Privacy policy

1. Controller and privacy contact

Ferdi Gökce
Trading as FEGO Executive Mobility
Bramfelder Dorfplatz 12
22179 Hamburg
Germany

Email for privacy enquiries: info@fego-mobility.de
Telephone: +49 40 74 06 17 17

2. Website access, hosting and security

The website and business email accounts are hosted by IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany. Accessing the website involves processing technical connection information, including your IP address, time of access, requested page or file, the referring page where applicable, and browser, device and operating system information.

This is necessary to deliver the website, maintain availability and identify and resolve errors and attacks. The legal basis is Article 6(1)(f) GDPR; our legitimate interest is a secure, functioning website. IONOS processes hosting and email data within the infrastructure it provides. Under the IONOS terms, a data processing agreement forms part of the general terms for contracts concluded since 19 July 2022. IONOS acts as a processor under Article 28 GDPR for these services. The applicable contractual documents and annexes must be checked against the individual account documents and retained for our records before publication.

For its web hosting products, IONOS describes anonymised logging and retention of visitor information for eight weeks. The applicability of these details and any additional IONOS WebAnalytics reports to our WordPress plan remains to be confirmed. This pre-release version therefore does not guarantee that all hosting logs are deleted after precisely that period. IONOS information on web hosting data (German).

The website uses HTTPS. Technical safeguards reduce the risk of unauthorised access, although no exchange of information over the internet can be guaranteed entirely risk-free.

3. Journey and concierge enquiries

We process the information you provide to clarify your requirements, assess availability and feasibility, prepare a quotation and communicate with you. This includes your name, email address, telephone number and customer address: street, house number, postal code, city and country. You may also provide a title and company name.

Depending on the requested service, we also process pick-up and destination, date and time, passenger numbers, duration, preferred vehicle, luggage, travel programme and other preferences. Concierge enquiries may concern musical tickets, hotel reservations or a private jet request, for example. Please do not put identity document copies, payment details or sensitive health information in free-text fields.

Article 6(1)(b) GDPR applies where we take steps at your request before entering a contract or perform a contract with you. Necessary communication and coordination concerning business contacts or other passengers is based on Article 6(1)(f) GDPR. Our legitimate interest is handling and delivering the requested service. We may also receive these details from the person making the enquiry, your company or an appointed intermediary.

Required information: Fields marked with an asterisk are needed in our online enquiry process to assess your requirements and prepare an individual quotation. Your complete customer address is used to identify and address that quotation; your telephone number is used for questions and personal coordination. The form cannot be submitted without the required information. Initial contact is also possible by telephone or email. The privacy acknowledgement records that you have read the notice; it is not consent to advertising.

The quick selection on the home page passes the journey details to the full enquiry using an encrypted form submission. Pick-up, destination, date and passenger count are not added to the page link as parameters. An enquiry email is only triggered when the full enquiry form is submitted.

Transfer, hourly and event enquiries are sent to booking@fego-mobility.de; concierge enquiries go to concierge@fego-mobility.de. When sending is enabled, an automatic acknowledgement contains your enquiry details and a reference number. It is not a binding booking confirmation. Making an enquiry does not subscribe you to a newsletter.

4. Email delivery, logs and spam prevention

WordPress sends messages through FluentSMTP using our IONOS mailboxes. Delivery logs in the website database include the sender and recipient, subject, message content, sending time and success or failure status. Authorised staff and technical support personnel can access them for handling enquiries and resolving delivery problems.

Enquiry-related messages rely on Article 6(1)(b) GDPR or Article 6(1)(f) GDPR for business contacts. Delivery checks and troubleshooting rely on Article 6(1)(f) GDPR; our legitimate interest is reliable handling without lost or duplicate enquiries.

Delivery log retention: The system is configured for 14 days. Actual automatic deletion has not yet been fully verified because regular WordPress task spawning is disabled. Before publication, execution of the cleanup task through the hosting environment or another reliable arrangement must be demonstrated. This period concerns technical logs and does not automatically delete messages from our mailboxes.

The form uses a hidden check field, a security token and temporary submission limits to prevent automated and repeated submissions. An identifier is derived from the IP address using a secret key. It is not anonymous, but does not contain the IP address in plain text. The counter remains valid for ten minutes after the last counted submission.

Cloudflare Turnstile

We use Cloudflare Turnstile, provided by Cloudflare, Inc. (USA), to protect our forms from automated submissions and abuse. When a protected form is opened, your browser connects to Cloudflare. Technical signals, including your IP address, browser information, connection characteristics and the website accessed, are processed. Our verification request does not include the journey or contact details entered in the form.

The processing serves our legitimate interest in secure, reliable enquiry forms under Article 6(1)(f) GDPR. Cloudflare processes signals on our behalf to provide protection and also under its own responsibility to improve bot detection. Processing may take place in the USA and other countries. Information about processing, retention and international transfer safeguards is available in Cloudflare’s notices linked below. We do not store verification tokens permanently; they are valid for up to five minutes and can be used only once.

Cloudflare Turnstile Privacy Addendum · Cloudflare Privacy Policy · Cloudflare Data Processing Addendum

A technical record linking a derived enquiry identifier, reference and delivery status remains valid for one hour to prevent duplicate acknowledgements. An internal failure notice may be retained for one day. Expired records are removed upon access or through scheduled cleanup; regular execution is included in the pending deletion review. These safeguards rely on Article 6(1)(f) GDPR.

5. Email, telephone and WhatsApp

When you contact us by telephone or email, we use your contact details and message to deal with your request. Article 6(1)(b) GDPR applies to an envisaged or agreed service. Other business correspondence relies on Article 6(1)(f) GDPR and our legitimate interest in responding appropriately. General matters can be sent to info@fego-mobility.de, partnerships to partners@fego-mobility.de and invoice enquiries to accounting@fego-mobility.de.

The WhatsApp buttons are external links, with no embedded WhatsApp chat window in the FEGO design. Opening a link takes you to WhatsApp. If you send a message, we use your telephone number, any profile name and message to handle the enquiry on the legal bases above. This channel is optional; email and telephone are alternatives.

The European provider is WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. WhatsApp processes additional usage and connection information under its own terms, including outside the European Economic Area, particularly in the USA. Its stated transfer arrangements include adequacy decisions and EU standard contractual clauses. Further details and contacts are in the WhatsApp privacy policy.

5a. Credit card payments through Stripe

Every quotation includes an external link for credit card payment through Stripe. You enter card details on Stripe’s payment page; our website enquiry form does not collect card details. When a personalised payment link is created, necessary customer details, quotation information and payment amounts may already be transmitted to Stripe.

Stripe processes payment and contact information and, when its payment page is opened, technical information such as IP address and device details. We receive information needed to allocate and account for the payment, particularly its status, amount and transaction reference. We process this information to handle payment and fulfil the contract (Article 6(1)(b) GDPR), coordinate with business representatives where applicable (Article 6(1)(f) GDPR), and meet statutory documentation duties (Article 6(1)(c) GDPR). Section 9 describes the retention criteria for our records.

The providers involved include Stripe Payments Europe, Limited, Ireland, and other Stripe entities. Depending on the task, Stripe acts as a processor or an independent controller, for example for fraud prevention and statutory checks. Data may also be processed in the United States. Stripe’s Data Processing Agreement and Data Transfers Addendum describe the roles and safeguards, including EU Standard Contractual Clauses. Further details about information, retention, responsible entities and your rights are provided in Stripe’s privacy notice. Making a payment does not subscribe you to marketing emails.

6. Enquiries and marketing emails

The current website enquiry form does not offer a newsletter subscription or a marketing consent checkbox. Submitting an enquiry does not subscribe you to marketing emails. We use your enquiry details to respond, prepare a quotation and coordinate the requested service.

If a separate email subscription is offered in the future, information about the provider, purpose, recipients, retention and withdrawal options will be provided before registration. You can object to the use of your personal data for direct marketing at any time by emailing info@fego-mobility.de. Necessary messages concerning your enquiry or booking remain separate from marketing.

7. Recipients and service partners

Within our business, access is given to those handling your enquiry or coordinating the service. Necessary hosting, email and appointed IT providers are also involved. Providers may process only the information necessary for their task; Article 28 GDPR applies where they act as processors.

Delivering your requested service may require sharing selected information with chauffeurs, transport partners or, for concierge services, hotels, ticket providers and air travel intermediaries. We share the details needed for the relevant arrangements or reservation. The specific service and partners are discussed personally. This relies on Article 6(1)(b) GDPR or Article 6(1)(f) GDPR for other passengers and business contacts.

Where legally required, information may also be disclosed to competent authorities or advisers subject to professional confidentiality. The basis is Article 6(1)(c) GDPR or Article 6(1)(f) GDPR for establishing or defending claims.

An international service you request may involve recipients outside the European Economic Area. Before a transfer, the recipient and applicable requirements of Articles 44 onwards GDPR must be established, such as an applicable adequacy decision, appropriate safeguards or a permitted exception in the individual case. Contacting us is not blanket consent to international transfers. Section 5 contains additional information about WhatsApp.

8. Cookies, fonts and embedded services

Storing information on or accessing information from your device is governed by section 25 of the German TDDDG. Operations strictly necessary to transmit a communication or provide a service you expressly request may be permitted without consent. Other technologies, particularly non-essential analytics or advertising tools, require valid consent before use. Processing personal data also requires a GDPR legal basis.

The reviewed FEGO forms do not themselves set analytics or advertising cookies. Technically necessary login and session information may be used for signed-in WordPress users and the protected preview. This supports authentication, access protection and the requested preview, rather than a customer advertising profile.

Fonts for the FEGO design are served locally. We use Cloudflare Turnstile to protect the forms against automated enquiries. Further information is provided in section 4. WhatsApp is provided as an external link. The reviewed FEGO page content contains no embedded external maps, video players or payment forms. Additional hosting features and cookies will be checked before publication. If further services are added later, the notices and any necessary consent controls will be updated first.

9. Retention and deletion

Enquiry and contact information should be retained only as long as needed to handle the request, deliver the agreed service or meet legal obligations. For an enquiry that does not lead to an order, the processing purpose ends when the matter is settled and no follow-up or continuation is expected. Further retention requires a reason, such as specific legal claims or statutory obligations.

If an order is placed, further retention depends on the document type, for example contracts, business correspondence, invoices and accounting records. The applicable commercial and tax retention requirements govern the period and when it starts. Data needed only for such obligations must be restricted to that purpose.

Backups may retain information until overwritten in the regular backup cycle. If data is restored, previous deletion actions must be reapplied. The operational retention and backup arrangements, including mailboxes and hosting logs, must be fully documented before publication. Section 4 describes configured technical retention periods and the outstanding deletion check.

10. Your rights

Subject to the respective legal conditions, you have rights of access to your personal data (Article 15 GDPR), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18) and data portability (Article 20). Portability applies in particular to data you provide that is processed by automated means on the basis of consent or a contract.

Objection: Under Article 21 GDPR, you may object to processing based on Article 6(1)(f) GDPR on grounds relating to your particular situation. You may object to direct marketing at any time without giving a reason.

Where processing relies on your consent, you may withdraw it at any time for the future. This does not affect the lawfulness of processing before withdrawal. To exercise your rights, use the contact details in section 1.

You may also complain to a data protection supervisory authority, particularly where you live or work or where the alleged infringement occurred. In Hamburg: Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit, Ludwig-Erhard-Str. 22, 20459 Hamburg, Germany; email: mailbox@datenschutz.hamburg.de; website: datenschutz-hamburg.de.

We make decisions about offers and providing journeys personally. These decisions are not based solely on automated processing producing legal or similarly significant effects within the meaning of Article 22 GDPR.