Privacy policy

This is a translation for your convenience. Only the German version is legally binding.

Last updated: October 2026

1. Controller

The controller responsible for processing personal data on this website within the meaning of the General Data Protection Regulation (GDPR) is:

DigitalTwin Technology GmbH
Schaafenstraße 25
50676 Köln
Germany
Phone: +49 176 98770263
Email: info@digitaltwin.technology

This policy applies to the website pasvyn.com. The pasvyn services themselves (payment page, app, operator dashboard) have their own privacy notices.

2. In short

• This website sets no cookies and uses no analytics or tracking tools.
• We embed no third-party content. The typeface, scripts and 3D model are loaded from our own web space.
• We do not store any information on your device or read any from it.
• Personal data is processed only as far as needed to deliver the website (server log files) or to answer your enquiry.

3. Hosting and server log files

This website is hosted by IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany. When you visit the website, the web server automatically processes the following data sent by your browser:

• IP address of the requesting device,
• date and time of access,
• file or address (URL) requested and referrer URL,
• browser type and version, operating system,
• amount of data transferred and HTTP status code.

Purpose: delivering the website and keeping it stable and secure, for example to fend off attacks. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is providing the website securely and reliably. Retention: the log files are deleted or anonymised automatically after a short time, unless they are needed longer to investigate a specific security incident.

We have concluded a data processing agreement with IONOS under Art. 28 GDPR. IONOS processes the data only on our instructions.

4. Contact by email or phone

When you contact us, for example to arrange a demo, we process the data you give us (such as name, company, email address, phone number and the content of your message) to handle your enquiry.

Legal basis: Art. 6(1)(b) GDPR where your enquiry relates to a contract or pre-contractual steps; otherwise Art. 6(1)(f) GDPR, our legitimate interest in answering enquiries. Retention: we delete the data once your enquiry has been dealt with, unless statutory retention obligations apply (such as six years for business letters under § 257 of the German Commercial Code and up to ten years under § 147 of the German Fiscal Code).

5. Nothing stored on your device

We set no cookies and use neither local storage nor similar techniques. If you choose the light or dark design, the choice applies only to the open page; when you follow links within our website, it is passed on as part of the address (e.g. ?theme=dark). This does not identify you. Your browser may keep files of this website in its cache so that they load faster; this is technically necessary for the transmission.

6. Encryption

This website uses SSL/TLS encryption. You can recognise an encrypted connection by "https://" in your browser's address bar.

7. Recipients and transfers to third countries

We do not pass your data on to third parties. The only recipients are our processors (web hosting and email), whom we have selected carefully and bound by contract. No data is transferred to countries outside the European Union or the European Economic Area.

8. Your rights

Under the GDPR you have the right to

• access the data we process about you (Art. 15 GDPR),
• rectification of incorrect data (Art. 16 GDPR),
• erasure (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR).

Right to object (Art. 21 GDPR): where we process data on the basis of Art. 6(1)(f) GDPR, you may object to this processing at any time on grounds relating to your particular situation.

To exercise your rights, an informal message to info@digitaltwin.technology is enough.

Right to lodge a complaint (Art. 77 GDPR): you may complain to a data protection supervisory authority, in particular in the member state of your residence, place of work or the place of the alleged infringement. The authority responsible for us is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestraße 2–4, 40213 Düsseldorf, Germany, www.ldi.nrw.de.

9. Obligation to provide data, automated decisions

You are not obliged by law or contract to provide personal data. Without the server log data, however, the website cannot be delivered, and without contact details we cannot answer your enquiry. There is no automated decision-making, including profiling (Art. 22 GDPR).

10. Changes

We update this privacy policy when the website or the law changes. The version published here applies.