Privacy Policy

This policy covers the website visualpageeditor.de. It is an English translation for your convenience; in the event of any discrepancy, the German version prevails. The separate policy for the Mac and iPad app is here.

1. Overview

This website is deliberately built to collect as little data as possible and, as a matter of principle, loads fonts, videos and images exclusively from the same server that delivers the page. Without your consent it sets no analytics or advertising cookies. Google Analytics 4 and Google Ads conversion tracking run in Google’s consent mode; they set cookies only when you click ‘Accept’ in the cookie banner (see section 5). Nothing is sold on this website and no payment data are processed here (see section 4). The footer also embeds the professional indemnity seal from exali.de, the image of which is loaded from exali servers (see section 7).

2. Controller

Olaf Kükelheim
Billebrinkhöhe 58
45136 Essen
Germany
Tel.: +49 176 156 27 455
Email: info [at] visualpageeditor.de

3. Server log files (hosting)

When you access the site, the hosting provider processes strictly necessary access data (including the page visited, the date and time of access, the volume of data transferred, the referrer, the browser, the operating system and the IP address) in order to deliver and secure the site. Legal basis: Article 6(1)(f) of the General Data Protection Regulation (GDPR) (legitimate interest in the stability and functionality of the website). The data are not passed on or used for any other purpose; we reserve the right to review the log files retrospectively should there be specific indications of unlawful use. Provider: IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany. This website also uses SSL/TLS encryption, recognisable by ‘https://’ and the padlock symbol in your browser’s address bar.

4. Purchase via the App Store

No purchase takes place on this website. No payment data are processed here, and no scripts or cookies of payment service providers are loaded. The app is downloaded and purchased exclusively via the App Store. Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, is responsible for this; Apple’s privacy policy applies: apple.com/legal/privacy. We do not receive buyers’ names, email addresses or payment data from Apple.

Earlier direct purchases: for purchases processed directly via this website before the switch (payment service provider Stripe Payments Europe Ltd., Dublin, Ireland), we retain the name, email address, amount, date of purchase, transaction number, the confirmation of consent to immediate commencement of the contract and the licence key issued. Purpose: compliance with retention obligations under tax and commercial law and evidence of consent under section 356(5) of the German Civil Code (BGB). Legal basis: Article 6(1)(c) GDPR. Retention period: ten years under section 147 of the German Fiscal Code (AO) and section 257 of the German Commercial Code (HGB), calculated from the end of the respective calendar year.

Electronic withdrawal function: consumers who concluded contracts with a statutory right of withdrawal on this website before the switch to the Mac App Store may declare their withdrawal using the electronic withdrawal function (Withdraw from contract). In doing so, the name, email address and details identifying the contract to be withdrawn from are collected and processed in order to handle the withdrawal and to confirm its receipt. The legal basis is Article 6(1)(b) GDPR together with Article 6(1)(c) GDPR, as we are under a legal obligation to provide an electronic withdrawal function (section 356a BGB). The function runs as a processor at Cloudflare Germany GmbH, Rosental 7, 80331 Munich, Germany (parent company Cloudflare, Inc., USA; third-country transfers based on the EU standard contractual clauses or the EU–U.S. Data Privacy Framework); the confirmation emails are sent via the mail server of IONOS SE (see section 3).

5. Cookies, analytics and advertising measurement

On your first visit this website displays a cookie banner with the buttons ‘Accept’ and ‘Decline’. The Google tag (Google Analytics 4 and Google Ads) is loaded in Google’s consent mode. As long as you have not consented – and permanently, if you decline – all storage types are set to ‘denied’: no analytics or advertising cookies are set and no information is stored on or read from your device. The Google tag then only sends cookieless signals to Google (e.g. page view, click on the App Store link, time, browser details, IP address for the transmission), without any identifier that recognises you. Google uses these signals for aggregated, modelled statistics and conversion measurement. The legal basis for this is Article 6(1)(f) GDPR (legitimate interest in measuring the effectiveness of our website and advertising). Cookies are set only after your express consent. The only strictly necessary cookie is ‘vpe-consent’, which records your decision (legal basis: section 25(2) no. 2 TDDDG, Article 6(1)(f) GDPR – legitimate interest in documenting your decision).

Google Analytics 4 (measurement ID G-XDE3DHQJBC)

Purpose: analysis of user behaviour in order to improve the website – for example which pages are viewed, how long a visit lasts and which source it came from.

Legal basis: Article 6(1)(a) GDPR (consent), together with section 25(1) TDDDG for storing and reading information on your device.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Transfer to a third country: data may be transferred to Google LLC in the USA. The transfer is based on the standard contractual clauses approved by the European Commission.

Retention period: user- and event-level data in Google Analytics are deleted after 14 months. The lifetime of the individual cookies is given in the table below.

Withdrawal (opt-out): you may withdraw your consent at any time with effect for the future by deleting the ‘vpe-consent’ cookie in your browser and selecting ‘Decline’ in the banner on your next visit (see ‘How can you withdraw your consent?’ below).

Google Ads conversion tracking (ID AW-18155781431)

Purpose: measuring the effectiveness of Google Ads adverts – that is, whether a click on an advert led to a click on the App Store link (download of the app).

Legal basis: Article 6(1)(a) GDPR (consent), together with section 25(1) TDDDG.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Transfer to a third country: data may be transferred to Google LLC in the USA. The transfer is based on the standard contractual clauses approved by the European Commission.

Activation: conversion tracking is loaded together with Google Analytics 4 via the same Google tag in consent mode. Without consent it only sends cookieless signals (see above); it sets cookies only after your consent.

Cookies used

How can you withdraw your consent?

You may withdraw your consent at any time with effect for the future; the lawfulness of processing carried out up to that point remains unaffected (Article 7(3) GDPR). There are two ways to do so:

• Delete the ‘vpe-consent’ cookie for visualpageeditor.de in your browser settings. The banner will reappear on your next visit and you can select ‘Decline’. Ideally also delete the ‘_ga’, ‘_ga_XDE3DHQJBC’ and ‘_gcl_au’ cookies.
• Open the site in a private window (incognito mode). No earlier decision applies there, so the banner reappears.

The website remains fully usable without consent – you are not put at any disadvantage.

6. The ‘Visual Page Editor’ app

The app for Mac and iPad works entirely offline and locally on your device. It requires no account, transmits no content to us and contains no telemetry or analytics. No personal data are transmitted by the app to us or to third parties. Unlocking via in-app purchase is handled by Apple through the App Store; Apple’s privacy policy applies.

7. Professional indemnity seal (exali.de)

The exali.de professional indemnity seal is embedded on this website. It informs you about our professional indemnity insurance and thereby fulfils the statutory information duty under section 2(11) of the German Service Information Duties Regulation (DL-InfoV). If you click on the seal, you are forwarded to a profile page at exali.de; there, exali AG processes access data (including IP address, date and time of access) as a separate controller in its own right. For more information, see exali’s privacy policy: exali.de – privacy policy.

Legal basis: Article 6(1)(f) GDPR (legitimate interest).

Purpose: presentation of the statutorily required mandatory information on professional indemnity insurance (section 2(11) DL-InfoV) in a visually appealing form.

Legitimate interest: providing an attractive online presence and fulfilling our information duties in a visually appealing manner.

8. Your rights

Applicable data protection law grants you the following rights vis-à-vis us as controller:

• right of access under Article 15 GDPR
• right to rectification under Article 16 GDPR
• right to erasure under Article 17 GDPR
• right to restriction of processing under Article 18 GDPR
• right to be informed under Article 19 GDPR
• right to data portability under Article 20 GDPR
• right to withdraw consent given under Article 7(3) GDPR
• right to object under Article 21 GDPR to processing based on our legitimate interest
• right to lodge a complaint with a data protection supervisory authority under Article 77 GDPR

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