1. Data controller
The controller within the meaning of Article 4(7) of the General Data Protection Regulation (GDPR) is:
Arsenii Piestovoperating under the name ReCyCoFichtenstrasse 2977815 BühlGermanyTelephone: +49 175 6258930
Email: info@recyco.world
ReCyCo is a digital B2B service for the structured presentation of materials and the initiation of contacts between companies.
2. General information on data processing
We process personal data only insofar as this is necessary to operate ReCyCo, communicate with companies and their contact persons, process inquiries, present materials or provide functions expressly requested by users.
Personal data means any information relating to an identified or identifiable natural person.
Purely company-related or material-related information that cannot be linked to a natural person generally does not constitute personal data within the meaning of the GDPR.
ReCyCo is intended exclusively for companies and their representatives acting in a business capacity. We do not specifically process personal data relating to children or minors.
3. Legal bases for processing
Depending on the processing activity, we rely in particular on the following legal bases:
- Article 6(1)(a) GDPR where consent has been given;
- Article 6(1)(c) GDPR where processing is necessary to comply with a legal obligation;
- Article 6(1)(f) GDPR where processing is necessary for the legitimate interests of ReCyCo or a third party, provided these are not overridden by the interests, fundamental rights or freedoms of the data subject.
Our legitimate interests include, in particular, the secure and reliable operation of ReCyCo, the handling of business inquiries, communication with companies and their contact persons, the structured presentation of materials and the initiation of B2B business contacts.
4. Hosting and server log files
ReCyCo is operated on a virtual server provided by:
netcup GmbHEmmy-Noether-Straße 1076131 KarlsruheGermanyWhen our website is accessed, the web server and application may process the following technical data in particular:
- IP address;
- date and time of access;
- URL or resource accessed;
- HTTP status code;
- amount of data transferred;
- referrer information, where transmitted;
- browser or User-Agent information;
- technical error and security information.
Processing is based on Article 6(1)(f) GDPR.
Our legitimate interest is the secure, stable and technically reliable operation of ReCyCo and the detection, analysis and prevention of errors, misuse and attacks.
Log data is retained only for as long as necessary for these purposes. The relevant factors include the time required for technical operations, error analysis and security assessment, as well as any specific security or misuse incident.
In the event of a specific security incident, relevant log data may be retained until the incident has been fully resolved.
Further information about data protection at netcup:
5. Domain administration and email communication via IONOS
Domain administration and the email mailbox info@recyco.world are provided through:
IONOS SEElgendorfer Str. 5756410 MontabaurGermanyIf you contact us by email, the following data in particular may be processed:
- your email address;
- your name, where provided;
- your company and role, where provided;
- the subject line;
- the contents of your message;
- attachments;
- technical email metadata.
Processing is generally based on Article 6(1)(f) GDPR.
Our legitimate interest is to handle and document business communications.
Further information:
6. Contacting us through the website
When you contact us through ReCyCo, we process the information you submit.
This may include, in particular:
- email address;
- name, where provided;
- subject or context of the inquiry;
- message content;
- reference to a material, where the inquiry is submitted in that context;
- any further information you voluntarily provide in your message.
Processing is generally based on Article 6(1)(f) GDPR.
Our legitimate interest is to handle and follow up on business inquiries.
Where individual fields are marked as mandatory, the information is needed to process the respective inquiry. Without the required information, it may not be possible to process the inquiry.
7. Material inquiries / Direct Inquiry
Interested companies may submit an inquiry to ReCyCo regarding a material presented on the platform.
The following data in particular may be processed:
- name of the contact person;
- business email address;
- company, where provided;
- telephone number, where provided;
- inquiry content;
- reference to the material concerned;
- further business information provided voluntarily.
Further exchanges may also involve processing information such as:
- requested quantities;
- frequency of demand or requirements;
- price expectations;
- commercial terms;
- other requirements voluntarily communicated.
ReCyCo may structure this information and prepare it for further contact initiation.
Where necessary to assess a specific expression of interest, material-related, demand-related and company-related information may be passed on in a structured form to the company that supplied the information about the material concerned.
However, personal contact details are disclosed to the other party only in accordance with the following section and on the basis of the consent provided for that purpose.
Material inquiries are processed on the basis of Article 6(1)(f) GDPR.
Our legitimate interest and the legitimate interests of the companies involved are to handle specific material inquiries and efficiently initiate the corresponding B2B contacts.
Submitting an inquiry to ReCyCo does not result in the conclusion of a contract with ReCyCo.
8. Disclosure of contact details between companies
Where there is mutual interest, ReCyCo may establish contact between the company that supplied information about a material and an interested company.
Specific personal contact details are not disclosed to the other party without prior consent.
Consent to disclosure is documented electronically.
Following the relevant consent, the following information in particular may be disclosed:
- name;
- company;
- business email address;
- telephone number, where available and authorised for disclosure;
- content or structured summary of the inquiry;
- further information expressly approved for establishing contact.
The legal basis for the disclosure of personal contact details is Article 6(1)(a) GDPR.
Consent may be withdrawn at any time with effect for the future.
Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
After contact has been established, the companies involved decide independently how to communicate further and process the data exchanged between them.
9. Material interviews and company communication
ReCyCo conducts discussions and interviews with companies concerning individual materials.
The following data in particular may be processed:
- name and business contact details of a contact person;
- that person's role within the company;
- company information;
- information about materials;
- technical and commercial material information;
- answers to structured questions;
- information about documents, analyses or certificates;
- information about the origin of a business contact.
Processing serves to collect, structure and present material information and to communicate with companies.
The legal basis is generally Article 6(1)(f) GDPR.
Where possible, personal contact details are handled separately from the material information itself.
Telephone and in-person interviews are not currently recorded as audio.
10. Publication of material listings
The first, publicly accessible version of ReCyCo displays information about materials.
The name of the company supplying the information, its contact details and the contact details of its respective contact person are not publicly displayed in the current first version.
Published information includes, in particular, information about the material itself and, where approved for publication:
- technical properties;
- quantities;
- material location information;
- images;
- analyses;
- certificates;
- documents;
- other material-related information.
Material listings are prepared on the basis of information and documents supplied to ReCyCo by the respective company for this purpose.
Only content that the company concerned has agreed may be published is made public.
If publication of a particular image, document or item of information is not permitted, that content is not published.
Where images, certificates, analyses or other documents contain personal information that is not required for the material listing, such information is removed, redacted or otherwise obscured before public publication, insofar as necessary and possible.
This may concern, in particular:
- personal telephone numbers;
- personal email addresses;
- signatures;
- names of contact persons who do not need to be identified;
- images of individuals;
- other personal information not required for the material listing.
Personal data is published only where publication is necessary or envisaged for the relevant purpose and there is an applicable legal basis under data protection law.
Approval by a company to publish a document or file does not automatically replace any legal basis that may be required for publishing personal data concerning natural persons contained in it.
These measures serve, in particular, the principle of data minimisation under Article 5(1)(c) GDPR.
11. Data from publicly accessible and other permitted sources
ReCyCo may research companies and their business contact persons itself or receive business contact leads from other permitted sources.
The following personal data in particular may be processed:
- name;
- company;
- business role;
- business email address;
- business telephone number;
- origin or source of the contact.
Possible sources include, in particular:
- company websites;
- publicly accessible company and industry directories;
- business contact details made publicly available;
- publicly accessible professional or business sources;
- recommendations or referrals from business contacts or other companies.
Where possible, ReCyCo records the specific source of a contact. If the precise individual source cannot be established, at least the source category is recorded.
The purpose of processing is to identify appropriate B2B contacts and make business-related contact in connection with ReCyCo.
The legal basis is Article 6(1)(f) GDPR.
Our legitimate interest is to establish and operate ReCyCo as a B2B service and contact companies for which ReCyCo or particular materials may be commercially relevant.
This does not affect the requirements of competition law governing any specific contact, in particular Section 7 of the German Act Against Unfair Competition (UWG).
As the data is not collected directly from the data subject, the information obligations under Article 14 GDPR also apply.
The required information is provided within a reasonable period after obtaining the personal data, and in any event no later than one month. If direct contact occurs earlier, the information is provided no later than the first communication. If disclosure to another recipient is planned before that, the information is provided no later than the first disclosure, unless a statutory exception to the duty to inform applies.
Where the contact constitutes direct marketing, we also expressly and separately draw attention to the right to object at any time under Article 21(2) and (3) GDPR, no later than the first communication.
12. Objection to further B2B contact
You may object at any time to the processing of your personal data for the purpose of further B2B contact.
Where personal data is processed for direct marketing, you may object to processing for that purpose at any time.
Following such an objection, personal data will no longer be processed for that purpose.
Data no longer required for further contact will be deleted unless another legal basis or statutory retention obligation prevents deletion.
We may retain a suppression or objection record limited to what is strictly necessary to ensure that the person concerned is not contacted again by mistake.
The legal basis for that record is Article 6(1)(f) GDPR.
Our legitimate interest is to ensure reliable compliance with the objection.
14. Double opt-in
A double opt-in procedure is provided for newsletter subscriptions.
An email address is activated for newsletter delivery only after successful confirmation.
The status and evidence information needed for the subscription and confirmation process is processed for this purpose.
In particular, this information enables us to demonstrate that consent was properly given.
Unconfirmed subscriptions are not used for newsletter delivery.
The data stored for this purpose is retained only for as long as necessary for the subscription and evidence process and is then deleted, unless another legal basis permits further retention.
The legal basis for subscribing to the newsletter is Article 6(1)(a) GDPR.
Necessary evidence data is retained on the basis of Article 6(1)(f) GDPR. Our legitimate interest is to be able to demonstrate that newsletter subscriptions were properly obtained.
16. Sending email through Resend
We use the Resend service for the technical delivery of certain emails, in particular newsletters and emails associated with double opt-in:
Plus Five Five, Inc.2261 Market Street #5039San Francisco, CA 94114USAThe following data in particular may be processed:
- the recipient's email address;
- message content;
- sending and delivery information;
- technical email and status data.
Resend processes personal data as part of the technical provision of email delivery services to ReCyCo.
According to Resend, a Data Processing Addendum is in place pursuant to Article 28 GDPR.
Resend processes and/or stores certain customer data in the United States.
In its current Data Processing Addendum, Plus Five Five, Inc. states that it is certified under the EU–U.S. Data Privacy Framework.
Where personal data is transferred under this certification, the transfer may be based on the European Commission's adequacy decision pursuant to Article 45 GDPR.
Resend's Data Processing Addendum also contains the European Commission's Standard Contractual Clauses for transfers for which such clauses are required.
The legal basis for sending newsletters is Article 6(1)(a) GDPR.
Further information:
18. Recipients of personal data
Where necessary for the respective purpose, personal data may be made accessible, in particular, to the following recipients or categories of recipients:
- authorised persons within the ReCyCo team;
- netcup GmbH in connection with hosting infrastructure;
- IONOS SE in connection with domain and email infrastructure;
- Plus Five Five, Inc. / Resend in connection with email delivery;
- the cloud-based workspace and documentation service Coda (Superhuman Docs) for the organisation and follow-up of business contacts and inquiries, including names, professional roles, business email addresses, telephone numbers and information about companies and inquiries;
- the company whose material is the subject of an inquiry, where disclosure is permitted and envisaged;
- an interested company, where the disclosure of personal contact details has been approved by the party concerned;
- public authorities, courts or other public bodies where disclosure is required by law.
According to the provider's published Data Privacy Addendum, the service is provided by Superhuman Platform Inc. Customer personal data may be processed in the United States. The provider states that applicable international transfers may rely on the EU–U.S. Data Privacy Framework and, where required, on the European Commission's Standard Contractual Clauses. Further information: Superhuman Data Privacy Addendum and Subprocessors.
Under ReCyCo's current structure, personal contact details are disclosed between the companies involved only after the consent provided for that purpose has been obtained.
19. Retention periods and deletion
As a general rule, personal data is retained only for as long as necessary for the respective processing purpose.
Server and security data
Server and security data is deleted as soon as it is no longer necessary for technical operations, error analysis or system security.
Where there is a specific security, misuse or error incident, the relevant data may be retained until the incident has been fully resolved.
Contact inquiries and Direct Inquiries
Data from contact and material inquiries is retained for processing the inquiry and any business communication that results from it.
After the inquiry has been fully handled, the data is retained only for a reasonable follow-up period.
Where no ongoing business relationship or other relevant business purpose remains, this data is generally deleted no later than twelve months after the last substantive contact, unless statutory retention obligations or other legitimate reasons justify longer retention.
B2B contact data
Business contact data is retained for as long as it remains relevant to ReCyCo's activities.
If there is no longer active communication or cooperation, we review whether further retention is necessary no later than twelve months after the last substantive contact.
If no ongoing purpose or other legal basis exists, the personal data is deleted.
In the event of an objection to further contact, the rules governing suppression records apply.
Contact persons associated with materials
Personal details of contact persons may be retained while a material listing is being actively managed.
After a material is permanently removed or the cooperation ends, personal contact details that are no longer required are deleted or anonymised.
Data is retained for longer only where a statutory obligation, a legitimate documentation purpose or another legal reason still applies.
Newsletter
Active newsletter data is retained until consent is withdrawn or the person unsubscribes.
Data relating to unconfirmed subscriptions is retained only for as long as necessary for the subscription and evidence process and then deleted, unless another legal basis permits further retention.
No further newsletters are sent after unsubscribing.
A suppression and evidence record limited to what is necessary may continue to be retained where required to respect the unsubscribe request reliably or demonstrate that valid consent had previously been given.
Statutory retention and legal claims
Where statutory retention obligations apply, deletion takes place only after the relevant statutory period has expired.
Data may also be retained to the extent necessary for the establishment, exercise or defence of legal claims.
20. Backups
ReCyCo uses technical backups to protect against data loss and restore systems in the event of technical problems.
Data deleted from active systems may remain in backups for a limited period until the relevant backup is overwritten or deleted as part of the normal backup cycle.
Backups are not used as an active archive of deleted personal data.
In the event of a complete system restoration, steps are taken to ensure that personal data previously lawfully deleted, blocked or subject to an objection is not permanently reintroduced into operational use.
21. Security of processing
ReCyCo implements appropriate technical and organisational measures to protect personal data against loss, unauthorised access, unauthorised alteration, disclosure or other misuse.
Access to personal data not intended for public disclosure is restricted to persons who need that data for their work in connection with ReCyCo.
Technical and organisational safeguards are reviewed and adapted in line with technological developments and the development of ReCyCo.
22. No automated decision-making
ReCyCo does not currently make decisions based solely on automated processing within the meaning of Article 22 GDPR that produce legal effects concerning a data subject or similarly significantly affect that person.
In particular, ReCyCo does not currently carry out automated personal scoring or profiling to decide which companies should enter into transactions with each other.
23. Rights of data subjects
Subject to the statutory requirements, you have the following rights in particular:
Right of access — Article 15 GDPR
You may request information about whether we process personal data concerning you and, if so, which data.
Right to rectification — Article 16 GDPR
You may request that inaccurate personal data be corrected and incomplete personal data be completed.
Right to erasure — Article 17 GDPR
You may request the erasure of your personal data subject to the statutory requirements.
Right to restriction of processing — Article 18 GDPR
You may request the restriction of processing subject to the statutory requirements.
Right to data portability — Article 20 GDPR
Where the statutory requirements are met, you may receive personal data that you have provided in a structured, commonly used and machine-readable format or request its transmission to another controller.
Right to object — Article 21 GDPR
Where we process personal data on the basis of Article 6(1)(f) GDPR, you may object to such processing at any time on grounds relating to your particular situation.
Where personal data is processed for direct marketing, you may object to processing for that purpose at any time.
Following such an objection, the personal data will no longer be processed for direct marketing.
Withdrawal of consent — Article 7(3) GDPR
You may withdraw consent at any time with effect for the future.
Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
24. Exercising your data protection rights
You may contact us at any time regarding data protection matters:
Arsenii Piestov / ReCyCoFichtenstrasse 2977815 BühlGermanyEmail: info@recyco.world
To protect personal data, we may take reasonable steps to verify that the person making a request is in fact the data subject or is authorised to exercise the relevant rights.
25. Right to lodge a complaint with a data protection supervisory authority
Under Article 77 GDPR, you have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes data protection law.
The authority responsible in particular for the controller's place of establishment is:
Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-WürttembergHeilbronner Straße 3570191 StuttgartGermanyEmail: poststelle@lfdi.bwl.de
Contact the Baden-Württemberg Data Protection Authority (LfDI)
You may also contact another supervisory authority competent under Article 77 GDPR.
26. Changes to this Privacy Policy
ReCyCo is currently in a pilot and development phase.
Functions, processing activities and technical service providers may change as the platform develops.
This Privacy Policy is updated when new processing activities, external services or other functions relevant to data protection are introduced, or when existing processes change materially.
The latest published version applies.