Privacy Policy
Last updated: 25 October 2026
1. Controller and Contact Information
The controller responsible for the processing of personal data in connection with this website is:
Luca Picone Chiodo
ORTUS Strategic
Am Windschlag 9
83043 Bad Aibling
Germany
Phone: +49 173 373 90 44
Email: lpc@ortusstrategic.com
2. General Information on Data Protection
ORTUS Strategic respects the privacy of visitors to this website and is committed to handling personal data responsibly and transparently.
Personal data is processed in accordance with the General Data Protection Regulation (GDPR) and applicable German data protection legislation.
This Privacy Policy explains what personal data may be collected, the purposes for which it is processed, the applicable legal bases and the rights available to individuals.
3. Website Hosting and Server Data
This website is hosted by:
IONOS SE
Elgendorfer Straße 57
56410 Montabaur
Germany
When visitors access this website, technical connection and access data may be processed to deliver the requested content and maintain the security, availability and stability of the website.
Depending on the technical configuration, this may include:
IP address
Date and time of access
Requested pages and files
Referring website
Browser type and version
Operating system and device information
Technical information required for secure communication
The legal basis for this processing is Article 6(1)(f) GDPR. Our legitimate interest is to provide a secure, functional and reliable website.
According to IONOS, access information collected through its web hosting infrastructure is anonymised and retained for up to eight weeks.
Technical data is not used by ORTUS Strategic to identify individual website visitors.
Further information is available in the IONOS Privacy Policy:
https://www.ionos.de/terms-gtc/datenschutzerklaerung/
4. Contact by Email
Visitors may contact ORTUS Strategic using the email address published on this website.
When an email is received, we process the personal data voluntarily provided by the sender. This may include:
Name and email address
Contact details
Subject and content of the message
Documents or information attached to the email
Technical information associated with email transmission
Personal data is processed for the purpose of responding to inquiries, communicating with the sender and, where applicable, preparing a potential business relationship.
Depending on the nature of the inquiry, the legal basis is:
Article 6(1)(b) GDPR, where processing is necessary for pre-contractual measures requested by the sender.
Article 6(1)(f) GDPR, where processing is necessary for our legitimate interest in responding to general communications.
Email communication is hosted through services provided by IONOS.
Correspondence is retained only for as long as necessary for its intended purpose, unless statutory retention obligations or other legitimate grounds require longer storage.
5. IONOS SiteAnalytics
This website uses IONOS SiteAnalytics, an analytics service provided by IONOS SE.
SiteAnalytics helps us understand how visitors use our website, which pages are accessed and how the technical performance and usability of the website can be improved.
The service is used for:
Statistical analysis of website usage
Measurement of website reach
Technical optimisation and improvement of the website
According to IONOS, the service uses tracking pixels or server-side log files and does not use cookies to store information on visitors' devices.
The following information may be collected:
Referrer (previously visited website)
Requested website or file
Browser type and version
Operating system
Device type
Time of access
IP address in anonymised form, used to determine the approximate geographical location
Legal basis
Where personal data is processed through the consent-based SiteAnalytics service, the legal basis is Article 6(1)(a) GDPR.
Where applicable, consent is also obtained in accordance with Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG).
Visitors can accept or reject SiteAnalytics through the website's privacy settings.
Consent may be withdrawn at any time with effect for the future.
Retention period
According to IONOS, analytics data is retained for eight weeks and subsequently deleted automatically.
Location of processing
According to IONOS, data is processed in Germany and the European Union.
Service provider
IONOS SE
Elgendorfer Straße 57
56410 Montabaur
Germany
Further information:
https://www.ionos.de/terms-gtc/datenschutzerklaerung/
6. Cookies, Consent and Privacy Settings
The website uses a consent management interface to allow visitors to make choices regarding optional analytics technologies.
According to the service provider, IONOS SiteAnalytics does not use cookies for analytics data collection.
Where technologies require consent under applicable law, they must not be activated before valid consent has been obtained.
Visitors may refuse optional analytics without losing access to the website.
Consent can be withdrawn or privacy preferences changed through the website's privacy settings.
Any withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
7. Recipients and Service Providers
Personal data may be processed by service providers involved in the technical operation of the website and email communication, particularly IONOS SE.
Such processing is limited to the purposes described in this Privacy Policy and must comply with applicable data protection requirements.
Personal data may also be disclosed where legally required or where another lawful basis permits disclosure.
ORTUS Strategic does not sell personal data.
8. International Data Transfers
According to IONOS, the SiteAnalytics data described above is processed within Germany and the European Union.
If other processing activities involve transfers of personal data outside the European Economic Area, such transfers must comply with the applicable requirements of Chapter V GDPR.
9. Data Retention
Personal data is retained only for as long as necessary for the purposes for which it was collected, unless longer retention is required or permitted by applicable law.
The relevant retention period depends on the category of data and the purpose of processing.
Analytics data is retained for eight weeks according to the information provided by IONOS.
Email correspondence is reviewed for deletion when the relevant communication has been completed and no further legitimate purpose or legal retention obligation applies.
10. Data Security
This website uses HTTPS encryption to protect information transmitted between visitors and the website.
Appropriate technical and organisational measures are applied to protect personal data against unauthorised access, alteration, disclosure, loss and misuse.
Nevertheless, internet-based communication cannot be guaranteed to be completely secure.
11. Your Rights under the GDPR
Subject to the applicable legal requirements, individuals have the following rights:
Right of access: Article 15 GDPR
Right to rectification: Article 16 GDPR
Right to erasure: Article 17 GDPR
Right to restriction of processing: Article 18 GDPR
Right to data portability: Article 20 GDPR
Right to object: Article 21 GDPR
Right to withdraw consent: Article 7(3) GDPR
Where processing is based on legitimate interests, you have the right to object on grounds relating to your particular situation, subject to the conditions of Article 21 GDPR.
Where personal data is processed for direct marketing purposes, you may object to such processing at any time.
To exercise your rights, please contact:
You have also the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates applicable data protection law.
12. Obligation to Provide Personal Data
Visitors are not required to provide personal data merely to browse the publicly accessible content of this website, except for technical information necessary for website delivery.
When contacting ORTUS Strategic by email, certain contact information is necessary to enable us to respond.
Failure to provide sufficient contact information may prevent us from responding to an inquiry.
13. Automated Decision-Making
No automated decision-making, including profiling within the meaning of Article 22 GDPR, is carried out by ORTUS Strategic in connection with the processing activities described in this Privacy Policy.
14. Updates to This Privacy Policy
This Privacy Policy may be updated to reflect changes in legal requirements, technical configurations or the processing of personal data.
The current version will be made available on this website.