Privacy Policy

1. Controller
Xlab Dynamics, sole proprietor Ghaith Noman, Rheinstraße 40–42, 64283 Darmstadt, Germany. Email:
hello@puffyrobot.com. Phone: +49 174 2117293.
2. Categories of data, purposes of processing and legal bases
2.1 Website access. Your IP address and standard technical request data are processed so the page can be
delivered and kept secure. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in operating a secure website).
2.2 Reservation. The email address you submit, and the campaign parameters in the link you arrived through,
are processed to register and manage your reservation and to contact you about the launch. Legal basis: Art.
6(1)(b) GDPR (pre-contractual steps at your request); for launch emails, Art. 6(1)(a) GDPR (consent), which
you may withdraw at any time.
2.3 Payment processing. Payment of the deposit is handled by Stripe. We receive confirmation of payment and a
payment reference; we do not receive your full card number. Legal basis: Art. 6(1)(b) GDPR, and Art. 6(1)(c)
GDPR for statutory retention.
2.4 Analytics and advertising. When you access this website, Google Analytics and the Meta Pixel are loaded
and store cookies or comparable identifiers on your device. They serve to measure use of the website and the
performance of our advertising. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the measurement and
improvement of our advertising). You may object to this processing at any time pursuant to Art. 21 GDPR by
contacting us, and you may prevent such storage by means of your browser settings or a tracker-blocking tool.
3. Recipients of personal data
• LaunchBoom / LaunchKit and the underlying Shopline platform - hosting of this funnel and storage of
reservation records.
• Stripe Payments Europe, Ltd. - payment processing.
• Google Ireland Ltd. - Google Analytics.
• Meta Platforms Ireland Ltd. - Meta Pixel.
• Cloudflare, Inc. - content delivery and security.
4. Transfers to third countries
Some of these providers process personal data outside the EU/EEA, in particular in the United States. Where the
recipient is certified under the EU-U.S. Data Privacy Framework, such transfers are made on the basis of the
European Commission's adequacy decision of 10 July 2023. In all other cases they are made on the basis of the
Standard Contractual Clauses adopted by the European Commission pursuant to Art. 46(2)(c) GDPR.
5. Storage period
5.1 Reservation and payment records are stored for the duration of the campaign and thereafter for the statutory
retention periods under German commercial and tax law (§ 257 HGB, § 147 AO). Those periods are mandatory.
A request for erasure does not shorten them; until they expire, the data is retained for that purpose alone and is
not otherwise processed.
5.2 Your email address is processed for launch emails until you unsubscribe or request its deletion, whereupon it
is removed from the mailing list. This is independent of the retention periods under 5.1, which concern
accounting records and not the mailing list.
5.3 Server log data is stored only for as long as it is required to deliver the website and to detect and investigate
attacks against it, and is deleted or anonymised thereafter.

6. Rights of the data subject
You have the right to obtain access to your personal data (Art. 15 GDPR), to rectification (Art. 16), to erasure
(Art. 17), to restriction of processing (Art. 18), to data portability (Art. 20) and to object to processing (Art. 21).
Where processing is based on consent, you may withdraw that consent at any time; the lawfulness of processing
carried out beforehand remains unaffected. To exercise these rights, please contact hello@puffyrobot.com.
You may also lodge a complaint with a supervisory authority — for us, the Hessian Commissioner for Data
Protection and Freedom of Information, Gustav-Stresemann-Ring 1, 65189 Wiesbaden, Germany.
7. Obligation to provide personal data
Provision of your email address is neither required by law nor by contract. Without it, however, we are unable to
register a reservation or to send you information about the launch.