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Privacy Policy

Last updated: August 2026

1. Introduction

Below we provide information about the processing of personal data in connection with the use of

  • our website https://www.governlens.com/
  • our social media profiles.

Personal data means any data that can be related to a specific natural person, for example their name or their IP address.

1.1 Contact details

The controller within the meaning of Art. 4(7) of the EU General Data Protection Regulation (GDPR) is GovernLens GmbH, Argelsrieder Straße 11, 81475 Munich, Germany, email: legal@governlens.com. We are legally represented by Leon Braun, Moritz von Raczeck.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, email: datenschutz@heydata.eu.

1.2 Scope of processing, purposes and legal bases

We set out the scope of the processing, the purposes and the legal bases in detail below. In principle, the following legal bases may apply to a processing operation:

  • Art. 6(1)(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent.
  • Art. 6(1)(1)(b) GDPR is the legal basis where the processing of personal data is necessary for the performance of a contract, for example where a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, for example in the case of enquiries about our products or services.
  • Art. 6(1)(1)(c) GDPR applies where we process personal data in order to comply with a legal obligation, as may be the case under tax law.
  • Art. 6(1)(1)(f) GDPR serves as the legal basis where we can rely on legitimate interests for the processing of personal data, for example for cookies that are necessary for the technical operation of our website.

1.3 Data processing outside the EEA

Where we transfer data to service providers or other third parties outside the EEA, adequacy decisions of the European Commission under Art. 45(3) GDPR guarantee the security of the data during the transfer, where such decisions exist, as is the case for the United Kingdom, Canada and Israel, for example.

For transfers of data to service providers in the USA, the legal basis for the transfer is an adequacy decision of the European Commission, provided that the service provider is additionally certified under the EU-US Data Privacy Framework.

In other cases (for example where no adequacy decision exists), the legal basis for the transfer is as a rule, that is unless we state otherwise, standard contractual clauses. These are a set of rules adopted by the European Commission and form part of the contract with the respective third party. Under Art. 46(2)(b) GDPR they ensure the security of the transfer. Many of the providers have given contractual guarantees going beyond the standard contractual clauses, which protect the data beyond those clauses. These include, for example, guarantees regarding the encryption of the data or regarding an obligation on the third party to notify data subjects where law enforcement authorities seek access to data.

1.4 Retention period

Unless expressly stated in this privacy policy, the data stored by us is deleted as soon as it is no longer required for its intended purpose and no statutory retention obligations prevent deletion. Where data is not deleted because it is required for other legally permissible purposes, its processing is restricted, that is the data is blocked and not processed for other purposes. This applies, for example, to data that we are required to retain for commercial or tax law reasons.

1.5 Rights of data subjects

Data subjects have the following rights against us with regard to the personal data concerning them:

  • right of access,
  • right to rectification or erasure,
  • right to restriction of processing,
  • right to object to processing,
  • right to data portability,
  • right to withdraw consent given at any time.

Data subjects also have the right to lodge a complaint with a data protection supervisory authority about the processing of their personal data. Contact details of the German data protection supervisory authorities are available at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

In the context of a business relationship or other relationship, customers, prospective customers or third parties only have to provide us with the personal data that is necessary for entering into, performing and terminating the business relationship or for the other relationship, or that we are required by law to collect. Without this data we will generally have to refuse to enter into a contract or to provide a service, or will no longer be able to perform an existing contract or other relationship.

Mandatory information is identified as such.

1.7 No automated individual decision-making

As a matter of principle, we do not use fully automated decision-making within the meaning of Article 22 GDPR to establish and perform a business relationship or other relationship. Should we use such procedures in individual cases, we will provide separate information about this where legally required.

1.8 Contacting us

When you contact us, for example by email or telephone, the data you provide (for example names and email addresses) is stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6(1)(1)(f) GDPR) in answering enquiries addressed to us. We delete the data arising in this context once its storage is no longer necessary, or restrict the processing where statutory retention obligations apply.

1.9 Customer surveys

From time to time we conduct customer surveys in order to get to know our customers and their wishes better. In doing so we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated processing is Art. 6(1)(1)(f) GDPR. We delete the data once the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time about our offers by email or by other means, unless they have objected. The legal basis for this processing is Art. 6(1)(1)(f) GDPR. Our legitimate interest lies in direct marketing (recital 47 GDPR). Customers may object to the use of their email address for advertising purposes at any time at no additional cost, for example via the link at the end of every email or by email to the email address stated above.

Prospective customers have the option of subscribing to a free newsletter. We process the data provided on registration exclusively for sending the newsletter. Registration takes place by selecting the relevant field on our website, by ticking the relevant box in a paper document or by another unambiguous action by which prospective customers declare their consent to the processing of their data, so that the legal basis is Art. 6(1)(1)(a) GDPR. Consent may be withdrawn at any time, for example by clicking the relevant link in the newsletter or by notifying the email address stated above. The processing of data up to the point of withdrawal remains lawful even in the event of withdrawal.

On the basis of recipients' consent (Art. 6(1)(1)(a) GDPR) we also measure the open and click rate of our newsletters in order to understand which content is relevant to our recipients.

  • We send newsletters using the Postmark tool provided by ActiveCampaign, LLC, 1 N Dearborn St., 5th Floor, Chicago, Illinois 60602, USA. In doing so the provider processes content data, usage data, meta/communication data and contact data in the USA. Further information is available in the provider's privacy policy at https://postmarkapp.com/privacy-policy.

2.1 Objection to advertising emails

We hereby object to the use of contact details published under our legal notice obligations for the purpose of sending advertising and information material that has not been expressly requested.

3. Data processing on our website

3.1 Notice for website visitors from Germany

Our website stores information on website visitors' terminal equipment (for example cookies) or accesses information already stored on the terminal equipment (for example IP addresses). Which information this is in detail can be found in the following sections.

This storage and this access take place on the basis of the following provisions:

  • Where this storage or access is strictly necessary in order for us to provide the service of our website expressly requested by website visitors (for example to operate a chatbot used by the website visitor or to ensure the IT security of our website), it takes place on the basis of § 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG).
  • Otherwise this storage or access takes place on the basis of the consent of website visitors (§ 25(1) TDDDG).

The subsequent data processing takes place in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2 Informational use of the website

When the website is used for information purposes only, that is when site visitors do not transmit information to us separately, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6(1)(1)(f) GDPR.

This data is:

  • IP address
  • date and time of the request
  • time zone difference from Greenwich Mean Time (GMT)
  • content of the request (specific page)
  • access status/HTTP status code
  • amount of data transferred in each case
  • website from which the request originates
  • browser
  • operating system and its interface
  • language and version of the browser software.

This data is also stored in log files. It is deleted once its storage is no longer necessary, at the latest after 14 days.

3.3 Web hosting and provision of the website

Our website is hosted by Vercel. The provider is Vercel Inc., 340 S Lemon Ave Unit 4133, Walnut, CA, USA. In doing so the provider processes the personal data transmitted via the website, for example content data, usage data, meta/communication data or contact data, in the USA. Further information can be found in the provider's privacy policy at https://vercel.com/legal/privacy-policy.

It is our legitimate interest to make a website available, so that the legal basis for the processing described is Art. 6(1)(1)(f) GDPR.

The legal basis for the transfer to a country outside the EEA is an adequacy decision. The security of the data transferred to the third country (that is a country outside the EEA) is ensured because the European Commission has decided, by way of an adequacy decision under Art. 45(3) GDPR, that the third country offers an adequate level of protection.

3.4 Contact form

When you contact us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in answering enquiries addressed to us. The legal basis for the processing is therefore Art. 6(1)(1)(f) GDPR. We delete the data arising in this context once its storage is no longer necessary, or restrict the processing where statutory retention obligations apply.

3.5 Job advertisements

We publish job advertisements on our website, on pages connected to the website or on third-party websites. The data provided in the course of an application is processed in order to carry out the application procedure. Where this data is necessary for our decision to enter into an employment relationship, the legal basis is Art. 88(1) GDPR in conjunction with § 26(1) of the German Federal Data Protection Act (BDSG). We have identified or indicated the data necessary to carry out the application procedure. If applicants do not provide this data, we cannot process the application. Further data is voluntary and not necessary for an application. If applicants provide further information, the basis is their consent (Art. 6(1)(1)(a) GDPR).

We ask applicants to refrain from including information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. Such information is not necessary for an application. If applicants nevertheless provide such information, we cannot prevent its processing as part of processing the CV or cover letter. Its processing is then also based on the applicants' consent (Art. 9(2)(a) GDPR).

Finally, we process applicants' data for further application procedures where they have given us their consent to do so. In this case the legal basis is Art. 6(1)(1)(a) GDPR.

We pass on applicants' data to the responsible members of the HR department, to our processors in the area of recruiting and to the other employees involved in the application procedure.

If we enter into an employment relationship with the applicant following the application procedure, we only delete the data after the end of the employment relationship. Otherwise we delete the data at the latest six months after an applicant has been rejected.

Where applicants have given us their consent to use their data for further application procedures as well, we only delete their data one year after receipt of the application.

3.6 Customer account

Website visitors can open a customer account on our website. We process the data requested in this context in order to perform the respective usage agreement concerning the account, so that the legal basis for the processing is Art. 6(1)(1)(b) GDPR.

3.7 Third-party providers

3.7.1 heyData

We have embedded a data protection seal on our website. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (for example IP addresses) in the EU.

The legal basis for the processing is Art. 6(1)(1)(f) GDPR. We have a legitimate interest in providing website visitors with confirmation of our data protection compliance. At the same time the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative for this confirmation.

The data is masked after collection so that it can no longer be related to a person. Further information is available in the provider's privacy policy at https://heydata.eu/datenschutzerklaerung.

4. Data processing on social media platforms

We have a presence on social media networks in order to present our organisation and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from users' online behaviour, which are used, for example, to display advertising matching users' interests on the networks' pages and elsewhere on the internet. To this end the network operators store information about usage behaviour in cookies on users' computers. It also cannot be ruled out that the operators combine this information with further data. Further information, as well as notes on how users can object to processing by the site operators, can be found in the privacy policies of the respective operators listed below. It may also be the case that the operators or their servers are located in non-EU countries, so that they process data there. This may give rise to risks for users, for example because the enforcement of their rights is made more difficult or because state authorities access the data.

Where users of the networks contact us via our profiles, we process the data provided to us in order to answer the enquiries. This is our legitimate interest, so that the legal basis is Art. 6(1)(1)(f) GDPR.

4.1 YouTube

We maintain a profile on YouTube. The operator is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=en.

4.2 LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy. An option to object to the data processing is available via the advertising settings: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to amend this privacy policy with effect for the future. A current version is available here at all times.

6. Questions and comments

For questions or comments regarding this privacy policy, please feel free to contact us using the contact details provided above.

This English text is a translation for convenience. In the event of discrepancies, the German version of this privacy policy prevails.