Privacy policy

Last updated: 25.01.2022

As the operator of this site, Sawayo GmbH ("Sawayo GmbH" or "we") takes the protection of your personal data very seriously. The protection of your privacy when processing personal data is an important concern for us. In the following, we would like to inform you which data we collect and process, for example, when you visit our website (hereinafter also referred to as "website") or use the services offered by us in other ways (hereinafter referred to as "services").

Responsible body

‍Thecontroller within the meaning of the EU General Data Protection Regulation (GDPR) is

Sawayo GmbH
Richard-Wagner-Straße 1 a
c/o Basislager Coworking GmbH
18055 Rostock

Our data protection officer is

heyData GmbH
Schützenstrasse 510117 Berlin

Logging of non-personal data when using our Internet presence

When you visit our website, information about this is stored and processed in a log file. This process is anonymized. Conclusions about your person are not possible.

Depending on the access protocol used, the log data record contains information with the following content:
- date and time of the page request
- IP address of the requesting device
- access methods/functions requested by the requesting device
- the function called up or the name of the file called up
- operating system and browser type or settings
- the amount of data transferred and the message as to whether the access/retrieval was successful

There is no possibility for us to link IP address and any personal data that may exist. The stored data is used exclusively for the purpose of identifying and tracking unauthorized access attempts/accesses to the web server as well as for statistical evaluations such as visitor numbers and page popularity and for improving our online offering. This data is used exclusively by us. It will not be passed on to third parties.


On our application you have the possibility to subscribe to a free newsletter. The data provided during registration will be processed exclusively for sending the newsletter. The legal basis for this data processing is Art. 6 (1) lit. a) DSGVO. You can object to this use of your email address at any time by sending a message to the contact option described below or via a link provided for this purpose in the newsletter.

Collection and use of personal data

In order for us to be able to provide certain services, the collection of personal data is unavoidable. We then request and store your inventory data (name, address and company name), your contact data (e.g. e-mail, telephone numbers, address)If you provide us with personal data for the purpose of contacting you, this data will only remain stored by us for as long as is necessary for the purpose of the respective communication and contact. As soon as the personal data is no longer required by us for these purposes and there is no longer any obligation to retain it, it will be deleted immediately.We use the data collected to answer your enquiries, for service and customer care and to comply with legal requirements. In order to provide our services to you, it may be necessary to pass on your personal data to companies that we use to provide the service or to process the contract. These are, for example, marketing agencies, technicians, IT and hosting service providers, payment service providers, operators of merchandise management systems. You can revoke the declaration of consent you have given us at any time and object to the creation of user profiles with effect for the future. In addition, you can - insofar as we use your personal data within the legally permissible scope for e.g. postal marketing measures - also object to this use. In both cases, an e-mail to the following address is sufficient:

Legal basis for processing

In accordance with Article 13 of the GDPR, we will inform you of the legal basis for our data processing. The legal basis for the processing depends in each case on the purpose for which the data is processed.If you have given us your consent for the processing of your personal data, we base the data processing on the consent you have given us in accordance with Art. 6 (1) a) DSGVO.However, the processing of your personal data may also be necessary for the following reasons, such as for the performance of a contract concluded with you or for the implementation of pre-contractual measures requested by you and in order to provide you with our services as well as to comply with our legal obligations (Art. 6 para. 1 sentence 1 lit. a to c DSGVO). We also use your personal data pursuant to Art. 6 para. 1 p. 1 lit. f DSGVO to pursue our legitimate interests, provided that your rights and freedoms are not overridden.

Data transmission to third parties

A transfer of your personal data to third parties for purposes other than those listed below does not take place. We will only disclose your personal data to third parties if and to the extent that:

- you have given your express consent to do so in accordance with Art. 6 (1) sentence 1 lit. a DSGVO,

- the disclosure in accordance with Art. 6 (1) sentence 1 lit. f DSGVO is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding legitimate interest in not disclosing your data,

- there is a legal obligation for the disclosure in accordance with Art. 6 Abs. 1 S. 1 lit. c DSGVO a legal obligation exists, as well as

- this is necessary according to Art. 6 Abs. 1 S. 1 lit. b DSGVO for the processing of contractual relationships with you, such as in the case of transfer to external service providers who support us in our business operations.

Our employees and partners are obliged by us to maintain confidentiality and to comply with data protection regulations.

Data transfers to third countries

Where we share your personal data in accordance with this Privacy Policy, this may involve the transfer of your personal data outside the European Economic Area (EEA). When we transfer your personal data outside the European Economic Area, we will always ensure that an adequate level of protection is in place by ensuring, where required by law, that at least one of the following appropriate safeguards is in place:

- transfer of personal data to countries that the European Commission considers to provide an adequate level of protection for personal data (the so-called "adequacy decision"); - use of specific, non-discriminatory safeguards for the transfer of personal data. "(the "Adequacy Decision");

- use of specific contracts approved by the European Commission that ensure the same level of protection for personal data as is provided in the EEA;

- transfer of personal data to an entity that has a valid Privacy Shield certification, thereby providing a level of protection for personal data similar to the EU standard; or

- transfer of personal data to an entity that has implemented binding internal data protection rules equivalent to the EU level of protection for personal data.

Storage period, deletion of personal data

The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 DSGVO. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

your rights

You have various rights in relation to data concerning your person. You have a right to receive, upon request and free of charge, information about the personal data we have stored about you, a right to rectification, deletion or restriction of the processing of this data and a right to object to the processing. Whether and to what extent these rights exist in individual cases and which conditions apply, is determined by the DSGVO and the Federal Data Protection Act. According to the DSGVO, you also have a fundamental right to data portability. Furthermore, if you have given your consent to the processing of your personal data, this consent can be revoked at any time with effect for the future.

If you have any questions, comments or requests regarding the collection, processing, use or deletion of your personal data by us, please contact

Right to complain to the competent supervisory authority

As a data subject, you have the right to lodge a complaint with the competent supervisory authority in the event of a breach of data protection law. The competent supervisory authority regarding data protection issues is the State Data Protection Commissioner of the federal state in which our company is located.

Data security

For security reasons and to protect the transmission of confidential content that you send to us as the site operator, our website uses SSL or TLS encryption. This means that data you transmit via this website cannot be read by third parties. You can recognize an encrypted connection by the "https://" address line of your browser and the lock symbol in the browser line.

All data to be processed in connection with the operation of this website is stored as part of the hosting. This is necessary to enable the operation of the website. We process the data accordingly on the basis of our legitimate interests pursuant to Art. 6 (1) f) DSGVO. To provide our service, we use services of web hosting providers to whom we transmit the above data.

Contact form

Data transmitted via the contact form, including your contact details, will be stored in order to be able to process your enquiry or to be available for follow-up questions. This data will not be passed on without your consent.

The data entered in the contact form is processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). A revocation of your already given consent is possible at any time. An informal communication by e-mail is sufficient for the revocation. The legality of the data processing operations carried out until the revocation remains unaffected by the revocation.

Data transmitted via the contact form will remain with us until you request us to delete it, revoke your consent to store it or there is no longer any need to store it. Mandatory legal provisions - in particular retention periods - remain unaffected.


Our website uses cookies. These are small text files that your web browser stores on your terminal device. Cookies help us to make our offer more user-friendly, effective and secure.

Some cookies are "session cookies." Such cookies are deleted by themselves at the end of your session. In contrast, other cookies remain on your terminal device until you delete them yourself. Such cookies help us to recognize you when you return to our website.

In the operating system settings of your device you will find the option to disable cookies. The deactivation of cookies may result in limited functionality of our website.

The setting of cookies, which are necessary for the exercise of electronic communication processes or the provision of certain functions desired by you, is based on Art. 6 para.1 lit. f DSGVO. As the operator of this website, we have a legitimate interest in storing cookies for the technically error-free and smooth provision of our services. If other cookies are set (e.g. for analysis functions), these are treated separately in this privacy policy.


You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

(1) is necessary for the conclusion or performance of a contract between you and us,

(2) is permitted by Union or Member State law to which we are subject and that law contains adequate measures to safeguard your rights and freedoms and your legitimate interests, or

(3) is made with your explicit consent.

Changes to this privacy policy

We reserve the right to change this privacy policy at any time with effect for the future. A current version is available on our website. Please visit our website regularly and inform yourself about the applicable data protection provisions.

Please also note that data protection regulations and data protection practices can also change continuously at third parties, e.g. Stripe. It is therefore advisable and necessary to keep yourself informed about changes in the legal provisions and the practices of companies.


If you have any questions, comments or requests regarding this Privacy Policy, please contact: