respond to all inquiries within 48 hours