1. Introduction and General Principles
This Privacy Policy describes how Sagacious Wonderer e.K. (“the Controller”) collects, uses, and protects the personal data of visitors (“the User” or “the Visitor”) to the website uberti.eu (“the Site”).
The protection of Users’ personal data is a priority for the Controller. This document is drafted in accordance with major international regulations, including Regulation (EU) 2016/679 (GDPR) and the California Consumer Privacy Act (CCPA/CPRA).
This policy applies to the Site and all services offered by it.
This document is provided in multiple languages for the convenience of users. The German language version is the sole legally binding version and shall prevail in the event of any discrepancies, disputes, or interpretative differences between the German version and any translation, in accordance with the Controller’s legal seat in Germany.
Use of the Site is conditional upon acceptance of the terms described in this document and in the Terms and Conditions.
2. Data Controller
The Data Controller for personal data is:
email: privacy@swek.com.de
postal address:
c/o COCENTER
Koppoldstr. 1
86551 Aichach
Germany
phone: +49 015678 897006
Contact via email is always preferred for any inquiries.
3. Data Security
The Controller implements appropriate technical and organisational security measures to prevent data loss, unlawful or incorrect use of data, and unauthorised access.
The site uses the SSL/TLS encryption protocol to protect communication.
In the event of a personal data breach, the Controller undertakes to notify the competent supervisory authority within 72 hours, as required by the GDPR, and to communicate the breach to the data subjects if it is likely to result in a high risk to their rights and freedoms.
4. Data Processed, Purposes, Legal Basis, and Retention Period
Different types of data are collected for the purposes and on the legal bases set out below.
It should be noted that most processing activities are technically managed by external service providers (third parties).
Site Navigation
- Data collected:
IP address (potentially anonymised), browser type, device parameters, pages visited, data collected via essential technical cookies. - Purpose:
To ensure the proper functioning and security of the Site and to obtain aggregated and anonymous statistical data on its use. - Legal basis:
The Controller’s legitimate interest (Art. 6(1)(f) GDPR) to maintain a secure and functional website. - Retention period:
Log data for up to 12 months; for cookies, please refer to the Cookie Policy.
Newsletter Subscription
- Data collected:
First name, last name, email address. - Purpose:
To send the newsletter, containing updates and travel tips. - Legal basis: Performance of a service requested by the User (Art. 6(1)(b) GDPR).
- Retention period:
Until the User unsubscribes (via the dedicated link in each email or by contacting the Controller).
For managing and sending the newsletter, this Site uses the platform Substack. When a User subscribes, their data (name, email address) is processed by Substack as the service provider.
Subscribing implies acceptance of Substack’s terms of service and privacy policy.
For more details, please consult the Substack Privacy Policy.
Affiliate Marketing
- Data collected:
Browse and purchase behaviour data tracked via third-party cookies or pixels (e.g., clicks on a link, purchases made on the partner site). - Purpose:
To allow the Controller to earn a commission on eligible purchases made by the User on affiliate partner sites, at no additional cost to the User. This helps to support the costs of running the blog. - Legal basis:
The User’s explicit consent (Art. 6(1)(a) GDPR), collected via the cookie banner. - Retention period:
Determined by the affiliate partner’s cookie (typically from 24 hours to 90 days). For more details, please refer to the Cookie Policy.
5. Affiliate Marketing Disclosure
This Site participates in affiliate programs to support itself economically. Some articles contain links to external products or services (e.g., hotels, tours, products on Amazon). If the User clicks on one of these links and makes a purchase, the Controller receives a small commission from the seller, at no additional cost to the User.
The tracking process is managed entirely by the affiliate partners’ technologies (cookies or pixels). The Controller does not directly collect or process any data related to this specific activity.
As an Amazon Associate, the Controller earns from qualifying purchases.
6. Data Sharing and Communication (Recipients)
Users’ personal data is not sold. It is shared with the following categories of third parties only when strictly necessary for the purposes described:
- Technical service providers:
Such as the hosting provider for the operation of the Site. - Newsletter platforms:
Such as Substack, which technically manages the sending of emails. - Affiliate networks:
Such as the Amazon Services LLC Associates Program, for tracking commissions. - Statistical analysis platforms:
Such as Google Analytics (with anonymised IP), to analyse Site traffic. - Competent authorities:
When required by a legal obligation.
These providers act as Data Processors on behalf of the Controller and have been selected for their guarantees of compliance with the regulations.
7. Data Transfers Outside the European Union
Some of the listed service providers (e.g., Google, Substack, Amazon) are based or have servers outside the European Economic Area (EEA), particularly in the United States. The transfer of data to these countries is legitimised by specific legal safeguards such as European Commission Adequacy Decisions (e.g., the EU-U.S. Data Privacy Framework) or the adoption of Standard Contractual Clauses (SCCs), which ensure an adequate level of protection.
8. User Rights Regarding Data Protection
Under the GDPR, the User (as the “data subject”) has the right to:
- Access your personal data.
- Rectify inaccurate data or complete incomplete data.
- Erase your data (right to be forgotten) under certain circumstances.
- Restrict the processing of your data.
- Receive your data in a structured, commonly used and machine-readable format (portability).
- Object to processing based on legitimate interest.
- Withdraw consent at any time.
For data processed by third-party service providers as independent controllers (e.g., Affiliate Networks), you may need to exercise your rights directly with them.
Rights for Users residing in California (CCPA/CPRA) For Users residing in California, local law provides specific rights, including:
- The right to know what personal data is collected and shared.
- The right to request the deletion of personal data.
- The right to “Opt-out” from the “sale” or “sharing” of personal information. This right can be exercised by managing your preferences via the cookie banner.
To exercise any of these rights, you can contact the Controller at the email address: privacy@swek.com.de
Requests will be processed within one month of receipt notification, subject to extension in cases of particular complexity.
The User also has the right to lodge a complaint with the competent supervisory authority.
The competent supervisory authority for the Data Controller is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA). However, the user has the right to contact the supervisory authority in their own state of residence.
9. Protection of Minors
The services offered by this Site are intended for an audience over the age of 18. The Controller does not knowingly collect or process personal data relating to minors under 18 years of age without parental consent. If the Controller becomes aware of the existence of such data, it will be deleted immediately.
10. Changes to this Privacy Policy
The Controller reserves the right to make changes to this privacy statement. It is recommended to consult this document regularly to be aware of any changes.
Last updated: 7 August 2025
Please also refer to the following documents: