Wolroy

Legal

Privacy policy

Last updated: June 2026. This version describes the data processing as of the website launch and is subject to a final legal review before publication.

1. Controller

The controller responsible for data processing on this website is:

Wolroy UG (haftungsbeschränkt), Laubacher Straße 4, 14197 Berlin, Germany. Represented by the Managing Director Robert Wolter. Email: info@wolroy.com.

We have not appointed a data protection officer, as there is no legal obligation to do so.

2. General

We process personal data only to the extent necessary for a functional, secure operation of this website and for handling your inquiries. The legal bases are in particular Art. 6 (1) (a) GDPR (consent), (b) (initiation or performance of a contract), and (f) (legitimate interest). This website is addressed to business partners, suppliers, investors, and public authorities, not to consumers.

3. Hosting and server log files

This website is hosted on Cloudflare Pages by Cloudflare, Inc. (101 Townsend Street, San Francisco, CA 94107, USA). Cloudflare also provides the network, DNS, and security infrastructure (content delivery network, web application firewall, bot management).

When the website is accessed, Cloudflare processes technically necessary access data, in particular the IP address, date and time of access, the resource requested, the referrer, and the user agent. This processing serves the secure and stable operation of the site. The legal basis is Art. 6 (1) (f) GDPR. A data processing agreement pursuant to Art. 28 GDPR is in place with Cloudflare. Requests from the EU are processed primarily via data centres in the EU. For third-country transfers, see section 9.

4. Contact form

When you use our contact form, we process the data you provide (name, email address, and message) in order to handle your inquiry. Transmission is encrypted via a Cloudflare Pages Function. Delivery to our mailbox info@wolroy.com is handled through the email service Resend (Plus Five Five, Inc.), with processing taking place in the EU region. To protect against automated abuse (spam) we use Cloudflare Turnstile, which works without cookies and without cross-device tracking.

The legal basis is Art. 6 (1) (a) GDPR (consent) and, where your inquiry is directed at the initiation or performance of a contract, Art. 6 (1) (b) GDPR; otherwise Art. 6 (1) (f) GDPR (handling of business inquiries). No open or click tracking of the sent emails takes place.

5. Contact by email

If you contact us by email (info@wolroy.com), we process your details in order to handle your request. We operate our mailboxes with IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany. The legal basis is Art. 6 (1) (b) or (f) GDPR.

We use only technically necessary cookies and, subject to your consent, optional services. For consent management we use the self-hosted open-source tool Klaro!. It transmits no data to third parties; your decision is stored locally in your browser.

Technically necessary cookies:

The legal basis for technically necessary cookies is Art. 6 (1) (f) GDPR in conjunction with § 25 (2) no. 2 TDDDG. Optional services are only used after your consent (Art. 6 (1) (a) GDPR, § 25 (1) TDDDG); you can withdraw this consent at any time with future effect via the cookie settings.

7. Reach measurement (Cloudflare Web Analytics)

Subject to your consent, we use Cloudflare Web Analytics for anonymous reach measurement. The method works without cookies, does not create user profiles, and performs no cross-device tracking. The legal basis is Art. 6 (1) (a) GDPR. You can withdraw your consent at any time via the cookie settings.

8. Recipients and processors

We pass personal data only to carefully selected processors with whom data processing agreements pursuant to Art. 28 GDPR are in place:

A complete, continuously maintained overview, with purpose, data category, region, and agreement status, is available in our list of subprocessors.

9. Transfers to third countries

Some of the named service providers (Cloudflare, Inc., Plus Five Five, Inc.) are based in the USA. Where personal data is transferred to the USA, we base this on the European Commission’s adequacy decision (EU-US Data Privacy Framework), insofar as the respective provider is certified, supplemented by standard contractual clauses pursuant to Art. 46 (2) GDPR. With Resend, processing is restricted to the EU region; Cloudflare processes EU requests primarily within the EU.

10. Storage period

We store personal data only for as long as is necessary for the stated purposes or as required by statutory retention obligations. Server and security data is deleted or anonymised after a short period. Inquiries via the contact form or by email are deleted once they have been conclusively handled and no retention obligations preclude deletion.

11. Your rights

Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), and objection to processing (Art. 21). You may withdraw any consent given at any time with future effect (Art. 7 (3) GDPR). To do so, please contact info@wolroy.com.

12. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin, email: mailbox@datenschutz-berlin.de.

13. Data security

We use TLS encryption for transmission (recognisable by “https://” and the padlock symbol in your browser).

14. Currency of this statement

We update this privacy policy whenever the underlying data processing or the legal situation changes.