The protection of your personal data is important to us. In this privacy policy (Datenschutzerklärung), we inform you in accordance with Art. 13 and 14 of the General Data Protection Regulation (GDPR, in German DSGVO) which personal data we process when you visit our website or contact us, for what purposes this is done and what rights you have.

1. Name and Address of the Controller

The controller within the meaning of the GDPR is:

Immobilienvermittlung Kulbacki (brand: FrankenImmo)
Owner: Adam Kulbacki
An der Steinernen Brücke 12, 95632 Wunsiedel
Telephone: 0151 58363197
Email: info@immo-kulbacki.de

2. Data Protection Officer

[Details of the data protection officer – to be added, insofar as there is an obligation to appoint one under Art. 37 GDPR and § 38 BDSG (Federal Data Protection Act).] For all questions about data protection, you can reach us using the contact details given above.

3. General Information on Data Processing

Data Categories and Data Sources

We process the following categories of personal data:

Master and contact data (e.g. name, address, telephone number, email address)
Content data (e.g. your message, details of the property, search profiles)
Contract and identification data in connection with a brokerage instruction
Usage and connection data (e.g. IP address, time of access, pages accessed)

The data comes from you yourself, for example from forms, emails, telephone calls or messages, as well as from the technical operation of the website.

Transfer of Data to Third Parties

Your data is only transferred to third parties if this is necessary to perform a contract (for example to prospective buyers or tenants, notaries or financing partners in the course of an instruction), if you have expressly consented or if we are legally obliged to do so. Technical service providers (hosting, form delivery) process data exclusively on our behalf in accordance with Art. 28 GDPR.

Transfer to Third Countries

Some of our service providers are based in the USA. A transfer only takes place if there is an adequacy decision (EU-US Data Privacy Framework) or appropriate safeguards such as EU standard contractual clauses are in place.

4. Purposes and Legal Bases of Processing

Provision and security of the website: Art. 6(1)(f) GDPR (legitimate interest in stable and secure operation)
Handling enquiries and preparing a brokerage contract: Art. 6(1)(b) GDPR
Performing brokerage contracts, valuations and placements: Art. 6(1)(b) GDPR
Fulfilling legal obligations, for example under the Money Laundering Act, commercial and tax law: Art. 6(1)(c) GDPR
Optional services such as statistics, only with your consent: Art. 6(1)(a) GDPR and § 25(1) TDDDG (Telecommunications Digital Services Data Protection Act)

5. Storage Period and Deletion

We only store personal data for as long as is necessary for the relevant purpose. We delete enquiries that do not lead to an instruction after twelve months at the latest. We retain data from brokerage contracts in accordance with the statutory periods: up to ten years under commercial and tax law (§ 257 HGB, § 147 AO) and five years under the Money Laundering Act (§ 8 GwG). The data is then deleted.

6. Hosting and Server Log Files

This website is hosted by Cloudflare, Inc. (101 Townsend St., San Francisco, CA 94107, USA) and delivered via its content delivery network. When the website is accessed, technically necessary data is processed: IP address, date and time, page accessed, browser and operating system, and the previously visited page (referrer). The processing serves the secure and stable provision of the website and the defence against attacks (Art. 6(1)(f) GDPR). A data processing agreement is in place with Cloudflare. Cloudflare is certified under the EU-US Data Privacy Framework. Log data is only stored for a short time.

7. Data Security

For security reasons, this website uses SSL or TLS encryption. You can recognise an encrypted connection by the padlock symbol and by "https://" in your browser's address bar. We also take technical and organisational measures to protect your data against loss, manipulation and unauthorised access.

8. Cookies and Local Storage

On your first visit, we ask you in a notice window which categories you allow. Technically necessary storage is always active: we store your choice in your browser's local storage (key "fi-consent") so that the notice window does not appear every time a page is accessed (§ 25(2) TDDDG). Optional services such as statistics are only activated if you consent. We currently do not use any analytics, marketing or advertising cookies.

You can change or withdraw your choice at any time via the "Cookie settings" link in the footer of every page. Further details can be found in our cookie policy.

9. Fonts

The fonts used on this website are loaded locally from our server. No connection is made to servers of Google or other font providers.

10. Contact Forms, Email and Telephone

If you contact us via a form, by email or by telephone, we process the information you provide (e.g. name, telephone number, email address, details of the property, your message) to handle your enquiry and for any follow-up questions. The legal basis is Art. 6(1)(b) GDPR (pre-contractual measures) or Art. 6(1)(f) GDPR (legitimate interest in responding to enquiries).

The forms are transmitted via the Web3Forms service, which forwards the entries in encrypted form to our email inbox. If the service is not active, your email program opens with a prepared message.

11. WhatsApp

On our website we link to WhatsApp. A connection to WhatsApp (WhatsApp Ireland Limited, Merrion Road, Dublin 4, Ireland) is only established when you click the link. If you write to us via WhatsApp, WhatsApp's privacy policy also applies. Please do not send us particularly sensitive data via WhatsApp. Alternatively, you can reach us at any time by telephone or email.

12. External Links and Maps

Our website contains links to external services, such as public authority portals or Google Maps. These are only accessed when you click the link; no data is transferred beforehand. The map of Upper Franconia on our website is our own graphic and does not load any content from third parties.

13. Brokerage Activities and the Money Laundering Act

If you instruct us with a placement, we process the data necessary to perform the contract (Art. 6(1)(b) GDPR). As estate agents, we are obliged under the Money Laundering Act (Geldwäschegesetz) to identify the contracting parties and to retain the documents for five years (Art. 6(1)(c) GDPR).

14. What Rights Do You Have?

Right of Access

You can request information as to whether and which personal data we process about you (Art. 15 GDPR).

Right to Rectification

You can request the rectification of inaccurate data or the completion of incomplete data (Art. 16 GDPR).

Right to Erasure (Right to Be Forgotten)

You can request the erasure of your data, provided there are no statutory retention obligations to the contrary (Art. 17 GDPR).

Right to Restriction of Processing

You can request that we restrict the processing of your data (Art. 18 GDPR).

Right to Data Portability

You can request to receive your data in a structured, commonly used and machine-readable format or to have it transmitted to another controller (Art. 20 GDPR).

Right to Object

If we process data on the basis of a legitimate interest, you can object at any time on grounds relating to your particular situation (Art. 21 GDPR).

You can withdraw consent you have given at any time with effect for the future (Art. 7(3) GDPR), for example via the "Cookie settings".

Exercising Your Rights as a Data Subject

To exercise your rights, an informal message to the contact details given above is sufficient. We usually reply within one month.

15. Right to Lodge a Complaint with the Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is the Bavarian State Office for Data Protection Supervision (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA), Promenade 18, 91522 Ansbach, lda.bayern.de.

16. Last updated

As of: November 2026. We will adapt this privacy policy if the website or the legal requirements change.

Privacy Policy