1. Controller
The controller responsible for processing personal data on this website is:
Zoltán Csomor
SustainProperty Advisory
Radeland 1
22927 Großhansdorf
Germany
Phone: +49 171 480 70 10
Email: connect@sustain-property.com
2. Principles
We process personal data only where necessary to provide this website, communicate with you, handle your newsletter registration or non-binding pre-order, or protect legitimate interests. Data is disclosed only when necessary to provide a service, legally required, covered by a legitimate interest or authorised by you.
3. Hosting and website delivery
This website is hosted and operated using ChatGPT Sites by OpenAI. When you access it, data including your IP address, date and time, requested page or file, transferred data volume, referrer, browser and operating system information, and status and security data may be processed.
Processing serves website delivery, stability and technical security, and the detection and prevention of misuse. The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is the secure, stable and economical operation of this website.
OpenAI may process this data as a hosting and operations provider under the agreements applicable to our account. ChatGPT Sites currently provides no fixed data residency commitment, so processing may also occur outside the European Economic Area. Any third-country transfers are governed by the applicable contractual and statutory safeguards.
Technical log data is retained only for as long as required for operation, security, troubleshooting and legal obligations. The specific retention period depends on the nature, purpose and security relevance of the data and the applicable hosting terms.
4. Cookie settings and local browser storage
Your cookie-dialogue choice is stored in local browser storage under the key “fm-cookie-consent-v2”. The selected categories and time of your choice are recorded so that we do not have to ask again on every visit.
Technically necessary functions are always active. Analytics and marketing services are activated only after your explicit consent under Section 25(1) TDDDG and Article 6(1)(a) GDPR. You can change or withdraw your choice at any time through “Cookie settings” at the bottom of the page.
5. Google Analytics
With your consent, we use Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Our measurement ID is G-8PW71WLT87. Google Analytics helps us understand how the campaign website is used, including page views, visit duration and traffic sources.
Data processed may include a shortened or otherwise processed IP address, device and browser information, approximate location, referrer, page views, interactions, and usage times and duration. Google may transfer data to affiliated companies and service providers, including in the United States. Retention, recipients and third-country safeguards are governed by the Google Analytics terms and our property settings.
Google Analytics loads only after you allow analytics. The legal basis is your consent under Article 6(1)(a) GDPR and Section 25(1) TDDDG. You may withdraw consent at any time with future effect through “Cookie settings”. On withdrawal, we attempt to remove Google Analytics cookies set by this website.
6. First-party audience measurement
In addition to Google Analytics, and only with your consent, we operate our own pseudonymous audience measurement within our website hosting. It records a randomly generated session identifier per browser tab, time, page and language version, visible page sections, selected interactions, referrer domain and UTM campaign parameters, device category, country code and active engagement time.
We do not store IP addresses, full user-agent strings, names, email addresses or form contents for this measurement. The session identifier is held in browser session storage under “fm-analytics-session-v1” and is removed when the tab closes. Measurement data is deleted automatically after 90 days. Processing starts only after you allow “Analytics”. The legal basis is Article 6(1)(a) GDPR and Section 25(1) TDDDG; consent can be withdrawn at any time through “Cookie settings”.
7. Contact enquiries
When you submit the contact form, we process your name, email address, company where provided, and message. The data is stored in a protected website-hosting database and used solely to handle and answer your enquiry.
If your enquiry concerns a contract or pre-contractual measures, the legal basis is Article 6(1)(b) GDPR. For other business enquiries, the legal basis is Article 6(1)(f) GDPR; our legitimate interest is handling communications and establishing business relationships.
Recipients may include the hosting, email and IT providers we use. Further disclosure occurs only where required to handle the enquiry, required by law or authorised by you. We delete enquiry data once its purpose has ended unless statutory retention or evidentiary duties apply.
8. Newsletter
When you subscribe to our newsletter, we process your email address, registration time, selected language and consent. We use the address solely to provide information about SustainProperty, the “When FM performs, Business performs.” campaign, publications and events.
We review and confirm the registration before adding it to the active distribution list. The legal basis is Article 6(1)(a) GDPR. You may withdraw consent at any time with future effect, for example by emailing connect@sustain-property.com. Processing before withdrawal remains lawful.
9. Non-binding pre-orders
For a non-binding pre-order, we process your name, email address, company and phone number where provided, street, house number, postcode and city, as well as shirt size, language version and quantity. We use this data to check the pre-order, availability, delivery time, shipping costs and next steps. Submission does not yet create a purchase contract.
To determine the city automatically, our server sends only the five-digit postcode you entered to the OpenPLZ API. Your name, email address, street and house number are not transmitted to OpenPLZ. The city added automatically remains editable.
The legal basis is Article 6(1)(b) GDPR. The data is stored in a protected website-hosting database accessible only through a protected internal inbox. If a pre-order is not pursued, we delete the data once no longer needed for review or queries. If a contract is concluded, statutory retention periods apply.
10. External links and social networks
This website contains ordinary links to external services, particularly LinkedIn, Instagram, and partner and event websites. A LinkedIn Insight Tag or other marketing tracker is not currently active.
Only when you open an external link does the respective provider process data under its own privacy policy. This may include your IP address, access time, browser information and the previously visited page.
11. No automated decision-making
We do not use automated decision-making, including profiling within the meaning of Article 22 GDPR, on this website.
12. Your rights
Where the statutory requirements are met, you have rights of access (Article 15 GDPR), rectification (Article 16), erasure (Article 17), restriction (Article 18), data portability (Article 20), and objection to processing based on Article 6(1)(e) or (f) GDPR (Article 21).
You may withdraw consent at any time with future effect (Article 7(3) GDPR). Processing before withdrawal remains lawful. To exercise your rights, email connect@sustain-property.com.
13. Right to lodge a complaint
You may lodge a complaint with a data protection supervisory authority. The authority responsible for our registered location is:
Independent State Centre for Data Protection Schleswig-Holstein (ULD)
Holstenstraße 98
24103 Kiel
Germany
Phone: +49 431 988-1200
Email: mail@datenschutzzentrum.de
www.datenschutzzentrum.de ↗
14. Security and updates
The website is transmitted over encrypted HTTPS. We take appropriate technical and organisational measures to protect personal data. This policy will be updated when services, processing operations or legal requirements change.