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Privacy Policy

Last updated: on publication of the live service.

1. Controller

Adler & Pfau GmbH, Hafenweg 16, 48155 Münster, Germany. info@adler-pfau.com.

A data protection officer, where required by law, will be named here by legal counsel.

2. Purpose of processing

We process personal data to operate the Wings49 Hub coordination platform: managing user accounts, publishing service offerings, transmitting requests between the parties involved, recording consent, and logging booking outcomes for audit purposes.

3. Legal basis

  • Art. 6(1)(b) GDPR — performance of a contract.
  • Art. 6(1)(a) GDPR — consent (candidate data sharing, non-essential cookies).
  • Art. 6(1)(c) GDPR — legal obligation (retention of certain audit records).
  • Art. 6(1)(f) GDPR — legitimate interest (security, fraud prevention, integrity).

4. Candidate consent and data sharing

Candidate personal data is never disclosed to a service provider until the candidate reviews the exact fields to be shared and grants explicit, revocable consent. Consent can be withdrawn at any time from the candidate dashboard; withdrawal does not affect the lawfulness of prior processing.

5. Payments

Wings49 Hub does not collect or process payments. Service payments flow directly between the provider and the payer. Wings49 Hub stores only the booking, the provider's invoice reference and its paid/unpaid status.

6. Cookies

We use strictly necessary cookies for authentication and security. Optional cookies for preferences, analytics and marketing are only set after you consent. You can review or change your choices at any time via Cookie Settings.

7. Recipients and processors

We rely on a small number of processors for hosting, authentication and email delivery, under written data-processing agreements. A current list is available on request from info@adler-pfau.com.

8. International transfers

The exact list of hosting regions and standard contractual clauses will be confirmed by legal counsel.

9. Retention

Personal data is retained for as long as the account exists and for the periods required by tax, commercial and consumer law. Audit records related to bookings and consent are kept in an append-only log for the statutory retention period.

10. Your rights

You have the right to access, rectification, erasure, restriction, portability and objection, as well as the right to lodge a complaint with a supervisory authority. Please contact info@adler-pfau.com to exercise these rights.

This policy is a working draft for the Release 1 preview. The final wording will be reviewed by legal counsel before general availability.