Privacy Policy

Last updated: 15 January 2026

Introduction

CipherDoctor AG ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal information when you visit our website at cipherdoctor.pro or use our student loan repayment strategy services.

Data Controller Information

CipherDoctor AG is the data controller responsible for your personal data. Our contact details are:

Data Collection

We collect and process the following types of personal data:

Information You Provide Directly

When you contact us or use our services, we may collect data we collect including:

  • Name and contact information (email address, phone number, postal address)
  • Financial information related to your student loans and repayment capacity
  • Employment and income details
  • Educational background and loan provider information
  • Communication preferences and consultation notes

Information Collected Automatically

When you visit our website, we automatically collect certain information through our data collection systems:

  • IP address and device information
  • Browser type and version
  • Pages visited and time spent on our website
  • Referring website and search terms used
  • Cookie and tracking technology data

Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

  • Consent: When you provide explicit consent for specific processing activities
  • Contract Performance: To provide our student loan advisory services
  • Legitimate Interests: For website analytics, service improvement, and business communications
  • Legal Obligation: To comply with applicable laws and regulations

How We Use Your Information

We use of your data and personal information for the following purposes:

  • Providing personalised student loan repayment strategies and financial counselling
  • Communicating with you about our services and responding to your enquiries
  • Processing payments and managing our client relationships
  • Improving our website functionality and user experience
  • Complying with legal and regulatory requirements
  • Protecting against fraud and ensuring website security

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please see our Cookie Policy.

Data Sharing and Disclosure

We do not sell your personal data to third parties. We may share your information in the following circumstances:

  • With service providers who assist us in delivering our services (under strict confidentiality agreements)
  • With regulatory authorities when required by law
  • With professional advisers (lawyers, accountants) for business purposes
  • In connection with a business merger, acquisition, or sale (with your consent)

International Data Transfers

Your personal data is primarily processed within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, including adequacy decisions or standard contractual clauses approved by the European Commission.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy. Generally, we keep client data for seven years after the end of our professional relationship to comply with legal and regulatory requirements. Website analytics data is typically retained for 26 months. You can request earlier deletion of your data, subject to our legal obligations.

Your Rights

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

  • Right of Access: Request a copy of the personal data we hold about you
  • Right to Rectification: Correct inaccurate or incomplete personal data
  • Right to Erasure: Request deletion of your personal data in certain circumstances
  • Right to Restrict Processing: Limit how we use your personal data
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Object: Object to processing based on legitimate interests or for direct marketing
  • Right to Withdraw Consent: Withdraw consent for processing where applicable

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include encryption, access controls, regular security assessments, and staff training on data protection principles.

Children's Privacy

Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date at the top of this page.

Contact Information

If you have any questions about this Privacy Policy, wish to exercise your rights, or need to contact us about data protection matters, please reach out to us:

Supervisory Authority

You have the right to lodge a complaint with the relevant data protection supervisory authority if you believe we have not handled your personal data in accordance with applicable law. In Germany, this is the Federal Commissioner for Data Protection and Freedom of Information (BfDI).

This Privacy Policy is governed by German and European Union data protection law. For any disputes arising from this policy, the courts of Frankfurt am Main, Germany shall have exclusive jurisdiction.