Last updated: 23 August 2026. This Privacy Policy explains how personal data is processed when you visit Mittworks Berlin, use the website or contact us through the website, by email or telephone.
1. Controller
The controller responsible for processing personal data is: Graham Holliday, sole proprietor trading as Mittworks Berlin, Stubenrauchstraße 5, 12161 Berlin, Germany. Telephone: +49 176 5076 3904. Email: info@mittworksberlin.com.
2. Hosting and operation of the website
This website is created and hosted using Framer, provided by Framer B.V., Rozengracht 207B, 1016 LZ Amsterdam, The Netherlands. When you access the website, technical information necessary to deliver and secure the website may be processed, including IP address, date and time of access, requested page or resource, browser type and version, operating system and device information, referring page, and technical request and error information. This processing is necessary to provide the website, maintain its security and stability, prevent misuse and diagnose technical problems. The legal basis, where personal data is processed, is Art. 6(1)(f) GDPR. Our legitimate interest is the secure, reliable and efficient operation of the website. Framer acts as a service provider for the operation of the website and may use approved subprocessors. Where personal data is transferred outside the European Economic Area, appropriate safeguards are used in accordance with the GDPR.
3. Framer Analytics
Framer provides built-in website analytics which we may use to understand general website usage. According to Framer, its built-in analytics do not use cookies or persistent identifiers. Framer uses technical information such as the IP address and browser information to calculate anonymised daily visitor statistics using a daily rotating identifier. We use these aggregate statistics to understand matters such as page views, traffic sources and general website performance. Framer Analytics is separate from Google Analytics and Microsoft Clarity, which are described below.
4. Contact form and enquiries
You can contact Mittworks through the contact form on this website, by email or by telephone. The website contact form is provided through Framer Forms. Information submitted through the form is processed by Framer and forwarded to our Microsoft Outlook email account. Depending on the information you provide, we may process your name, email address, telephone number, the type of training you are interested in, information about your training goals or experience, your message, and any other information you voluntarily provide. We use this information to respond to your enquiry, provide information about Mittworks training, discuss availability, arrange introductory or training sessions and, where applicable, establish or administer a client relationship. If your enquiry relates to entering into or performing a contract, the legal basis is Art. 6(1)(b) GDPR. For other enquiries, the legal basis is Art. 6(1)(f) GDPR, based on our legitimate interest in responding to communications relating to Mittworks and its services. Framer Forms also uses technical measures designed to identify and reduce spam and abusive submissions.
Email processing through Microsoft Outlook. Form submissions and direct emails are received and managed using Microsoft Outlook. For users and customers in the European Economic Area, relevant Microsoft services are generally provided by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Microsoft may process email and associated technical information as necessary to provide, secure and maintain its services. We retain correspondence only for as long as reasonably necessary to deal with your enquiry or client relationship. Information that is subject to statutory accounting, tax, contractual or other legal retention requirements may be retained for the applicable statutory period.
5. Cookies and consent
This website uses cookies and similar technologies. Cookies that are strictly necessary to provide a service requested by you may be used without consent where permitted by law. Analytics and similar non-essential technologies are only activated after you have given your consent. The legal basis for storing or accessing non-essential information on your device is § 25(1) TDDDG. Where personal data is subsequently processed on the basis of your consent, the legal basis is Art. 6(1)(a) GDPR. You can refuse analytics cookies without affecting your ability to use the essential functions of the website. You can also withdraw or change your consent at any time using the Cookie Settings available on the website. Withdrawal does not affect processing that occurred lawfully before consent was withdrawn.
6. Google Analytics
With your consent, we use Google Analytics 4 to understand how visitors use the Mittworks website. Google Analytics is provided in Europe by Google Ireland Limited, Ireland. Google Analytics may collect pages viewed, date and time of visits, approximate geographical information, referring websites or sources, browser and device information, operating system, interactions with the website, session information and pseudonymous identifiers. Google Analytics uses cookies and similar technologies to distinguish users and sessions. Standard Google Analytics cookies include _ga, used to distinguish visitors, and ga[identifier], used to maintain session information. These cookies normally have a maximum lifetime of up to two years unless their settings are changed. Google states that Google Analytics 4 does not log or store individual IP addresses. We use Google Analytics solely to measure and improve the performance and usability of the Mittworks website. Google Analytics is activated only after you have consented to analytics technologies. The legal basis is Art. 6(1)(a) GDPR together with § 25(1) TDDDG. User-level and event-level Google Analytics data is retained according to the settings of our Analytics property and for no longer than the retention periods made available for a standard Google Analytics 4 property. Aggregated statistical reports may remain available for longer. Google may process data through companies or infrastructure outside the European Economic Area. Where required, Google uses recognised transfer mechanisms such as adequacy arrangements or Standard Contractual Clauses. You can withdraw your consent at any time through the website’s Cookie Settings.
7. Microsoft Clarity
With your consent, we use Microsoft Clarity to understand how visitors interact with the website and to identify areas where the website experience can be improved. Microsoft Clarity is provided to customers in the European Union by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Clarity provides behavioural website analytics such as clicks and taps, scrolling, mouse movement, navigation between pages, browser and device information, page and layout information, traffic sources, heatmaps and session replay. Session replay does not consist of a conventional video recording. Instead, Clarity records technical information about the page and visitor interactions and reconstructs the session for analysis. We use this information to understand how visitors navigate the website, identify usability problems and improve the website. Clarity may use first-party and third-party cookies and pseudonymous identifiers. Depending on the configuration, these may include _clck, _clsk, CLID, MUID, MR, ANONCHK and SM. Clarity is activated with cookies only after analytics consent has been provided. The legal basis is Art. 6(1)(a) GDPR together with § 25(1) TDDDG. Microsoft currently retains different categories of Clarity information for different periods. Standard playback data is generally retained for 30 days, while certain aggregated analytics, heatmaps and selected session information may be retained for up to 9 months. Microsoft stores Clarity data using Microsoft Azure infrastructure. Data may also be processed by Microsoft companies outside the European Economic Area. Microsoft uses appropriate transfer mechanisms, including Standard Contractual Clauses where applicable. You can withdraw your consent at any time through the website’s Cookie Settings.
8. No online booking or payment processing
Mittworks does not currently provide online booking or payment processing through this website. Accordingly, the website does not collect payment card information or process payments through providers such as Stripe or PayPal. If you subsequently arrange and pay for training outside the website, information connected with that transaction may be processed separately where necessary to perform the contract and comply with accounting and tax obligations.
9. No newsletter
Mittworks does not currently operate an email newsletter through this website. Contact information submitted through an enquiry form is not added to a marketing mailing list merely because you contacted us.
10. External links and social media
The website may contain normal links to third-party websites or social-media services. Third-party social-media feeds, videos, maps or similar services are not currently embedded directly into the website. When you click an external link, you leave the Mittworks website. Any processing that subsequently takes place is controlled by the operator of the external service and is subject to that provider’s privacy information.
11. Recipients of personal data
We only disclose personal data where this is necessary for operating the website, communicating with you, providing our services, complying with legal requirements or pursuing legitimate legal interests. Depending on the circumstances, recipients or service providers may include Framer B.V. for website hosting and forms; Microsoft for Outlook email and Microsoft Clarity; Google for Google Analytics; technical service providers assisting with the operation or security of the website; and accountants, legal advisers or public authorities where disclosure is required or legally justified. We do not sell personal data.
12. International data transfers
Some of the technology providers used by Mittworks operate internationally and may process personal data outside Germany or the European Economic Area. Where the GDPR requires additional safeguards for such transfers, processing takes place on the basis of an applicable adequacy decision, the EU-U.S. Data Privacy Framework where applicable, Standard Contractual Clauses approved by the European Commission, or another legally recognised transfer mechanism.
13. Retention of personal data
We retain personal data only for as long as necessary for the purpose for which it was collected. The relevant retention period depends on the nature of the information and may be affected by contractual, accounting, tax or legal obligations. In particular: general enquiries are retained only for as long as necessary to respond to and manage the enquiry; information relating to an ongoing client relationship may be retained for the duration of that relationship; records subject to statutory retention obligations are retained for the required statutory period; Google Analytics data is retained according to the configured Analytics retention settings; and Microsoft Clarity data is retained according to the periods described in section 7. When information is no longer required and there is no legal basis to retain it, it is deleted or anonymised.
14. Your data protection rights
Subject to the requirements and limitations of the GDPR, you have the right to obtain information about personal data we process about you under Art. 15 GDPR; request correction of inaccurate data under Art. 16 GDPR; request deletion of your personal data under Art. 17 GDPR; request restriction of processing under Art. 18 GDPR; receive certain personal data in a portable format under Art. 20 GDPR; object to processing based on legitimate interests under Art. 21 GDPR; and withdraw consent at any time where processing is based on consent under Art. 7(3) GDPR. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. To exercise your rights, contact info@mittworksberlin.com.
15. Right to lodge a complaint
You have the right to lodge a complaint with a data protection supervisory authority. For Mittworks, the competent supervisory authority is Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59–61, 10555 Berlin, Germany. You may also contact another data protection authority where permitted by the GDPR.
16. Security
We take appropriate technical and organisational measures to protect personal data against accidental or unlawful loss, alteration, disclosure, destruction or unauthorised access. The website is delivered over an encrypted HTTPS connection.
17. Changes to this Privacy Policy
We may update this Privacy Policy when the website, our services, the technology providers we use or applicable legal requirements change. The version currently published on the website is the applicable version.
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