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Privacy Policy

How we handle personal data Clear, transparent and GDPR-compliant

This page explains which data we process, why we process it, which providers are involved, how long we retain this data, and what your rights are under the GDPR.

Last updated: 2026-07-31
Plain language: We do not sell personal data. We only process data to provide services, maintain secure systems, and comply with legal obligations.

1. Controller Information

Stepien Digital is a company established in Germany and acts as the data controller within the meaning of the General Data Protection Regulation (GDPR).

Controller
Fernando Stepien
VAT ID (USt-IdNr.): DE454302821
Address: Hauptstraße 23, 76549 Hügelsheim, Germany.

2. Scope of this Privacy Policy

This Privacy Policy explains how personal data is collected, used, stored, shared, and protected when you visit Stepien Digital's websites, contact us, or use any of our services.

This policy applies to visitors, prospective clients, business clients, partners, production participants, and others connected to our services including websites, Google Business Profile, photography, videography, digital content, aerial photography and videography, Step Inside immersive experiences, review management, and digital presence.

3. Data We Process

We may process the following categories of personal data, depending on the interaction and scope of the service.

Business contact data
Names, company name, position, business address, and other contact information shared in a business context.
Email addresses and phone numbers
Used to respond to inquiries, coordinate onboarding, and provide support.
Client-provided content
Texts, photographs, videos, logos, and business information provided for website creation, digital presence management, and related services.
Technical usage data
Device information, browser type, basic usage telemetry, and server logs necessary to operate and protect services.
Billing information
Payment information processed through Stripe and billing information required for invoicing, accounting and tax purposes.
Communication data
Messages and attachments you send us, as well as related metadata such as timestamps and subjects.
Photographs, video, and audio recordings
Images, footage, and audio captured during production services, including 360° panoramas, Step Inside immersive content, and aerial photography and videography.
Google Business Profile data
Business information, photographs, responses to reviews, and other content managed on behalf of clients through Google Business Profile.
Review and feedback data
Customer reviews, ratings, feedback, and responses collected and managed through our review management services.
Production participant data
Names, likeness, and appearance of individuals who participate in photography, video, or drone productions, where applicable.
We do not intentionally collect special categories of personal data, unless you expressly provide them and the processing is necessary for a legitimate purpose permitted by law.

4. Purpose of Processing

We process personal data to deliver and administer our services, develop and maintain websites, configure and manage business profiles, produce photographs and videos, provide aerial photography and videography using drones where legally permitted, create Step Inside immersive experiences, support review management and digital presence, communicate with clients, maintain secure systems, process billing, and comply with legal obligations.

Service provision
Planning, creation, operation, and maintenance of websites, Google Business Profile, photography, videography, digital content, aerial photography and videography, Step Inside experiences, review management, and related infrastructure.
Security
Prevention of abuse, service protection, and monitoring of availability and performance.

Depending on the situation, processing may be based on contract performance or pre-contractual measures, compliance with legal obligations, legitimate interests of Stepien Digital or third parties, and, where required, the data subject's consent. When consent is required, we will request it clearly, specifically, and in a manner that can be withdrawn at any time.

5. Hosting and Infrastructure

Websites and databases are hosted on SmarterASP.NET. DNS and security services are managed through Cloudflare. Media and static assets may be stored and delivered via Cloudflare R2.

SmarterASP.NET Hosting
Hosts the application runtime, databases, and operational logs necessary for stability and security.
Cloudflare DNS and Security
Provides DNS management, security features, and protection layers to reduce malicious traffic and abuse.
Cloudflare R2 Storage
Stores and delivers media and assets that improve performance and reliability.
Private backups
Private repositories may be used for version control and disaster recovery when necessary for a specific project.
Infrastructure choices focus on availability, security, and consistent delivery for clients and visitors.

6. Third-Party Services

We use third-party services only when necessary to provide services, execute infrastructure, process payments, improve security, or support operations.

Stripe
Payment processing and billing flows. Stripe processes payment-related data as an independent controller or processor, depending on the context.
Cloudflare
DNS, security features, and static asset delivery. Cloudflare may process technical connection data to provide security and performance.
SmarterASP.NET
Application and database hosting, including the technical logs necessary to operate services securely.
GitHub
Private repositories and backups used for version control and disaster recovery, when applicable.
Cloudflare Web Analytics (instead of Google Analytics)
We use Cloudflare Web Analytics instead of Google Analytics to understand aggregate website usage and improve performance. This solution is designed to work without marketing cookies and does not rely on identifiers stored in the browser, such as cookies or localStorage. Limited technical data, such as IP address, user agent, referrer, and page events, may be processed in an aggregated, privacy-oriented manner without cross-site tracking.

When relying on providers, we seek to use appropriate contractual protections and technical safeguards.

7. Cookies and Technical Data

Our websites process technical data necessary to display pages, protect services, prevent abuse, and measure aggregate usage. This may include server logs, IP addresses, request metadata, and security or analytics signals. We use Cloudflare Web Analytics instead of Google Analytics and avoid marketing or behavioral tracking technologies on this site.

Essential cookies
Cookies necessary for core website functionality may be used, such as session management and security protection.
Security logs
Logs may include timestamps, request paths, and technical identifiers used to detect and block malicious traffic.
This Stepien Digital website uses Cloudflare Web Analytics instead of Google Analytics. The tool is designed to operate without marketing cookies or cross-site tracking. Additional protection measures are used to keep the website secure.

8. Communications

When you contact us, we process the provided data to respond, document the request, and support service delivery.

Communication data may include message content, attachments, and technical metadata. We retain communication data for as long as necessary to handle the request and comply with legal obligations.

9. Billing and Payments

Billing information may be processed for invoicing, ongoing service management, and maintaining accounting records. Payments may be processed through Stripe.

We do not store complete card details in our systems. Payment card data is handled by Stripe according to its security standards.

10. Data Retention

We retain personal data only for as long as necessary for the stated purposes and to comply with legal retention obligations.

Contract and billing records
Retained in accordance with legal accounting and tax obligations in Germany.
Support and communication
Retained for a reasonable period to resolve requests and maintain service continuity.
Security logs
Retained for security monitoring, incident response, and abuse prevention, then deleted or anonymized when no longer needed.
Production materials
Photographs, videos, and other production materials are retained for as long as necessary to fulfill the contracted purpose and for portfolio use, unless confidentiality is requested by the client.

11. International Transfers

Depending on the service providers we use, personal data may be transferred to or processed outside the European Economic Area (EEA). Where such transfers occur, we rely on appropriate safeguards in accordance with the GDPR.

12. Data Subject Rights

Data subjects have the right to access, rectification, erasure, restriction of processing, objection, and data portability under the GDPR.

How to exercise rights
Send a request to the email address listed in the Contact section. [email protected]We will review and respond to your request in accordance with applicable legal deadlines and requirements.
Identity verification
We may request verification to protect your data from unauthorized access.
You may also have the right to lodge a complaint with a supervisory authority.

13. Security Measures

Stepien Digital uses encryption during data transmission, firewall protections, access controls, and monitoring mechanisms to protect personal data.

Encryption
TLS encryption is used for data in transit whenever supported and applicable.
Access controls
Access to administrative systems is limited based on need-to-know and the principle of least privilege.
Monitoring
Monitoring and alerts to detect incidents, downtime, and suspicious activity.

14. Limitation of Liability

Stepien Digital is not liable for misuse of its services, unlawful content provided by clients, or actions taken by third-party platforms.

Clients remain responsible for the legality of the content they provide and the compliance obligations that apply to their specific business activities.

15. Updates to this Policy

This Privacy Policy may be updated to reflect legal or technical changes. The current version is published on the website.

16. Contact

If you have any questions about this Privacy Policy, please contact us through the channels provided below.

17. Photography and Video

Stepien Digital provides photography and video production services whenever they are part of the agreed scope of work. This section explains the conditions that apply to these services.

Joint Planning
All production planning is done in collaboration with the client, ensuring alignment of expectations and objectives.
Client Responsibility
The client is responsible for ensuring they have authorization for people, locations, brands, or property to be photographed or filmed when necessary.
Internal Restrictions
If there are internal restrictions (e.g., patients, employees, minors, or restricted areas), the client must inform us in advance.
Authorizations
Stepien Digital is not responsible for images captured in locations or situations where the client did not obtain the necessary authorizations.
Clients are responsible for ensuring that all required permissions and authorizations have been obtained before production begins.

18. Material Usage Rights

This section defines the usage rights for material produced by Stepien Digital.

Usage License
The client receives a license to use the produced material for the contracted purposes.
Copyright
Copyright in photographs and videos remains with Stepien Digital unless otherwise agreed in writing.
Resale Prohibition
The client may not resell, sublicense, or commercialize this material as if it were their own production or that of third parties.
These provisions protect Stepien Digital's intellectual property rights.

19. Portfolio Use

Unless otherwise agreed in writing, Stepien Digital may use completed projects, photographs and videos in its portfolio, on its website and in other marketing materials.

The default rule is that Stepien Digital may showcase its work, but respects those who request confidentiality.

20. Drone Photography and Videography

Stepien Digital provides drone photography and videography services in compliance with all applicable laws and regulations.

Legal Compliance
Whenever drone operations are carried out, the operation will be performed in compliance with applicable legislation.
Restriction Verification
All flight restrictions will be verified in advance.
Legal and Safety Conditions
The operation will only be carried out when legal and safety conditions are met.
Alternatives
If the location prevents flight due to regulatory, meteorological, or operational reasons, Stepien Digital may propose an alternative capture method.
Stepien Digital does not control airspace or weather conditions, therefore cannot guarantee drone footage in any situation.

21. Flight Conditions

Factors such as rain, wind, temporary restrictions, controlled areas, events, emergencies, and local regulations may prevent aerial footage from being carried out.

Rain
Adverse weather conditions may prevent flight.
Wind
Strong winds may make safe drone operation unfeasible.
Temporary Restrictions
Temporary flight restrictions may be imposed by authorities.
Controlled Areas
Areas with air traffic control or exclusion zones may prevent flight.
Events
Public or private events may have flight restrictions.
Emergencies
Emergency situations may suspend drone operations.
Local Regulations
Local or municipal legislation may restrict drone usage.
Operational Conditions
Unfavorable operational conditions may lead to flight cancellation.
Stepien Digital does not guarantee aerial footage in any situation, as it does not control weather conditions, airspace, or legal restrictions.

22. Client Responsibility During Production

The client is responsible for providing access to the contracted environments and obtaining all necessary authorizations for the production.

Property Access
The client must ensure access to the property where production will take place.
Owner Authorization
The client must obtain authorization from the property owner when applicable.
Private Area Recording
The client must obtain authorization for recording in private areas.
Voluntary Participation
The client must obtain authorization for people who will voluntarily participate in the images.
Stepien Digital is not responsible for issues arising from the client's lack of authorizations.

23. Minors

If minors appear in the images, authorization from their legal guardians is required. This authorization must be obtained by the client, and Stepien Digital may request proof of such authorization before production.

Minor protection is a priority. Stepien Digital does not carry out productions with minors without the proper authorization from their legal guardians.

24. Client-Provided Content

If the client provides logos, music, texts, photographs, videos, or any other content, they declare that they hold the rights to use such material.

Logos
The client declares they hold usage rights over the provided logos.
Music
The client declares they hold usage rights over the provided music.
Texts
The client declares they hold usage rights over the provided texts.
Photographs
The client declares they hold usage rights over the provided photographs.
Videos
The client declares they hold usage rights over the provided videos.
Stepien Digital is not responsible for any copyright infringement caused by content sent by the client.

25. Artificial Intelligence

Certain Stepien Digital services may use artificial intelligence to assist with information organization and content suggestions. Stepien Digital does not use personal data to train its own AI models. Where AI-assisted processing is used, it is based on our legitimate interest in improving the quality and efficiency of our services.

26. Stepien Digital Platform

Certain services may be provided through Stepien Digital's own platform upon client authorization. These services include:

Digital Presence Management
Tools for integrated management of clients' digital presence.
Step Inside
Interactive immersive experience that allows visitors to explore a business, venue or project before their first visit.
Stepien Review
Solution for collecting, managing and improving customer reviews and online reputation.

This Privacy Policy is provided in English for convenience only. In case of discrepancies or interpretation questions, the German version shall prevail.