Privacy Policy

Last Updated: 9 July 2025

This Privacy Policy explains how Horton AppWorks ("we", "us", or "our") collects, processes, and protects your personal data when you visit our website or use our services. We process your data in accordance with the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG).

1. Data Controller

The controller responsible for data processing under Article 4(7) GDPR is:
Horton AppWorks
Attn: Niklas Michel
Email: privacy@hortonappworks.com

2. Categories of Personal Data We Process

We may collect and process the following categories of personal data:

  • Contact Information – e.g. name, email address, telephone number (if you provide it to us directly).
  • Usage Data – including your IP address, browser type, operating system, accessed pages, date and time of access.
  • Cookies & Similar Technologies – used to improve website functionality and analyze usage.

3. Legal Bases for Processing

We process your personal data based on the legal grounds set out in Article 6(1) GDPR:

  • Consent – where you have given your explicit consent (Art. 6(1)(a)).
  • Contractual necessity – to fulfil a contract or take steps prior to entering into one (Art. 6(1)(b)).
  • Legal obligation – to comply with statutory or regulatory duties (Art. 6(1)(c)).
  • Legitimate interests – for example, ensuring website security or improving services (Art. 6(1)(f)), provided these are not overridden by your fundamental rights.

4. Purposes of Processing

Your personal data is processed for the following purposes:

  • To operate and improve our website and services;
  • To respond to your inquiries or support requests;
  • To fulfil legal obligations;
  • To enforce our Terms of Service;
  • Any other purpose for which you have given consent.

5. Data Sharing and International Transfers

We do not sell your personal data. However, we may share your data under the following conditions:

  • With service providers – such as hosting, analytics, or customer support providers, who are contractually bound to protect your data under GDPR-compliant data processing agreements;
  • For legal compliance – where required by applicable law, court order, or government regulation;
  • In the context of business transfers – such as a merger, acquisition, or asset sale, in accordance with Article 6 GDPR.

If we transfer personal data outside the European Economic Area (EEA), we ensure appropriate safeguards (e.g., Standard Contractual Clauses pursuant to Art. 46 GDPR).

6. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes stated in this policy or as required by applicable legal obligations. Retention periods vary depending on the nature and context of the processing activity.

7. Data Security

We implement appropriate technical and organizational measures in accordance with Article 32 GDPR to protect your data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. However, no internet-based system can be completely secure. We encourage users to take steps to protect their own devices and credentials.

8. Your Rights under the GDPR

You have the following rights regarding your personal data, in accordance with Articles 12–23 GDPR:

  • Right of access (Art. 15) – to request information about the data we hold;
  • Right to rectification (Art. 16) – to correct inaccurate data;
  • Right to erasure (Art. 17) – under specific conditions (“right to be forgotten”);
  • Right to restrict processing (Art. 18);
  • Right to data portability (Art. 20);
  • Right to object (Art. 21) – including to direct marketing or profiling;
  • Right to withdraw consent (Art. 7(3)) – at any time with future effect.

To exercise your rights, contact us at privacy@hortonappworks.com. We will respond within the time limits set by the GDPR.

9. Cookies

We use cookies to personalize content, analyze traffic, and improve website functionality. You can manage your preferences via your browser or device settings.

10. Links to External Websites

Our website may contain links to third-party websites. We are not responsible for their content or data protection practices. This Privacy Policy applies only to our own services and domains.

11. Right to Lodge a Complaint

If you believe that your data has been unlawfully processed, you have the right to lodge a complaint with a supervisory authority under Article 77 GDPR. In Germany, this may be:

Federal Commissioner for Data Protection and Freedom of Information (BfDI)
Graurheindorfer Str. 153, 53117 Bonn
www.bfdi.bund.de

Or the data protection authority of your federal state.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements or our practices. The most current version will always be published on this page.

13. Contact

If you have any questions or concerns regarding this Privacy Policy, please contact us at:
Horton AppWorks
Email: privacy@hortonappworks.com

Disclaimer on Translations

This English version of the Privacy Policy is provided for convenience. In the event of any conflict or ambiguity with translated versions, the English version shall prevail and be legally binding.