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Privacy Policy

Information on the processing of personal data in accordance with the GDPR and BDSG · Last updated: 30 May 2026

Short versionModerna Wohnbau uses a Hostinger hosting setup with the primary server location in Germany and backup storage in France. Contact and booking data is used to respond to enquiries, Google Analytics loads only after consent, and the protected admin area is limited to authorised team members.

Table of Contents

  1. Controller
  2. Data protection officer
  3. Legal bases and retention
  4. Hosting, EU server locations, and server log files
  5. Technically necessary storage
  6. Contact forms, readiness checks, and deal-sheet requests
  7. Email delivery
  8. GoHighLevel appointment booking
  9. Google Analytics
  10. External content and links
  11. Admin and client portal
  12. Your rights as a data subject
  13. Changes to this privacy policy

1. Controller

The controller within the meaning of the GDPR and other national data protection laws is:

Moderna Wohnbau
Einzelunternehmen Davide Miroballi
Stunzstraße 39
81677 Munich, Germany

Email: info@moderna-wohnbau.de
Phone: +49 151 56266640
Phone: +49 171 3813430

2. Data Protection Officer

Due to the company's current size, the appointment of a data protection officer is not mandatory under Section 38 BDSG. For privacy questions, contact us at info@moderna-wohnbau.de, +49 151 56266640, or +49 171 3813430.

3. Legal Bases and Retention

We process personal data only where this is necessary to provide the website, answer enquiries, prepare or perform a contract, comply with legal duties, protect legitimate interests, or where you have given consent.

  • Article 6(1)(a) GDPR: consent
  • Article 6(1)(b) GDPR: pre-contractual measures or contract performance
  • Article 6(1)(c) GDPR: legal obligations
  • Article 6(1)(f) GDPR: legitimate interests, including secure website operation and enquiry management

We delete or restrict personal data when the purpose no longer applies, unless statutory retention duties require longer storage. Business correspondence and accounting-relevant records may be retained for up to 6 or 10 years under German commercial and tax law.

4. Hosting, EU Server Locations, and Server Log Files

This website is hosted with Hostinger. Our current hosting configuration uses Germany as the primary server location. Backup storage for the website is configured in France. Both locations are within the European Union.

Hostinger acts as a processor for hosting, storage, technical delivery, security, and backup services. We have configured the hosting location to keep website hosting and backups in the EU as far as this is available within our Hostinger plan. Hostinger may still process limited technical or support data where this is necessary to provide, secure, maintain, or support the hosting service.

When you access the website, technical data may be processed in server log files, including IP address, date and time of access, requested URL, referrer URL, browser, operating system, transferred data volume, and access status.

The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is secure, stable, and efficient website operation, including backup and recovery. Log data is used for security, error analysis, and abuse prevention and is not combined with form submissions unless required to investigate misuse.

Further information: Hostinger Privacy Policy, Hostinger Data Processing Agreement, and Hostinger server locations

5. Technically Necessary Storage

The public website can generally be used without account cookies. The protected admin area uses a secure session cookie named MWBSESSID for login state and CSRF protection. This cookie is technically necessary and is deleted when the browser session ends.

The analytics consent banner stores your choice in your browser's local storage under mwb_analytics_consent. This is used only to remember whether Google Analytics may be loaded.

The on-site chat assistant is a local, rule-based website assistant. It runs in your browser, does not send your chat messages to an AI provider, and does not store chat history on our server. If you submit a readiness check through the assistant, the details you enter are sent to our lead API and processed as described below. If you use a link in the assistant to contact us, book a call, or open another service, the privacy information for that service applies.

6. Contact Forms, Readiness Checks, and Deal-Sheet Requests

When you use the contact form, submit a buying-readiness check, or request a deal sheet, we process the data you submit through our PHP lead API and store it in our website database.

Depending on the form, this may include:

  • Name
  • Email address
  • Telephone number, if provided
  • Topic, message, income range, employment status, residency status, savings range, buying timeline, source page, consent status, and time of submission
  • IP address, stored for security and consent documentation

The purpose is to answer your enquiry, send requested deal-sheet information, arrange a strategy call, and prepare a possible business relationship. Legal basis: Article 6(1)(b) GDPR and Article 6(1)(f) GDPR; where a consent checkbox is used, also Article 6(1)(a) GDPR.

For enquiry management, lead qualification, and follow-up, we may sync submitted lead data to GoHighLevel / LeadConnector as our CRM provider. This can include name, email address, telephone number, enquiry source, message content, readiness-check details, selected appointment details, and internal CRM tags. GoHighLevel may process data outside the EU and provides privacy and data processing terms for business customers.

Further information: GoHighLevel Privacy Policy

Lead and enquiry data is normally stored for up to 24 months after the last interaction unless a contract is concluded or statutory retention duties require longer storage.

7. Email Delivery

Contact form messages are also sent by server-side SMTP email to admin@moderna-wohnbau.de. SMTP credentials are stored outside the public web directory. The email contains the submitted contact data, message, lead ID, and IP address so our team can respond and investigate misuse if necessary.

Legal basis: Article 6(1)(b) GDPR and Article 6(1)(f) GDPR.

8. GoHighLevel Appointment Booking

We use an embedded GoHighLevel / LeadConnector calendar for online appointment booking. The calendar widget is loaded from GoHighLevel's LeadConnector booking domain when you open the booking popup. If you book an appointment, GoHighLevel may process your name, email address, telephone number, selected appointment time, IP address, technical browser data, and any information you enter in the booking form.

Our server may call the GoHighLevel calendar API to retrieve the number of available appointment slots. This availability check does not send your contact form data to GoHighLevel.

Completed appointments are stored directly in our GoHighLevel CRM calendar and may be linked to your CRM contact record so our team can prepare and follow up on the strategy call.

Legal basis for booking: Article 6(1)(b) GDPR and Article 6(1)(f) GDPR. GoHighLevel may process data outside the EU and provides privacy and data processing terms for business customers.

Further information: GoHighLevel Privacy Policy

9. Google Analytics

We use Google Analytics 4 to understand how visitors use public pages. Google Analytics is loaded only after you click "Accept" in the analytics consent banner. If you decline, Google Analytics is not loaded by our website.

Google Analytics may process page views, approximate location, device and browser data, referrer, interactions, and pseudonymous identifiers. According to Google, Google Analytics 4 does not log or store individual IP addresses.

Legal basis: Article 6(1)(a) GDPR and Section 25(1) TTDSG. You can change your choice by clearing the website data/local storage for this domain in your browser.

Further information: Google Analytics EU data and privacy and Google Privacy Policy

10. External Content and Links

The site loads fonts from Google Fonts and some images from Unsplash. When these resources load, your browser may transmit technical data such as your IP address and browser information to the respective provider. Legal basis: Article 6(1)(f) GDPR, our legitimate interest in a consistent and performant website presentation.

The site also links to WhatsApp, Facebook, Instagram, GoHighLevel / LeadConnector, and other external pages. These providers process data under their own responsibility when you click those links or use their services.

Further information: Google Privacy Policy, Unsplash Privacy Policy, and WhatsApp EEA Privacy Policy

11. Admin and Client Portal

The admin area and client portal are marked noindex and use database-backed accounts, password-protected access, session cookies, CSRF protection, role-based permissions, self-service and admin-issued password reset links, and audit logs. Authorised admins and managers can create client portal accounts, send create-password or password reset emails, assign agents, manage client folders, and manage document slots. Portal roles are client, agent, manager, and admin; managers can see all client folders and assign agents to cases.

If you receive portal access, we process account data, private recovery email addresses where needed, profile information, property-file assignments, uploaded documents, document status, download/open actions, notes, password reset metadata, and technical security data. Depending on the document, this may include identity, residency, income, employment, financing, notary, bank, insurance, handover, tenant, or property documents.

Files may be stored or linked through Google Drive, GoHighLevel / LeadConnector media, external HTTPS links, or a protected server upload area. Access is restricted so clients can only see their own assigned folders, assigned agents can see their cases, and managers or authorised administrators can manage the relevant documents. Legal basis: Article 6(1)(b) GDPR, Article 6(1)(f) GDPR, and where applicable statutory retention obligations.

12. Your Rights as a Data Subject

You have the following rights regarding your personal data:

  • Right of access (Art. 15 GDPR)
  • Right to rectification (Art. 16 GDPR)
  • Right to erasure ("right to be forgotten", Art. 17 GDPR)
  • Right to restriction of processing (Art. 18 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to object to processing (Art. 21 GDPR)
  • Right to withdraw consent with future effect (Art. 7(3) GDPR)

To exercise your rights, please contact info@moderna-wohnbau.de, +49 151 56266640, or +49 171 3813430.

Right to Lodge a Complaint with a Supervisory Authority. You have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your personal data.

Responsible authority:
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach, Germany

Telephone: +49 (0) 981 53 1300 · Website: https://www.lda.bayern.de

13. Changes to this Privacy Policy

We reserve the right to adapt this privacy policy so that it always complies with current legal requirements or to implement changes to our services in the privacy policy, for example when introducing new services. The new privacy policy will then apply to your next visit.

This privacy policy applies to all online presences and lead forms of Moderna Wohnbau.
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