Introduction
This Privacy Policy explains how we collect, use, share, and protect personal data when you visit or interact with our website www.thenewways.eu (“Website”).
It fulfils our information obligations under the EU General Data Protection Regulation (“GDPR”) and applies to all visitors and users of the Website.
Controller and contact details
The controller responsible for processing your personal data through this Website is:
Shelbric A. Fuller
Karl Marx Strasse 149
12043 Berlin Germany
You can contact us regarding privacy matters at: shelbric.fuller@gmx.de
Categories of personal data we collect
Depending on how you use the Website, we may process the following categories of personal data:[
Technical and usage data: IP address, browser type and version, device information, operating system, referring URLs, pages viewed, time and date of visits, and other server log data.
Cookie and tracking data: identifiers stored in cookies or similar technologies and information on how you interact with our Website (e.g. page views, clicks, scrolls).
Communication data: name, contact details, and message content if you contact us via email, contact form, or other communication channels.
Account and subscription data (if enabled): login details, profile information, order or booking history, and preferences when you create an account, subscribe to a newsletter, or sign up for services.
We do not intentionally collect special categories of personal data (e.g. health, political opinions, religious beliefs) via this Website.[
Cookies and similar technologies
Our Website uses cookies and similar technologies (such as local storage and pixels) to ensure proper functioning, improve performance, and analyse Website traffic.
When legally required, we ask for your consent before placing non‑essential cookies and allow you to manage your preferences through a cookie banner or settings tool.
We distinguish between:
Strictly necessary cookies: required for Website operation and security; these are set on the basis of our legitimate interest in providing a functional Website.
Analytics and performance cookies: help us understand how visitors use the Website to improve content and usability; these are only set with your consent.
Details of the specific cookies used (name, provider, purpose, storage duration) will be made available in a separate cookie notice or within the cookie banner configuration.
Purposes and legal bases for processing
We process personal data only when we have a valid legal basis under Article 6 GDPR and for clearly defined purposes.
We may process your data for the following purposes:
Website operation and security – to display the Website, maintain server logs, prevent abuse, and ensure stability. Legal basis: our legitimate interest in operating a secure and functional online service (Article 6(1)(f) GDPR).
Analytics and performance – to understand how visitors use the Website, improve content, and measure reach, based on aggregated statistics. Legal basis: your consent (Article 6(1)(a) GDPR) where required.
Responding to enquiries – to process and respond to contact requests, support queries, and feedback submitted via forms or email. Legal basis: performance of a contract or steps taken at your request (Article 6(1)(b) GDPR) and/or our legitimate interest in providing customer service (Article 6(1)(f) GDPR).
Accounts, bookings, and services (if offered) – to create and manage user accounts, process bookings or orders, and deliver contracted services. Legal basis: performance of a contract (Article 6(1)(b) GDPR).
Marketing communication (optional) – to send newsletters or information about services, where you have opted in. Legal basis: your consent (Article 6(1)(a) GDPR) and/or legitimate interest in direct marketing, subject to applicable e‑privacy rules.
Legal and compliance obligations – to comply with retention duties, tax or accounting laws, and to respond to requests from public authorities. Legal basis: legal obligation (Article 6(1)(c) GDPR).
Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms and determined that our interests do not override your privacy expectations.
Analytics and performance monitoring
We may use analytics tools (for example, privacy‑friendly website analytics or third‑party providers) to collect aggregated statistics on Website usage, such as page views, traffic sources, and visitor interactions.
These tools typically process your IP address and device information, which may be shortened or pseudonymised, to generate insights without directly identifying you.
Where required, analytics cookies will only be set after you have given consent through the cookie banner, and you can withdraw this consent at any time by changing your settings or deleting cookies.
Contact forms, enquiries, and accounts
If you contact us via our contact form, email, or other communication channels, we process the information you provide (such as name, email address, subject, and message) to handle your enquiry.
If we offer user accounts, bookings, or other online services, we will process the data necessary to create and manage your account, authenticate you, and provide the requested service.
We store enquiry‑related data only as long as necessary to resolve your request and for a limited period afterwards, where required for documentation or defence of legal claims.
Marketing and service emails
We may send you:
Service and transactional emails – messages relating to account creation, password resets, bookings, or important changes to our services; these are necessary for contract performance and cannot be unsubscribed from in most cases.
Marketing emails or newsletters – only if you have expressly subscribed or if permitted under applicable law for existing customers; you can unsubscribe at any time using the link in each email or by contacting us.
We process your contact details for marketing communications based on your consent or our legitimate interest in direct marketing, in line with GDPR and e‑privacy rules.
Embedded content, fonts, and social media
Our Website may include embedded content or integrations from third parties, such as fonts, videos, maps, or social media share buttons.[][]
When you access such content, the third‑party provider may receive technical and usage data (including your IP address, browser information, and page visited) and may set cookies or similar technologies.[][]
We only integrate third‑party services when necessary for the design or functionality of the Website and endeavour to use privacy‑friendly settings where available. Please review the privacy policies of the respective third‑party providers for more information.[][]
Data recipients and international transfers
We do not sell your personal data. We only share it where necessary for the purposes described above or where we are legally obliged to do so.
Typical categories of recipients include:
Hosting and infrastructure providers that store and serve the Website.
IT and support service providers who help maintain our systems.
Analytics or email service providers we use to analyse traffic or send communications.
Professional advisers (e.g. legal or accounting) where necessary.
Public authorities and courts where required by law.
Some of these recipients may be located outside the European Economic Area (EEA). In such cases we ensure an adequate level of data protection, for example by relying on adequacy decisions or standard contractual clauses as provided for under GDPR.
Data retention
We store personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by law.
In particular:
Server logs and technical data are usually retained for a short period for security and troubleshooting, then deleted or anonymised.
Contact form and enquiry data are kept as long as needed to manage your request and for a limited period afterwards where necessary for documentation.
Account, booking, or contract‑related data are stored for the duration of the contractual relationship and in line with statutory retention periods (e.g. tax and commercial law).
Marketing‑related data are retained until you withdraw your consent or object to processing, unless we are required to keep certain records for proof of compliance.
We regularly review our retention periods and delete or anonymise data when it is no longer needed.
Your rights under GDPR
Under the GDPR, you have several rights regarding your personal data:
Right to be informed – to receive clear information about how we process your data.
Right of access – to obtain confirmation that we process your data and receive a copy of it.
Right to rectification – to request correction of inaccurate or incomplete data.
Right to erasure (“right to be forgotten”) – to request deletion of your data where certain conditions are met (e.g. data no longer needed, unlawful processing, or withdrawal of consent).
Right to restriction of processing – to have processing limited in certain circumstances (e.g. while accuracy is being verified).
Right to data portability – to receive data you provided in a structured, commonly used, machine‑readable format and transmit it to another controller.
Right to object – to object to processing based on legitimate interests or to direct marketing.
Rights related to automated decision‑making and profiling – to not be subject to decisions based solely on automated processing that have significant effects on you, and to request human review where applicable.
To exercise these rights, please contact us using the details provided above. We will respond without undue delay and in any case within one month, subject to legal extensions in complex cases.
You also have the right to lodge a complaint with your local Data Protection Authority (for example, the authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement).
Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or destruction.
While no online service can guarantee absolute security, we regularly review our security practices and adjust them to the current state of the art and regulatory requirements.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time, for example to reflect changes in our services, legal requirements, or technical developments.
The version published on this Website applies; we indicate the date of the latest update at the top or bottom of the Policy and encourage you to review it periodically.