Privacy
Privacy notice
This notice explains how Circlepass processes personal data submitted through the optional readiness follow-up request.
Who is responsible
Circlepass is operated by Marco Curado Both, established in Germany. Contact privacy@circlepass.eu with privacy questions or requests.
What we collect and why
The public readiness check calculates and displays a directional report in your browser without requiring contact details. If you separately request a discussion, we receive your name, work email, company, optional role and phone number, sector, product type, readiness category, website language, and request date/reference with schema/rules versions. We do not receive your detailed readiness answers, product-line free text or generated report through this form. We also receive limited source information, such as the public landing route and referring hostname; no campaign parameters are currently allowlisted. Intake services also handle technical request information, including IP address and browser information, for delivery, security and spam prevention. We use the submission to respond to your enquiry and manage relevant follow-up, not to deliver or unlock the on-page report. Provide a phone number only if you would like a callback about this request. Do not submit sensitive personal data or confidential product evidence through this form.
Legal basis
We use Article 6(1)(f) GDPR for business representatives' requested discussions, relevant enquiry records and proportionate delivery/security measures. Our legitimate interests are responding to requests, maintaining the information needed for that follow-up and protecting the intake service. Where you would personally be party to a prospective contract, processing necessary to take pre-contractual steps at your request instead uses Article 6(1)(b). Reading or acknowledging this notice is not consent to unrelated processing or marketing.
Services used and international processing
Marco handles the request using Formward (EGF Fastighetsservice AB, Sweden) for intake and notification delivery, Zoho Mail for notification emails, follow-up correspondence and our privacy-contact mailbox, and Notion for necessary CRM records in manually maintained tables. Formward acts as our processor and publishes EU intake hosting and EU notification-delivery subprocessors. Our Zoho account uses its EU region and a signed data processing agreement; Zoho describes possible support access outside the EEA. Notion may process information outside the EEA, including in the United States. Notion publishes reliance on standard contractual clauses, and Zoho describes standard contractual clauses for relevant international transfers. These arrangements do not mean all processing stays in the EU. See Notion's GDPR information and Zoho's privacy FAQ, or contact privacy@circlepass.eu for applicable safeguard information or copies, subject to necessary redactions.
Retention
We keep information while it remains necessary to handle your request or an active commercial relationship. We review inactive records annually and delete or genuinely anonymise information with no continuing purpose, except where justified legal retention applies. Provider backups may retain residual copies through their normal protected rotation/deletion processes; deletion from the operational inbox is not a promise that every provider copy disappears immediately.
Choices and rights
You can view the on-page report without submitting contact details or requesting a discussion. Name, work email and company are required to submit this optional request; role and phone are optional. Without the required information we cannot handle the request through this form, but your report remains available. Request acceptance does not mean a conversation is booked or a response has already been sent. Under applicable conditions, you may request access, correction, erasure, restriction and portability, and object to processing based on legitimate interests on grounds relating to your particular situation. You may complain to a competent supervisory authority, including in the EU country of your habitual residence, workplace or an alleged infringement. Contact privacy@circlepass.eu. Requesting follow-up does not subscribe you to marketing updates. The tool does not make an automated decision producing legal or similarly significant effects about you; its report is directional, not a compliance guarantee or final legal determination.
Website analytics
Circlepass is operated personally by Marco Curado Both, established in Germany. Privacy questions and requests: privacy@circlepass.eu.
We use Umami Cloud for aggregate traffic and acquisition, public-page and CTA engagement, and the readiness/report journey, with Umami Software, Inc. as processor for Circlepass analytics on our behalf. Umami may separately act as controller for service administration, security, fraud prevention and its own legal obligations. Optional analytics uses your consent under Article 6(1)(a) GDPR and Section 25(1) TDDDG. Refusing has no effect on site use. Withdraw at any time in Analytics settings to stop future measurements; withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Measurements include only known public paths, language, approved coarse campaign/referrer information and predefined events. They exclude personal contact and form content, readiness answers/results, reports, lead/submission IDs, raw page titles, arbitrary URL parameters and fragments.
Script and measurement requests nevertheless expose IP address and browser metadata to the provider. Umami derives sessions, approximate location and device/browser statistics. According to Umami, raw IP addresses are not stored in its analytics dataset; this does not cover all operational or security logs.
We store only a versioned allow/deny preference in first-party local storage, without a visitor ID. Missing or invalid choices keep analytics off. Do Not Track is an additional veto. No analytics cookies, advertising, session replay, heatmaps or persistent identity stitching are enabled.
Provider: Umami Software, Inc., via Umami Cloud Hobby/free. The account has the EU region selected, sole-founder access and six-month analytics retention. This period does not necessarily cover provider logs, backups or account records; the selected region is not a guarantee of EU-only processing.
For applicable rights, including access, correction, erasure, restriction of processing, withdrawal of consent and, where applicable, data portability, contact privacy@circlepass.eu. You may complain to a competent data-protection authority. We do not create extra visitor identifiers solely to match analytics records to a person. Analytics is separate from readiness/report submissions and optional marketing, which retain their own notices and controls.