As of: June 2026
This is a courtesy English translation. In case of discrepancies, the German version shall prevail.
1. Controller
The controller for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is:
Klarnode GmbH, Kolonnenstr. 8, 10827 Berlin, Germany. Email: hello@klarnode.de.
A Data Protection Officer has not been appointed as the legal requirements (Art. 37 GDPR, § 38 BDSG) are not met.
2. General information on data processing
We process personal data of our users only insofar as this is necessary to provide a functional website as well as our content and services. Processing generally takes place only with the user's consent or where a legal basis permits the processing.
3. Server log files
When you access our website, the hosting provider automatically collects information in so-called server log files: browser type and version, operating system used, referrer URL, host name of the accessing computer, time of the server request and IP address. This data is not merged with other data sources and is generally deleted after 14 days. The legal basis is Art. 6 (1) (f) GDPR; our legitimate interest lies in the secure and stable operation of the website.
4. Hosting — Cloudflare Pages
Our website is hosted by Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA (service: Cloudflare Pages). Cloudflare operates a global content delivery network (CDN) and processes your IP address to deliver content and protect the website from attacks. Cloudflare may set technically necessary cookies for this purpose (e.g. __cf_bm).
Data transfers to the USA are based on EU Standard Contractual Clauses (Art. 46 (2) (c) GDPR) and the EU-US Data Privacy Framework (adequacy decision pursuant to Art. 45 GDPR). The legal basis for processing is Art. 6 (1) (f) GDPR.
Cloudflare privacy policy: https://www.cloudflare.com/privacypolicy/
5. Contact & forms
If you contact us by email or via a contact form, the data you provide (e.g. name, email address, company, content of the request) will be stored to process your enquiry. The same applies to application forms (careers) and the referral form (referral portal).
Data is stored in a Cloudflare D1 database and any uploaded files (e.g. CVs) in Cloudflare R2 (S3-compatible object storage). Both services are operated by Cloudflare; the safeguards described in section 4 apply.
The legal basis is Art. 6 (1) (b) GDPR (pre-contractual or contractual measures) or Art. 6 (1) (f) GDPR (legitimate interest in efficiently processing enquiries). Data will be deleted once it is no longer required for the purpose, provided no statutory retention obligations apply.
5a. Newsletter
When you subscribe to our newsletter, we process your email address and language preference for the purpose of sending regular newsletters. Registration uses a double opt-in process: after entering your email address, you will receive a confirmation email. Your subscription only becomes active after clicking the confirmation link.
The legal basis is Art. 6 (1) (a) GDPR (consent). You can withdraw your consent at any time with effect for the future by using the unsubscribe link in every newsletter email or by contacting us at hello@klarnode.de.
Your data is stored until you unsubscribe and will be deleted immediately thereafter.
6. Email — Resend
For sending transactional emails (e.g. confirmations after contact form submission, referral confirmations, newsletters), we use the service Resend (Resend, Inc., USA). Your email address and the email content are transmitted to Resend. Processing takes place in the EU region.
The legal basis is Art. 6 (1) (f) GDPR (legitimate interest in reliable email delivery). Data transfers are based on EU Standard Contractual Clauses.
Resend privacy policy: https://resend.com/legal/privacy-policy
7. CAPTCHA — Cloudflare Turnstile
To protect our forms from automated access (spam/bots), we use Cloudflare Turnstile. A token is generated to verify your interaction with the form. Cloudflare processes your IP address and browser metadata for this purpose. No visible puzzles (CAPTCHAs) are displayed.
The legal basis is Art. 6 (1) (f) GDPR (legitimate interest in protection against abuse). The safeguards described in section 4 apply.
8. Web fonts (self-hosted)
We use the fonts IBM Plex Sans and IBM Plex Mono. These are hosted locally on our server and are not loaded from external servers (such as Google Fonts). No data is transmitted to third parties when loading fonts.
9. Google Tag Manager & web analytics
We use Google Tag Manager (Google LLC, USA) to manage analytics and marketing tags on our website. The Tag Manager itself does not store cookies and does not collect personal data. It merely triggers other tags that may collect data.
Via the Tag Manager, we integrate Google Analytics 4, which collects usage data (e.g. pages viewed, time on site, device type, approximate location). Google Analytics uses cookies (see our Cookie Policy). IP anonymisation is enabled by default.
The legal basis is Art. 6 (1) (a) GDPR (consent). Analytics cookies are only set after you give your consent via our cookie banner. You can withdraw your consent at any time with effect for the future.
Data transfers to the USA are based on the EU-US Data Privacy Framework.
Google privacy policy: https://policies.google.com/privacy. Opt-out: https://tools.google.com/dlpage/gaoptout
10. Cookies
Our website uses technically necessary cookies required for the operation of the site (legal basis: § 25 (2) TDDDG). In addition, we use analytics cookies only with your express consent (§ 25 (1) TDDDG, Art. 6 (1) (a) GDPR), which you can withdraw at any time with effect for the future.
A detailed list of all cookies can be found in our Cookie Policy.
11. Processing & nearshore delivery partner
To deliver our services, we work with independent nearshore delivery partners. Where personal data is processed on our behalf in this context, this is done exclusively on the basis of data processing agreements (DPA) pursuant to Art. 28 GDPR and in compliance with EU-compliant data protection standards. Klarnode remains the responsible party towards you.
12. Recipients & third-country transfers
Your data is transferred to recipients only insofar as this is legally permitted or required. The following categories of recipients may receive data:
Cloudflare, Inc. (hosting, CDN, Turnstile, D1, R2) — USA — safeguard: EU Standard Contractual Clauses + EU-US Data Privacy Framework.
Google LLC (Tag Manager, Analytics) — USA — safeguard: EU-US Data Privacy Framework.
Resend, Inc. (email delivery) — USA — safeguard: EU Standard Contractual Clauses.
Anthropic, PBC (AI-assisted document analysis for applicant management) — USA — safeguard: Data Processing Agreement + EU Standard Contractual Clauses.
13. Retention period
We store personal data only for as long as necessary to achieve the respective purposes. Specifically:
Contact enquiries: until the matter is resolved, then deleted unless statutory retention obligations apply.
Applications: 6 months after completion of the application process.
Referrals: 12-month protection period, then deleted unless a reward claim exists.
Newsletter subscribers: until unsubscription, followed by immediate deletion.
Server log files: 14 days.
Commercial and tax law retention obligations: up to 10 years (§ 147 AO, § 257 HGB).
14. Automated decision-making
Automated decision-making including profiling pursuant to Art. 22 GDPR does not take place.
15. Your rights
You have the right at any time to access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21). You can withdraw any consent given at any time with effect for the future. A message to hello@klarnode.de is sufficient to exercise these rights.
Right to object (Art. 21 GDPR): Where we process your personal data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you have the right to object at any time. We will then no longer process the personal data unless there are compelling legitimate grounds. Contact hello@klarnode.de to exercise this right.
16. Right to lodge a complaint
Without prejudice to any other remedy, you have the right to lodge a complaint with a data protection supervisory authority, in particular the Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin (https://www.datenschutz-berlin.de).