Legal

Privacy Policy

Last updated · 30 June 2026

1. Who is responsible (Controller)

The controller responsible for data processing on this website within the meaning of the EU General Data Protection Regulation (GDPR) is:

Nikolay Gladkov
Oettingenstraße 40
80538 München
Germany

Email: hello@cairncircle.com

We have not appointed a Data Protection Officer, as we are not legally required to do so.

2. Scope of this policy

This policy applies only to this marketing website, cairncircle.com (the public, information-only site). It does not cover the Cairncircle platform/application or any account-based services — those are provided under, and governed by, a separate Privacy Policy and Terms of Service made available within the platform itself.

3. What we process, and why

This website is a static, information-only site. We do not use cookies, analytics, tracking pixels, advertising, or social-media plugins, and we do not ask you to fill in any form. Fonts are self-hosted; the site makes no requests to third-party content networks. The only personal data we process is the following.

3.1 Server log files (hosting / delivery)

When you visit the site, our hosting provider automatically records technical access data needed to deliver the page and keep it secure:

• your IP address,
• date and time of the request,
• the page/file requested,
• referrer URL (if sent by your browser),
• browser type and operating system (user agent).

Purpose: delivering the website, ensuring stability and security, and defending against attacks.
Legal basis: Art. 6 (1) (f) GDPR (our legitimate interest in a secure, functioning website).
Retention: these logs are processed by our hosting provider for a limited period for security purposes and are then deleted or anonymised.

3.2 Contacting us by email

If you email us (e.g. via the “Request access” link to hello@cairncircle.com), we process your email address and the content of your message in order to respond.

Purpose: handling your enquiry and any related correspondence.
Legal basis: Art. 6 (1) (b) GDPR (steps prior to a possible contract, at your request) and/or Art. 6 (1) (f) GDPR (our legitimate interest in answering enquiries).
Retention: we keep your message for as long as needed to handle your request and, where applicable, to comply with statutory retention periods, after which it is deleted.

3.3 Email-address protection script

To protect the contact address shown on the site from automated spam harvesting, our hosting provider (Cloudflare) injects a small client-side script that decodes the email address in your browser. This runs locally in your browser and is not used to track you.

4. Hosting and recipients (Processors)

The website is hosted on Cloudflare Pages, provided by Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA). Cloudflare acts as our processor under Art. 28 GDPR (hosting, content delivery, TLS encryption, and protection against attacks) on the basis of a data processing agreement.

We do not otherwise sell or share your personal data. Disclosure to third parties only takes place where we are legally obliged to do so.

5. International data transfers

Processing by Cloudflare may involve transfers of personal data to the United States. Such transfers are safeguarded by the EU Standard Contractual Clauses (Art. 46 GDPR) and/or Cloudflare’s certification under the EU–US Data Privacy Framework, together with supplementary technical measures.

6. Your rights

Under the GDPR you have the right to:

• access your personal data (Art. 15),
• rectification of inaccurate data (Art. 16),
• erasure (Art. 17),
• restriction of processing (Art. 18),
• data portability (Art. 20),
• object to processing based on legitimate interests (Art. 21).

Where processing is based on consent, you may withdraw that consent at any time with effect for the future.

To exercise any of these rights, contact us at hello@cairncircle.com.

You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The authority responsible for us is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18, 91522 Ansbach, Germany
www.lda.bayern.de

7. Data security

We use TLS/HTTPS encryption for all traffic to and from this website to protect data in transit.

8. Children

This website is not directed at children, and we do not knowingly process the personal data of children.

9. No automated decision-making

We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.

10. Changes to this policy

We may update this policy to reflect changes in our practices or legal requirements. The current version is always available on this page, with the “Last updated” date above.

11. Contact

For any privacy-related question: hello@cairncircle.com