Privacy Policy
This policy tells you which personal data we process when you visit this website and buy our digital products, for what purposes, on which legal basis and what rights you have (Art. 13, 14 GDPR).
Controller
Lunasev LLC (SeviTrades), 3833 Powerline Rd, Suite 201, Fort Lauderdale, FL 33309, USA. Contact: info@sevilaytrades.de or via our contact form. No separate EU representative under Art. 27 GDPR is currently appointed; please send requests to the address above. We have not appointed a data protection officer, nor are we required to.
Processing, purposes, legal bases
- Website access (server log files): technical connection data incl. IP address. Purpose: secure delivery, fault and attack defence. Legal basis: Art. 6(1)(f) GDPR. Stored at the host, per its documentation at most 30 days. Fonts are served from our own server; no connection to third parties.
- Purchase & payment: no purchase is currently possible (buttons inactive). Once selling starts, payments are processed via Stripe (Stripe, Inc., USA); you enter payment data directly with Stripe and we never receive full card details. Purpose: processing your payment and triggering delivery. Legal basis: Art. 6(1)(b) GDPR.
- E-book delivery: we create a member record (email, product purchased, transaction reference, status) and generate a personal download link. Purpose: providing the book. Legal basis: Art. 6(1)(b) GDPR. The link does not end with a community term (the book is bought).
- Community via Telegram: after purchase we create an invitation link labelled only with a pseudonymous member ID. We do not transmit your email or payment data to Telegram. From your join request we store your Telegram user ID to link your account to the purchase; after the term we remove you automatically (no permanent ban). Legal basis: Art. 6(1)(b) GDPR.
- Access and transaction emails: sent via Resend (EU region) or, alternatively, Brevo (Sendinblue SAS, Paris). Transmitted: email address, subject and content. Legal basis: Art. 6(1)(b) GDPR, for the order confirmation additionally (c) (§ 312f BGB). We do not send a newsletter.
- Contact form / email: name, email address and message. Purpose: handling your request. Legal basis: Art. 6(1)(b) GDPR (if contract-related), otherwise (f). Form entries are not stored in a database but only delivered as an email to our mailbox.
- Legal retention & legal claims: purchase-related data is retained where required by tax/commercial law (Art. 6(1)(c)) or to assert and defend claims (Art. 6(1)(f)).
Recipients of your data
We do not sell your data. Service providers that support us:
- Vercel, Inc. (USA) — hosting of this website.
- Supabase, Inc. — database, operated in the EU region Frankfurt.
- Resend, Inc. (USA) or Sendinblue SAS (“Brevo”, France) — email delivery.
- Heinlein Hosting GmbH (“mailbox.org”, Berlin) — our email mailbox.
- Telegram Messenger Inc. — messenger and community group.
- Stripe, Inc. (USA) — payment processing once selling starts.
- Our IT service provider (Germany) — operation and maintenance on our behalf.
Transfers to third countries
Vercel, Resend and Stripe (USA) state that they comply with the EU-US Data Privacy Framework; in addition, the EU Standard Contractual Clauses (2021/914) are agreed (for Stripe once the account is connected). Supabase stores in Frankfurt but is based/has locations outside the EU; the Standard Contractual Clauses apply to any third-country access (no DPF) — we conclude the relevant data processing agreement before processing customer data. Telegram (registered in the British Virgin Islands): no adequacy decision and no Standard Contractual Clauses; we base this transfer on Art. 49(1)(b) GDPR (performance of the contract), as the community cannot be provided without Telegram. A level of protection equivalent to EU law cannot be guaranteed for this — if you do not want that, please do not book community access (the e-book works without Telegram). Our mailbox provider and IT provider are located in Germany.
Cookies and consent
We use no analytics, tracking or marketing cookies. Your choice in the notice banner is stored locally in your browser (§ 25(2) no. 2 TDDDG). Should we ever use processing that requires consent, we load it only after your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG), which you can withdraw at any time with effect for the future.
Your rights
You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and objection (Art. 21), and the right to lodge a complaint with a data protection supervisory authority (Art. 77). An informal message to info@sevilaytrades.de is sufficient. No automated decision-making under Art. 22 GDPR takes place; removal from the community after the term is the agreed end of the contract.