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Privacy Policy

Last updated: October 2026

Data Controller pursuant to Art. 4 No. 7 GDPR

Raffael Hühnerschulte

Individual Entrepreneur Raffael Hühnerschulte

Nino and Ilia Nakashidze Street 1, Building 3, Apartment 3

Krtsanisi District, Tbilisi

Georgia

E-mail:


Data Processing Principles

This website collects only the data strictly necessary for operation and communication. No cookies are set, no web analytics are used, and no data is shared with advertising networks.

No Cookies No Tracking No Google Analytics No Ads


What Data Is Processed?

Server Logs

The web server automatically records the following data on each request (server logs):

This data is technically necessary and is used solely for error diagnosis and attack prevention. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure operation). Logs are automatically deleted after 14 days at the latest.

Contact Form

The contact form transmits your name, e-mail address, optionally your company, and your message. This data is used to respond to your enquiry and is stored in a CRM system (HubSpot) for structured follow-up; an e-mail notification is simultaneously sent via Hostinger SMTP. Data is transferred to HubSpot, Inc. (USA) — the legal basis for this third-country transfer is the EU-US Data Privacy Framework, under which HubSpot is certified (Art. 45 GDPR). Legal basis for processing: Art. 6(1)(b) GDPR (pre-contractual measures) or Art. 6(1)(f) GDPR.

AI Chat ("Raffael AI")

Chat messages are transmitted to a language model via the Ollama cloud API (Ollama, Inc., USA) for processing. This constitutes a transfer of conversation content to a US-based third-party provider — see "Data Processors" below. Chat histories are not stored persistently server-side and are no longer retrievable once the browser session ends. Legal basis: Art. 6(1)(f) GDPR.

If a user chooses to leave contact details at the end of a conversation (name, e-mail, optionally company, phone, and an automatically generated conversation summary), those details are stored in HubSpot CRM under the same conditions as contact form submissions. Legal basis: Art. 6(1)(b) or Art. 6(1)(f) GDPR.

LinkedIn Link

This website contains a link to a LinkedIn profile. Clicking it takes you away from this website. LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, becomes responsible for data processing at that point. LinkedIn's Privacy Policy applies.


Hosting & Data Transfer

This website is hosted on servers within the European Union. All data is transmitted encrypted via HTTPS (TLS 1.2 / 1.3).

Contact data and chat leads are transferred to HubSpot, Inc. (USA). The transfer to the United States is based on the EU-US Data Privacy Framework (Art. 45 GDPR), under which HubSpot is certified. See "Data Processors" below for details.

Data Processors

Data processing agreements (Art. 28 GDPR) or equivalent safeguards are in place for:

HubSpot, Inc.

25 First Street, Cambridge, MA 02141, USA

Purpose: CRM — storage and management of contact enquiries and chat leads

Transfer basis: EU-US Data Privacy Framework (Art. 45 GDPR)

HubSpot Privacy Policy

Ollama, Inc.

San Francisco, CA, USA

Purpose: AI language model — processing of chat messages via the Ollama cloud API

Transfer basis: Standard Contractual Clauses (Art. 46(2)(c) GDPR)

Ollama Privacy Policy

Hostinger International Ltd.

61 Lordou Vironos str., 3095 Limassol, Cyprus (EU)

Purpose: SMTP — delivery of e-mail notifications for new contact submissions

Hostinger Privacy Policy


Your Rights as a Data Subject

Under the GDPR you have the following rights:

To exercise these rights, please contact the e-mail address listed above.


Supervisory Authority

The controller is based in Georgia and has no establishment in the EU. Where the GDPR applies, you have the right to lodge a complaint with a supervisory authority in the EU, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (Art. 77 GDPR).


Changes to This Policy

This privacy policy may be updated when technical circumstances or the legal situation change. The current version is always available at coach-raffael.com/datenschutz.html.