Privacy Policy

1. Data Controller

The data controller responsible under the General Data Protection Regulation (GDPR) and other applicable data protection laws is:

2. General Information

Protecting your personal data is important to us. We process personal data collected when you visit our website in accordance with the GDPR, the German Federal Data Protection Act (BDSG), and the Telecommunications Digital Services Data Protection Act (TDDDG). This policy describes what data we collect on this website, for what purpose, and what rights you have.

This website currently serves exclusively as an information page ("Coming Soon"). The website itself does not use contact forms, user accounts, ordering functions, analytics or tracking tools, or cookies for marketing or measurement purposes. Outside the website, however, we process personal data through our customer relationship management (CRM) system and lead campaigns on third-party platforms (see sections 5 and 6).

3. Website Provision and Server Log Files

When you access our website, our hosting provider automatically collects and stores information in server log files transmitted by your browser, including:

• Anonymized IP address of the accessing computer
• Date and time of access
• Name and URL of the requested file
• Referrer URL (previously visited page)
• Browser used, operating system, and device type
• Amount of data transferred and HTTP status code

This data cannot be assigned to any individual. Processing is based on Article 6 (1) lit. f GDPR. Our legitimate interest lies in the technically error-free presentation, stability, and security of our website. Log files are deleted after 30 days at the latest, unless further retention is required for evidentiary purposes.

4. Contact via Email or Phone

If you contact us by email or phone, your information will be stored to process your request and to respond to follow-up questions. The legal basis is Article 6 (1) lit. b GDPR if your inquiry relates to the performance of a contract or pre-contractual measures; in all other cases, Article 6 (1) lit. f GDPR (our legitimate interest in effectively answering inquiries).

Your data will be deleted once it is no longer required for the stated purpose, provided that no statutory retention obligations (particularly under HGB and AO) apply.

5. Customer Relationship Management (Salesforce / CRM)

To manage our prospects and customer contacts and to conduct our communication, we use the CRM system Salesforce. The provider is Salesforce, Inc., Salesforce Tower, 415 Mission Street, San Francisco, CA 94105, USA, and its European subsidiaries (jointly "Salesforce").

In Salesforce, we process in particular the following data: first and last name, salutation, postal address, email address, phone number, information from your inquiry or contact, communication history, processing status information, and where applicable, information about your professional role or company.

Purposes of processing include:

• Processing and answering inquiries and providing advice on our aligner solutions
• Documenting customer communication and maintaining customer history
• Initiating, executing, and managing contractual relationships
• Sending informational, service, and marketing emails (newsletters, product information, invitations)
• Segmentation and analysis of contacts to optimize our outreach

Legal bases are:

• Article 6 (1) lit. b GDPR — initiation and performance of contractual relationships
• Article 6 (1) lit. a GDPR in connection with Section 7 (2) UWG — your consent for promotional email communication (mailings, newsletters)
• Article 6 (1) lit. f GDPR — our legitimate interest in efficient customer service and, in B2B contexts and within the limits of Section 7 (3) UWG, in maintaining existing business relationships

You may withdraw your consent to receive promotional communications at any time with future effect, for example via the unsubscribe link in each mailing or by informal notice using the contact details in section 1.

International data transfer: Salesforce is a US provider; processing of your data in the USA or other third countries cannot be excluded. We have concluded a data processing agreement with Salesforce (Article 28 GDPR). Data transfer to the USA is based on the EU-US Data Privacy Framework (European Commission adequacy decision of 10.07.2023), under which Salesforce is certified, as well as supplemented by the Standard Contractual Clauses (SCC, Implementation Decision (EU) 2021/914) with appropriate additional safeguards.

Your data will be stored in Salesforce as long as necessary for the stated purposes, in the case of marketing consents until withdrawn, and otherwise subject to applicable commercial and tax law retention requirements.

For more information on data protection at Salesforce: https://www.salesforce.com/company/legal/privacy/.

6. Meta Lead Ads (Facebook / Instagram)

We run ads on Facebook and Instagram in the Lead Ads format. The provider of these services is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland ("Meta"). When you respond to such an ad, a form opens within the respective platform, allowing you to provide us with your contact details (e.g., name, email address, phone number, and any other information you provide regarding your inquiry).

Processing flow: The data is first collected and processed by Meta on their infrastructure; it is then transmitted to us (Modern Me GmbH / modern clear) so we can respond to your inquiry and contact you about our services. After transmission to us, we process the data in our CRM system (see section 5) for the purposes stated there.

Purposes are reaching potential prospects, generating leads, and subsequently contacting and advising them. Legal basis for our processing is your explicit consent, which you provide by submitting the Lead form (Article 6 (1) lit. a GDPR, Section 7 (2) UWG), and Article 6 (1) lit. b GDPR for pre-contractual measures. You may withdraw your consent at any time with future effect.

Joint responsibility: To the extent Meta and we jointly determine the purposes and means of processing — particularly in collecting and initially evaluating Lead form data on the platform — joint responsibility exists under Article 26 GDPR. We have entered into an appropriate agreement with Meta ("Controller Addendum" / "Joint Controller Addendum") that regulates responsibilities. Regardless, you may assert your data subject rights against both us and Meta.

International data transfer: Meta processes data in the USA as well. The transfer is based on the European Commission's adequacy decision under the EU-US Data Privacy Framework, under which Meta is certified, as well as supplemented by the European Commission's Standard Contractual Clauses for transfers outside the framework.

For more information on data processing by Meta and your rights and settings options, see Meta's privacy policy: https://www.facebook.com/privacy/policy and for Lead Ads specifically: https://www.facebook.com/business/help/1474565210974879.

7. Fonts and Icons

The fonts used on this website ("Be Vietnam Pro", "Inter") and the icon set ("Material Symbols Outlined") are served locally from our own server. When you access our page, there is no connection to Google servers or other third-party CDNs, and no personal data (in particular, no IP address) is transmitted to third parties for this purpose.

8. Cookies

This website does not use cookies that would require consent under Section 25 (1) TDDDG. In particular, no analytics, advertising, or tracking cookies are used.

9. SSL/TLS Encryption

This website uses SSL/TLS encryption for security and to protect the transmission of confidential content. You can recognize an encrypted connection by the address bar changing from "http://" to "https://" and a padlock icon in your browser bar.

10. Your Rights as a Data Subject

Under the GDPR, you have the following rights regarding your personal data:

• Right of access (Article 15 GDPR)
• Right to rectification (Article 16 GDPR)
• Right to erasure (Article 17 GDPR)
• Right to restrict processing (Article 18 GDPR)
• Right to data portability (Article 20 GDPR)
• Right to object to processing (Article 21 GDPR)
• Right to withdraw consent with future effect (Article 7 (3) GDPR)

To exercise your rights, simply contact us using the contact details in section 1.

11. Right to Lodge a Complaint

Notwithstanding any other legal remedies, you have the right to lodge a complaint with a data protection authority, in particular in the Member State of your residence, place of work, or where the alleged infringement occurred. The competent authority for us is:

State Commissioner for Data Protection and Information Freedom (Landesbeauftragte für Datenschutz und Informationsfreiheit) North Rhine-Westphalia
Kavalleriestraße 2–4
40213 Düsseldorf
www.ldi.nrw.de

12. Objection to Direct Marketing

We hereby object to the use of contact information published under legal disclosure requirements for sending unsolicited advertising and promotional materials. The operators of this website explicitly reserve the right to take legal action in the event of unsolicited transmission of advertising information, such as spam emails.

13. Currency and Updates to This Privacy Policy

This privacy policy is currently valid and has the status of April 2026. As our website and offered services develop or due to changes in legal or regulatory requirements, it may become necessary to update this privacy policy. You can access the current version at any time on this page.