This policy explains how we process personal data when you visit this website, contact us, book a call, or work with us as a client.
The controller under the EU General Data Protection Regulation (GDPR) is:
Elias Müller, trading as EAL Digital (brand: Truss Consulting)
Fichtenstraße 7a, 84098 Hohenthann, Germany
Email: elias@trussconsulting.ai
We have not appointed a data protection officer because the law does not require one for a business of our size. Please send any privacy questions to the email address above.
This policy covers:
Our services are aimed at businesses. We process the personal data of the people who contact us or work with us on behalf of a business.
We process personal data only where the GDPR allows it. Each section below names the legal basis that applies.
This website is hosted by Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA, which also provides the content delivery network. When you visit it, the server automatically records technical data:
We need this data to deliver the website and keep it secure. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR). Logs are kept only for a short period unless they are needed to investigate a security incident. Our host processes the data on our behalf under a data processing agreement. Transfers to the USA are covered by section 14.
This website sets no cookies and uses no analytics or advertising tools. All fonts, scripts and images are served from our own host. No data is sent to Google Fonts or other third-party content networks when you load the page.
Our YouTube videos are not embedded. They are plain links. YouTube (Google Ireland Ltd.) processes data only once you click a link and open its website, under its own privacy policy.
When you contact us by email, direct message or form, we process the data you send so that we can reply. This includes your name, contact details, business details and message. The legal basis is pre-contractual steps (Art. 6(1)(b) GDPR) or our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR).
Our team may contact business owners by Instagram direct message, using information those businesses have made public. The legal basis is our legitimate interest in offering our services to businesses (Art. 6(1)(f) GDPR). If you reply that you are not interested, or object at any time, we stop contacting you. Instagram is operated by Meta Platforms Ireland Ltd.; Meta's own processing is governed by its privacy policy.
Calls are booked through iClosed, an external scheduling service, using a link we share with you directly. We process your name, email, phone number, business details and your answers to the booking questions so that we can prepare and hold the call. The legal basis is pre-contractual steps (Art. 6(1)(b) GDPR). The booking provider processes this data on our behalf.
We hold sales and client calls by video through Google Meet (Google Ireland Ltd.). With your consent, we record and transcribe calls using Fathom (Fathom Video Inc., USA), an AI-supported meeting tool. We use recordings and transcripts to prepare summaries, document advice, assure quality and train our team. We tell you at the start of each call when it is being recorded.
The legal basis is your consent (Art. 6(1)(a) GDPR). For client calls, it is also the performance of our contract (Art. 6(1)(b) GDPR). We keep recordings as long as we need them for these purposes. You can ask us to delete a recording at any time.
We manage leads, clients and projects with these tools, each of which processes data on our behalf:
| Tool | Purpose | Provider |
|---|---|---|
| Airtable | CRM: contacts, call status, deal data | Formagrid Inc., USA |
| ClickUp | Project and task management | Mango Technologies Inc., USA |
| Slack | Internal team communication | Slack Technologies, USA |
| Telegram | Chat support with clients | Telegram FZ-LLC, Dubai, UAE (processes data under its own privacy policy) |
| Google Workspace | Email, documents, storage | Google Ireland Ltd. |
The legal basis is pre-contractual steps and contract performance (Art. 6(1)(b) GDPR) and our legitimate interest in organising our business efficiently (Art. 6(1)(f) GDPR).
Clients pay through Comma (formerly Fanbasis) or by bank transfer. The payment provider processes payment data, such as card details, under its own responsibility. We receive only the information needed to match the payment, such as name, amount and date. The legal basis is contract performance (Art. 6(1)(b) GDPR) and our accounting duties (Art. 6(1)(c) GDPR).
After you book a call, we send you preparation emails and materials through our booking provider's automated email workflows. The legal basis is pre-contractual steps (Art. 6(1)(b) GDPR). We send newsletters or other marketing emails only with your consent (Art. 6(1)(a) GDPR). You can unsubscribe through the link in every email.
We currently use no analytics tools or advertising pixels on this website. If we add any, such as the Meta Pixel or Google Analytics, we will use them only with your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG) and update this policy beforehand.
We run profiles on Instagram, YouTube and LinkedIn. When you interact with them, the platform operator (Meta Platforms Ireland Ltd., Google Ireland Ltd. or LinkedIn Ireland Unlimited Company) processes your data under its own privacy policy. For Instagram page statistics, we and Meta are joint controllers (Art. 26 GDPR).
We share personal data only with the service providers named in this policy, and only as far as needed. We also share it with our team members (including freelancers bound to confidentiality), tax advisers and authorities where the law requires.
Some providers are based in the USA or may access data from there. Transfers take place on the basis of the EU–US Data Privacy Framework where the provider is certified under it (Art. 45 GDPR), or otherwise on the basis of the EU Standard Contractual Clauses (Art. 46 GDPR).
We delete personal data once it is no longer needed for the purpose it was collected for. Specifically:
You have the following rights:
Right to object (Art. 21 GDPR): where we process your data based on legitimate interests, you may object at any time for reasons arising from your particular situation. You may object to direct marketing at any time without giving reasons. To exercise any of these rights, email elias@trussconsulting.ai.
You can complain to a data protection supervisory authority. The authority responsible for us is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany.
This website uses TLS encryption. We protect data with appropriate technical and organisational measures. We do not make decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you (Art. 22 GDPR).
We update this policy when our services, tools or the law change. The current version is always available at eliasmüller.com/privacy.html.