Privacy policy
Draft for owner approval before production. Technical checks do not replace legal review.
Version: 2026-10-18.3
Katarzyna Guelib · VRACHIOLIElsendeich 18, 47559 Kranenburg, Germany
shop@vrachioli.com · +49 177 5464296
§ 1. Controller and infrastructure
The controller is Katarzyna Guelib, contact above. The private server is at its owner's home in Germany. The owner maintains and secures it under authorisation; a separate processor requires an Article 28 GDPR agreement. Spaceship supplies vrachioli.com. SMTP provider remains unconfirmed; no claim is made that all mail is stored in Germany.
§ 2. Data, purposes and bases
An enquiry stores model, ID/URL, language, time and reference. A post-conversation reading acknowledgement stores the case reference, declaration, language, time, version and a copy of the displayed documents. Only authorised administration can access the record in the panel; it is not public. An unconfirmed individual link expires after 30 days. Possession of the link does not verify identity. Supplied contact, agreements, payments, shipping, complaints and damage photos are processed. Article 6(1)(b) GDPR: pre-contract steps/performance; (c): duties; (f): security, correspondence and claims. Separate required consent is not a purchase condition.
§ 3. Recipients and storage
PostgreSQL/photos are on the server; encrypted backups on selected USB/disk/partition. Authorised administrators, mail providers, carriers, banks, accountants and authorities get necessary data. No data sale. Providers and safeguards for non-EEA transfers must be established before enabling that service.
§ 4. Retention
Retain data as needed for the matter, contract and claims. Accounting records generally 8 years, business correspondence 6 and certain books 10 (section 147 AO), with statutory calculation/extensions. Ordinary claims can be 3 years under sections 195–199 BGB. Data no longer required by law or purpose must be deleted/anonymised after periodic review.
§ 5. Backups and erasure
This version does not automatically delete archives. Deleting an entry does not remove it from old backups. The controller must plan deletion/replacement after preserving mandatory documents and reapply erasure requests after restoration. Automatic 12-month, 30-day or 90-day periods are not claimed as implemented; arrangements are needed before production.
§ 6. Browser and WhatsApp
Language and contact drafts are remembered; browser site data can be cleared. Starting a conversation requires no checkboxes. Afterwards, the customer can personally acknowledge reading the policies. Opening WhatsApp takes prepared model or acknowledgement data to an external service with its own privacy rules. The customer sends the message. The administrator cookie supports login.
§ 7. Rights and security
Under GDPR conditions request access, correction, erasure, restriction or portability, object and withdraw consent. Retention duties or claims may limit erasure. Contact shop@vrachioli.com; complain to LDI Nordrhein-Westfalen or a competent authority. Access controls, encrypted backups and production HTTPS apply. Anti-spam stores a connection-identifier hash and attempt times. Enquiries are not public; contracts are not solely automatically concluded.
§ 8. Reviews, photos and translations
The optional form stores a name or nickname, text, selected language, up to three photos, consent text/version and submission time. Publication is based on consent (Article 6(1)(a) GDPR), withdrawable via shop@vrachioli.com. Photos are compressed and location metadata removed. Pending or rejected reviews and photos are not public. A random token stored in this browser provides a private receipt for the latest submission; only its hash is stored on the server. It does not identify the computer. Purchases are not verified. A rule-based filter may make mistakes; the owner can change the status. If the owner enables DeepL, only published review text is sent to DeepL for machine translation and stored with translations in the database in Germany. Names, photos and IPs are not attached, but personal data included in the text may reach DeepL. The service is not enabled without a key. Before activation the owner must establish appropriate GDPR processing terms and provider information. Publication lasts until consent is withdrawn, the review is deleted or its purpose ends. Unpublished entries require regular review and erasure once unnecessary for moderation or claims. Erasure from the live database includes photos/translations, not old encrypted backups; the backup rules above apply. Hashed connection identifiers and attempt times prevent spam on the legitimate security interest basis (Article 6(1)(f)). Purchases and photo content are not automatically verified.