Privacy Policy

1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. Detailed information on data protection can be found in our privacy policy, which is linked below.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. Their contact details can be found in the section "Information on the responsible body" in this privacy policy.

How do we collect your data?

Your data is collected, firstly, because you provide it to us. This could include, for example, data that you enter into a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you access this website.

What do we use your data for?

Some data is collected to ensure the website functions correctly. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right to obtain information free of charge at any time regarding the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. Furthermore, you have the right, under certain circumstances, to request the restriction of the processing of your personal data. You also have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time with regard to this and other questions concerning data protection.

2. Hosting

IONOS

We host our website with IONOS SE. The provider is IONOS SE, Elgendorfer Str. 57, 56410 Montabaur (hereinafter referred to as IONOS). When you visit our website, IONOS collects various log files, including your IP address. For details, please see the IONOS privacy policy: https://www.ionos.de/terms-gtc/terms-privacy.

The use of IONOS is based on Article 6(1)(f) GDPR. We have a legitimate interest in ensuring the most reliable presentation of our website possible. If corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

Order processing

We have concluded a data processing agreement (DPA) with the aforementioned provider. This is a legally required contract under data protection law, which ensures that the provider processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

3. General information and mandatory disclosures

Data protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data are collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g., when communicating via email) can have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Note regarding the responsible body

The responsible body for data processing on this website is:

Kevin Sternad

Apfelstraße 36, 52525 Heinsberg, represented by: Kevin Sternad

Telephone: 49 157 39342024 Email: info@lieblingsimmo.de

The responsible entity is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).

Storage duration

Unless a more specific retention period is stated within this privacy policy, your personal data will remain with us until the purpose for processing the data no longer applies. If you submit a legitimate request for erasure or withdraw your consent to data processing, your data will be deleted, provided we have no other legally permissible grounds for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the data will be deleted once these grounds cease to apply.

General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Article 6(1)(a) GDPR or Article 9(2)(a) GDPR if special categories of data pursuant to Article 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing also takes place on the basis of Article 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g., via device fingerprinting), data processing additionally takes place on the basis of Section 25(1) of the German Telecommunications and Telemedia Data Protection Act (TTDSG). You can withdraw your consent at any time. If your data is required for the performance of a contract or for taking steps prior to entering into a contract, we process your data on the basis of Article 6(1)(b) GDPR. Furthermore, we process your data if it is necessary for compliance with a legal obligation, on the basis of Article 6(1)(c) GDPR. Data processing may also be based on our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. Information on the applicable legal bases in each individual case is provided in the following paragraphs of this privacy policy.

Notice regarding data transfer to the USA and other third countries

We use tools from companies based in the USA or other third countries that do not offer adequate data protection. When these tools are active, your personal data may be transferred to and processed in these third countries. Please note that a level of data protection comparable to that of the EU cannot be guaranteed in these countries. For example, US companies are obligated to disclose personal data to security authorities without you, as the data subject, having any legal recourse. Therefore, it cannot be ruled out that US authorities (e.g., intelligence agencies) may process, analyze, and permanently store your data located on US servers for surveillance purposes. We have no control over these processing activities.

Revocation of your consent to data processing

Many data processing operations are only possible with your explicit consent. You can revoke your consent at any time. The legality of data processing carried out before the revocation remains unaffected by the revocation.

Right to object to data processing in special cases and to direct marketing (Art. 21 GDPR)

If data processing is based on Article 6(1)(e) or (f) of the GDPR, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you; this also applies to profiling based on these provisions. The specific legal basis for each processing operation can be found in this privacy policy. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves the purpose of establishing, exercising or defending legal claims (objection pursuant to Art. 21 para. 1 GDPR).

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object, your personal data will subsequently no longer be processed for direct marketing purposes (objection pursuant to Article 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged infringement. This right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to data portability

You have the right to receive the data that we process automatically based on your consent or in fulfillment of a contract, either for yourself or for a third party, in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done if technically feasible.

SSL or TLS encryption

This site uses SSL/TLS encryption for security reasons and to protect the transmission of confidential information, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the browser's address bar changes from "http://" to "https://" and by the lock symbol in your browser's address bar.

When SSL or TLS encryption is enabled, the data you send to us cannot be read by third parties.

Information, deletion and correction

Under applicable law, you have the right to request information, free of charge, about your stored personal data, its origin and recipients, and the purpose of the data processing, as well as the right to rectification or erasure of this data. You can contact us at any time with regard to this and any other questions concerning personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time to do so. The right to restrict processing exists in the following cases:

• If you dispute the accuracy of your personal data stored with us, we generally need time to verify this. For the duration of the verification process, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
• If we no longer need your personal data, but you require it for the establishment, exercise or defense of legal claims, you have the right to request restriction of processing of your personal data instead of erasure.
• If you have objected to processing pursuant to Article 21(1) GDPR, a balancing of interests between your interests and ours must be carried out. Until it is determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from being stored – may only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

Objection to advertising emails

The use of contact details published as part of the legal notice for sending unsolicited advertising and informational materials is hereby prohibited. The operators of these pages expressly reserve the right to take legal action in the event of unsolicited advertising, such as spam emails.

4. Data collection on this website

Cookies

Our website uses so-called "cookies." Cookies are small text files that do not harm your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are automatically deleted after you leave our website. Persistent cookies remain stored on your device until you delete them yourself or until they are automatically deleted by your web browser.

In some cases, cookies from third-party companies may also be stored on your device when you visit our site (third-party cookies). These enable us or you to use certain services provided by the third-party company (e.g., cookies for processing payment services).

Cookies serve various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies are used to analyze user behavior or to display advertising.

Cookies that are necessary for carrying out electronic communication, for providing certain functions you have requested (e.g., for the shopping cart function), or for optimizing the website (e.g., cookies for measuring website traffic) (necessary cookies) are stored on the basis of Article 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies to ensure the technically flawless and optimized provision of its services. If consent to the storage of cookies and similar recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Article 6(1)(a) GDPR and Section 25(1) TTDSG); this consent can be revoked at any time.

You can configure your browser to notify you when cookies are set and to allow cookies only in individual cases, to accept cookies in certain cases or to generally reject them, and to automatically delete cookies when you close your browser. Disabling cookies may limit the functionality of this website.

If cookies from third-party companies or for analysis purposes are used, we will inform you separately about this within the framework of this privacy policy and, if necessary, request your consent.

Server log files

The website provider automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. This information includes:

• Browser type and browser version
• Operating system used
• Referrer URL
• Hostname of the accessing computer
• Time of server request
• IP Address

This data will not be combined with other data sources.

This data is collected on the basis of Article 6(1)(f) GDPR. The website operator has a legitimate interest in the technically flawless presentation and optimization of its website – for this purpose, the server log files must be recorded.

Contact form

If you send us inquiries via the contact form, your information from the inquiry form, including the contact details you provided, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We will not share this data without your consent.

The processing of this data is based on Article 6(1)(b) GDPR if your request is related to the performance of a contract or is necessary for taking steps prior to entering into a contract. In all other cases, processing is based on our legitimate interest in the effective handling of inquiries addressed to us (Article 6(1)(f) GDPR) or on your consent (Article 6(1)(a) GDPR), if such consent has been obtained; you may withdraw your consent at any time.

The data you enter in the contact form will remain with us until you request its deletion, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g., after your inquiry has been processed). Mandatory legal provisions – in particular, retention periods – remain unaffected.

Inquiries via email, telephone or fax

When you contact us by email, telephone, or fax, your inquiry, including all resulting personal data (name, inquiry), will be stored and processed by us for the purpose of handling your request. We will not share this data without your consent.

The processing of this data is based on Article 6(1)(b) GDPR if your request is related to the performance of a contract or is necessary for taking steps prior to entering into a contract. In all other cases, processing is based on our legitimate interest in the effective handling of inquiries addressed to us (Article 6(1)(f) GDPR) or on your consent (Article 6(1)(a) GDPR), if such consent has been obtained; you may withdraw your consent at any time.

The data you send us via contact requests will remain with us until you request its deletion, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions – in particular, statutory retention periods – remain unaffected.

Communication via WhatsApp

We use the instant messaging service WhatsApp, among others, to communicate with our customers and other third parties. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Communication is end-to-end encrypted (peer-to-peer), preventing WhatsApp or other third parties from accessing the content of the communication. However, WhatsApp does have access to metadata generated during the communication process (e.g., sender, recipient, and time). We would also like to point out that, according to WhatsApp, it shares its users' personal data with its US-based parent company, Facebook. Further details on data processing can be found in WhatsApp's privacy policy at: https://www.whatsapp.com/legal/#privacy-policy.

The use of WhatsApp is based on our legitimate interest in communicating with customers, prospective customers, and other business and contractual partners as quickly and effectively as possible (Art. 6 para. 1 lit. f GDPR). If corresponding consent has been requested, data processing is carried out exclusively on the basis of this consent; this consent can be revoked at any time with effect for the future.

The content of communications exchanged between you and us on WhatsApp will remain with us until you request its deletion, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions – in particular, retention periods – remain unaffected.

We use WhatsApp in the "WhatsApp Business" version.

Data transfers to the USA are based on the EU Commission's Standard Contractual Clauses. Details can be found here: https://www.whatsapp.com/legal/business-data-transfer-addendum.

Jotform

We have integrated Jotform into this website. The provider is Jotform Inc., 111 Pine St. Suite, 1815 San Francisco, California 94111, USA (hereinafter referred to as Jotform).

Jotform allows us to create online forms to collect messages, inquiries, and other input from our website visitors. All information you enter is processed on Jotform's servers.

The use of Jotform is based on our legitimate interest in determining your request in the most user-friendly way possible (Art. 6 para. 1 lit. f GDPR). If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and Section 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

The data you entered in the form will remain with us until you request its deletion, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions – in particular, retention periods – remain unaffected.

Data transfers to the USA are secured by EU Standard Contractual Clauses, which we have concluded with Jotform. Details can be found here: https://www.jotform.com/gdpr-compliance/dpa/.

Order processing

We have concluded a data processing agreement (DPA) with the aforementioned provider. This is a legally required contract under data protection law, which ensures that the provider processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

5. Analytics tools and advertising

IONOS WebAnalytics

This website uses the analytics services of IONOS WebAnalytics (hereinafter: IONOS). The provider is 1&1 IONOS SE, Elgendorfer Straße 57, D – 56410 Montabaur. As part of the analysis with IONOS, visitor numbers and behavior (e.g., number of page views, duration of a website visit, bounce rates), visitor sources (i.e., the website from which the visitor came), visitor locations, and technical data (browser and operating system versions) are analyzed. For this purpose, IONOS stores the following data in particular:

• Referrer (previously visited website)
• requested website or file
• Browser type and browser version
• Operating system used
• Device type used
• Time of access
• IP address in anonymized form (used only to determine the location of access)

According to IONOS, data collection is completely anonymized, meaning it cannot be traced back to individual persons. IONOS WebAnalytics does not use cookies.

The data is stored and analyzed based on Article 6(1)(f) GDPR. The website operator has a legitimate interest in the statistical analysis of user behavior in order to optimize both its website and its advertising. If consent has been obtained, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) of the German Telecommunications and Telemedia Data Protection Act (TTDSG), insofar as the consent includes the storage of cookies or access to information on the user's device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

For further information on data collection and processing by IONOS WebAnalytics, please refer to the IONOS privacy policy at the following link:

https://www.ionos.de/terms-gtc/index.php?id=6

Order processing

We have concluded a data processing agreement (DPA) with the aforementioned provider. This is a legally required contract under data protection law, which ensures that the provider processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

Consent with Usercentrics

This website uses Usercentrics' consent technology to obtain your consent to the storage of certain cookies on your device or the use of certain technologies and to document this in accordance with data protection regulations. The provider of this technology is Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, website: https://usercentrics.com/de/ (hereinafter referred to as "Usercentrics").

When you visit our website, the following personal data will be transferred to Usercentrics:

• Your consent(s) or the withdrawal of your consent(s)
• Your IP address
• Information about your browser
• Information about your device
• Time of your visit to the website

Furthermore, Usercentrics stores a cookie in your browser to associate your given consents or their revocation with you. The data collected in this way is stored until you request its deletion, delete the Usercentrics cookie yourself, or the purpose for data storage no longer applies. Mandatory legal retention obligations remain unaffected.

Usercentrics is used to obtain the legally required consent for the use of certain technologies. The legal basis for this is Article 6(1)(c) GDPR.

6. Newsletters and direct mail advertising

Newsletter­daten

If you wish to subscribe to the newsletter offered on this website, we require your email address and information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use this data exclusively for sending the requested information and do not share it with third parties.

The processing of the data entered in the newsletter registration form is based solely on your consent (Art. 6 para. 1 lit. a GDPR). You can revoke your consent to the storage of your data, your email address, and its use for sending the newsletter at any time, for example, via the "Unsubscribe" link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.

The data you provide for the purpose of subscribing to our newsletter will be stored by us or our newsletter service provider until you unsubscribe. After you unsubscribe or the purpose for receiving the newsletter no longer applies, your data will be deleted from the newsletter distribution list. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion, based on our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR.

Data that we have stored for other purposes remains unaffected.

After you unsubscribe from our newsletter mailing list, your email address may be stored on a blacklist by us or our newsletter service provider if this is necessary to prevent future mailings. The data on the blacklist will only be used for this purpose and will not be combined with other data. This serves both your interest and our interest in complying with legal requirements for sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage on the blacklist is not time-limited. You can object to this storage if your interests outweigh our legitimate interest.

Direct advertising

We use your address for sending postal advertising (postal advertising) in compliance with all legal regulations.

The legal basis for this is our legitimate interest in direct marketing pursuant to Article 6(1)(f) in conjunction with Recital 47 of the GDPR. If corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) of the GDPR; this consent can be revoked at any time. More specific regulations may be communicated to you during data collection and take precedence over this regulation.

Your address will remain with us until the purpose for data processing no longer applies. If you submit a legitimate request for erasure or withdraw your consent to postal advertising, your data will be deleted unless we have other legally permissible grounds for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, deletion will occur once these grounds cease to apply.

We use the following service provider for sending our direct mail campaigns:

[Name and full address of the service provider]

7. eCommerce and payment providers

Processing of data (customer and contract data)

We collect, process, and use personal data only to the extent necessary for establishing, defining the content of, or amending the contractual relationship (master data). This is done on the basis of Article 6(1)(b) GDPR, which permits the processing of data for the performance of a contract or for taking steps prior to entering into a contract. We collect, process, and use personal data relating to the use of this website (usage data) only to the extent necessary to enable the user to access the service or for billing purposes.

The collected customer data will be deleted after completion of the order or termination of the business relationship. Statutory retention periods remain unaffected.

Credit checks

When you purchase on account or use any other payment method where we provide the goods or services in advance, we may conduct a credit check (scoring). For this purpose, we transmit the data you entered (e.g., name, address, age, or bank details) to a credit agency. Based on this data, the probability of payment default is determined. If the risk of payment default is deemed too high, we may refuse the payment method in question.

Credit checks are carried out on the basis of contract fulfillment (Art. 6 para. 1 lit. b GDPR) and the prevention of payment defaults (legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR). If consent has been obtained, the credit check is carried out on the basis of this consent (Art. 6 para. 1 lit. a GDPR); this consent can be revoked at any time.

8. Audio and video conferences

Data processing

We use online conferencing tools, among other methods, to communicate with our customers. The specific tools we use are listed below. When you communicate with us via video or audio conference over the internet, your personal data will be collected and processed by us and the provider of the respective conferencing tool.

The conference tools collect all data that you provide/use to access the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, the start and end times of your participation, the number of participants, and other "contextual information" related to the communication process (metadata).

Furthermore, the tool provider processes all technical data necessary for handling online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and the type of connection.

If content is exchanged, uploaded, or otherwise made available within the tool, it will also be stored on the tool provider's servers. Such content includes, in particular, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards, and other information shared during the use of the service.

Please note that we do not have full control over the data processing operations of the tools used. Our options are largely determined by the respective provider's company policy. Further information on data processing by the conference tools can be found in the privacy policies of the respective tools, which we have listed below this text.

Purpose and legal basis

The conference tools are used to communicate with prospective or existing business partners or to offer certain services to our customers (Art. 6 para. 1 lit. b GDPR). Furthermore, the use of these tools serves to generally simplify and expedite communication with us or our company (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Where consent has been requested, the use of the relevant tools is based on this consent; this consent can be revoked at any time with effect for the future.

Storage duration

The data we collect directly via video and conferencing tools will be deleted from our systems as soon as you request its deletion, withdraw your consent to its storage, or the purpose for data storage no longer applies. Stored cookies remain on your device until you delete them. Mandatory legal retention periods remain unaffected.

We have no control over how long your data is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.

Conference tools used

We use the following conference tools:

Zoom

We use Zoom. The provider of this service is Zoom Communications Inc., San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. Details regarding data processing can be found in Zoom's privacy policy: https://zoom.us/de-de/privacy.html.

Data transfers to the USA are based on the EU Commission's standard contractual clauses. Details can be found here: https://zoom.us/de-de/privacy.html.

9. Own services

Handling of applicant data

We offer you the opportunity to apply to us (e.g., by email, post, or via our online application form). Below, we inform you about the scope, purpose, and use of your personal data collected during the application process. We assure you that the collection, processing, and use of your data will be carried out in accordance with applicable data protection law and all other legal provisions, and that your data will be treated with strict confidentiality.

Scope and purpose of data collection

When you submit an application to us, we process your associated personal data (e.g., contact and communication data, application documents, notes from job interviews, etc.) to the extent necessary for deciding whether to establish an employment relationship. The legal basis for this is Section 26 of the German Federal Data Protection Act (BDSG) (initiation of an employment relationship), Article 6 Paragraph 1 Letter b of the GDPR (general contract initiation), and – if you have given your consent – Article 6 Paragraph 1 Letter a of the GDPR. You can withdraw your consent at any time. Within our company, your personal data will only be shared with individuals involved in processing your application.

If your application is successful, the data you have submitted will be stored in our data processing systems on the basis of Section 26 BDSG and Article 6 Paragraph 1 Letter b GDPR for the purpose of carrying out the employment relationship.

Data retention period

If we are unable to offer you a position, you decline a job offer, or you withdraw your application, we reserve the right to retain the data you submitted for up to six months from the conclusion of the application process (rejection or withdrawal of the application) based on our legitimate interests (Art. 6 para. 1 lit. f GDPR). After this period, the data will be deleted and any physical application documents destroyed. This retention serves, in particular, as evidence in the event of legal proceedings. If it becomes apparent that the data will be required after the six-month period (e.g., due to threatened or pending legal proceedings), deletion will only occur once the purpose for the extended retention no longer applies.

Longer storage may also take place if you have given your consent (Art. 6 para. 1 lit. a GDPR) or if statutory retention obligations preclude deletion.