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Privacy Policy

Last updated: September 25, 2026

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

CircularTree GmbH

Fehrbelliner Str. 50, 10119 Berlin, Germany

Phone: +49 30 91528404

Email: info@circulartree.com

Data Protection Lead: Gunther Walden, reachable at info@circulartree.com.

2. General information on data processing

This privacy policy informs you about the nature, scope and purpose of the processing of personal data on our website. We process personal data only where necessary to provide a functional website and our content and services, or where you have given consent. The legal bases are in particular Art. 6(1)(a) GDPR (consent), (b) (performance of a contract), (c) (legal obligation) and (f) (legitimate interest).

3. Hosting

Our website is hosted by UAB “Hostinger” (Švitrigailos g. 34, 03230 Vilnius, Lithuania). Hostinger processes, on our behalf, the data required to operate and deliver the website. The legal basis is our legitimate interest in the secure and efficient provision of our website (Art. 6(1)(f) GDPR). A data processing agreement (DPA) pursuant to Art. 28 GDPR is in place with the provider.

For acceleration and caching we also use QUIC.cloud, which temporarily stores content in a cache. Further information: https://quic.cloud/privacy-policy/

4. Provision of the website and server log files

Each time our website is accessed, our system automatically collects data from the accessing device (e.g. IP address, date and time of access, page accessed, volume of data transferred, browser type and operating system). The legal basis is our legitimate interest in the technical provision and security of the website (Art. 6(1)(f) GDPR). This data is deleted after a short period unless required to investigate security incidents.

5. Cookies and consent management (WPConsent)

Our website uses cookies and comparable technologies. Technically necessary cookies are used on the basis of Art. 6(1)(f) GDPR and § 25(2) TDDDG. All non-essential cookies – in particular for analytics, statistics and marketing – are only set after you have given express consent via our cookie consent banner (Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG).

To manage your consent we use the consent management solution WPConsent. Your consent choice is stored in a cookie   so that your selection can be taken into account on future visits. You can change or withdraw your consent at any time with effect for the future via the settings of the consent banner. A detailed list of the cookies we use can be found in our Cookie Policy. Further information about the provider: https://wpconsent.com/

6. Web analytics: Google Analytics 4 (via Google Tag Manager)

Where you have given consent, we use Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. It is integrated via Google Tag Manager. Google Analytics uses cookies and similar technologies to evaluate the use of our website (e.g. browser type/version, operating system, referrer URL, time of access). In Google Analytics 4, IP addresses are anonymised by default and are not stored permanently.

The legal basis is solely your consent pursuant to Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG. A data processing agreement is in place with Google. Data may be transferred to Google servers in the USA; such transfers are based on the EU Standard Contractual Clauses and supplementary safeguards. Collected data is automatically deleted in Google Analytics 4 according to the retention settings (event data after 2 months, user data after 14 months).

You can withdraw your consent at any time via our consent banner. Further information: https://policies.google.com/privacy

7. Web analytics: Matomo (Matomo Cloud)

Where you have given consent, we also use Matomo, a web analytics service provided by InnoCraft Ltd. (150 Willis Street, 6011 Wellington, New Zealand), in its “Matomo Cloud” edition. Data of European customers is hosted in the EU (Germany). Matomo uses cookies (e.g. “_pk_id”, “_pk_ses”) to evaluate the use of our website. The legal basis is solely your consent pursuant to Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG. A data processing agreement is in place with the provider. New Zealand benefits from an EU Commission adequacy decision, ensuring an adequate level of data protection. You can withdraw your consent at any time via our consent banner. Further information: https://matomo.org/privacy-policy/

8. HubSpot (newsletter, forms, contact management)

For our newsletter, some of our forms and our contact management we use HubSpot, a service provided by HubSpot, Inc. (2 Canal Park, Cambridge, MA 02141, USA). HubSpot processes the data you provide in forms or when subscribing to the newsletter (e.g. name, email address) as well as technical usage data.

Where HubSpot sets cookies or comparable tracking technologies, this only occurs after your consent via our consent banner (Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG). The processing of data to handle your enquiry or to initiate a contract is based on Art. 6(1)(b) or (f) GDPR.

A data processing agreement pursuant to Art. 28 GDPR is in place with HubSpot. As HubSpot also processes data in the USA, any third-country transfer is based on the EU Standard Contractual Clauses and supplementary safeguards. Further information: https://legal.hubspot.com/privacy-policy

9. Contact forms (Forminator)

Some of our forms are built with the WordPress plugin Forminator (WPMU DEV / Incsub, LLC). The data you enter into the form is processed to handle your enquiry and stored in our WordPress database on our server (see section 3). The legal basis is Art. 6(1)(b) or (f) GDPR. The data is deleted once it is no longer required to achieve the purpose, provided no statutory retention obligations apply.

10. Newsletter

When you subscribe to our newsletter, we process the data you provide (in particular your email address) to send the newsletter. Subscription uses the double opt-in procedure: after signing up you receive a confirmation email with which you confirm your subscription. The legal basis is your consent (Art. 6(1)(a) GDPR).

You can unsubscribe at any time and withdraw your consent with effect for the future, e.g. via the unsubscribe link in every newsletter email. Technical distribution is handled via HubSpot (see section 8).

11. Live chat (Tidio)

We use the live chat service Tidio on our website (provider: Tidio; further details on the provider and contracting structure are available in Tidio’s privacy policy). When you use the chat, the data you enter and technical usage data are processed to answer your enquiry. Tidio sets cookies or comparable technologies for this purpose, which are only loaded after your consent via our consent banner (Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG); handling your enquiry is based on Art. 6(1)(b) or (f) GDPR. A data processing agreement is in place with the provider. Where personal data is transferred to a third country outside the EU/EEA, this is based on appropriate safeguards, in particular the EU Standard Contractual Clauses. Further information: https://www.tidio.com/privacy-policy/

12. YouTube videos

We embed videos from YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). The YouTube content is only loaded after you have given consent via our consent banner (Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG). When playing a video, YouTube may set cookies and transfer data – including to the USA; this is based on the EU Standard Contractual Clauses. Further information: https://policies.google.com/privacy

13. Fonts (Google Fonts – self-hosted)

To display fonts consistently we use Google Fonts, which we have integrated locally on our server (self-hosting). No data is transmitted to Google when the fonts are delivered; in particular, your IP address is not passed on to Google.

14. Our presence on social networks

We maintain a profile on LinkedIn to communicate with users and provide information about our services. Responsibility for the data processing there lies with the respective platform operator alongside us; in part this constitutes joint controllership (Art. 26 GDPR). We point out that your data may also be processed outside the EU/EEA. The legal basis is our legitimate interest in an effective public presence (Art. 6(1)(f) GDPR) or, where required, the consent you have given to the platform operator (Art. 6(1)(a) GDPR).

15. Social media share button (LinkedIn / “Shariff”)

Our website allows you to share content via LinkedIn. To protect your data we use the “Shariff” solution: the share button is embedded as a static image containing only a link to LinkedIn. Data (e.g. your IP address) is only transmitted to LinkedIn once you actively click the button. If you do not click it, no data is transferred.

16. Your rights under the GDPR

If we process your personal data, you have the following rights under the General Data Protection Regulation (GDPR), subject to the applicable legal requirements:

  • Right of access (Art. 15 GDPR): You have the right to obtain information about whether and how we process your personal data and to receive a copy of such data.
  • Right to rectification (Art. 16 GDPR): You have the right to request the correction of inaccurate or incomplete personal data.
  • Right to erasure (Art. 17 GDPR): You have the right to request the deletion of your personal data where the applicable legal requirements are met.
  • Right to restriction of processing (Art. 18 GDPR): You may request that the processing of your personal data be restricted under certain circumstances.
  • Right to data portability (Art. 20 GDPR): Where applicable, you have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format and to transmit that data to another controller.
  • Right to object (Art. 21 GDPR): Where we process your personal data on the basis of our legitimate interests, you have the right to object to such processing on grounds relating to your particular situation. You may object to the processing of your personal data for direct marketing purposes at any time.
  • Right to withdraw consent: Where processing is based on your consent, you may withdraw your consent at any time with effect for the future. The lawfulness of processing carried out before the withdrawal remains unaffected.
  • Right to lodge a complaint (Art. 77 GDPR): You have the right to lodge a complaint with a competent data protection supervisory authority if you believe that the processing of your personal data infringes applicable data protection law. The authority competent for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit).

To exercise any of these rights, please contact us using the contact details provided in this Privacy Policy.

17. Data security

We take appropriate technical and organisational measures to protect your data. Please note that data transmission over the internet (e.g. by email) may have security gaps; complete protection against access by third parties is not possible.

18. Validity and changes

This privacy policy is currently valid. As our website develops or legal requirements change, it may become necessary to amend it.

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