Privacy Policy


xcircle UG (limited liability)
c/o ICAA GmbH
Belgradstr. 19
80796 Munich

Managing Shareholders:
Dr. Annette Doms | Christina Brugger

Register: Local Court Munich | HRB 275966

Contact us

T: +49 (0) 178 2663366



Privacy policy

This privacy policy informs you about the nature, scope and purpose of the processing of your personal data in connection with the website and the services associated with it, in particular the use of this website and the purchase of artworks via this website.

1. Data controller and contact details

The data controller in connection with the website is:

xcircle UG (limited liability)

Dr. Annette Doms/Christina Brugger

Belgrade Street 19

80796 Munich 

Phone: +49 178 2663366



2. Processing of data

 Visiting the website

When you visit our website, the browser you use automatically sends information to our website server. The following information is temporarily stored in log files:

- Date and time of access to the website,

- Your internet protocol address (IP address),

- Internet service provider of the accessing system,

- type of browser used and the operating system,

- the amount of data transferred in each case

- Websites from which you have accessed our website,

- Websites that are accessed by your system via our website.

The data is processed to ensure the functionality of our website. In addition, the data serves the technical optimisation of the website as well as the security and stability of our information technology systems. We do not use this data for marketing purposes or to draw conclusions about your person. 

The legal basis for the storage of the data and log files is Art. 6 para. 1 p. 1 lit. f DSGVO (legitimate interest). The legitimate interest follows from the above-mentioned purposes.

The personal data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. When data is stored in log files, the data is deleted after seven days at the latest. If data is stored beyond this period, your IP address will be deleted or made anonymous. 

2.1 Contacting us

If you contact us (e.g. by e-mail, contact form, telephone or social media), your personal data will be processed in order to handle the contact request and its processing. 

The legal basis for this processing of the transmitted data is Art. 6 para. 1 p. 1 lit. b DSGVO (legitimate interest). The legitimate interest results from the fact that we can only carry out the action desired by the user (e.g. answering enquiries) by processing the user's data accordingly. If the contact is aimed at the possibility of concluding a purchase contract with us or another business relationship or an employment contract, Article 6 (1) sentence 1 lit. b 2.2 DSGVO (contract performance and pre-contractual measures) is also or alternatively the legal basis for the processing. 

We delete this data as soon as it is no longer required to achieve the purpose for which it was collected, i.e. regularly when the respective conversation with you has ended. The conversation is ended when the matter in question has been finally clarified. Otherwise, the statutory retention periods apply. This data is not passed on to third parties.

2.3 Newsletter

Consent to the processing of personal data for sending the newsletter.

With your consent, you agree that xcircle UG (limited liability)) may process your personal data in accordance with the following conditions in order to send you our newsletter and similar information by email.

2.3.1 Processing of personal data

The personal data we process includes your e-mail address and optionally your first and last name and title. This information is used to be able to send you our newsletter personally.

2.3.2 Purpose of the data processing

Your data will be used exclusively for sending our newsletter and comparable information. The newsletter contains news, offers, event invitations and other relevant information in connection with and our services.

2.3.3 Consent and revocation

The legal basis for the processing of personal data in this context is Art. 6 para. 1 lit. p. 1 a) DSGVO (consent). 

By ticking the following box, you expressly consent to your personal data being processed in accordance with this declaration of consent:

[ ] I would like to receive the newsletter from and consent to the processing of my personal data for this purpose.

You have the right to withdraw this consent at any time by contacting us or clicking on the unsubscribe link contained in our emails. The withdrawal of your consent will not affect the lawfulness of the processing that was carried out on the basis of your consent prior to the withdrawal. Alternatively, you can send your unsubscribe request by email to the contact details provided in section 1 above.

2.3.4 Storage period

Your personal data will be stored for as long as you have subscribed to the newsletter. If you unsubscribe from the newsletter, your data will be deleted immediately, provided that there are no legal storage obligations to the contrary.

2.3.5 Data protection

We protect your data in accordance with the applicable data protection laws and take appropriate security precautions to prevent unauthorised access or disclosure.

By providing your consent, you acknowledge and agree to's privacy policy.

We appreciate your trust and assure you that your data will only be used in accordance with the conditions described here.

2.4 Cookies and Tracking

We use so-called cookies on our website. These are small text files that are automatically stored in the internet browser or by the internet browser on your end device (e.g. computer, tablet, smartphone, etc.) when you visit our website. These cookies contain characteristic sequences of lines that enable the internet browser to be uniquely identified when the website is called up again. We use cookies to make our website more user-friendly. These cookies enable us to automatically anonymise that you have already visited our website when you visit it again. These cookies are automatically deleted after a defined period of time. 

The legal basis for the above processing of personal data is Art. 6 para. 1 p. 1 lit. f) DSGVO (legitimate interest). The legitimate interest follows from the above-mentioned purposes, to anonymise the use of the website and to improve your user experience.

You can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time using an Internet browser or other software programmes. This is possible in all common Internet browsers. If you deactivate the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

2.5 Google Analytics

This website uses Google Analytics (including the Google Optimize and Google Universal Analytics functions), a web analysis service from Google. If you do not consent to the use of this tool when (first) accessing the website, no personal data of yours will be processed with the help of this tool. This service enables us to evaluate the use of our website and collect information about the needs of users in order to improve the user-friendliness and quality of our online services. In order to be able to carry out these evaluations, aggregated and anonymous statistical data in particular are collected. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site.

The information generated by the cookie about your use of the website is generally transmitted to a Google server in the USA and stored there. Since this website uses IP Anonymisation, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

You can prevent the storage of the corresponding cookies by making the appropriate setting in your browser software. However, we would like to point out that in this case you may not be able to use all the functions of the website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following location.

Further information on Google Analytics can be found here:

Terms of Service | Google Analytics – Google

The legal basis for the processing of personal data described above is Art. 6 para. 1 sentence 1 lit. a) DSGVO (consent).

3. Data transfer to third parties

The personal data collected in connection with the use of the website will not be passed on to third parties or transmitted in any other way without your consent, except in cases expressly described in this data protection declaration.

Exceptions to this are the transfer of personal data in the case of a legal obligation to disclose (e.g. to state institutions and authorities), insofar as we are legally obliged to do so. The legal basis for this processing of your personal data is Art. 6 para. 1 sentence 1 lit. c) DSGVO (fulfilment of a legal obligation).

For the operation of the website and the services offered on the website (for example, hosting of the website or newsletter dispatch), we may use external service providers who process your personal data on our behalf. These service providers process the data exclusively in accordance with our instructions. The legal basis for such data processing is Art. 28 DSGVO (commissioned processing).

4. Duration of storage of your personal data

Insofar as no other storage period results from the other provisions of this data protection declaration, we generally only store your personal data obtained by us in connection with the use of the website for as long as this is necessary to fulfil the corresponding processing purpose (e.g. to process your requests or enquiries to us), thereafter only to the extent and insofar as we are obliged to do so due to legal storage obligations. If we no longer need your data for the purposes described above, it will only be stored for the relevant statutory retention period and not processed for other purposes.

5. Your rights

You have the right to request information about your personal data stored by us at any time. Insofar as the legal requirements are met, you also have the right to demand that we correct, delete or restrict the processing of the relevant data, the right to object to the processing of your data by us and the right to receive the personal data relating to you from us in a structured, standard and machine-readable format. If you have given your consent to the use of personal data, you may withdraw this consent at any time.

If you believe that our processing of your personal data violates applicable data protection law, you may lodge a complaint with the competent data protection supervisory authority.