Privacy Policy
Last updated: 29 August 2026
1. Controller
The controller responsible for processing personal data on this website is:
Fingerklang
Owner: David Sehling
Robert-Koch-Str. 3–5
52152 Simmerath
Germany
Phone: +49 157 56059821
Email: hello@fingerklang.com
2. General information about data processing
We process personal data only where this is necessary to operate fingerklang.com, answer enquiries, provide digital content, manage customer accounts and memberships, perform contracts or send email updates, or where you have given your consent.
Depending on the processing activity, the legal bases include Article 6(1)(a) GDPR (consent), Article 6(1)(b) GDPR (contract or pre-contractual measures), Article 6(1)(c) GDPR (legal obligation) and Article 6(1)(f) GDPR (legitimate interests, in particular the secure and efficient operation of the website and handling of enquiries).
3. Shopify hosting and shop system
This website and online shop are provided through Shopify. For merchants in the European Economic Area, the contracting entity is generally Shopify International Limited, Ireland. When you visit the website, Shopify processes technical data including your IP address, date and time of access, pages requested, referrer URL, browser and device information, and security and log data. This is used in particular to deliver the website, ensure stability, analyse errors, maintain security and prevent misuse.
When you create a customer account, place an order, purchase a membership or use other shop functions, the contact, account, contract, order and payment information required for these functions is processed through Shopify. The legal basis is in particular Article 6(1)(b) GDPR; security measures may additionally rely on Article 6(1)(f) GDPR. Records subject to statutory retention requirements are processed on the basis of Article 6(1)(c) GDPR.
Further information: Shopify Consumer Privacy Policy and Shopify Data Processing Addendum.
4. Cookies, local storage technologies and consent management
Shopify and integrated services may use cookies and similar technologies. Technologies that are technically necessary are used to provide the website, security functions, cart, checkout, customer account and functions you request. Where non-essential technologies are used for analytics, personalization or marketing, they are generally used only after your consent through the available consent management controls.
The relevant legal bases include Section 25(2) TDDDG and Article 6(1)(b) or (f) GDPR for technically necessary operations, and Section 25(1) TDDDG and Article 6(1)(a) GDPR for operations requiring consent. You can withdraw consent for the future through the privacy or cookie settings offered on the website.
5. Fingerklang Early List and email updates via Kit
If you join the Fingerklang Early List or other email updates, we process in particular your email address and technical registration information such as the time of registration, form source and confirmation status. The purpose is to inform you about the launch of Fingerklang, selected releases and Circle updates.
We use Kit, Inc., USA (formerly ConvertKit) for registration, list management and email delivery. Processing is based on your consent under Article 6(1)(a) GDPR. Where a confirmation email is used, it serves to verify your registration and document your consent.
You can withdraw your consent at any time with effect for the future through the unsubscribe link in each email or by contacting hello@fingerklang.com. Further information: Kit Privacy Policy.
6. Contact form, email and telephone
If you contact us through the contact form, by email or by telephone, we process the information you provide, such as your name, email address, telephone number and message, in order to respond to and document your enquiry.
Where an enquiry relates to a contract or pre-contractual measures, Article 6(1)(b) GDPR is the legal basis. In other cases, processing is based on our legitimate interest in reliably handling enquiries under Article 6(1)(f) GDPR. Where statutory retention obligations apply, Article 6(1)(c) GDPR also applies.
7. Digital content, Free TABs, videos and downloads
Digital content such as Free TABs, videos, audio files and downloads may, depending on the offer, be provided without newsletter registration. When such content is opened or downloaded, the technical access data described under “Shopify hosting and shop system” is processed. Where you specifically request a file or video, processing is necessary to provide the content you requested.
8. Customer account
A Fingerklang customer account may be required for certain protected areas and for managing a Circle membership. In particular, your email address, customer ID, login or authentication data, account activity and, where applicable, contract data may be processed. Authentication is provided through Shopify customer accounts. The legal basis is Article 6(1)(b) GDPR.
9. Fingerklang Circle and Appstle Memberships
We use Appstle Memberships by Appstle Inc. to technically manage Fingerklang Circle memberships. Data required to set up, verify and manage the membership may be processed, including customer ID, name, email address, membership status, product or plan assignment and technical usage data. Processing serves contract performance under Article 6(1)(b) GDPR.
Further information: Appstle Memberships Privacy Policy.
10. Orders and payment processing
For paid offers, we process the information necessary for ordering and contract performance, including name, contact details, billing information, the purchased service, price, payment status and transaction and receipt data. Payment processing is carried out through Shopify and the payment provider selected at checkout. The selected payment provider receives the information required to process the payment and processes it under its own privacy terms.
The legal basis is Article 6(1)(b) GDPR. Data required under tax and commercial law is processed under Article 6(1)(c) GDPR for the statutory retention periods.
11. Recipients and processors
Personal data is disclosed only to recipients that require it for the purposes described above. These include in particular Shopify, Kit, Appstle, ManyChat, the selected payment provider and, where necessary, technical service providers, tax or legal advisers and public authorities where a legal obligation applies. Where a service provider acts as a processor, processing is carried out on the basis of the required data protection agreement.
12. International data transfers
Some service providers are located or operate technical infrastructure outside the European Economic Area. Transfers take place only in accordance with the applicable legal requirements, for example on the basis of an adequacy decision, the EU-U.S. Data Privacy Framework, appropriate Standard Contractual Clauses or other permitted safeguards. Further details are available in the privacy information of the respective providers.
13. Retention
We retain personal data only for as long as it is necessary for the relevant purpose. It is then deleted or restricted unless statutory retention obligations, legitimate evidence interests or limitation periods require longer storage. Contract, order and accounting data may be retained for the periods required by commercial and tax law. Newsletter data is generally retained until consent is withdrawn or email communications end; evidence of consent may be retained longer where necessary for legal defence.
14. Your rights
Subject to the legal requirements, you have rights including access, rectification, erasure, restriction of processing, data portability and objection to processing based on Article 6(1)(e) or (f) GDPR. You may withdraw consent at any time with effect for the future.
To exercise your rights, contact hello@fingerklang.com. Where necessary to protect your data, we may request appropriate proof of identity.
15. Right to lodge a complaint
You have the right to lodge a complaint with a data protection supervisory authority. For our business location in North Rhine-Westphalia, the State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia (LDI NRW) is particularly relevant. Further information: LDI NRW.
16. Data security
We and our service providers use appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access and unauthorised alteration. Data transmitted through the website is generally encrypted using TLS/HTTPS.
17. Instagram communication and automation via ManyChat
We use ManyChat, a service provided by ManyChat, Inc., USA, for communication through Instagram and for certain automated communication workflows. ManyChat is connected to our Instagram presence and may be used, for example, to respond to comments or direct messages initiated by you, provide requested links or information, and organise recurring communication processes.
Depending on your interaction and the relevant workflow, the data processed may include your Instagram username or platform ID, profile information, comments, the content of direct messages, the time and type of your interactions, information you voluntarily provide, and technical assignment or status information.
Where processing is necessary to respond to a communication or request initiated by you or to provide information requested by you, processing is based, depending on the circumstances, on Article 6(1)(b) GDPR or on our legitimate interest in efficient and user-friendly communication pursuant to Article 6(1)(f) GDPR. Where promotional messages are sent beyond your immediate request and consent is legally required, processing is based on Article 6(1)(a) GDPR. You may withdraw your consent at any time with effect for the future.
ManyChat may process customer data as a processor on our behalf and may process certain data for its own purposes as an independent controller. As ManyChat is based in the United States and may use subprocessors, personal data may also be processed outside the European Economic Area. According to ManyChat, transfers from the EEA are based in particular on the EU-U.S. Data Privacy Framework and, where required, appropriate Standard Contractual Clauses.
When you interact with us through Instagram, Meta Platforms Ireland Limited or the relevant Meta entity also processes personal data in accordance with Instagram's own privacy policy. We have only limited influence over this processing by the platform.
Further information: ManyChat Privacy Policy, ManyChat Data Processing Addendum and Instagram Privacy Policy.
18. Changes to this Privacy Policy
We update this Privacy Policy when functions, service providers or legal requirements change. The version published on this website applies.