Foreword

We, KAVA Handels GmbH (4982 Studio) (hereinafter: “the company”, “we” or “us”), take the protection of your personal data seriously and would like to inform you here about data protection in our company.

Within the scope of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: “GDPR”) to ensure the protection of personal data of the data subject affected by processing (we will also address you as the data subject below using “customer”, “user”, “you”, “your” or “data subject”).

Where we decide, either alone or jointly with others, on the purposes and means of data processing, this primarily includes the obligation to inform you transparently about the type, scope, purpose, duration, and legal basis of the processing (cf. Articles 13 and 14 GDPR). With this statement (hereinafter: “Privacy Notice”), we inform you about how your personal data is processed by us.

Our Privacy Notice is modular in structure. It consists of a general part covering any processing of personal data and processing situations that apply each time a website is accessed (A. General) and a special part, the content of which relates only to the processing situation specified there with the designation of the respective offering or product, in particular the website visit described in more detail here (B. Visiting websites).

To find the parts relevant to you, please refer to the following overview of the subdivision of the Privacy Notice:

A. General

(1) Definitions

Following the model of Article 4 GDPR, the following definitions apply to this Privacy Notice:

– “Personal data” (Article 4(1) GDPR) means any information relating to an identified or identifiable natural person (“data subject”). A person is identifiable if they can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data, or by means of information relating to their physical, physiological, genetic, mental, economic, cultural or social identity characteristics. Identifiability may also exist through linking such information with other information or additional knowledge. The form or embodiment of the information is irrelevant (photos, video or audio recordings may also contain personal data).

– “Processing” (Article 4(2) GDPR) means any operation performed on personal data, whether or not by automated (i.e., technology-assisted) means. This includes in particular collection (i.e., obtaining), recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, as well as changing a target or purpose determination on which processing was originally based.

– “Controller” (Article 4(7) GDPR) means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

– “Third party” (Article 4(10) GDPR) means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data; this also includes other group-affiliated legal entities.

– “Processor” (Article 4(8) GDPR) means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, in particular in accordance with the controller’s instructions (e.g., IT service providers). In terms of data protection law, a processor is in particular not a third party.

– “Consent” (Article 4(11) GDPR) of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes, by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

---

(2) Name and address of the controller responsible for processing

The entity responsible for processing your personal data within the meaning of Article 4(7) GDPR is us:

KAVA Handels GmbH (4982 Studio), Kangsan Lee
Keltenstr. 8, 76744, Wörth am Rhein
Telephone number: +49 163 155 5302
Email address: support@4982-stuido.com

Further information about our company can be found in the imprint information on our website under Imprint.

---

(3) Contact details of the Data Protection Officer

For all questions and as your contact person on the topic of data protection, our company Data Protection Officer is available to you at any time. Their contact details are:

KAVA Handels GmbH (4982 Studio) , Kangsan Lee
Keltenstr. 8, 76744, Wörth am Rhein
Email: support@4982-studio.com

---

(4) Legal bases for data processing

As a matter of law, in principle any processing of personal data is prohibited and is only permitted if the processing falls under one of the following legal bases:

– Article 6(1) sentence 1 lit. a GDPR (“Consent”): if the data subject has freely, in an informed manner and unambiguously indicated by a statement or clear affirmative action that they consent to the processing of their personal data for one or more specific purposes;

– Article 6(1) sentence 1 lit. b GDPR: if processing is necessary for the performance of a contract to which the data subject is party, or for steps at the request of the data subject prior to entering into a contract;

– Article 6(1) sentence 1 lit. c GDPR: if processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., statutory retention obligations);

– Article 6(1) sentence 1 lit. d GDPR: if processing is necessary in order to protect vital interests of the data subject or of another natural person;

– Article 6(1) sentence 1 lit. e GDPR: if processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or

– Article 6(1) sentence 1 lit. f GDPR (“Legitimate interests”): if processing is necessary for the purposes of the legitimate (in particular legal or economic) interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject (in particular where the data subject is a minor).

The storage of information in the end user’s terminal equipment or access to information already stored in the terminal equipment is only permitted if covered by one of the following legal bases:

– § 25(1) TTDSG: if the end user has consented on the basis of clear and comprehensive information. Consent must be given in accordance with Article 6(1) sentence 1 lit. a GDPR;

– § 25(2) no. 1 TTDSG: if the sole purpose is the transmission of a message over a public telecommunications network; or

– § 25(2) no. 2 TTDSG: if storage or access is strictly necessary in order to provide a telemedia service explicitly requested by the user.

For the processing operations we carry out, we specify below the applicable legal basis in each case. Processing may also be based on multiple legal bases.

---

(5) Data deletion and storage duration

For the processing operations we carry out, we indicate below how long data is stored by us and when it is deleted or blocked. Unless an explicit storage period is stated below, your personal data will be deleted or blocked as soon as the purpose or legal basis for storage no longer applies. As a rule, your data is stored only on our servers in Germany, subject to any disclosure in accordance with A.(7) and A.(8).

Storage may, however, extend beyond the specified period in the event of a (threatened) legal dispute with you or other legal proceedings, or if storage is required by statutory provisions to which we, as the controller, are subject (e.g., § 257 HGB, § 147 AO). When the statutory retention period expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for it.

---

(6) Data security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorized access by third parties (e.g., TLS encryption for our website), taking into account the state of the art, implementation costs, and the nature, scope, context and purposes of processing as well as the existing risks of a data breach (including its likelihood and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

We will be happy to provide further information on request. Please contact our Data Protection Officer for this purpose (see A.(3)).

---

(7) Cooperation with processors

As with any larger company, we use external domestic and foreign service providers to handle our business operations (e.g., for IT, logistics, telecommunications, sales and marketing). They act only on our instructions and have been contractually obliged within the meaning of Article 28 GDPR to comply with data protection requirements.

If personal data is transferred by us to our subsidiaries or transferred by our subsidiaries to us (e.g., for advertising purposes), this is done on the basis of existing processing relationships.

---

(8) Requirements for transferring personal data to third countries

Within our business relationships, your personal data may be transferred or disclosed to third-party companies. These may also be located outside the European Economic Area (EEA), i.e., in third countries. Such processing is carried out exclusively for the performance of contractual and business obligations and for maintaining your business relationship with us (legal basis: Article 6(1) lit. b or lit. f GDPR, respectively, in conjunction with Articles 44 et seq. GDPR). We will inform you of the specific details of such transfers below at the relevant points.

The European Commission certifies for certain third countries, by means of so-called adequacy decisions, a level of data protection comparable to the EEA standard (a list of these countries and a copy of the adequacy decisions can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). In other third countries to which personal data may be transferred, there may be no consistently high level of data protection due to a lack of legal provisions. Where this is the case, we ensure that data protection is sufficiently guaranteed. This may be achieved through binding corporate rules, the European Commission’s standard contractual clauses for the protection of personal data pursuant to Article 46(1), (2) lit. c GDPR (the 2021 standard contractual clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en), certifications or approved codes of conduct. Please contact our Data Protection Officer (see A.(3)) if you would like more information.

---

(9) No automated decision-making (including profiling)

We do not intend to use personal data collected from you for a procedure of automated decision-making (including profiling).

---

(10) No obligation to provide personal data

We do not make the conclusion of contracts with us dependent on you providing personal data in advance. As a customer, you generally have no legal or contractual obligation to provide us with your personal data; however, it may be that we can provide certain services only in a limited manner or not at all if you do not provide the data required for that purpose. If this is exceptionally the case within the products offered by us described below, you will be informed separately.

---

(11) Legal obligation to disclose certain data

We may, under certain circumstances, be subject to a specific statutory or legal obligation to make lawfully processed personal data available to third parties, in particular public authorities (Article 6(1) sentence 1 lit. c GDPR).

---

(12) Your rights

You may assert your rights as a data subject regarding your processed personal data at any time using the contact details provided above under A.(2). As a data subject, you have the right:

– pursuant to Article 15 GDPR, to request information about your data processed by us, in particular information about the purposes of processing, the categories of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected from us, as well as the existence of automated decision-making including profiling and, where applicable, meaningful information about its details;

– pursuant to Article 16 GDPR, to request without undue delay the rectification of inaccurate data or completion of your data stored by us;

– pursuant to Article 17 GDPR, to request the erasure of your data stored by us, unless processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defense of legal claims;

– pursuant to Article 18 GDPR, to request restriction of processing of your data where you contest the accuracy of the data or where processing is unlawful;

– pursuant to Article 20 GDPR, to receive your data that you have provided to us in a structured, commonly used and machine-readable format or to request transmission to another controller (“data portability”);

– pursuant to Article 21 GDPR, to object to processing where processing is based on Article 6(1) sentence 1 lit. e or lit. f GDPR. This is in particular the case if processing is not necessary for the performance of a contract with you. If the objection is not directed against direct marketing, we ask you, when exercising such an objection, to explain the reasons why we should not process your data as we do. In the case of a justified objection, we will examine the situation and either stop or adjust the processing or demonstrate our compelling legitimate grounds on which we continue processing;

– pursuant to Article 7(3) GDPR, to withdraw at any time any consent you have given once (including prior to the applicability of the GDPR, i.e., before 25 May 2018)—that is, your voluntary, informed and unambiguous expression by statement or clear affirmative action that you consent to the processing of the personal data concerned for one or more specific purposes. This means that we may no longer continue data processing based on this consent in the future; and

– pursuant to Article 77 GDPR, to lodge a complaint with a data protection supervisory authority about the processing of your personal data in our company, for example with the supervisory authority responsible for us: The State Commissioner for Data Protection and Freedom of Information Rhineland-Palatinate Hintere Bleiche 34, 55116 Mainz, Germany E-Mail: poststelle@datenschutz.rlp.de

---

(13) Changes to the Privacy Notice

In the course of further developments in data protection law and technological or organizational changes, our Privacy Notice is regularly reviewed for the need for adjustments or supplements. You will be informed of changes in particular on our German website at www.4982-studio.com This Privacy Notice is current as of March 2026.

B. Visiting websites

(1) Explanation of the function

Information about our company and the services we offer can be found in particular at www.4982-studio.com including its associated subpages (hereinafter collectively: “websites”). When visiting our websites, personal data relating to you may be processed.

---

(2) Processed personal data

When using the websites for informational purposes, the following categories of personal data are collected, stored and further processed by us:

“Log data”: When you visit our websites, a so-called log record (server log files) is stored temporarily and in anonymized form on our web server. It consists of:

– the page from which the page was requested (referrer URL)
– the name and URL of the requested page
– the date and time of access
– the description of the type, language and version of the web browser used
– the IP address of the requesting computer, which is shortened so that personal reference can no longer be established
– the amount of data transferred
– the operating system
– the message whether access was successful (access status/HTTP status code)
– the GMT time zone difference

“Contact form data”: When using contact forms, the data transmitted in this way is processed (e.g., gender, first and last name, address, company, email address and the time of transmission).

In addition to purely informational use of our website, we offer subscription to our newsletter, with which we inform you about current developments in business law and events. If you subscribe to our newsletter, the following “newsletter data” is collected, stored and further processed by us:

– the page from which the page was requested (referrer URL)
– the date and time of access
– the description of the type of web browser used
– the IP address of the requesting computer, which is shortened so that personal reference can no longer be established
– the email address
– the date and time of registration and confirmation

We inform you that we evaluate your user behavior when sending the newsletter. For this evaluation, the emails sent contain so-called web beacons / tracking pixels, which are one-pixel image files stored on our website. For the evaluations, we link the above data and the web beacons with your email address and an individual ID. Links contained in the newsletter also contain this ID. The data is collected exclusively in pseudonymized form, i.e., the IDs are not linked with your further personal data and direct identification is excluded.

---

(3) Purpose and legal basis of data processing

We process the personal data described above in accordance with the provisions of the GDPR, the other relevant data protection regulations, and only to the extent necessary. Insofar as the processing of personal data is based on Article 6(1) sentence 1 lit. f GDPR, the stated purposes also constitute our legitimate interests.

Processing of log data serves statistical purposes and improves the quality of our website, in particular the stability and security of the connection (legal basis: Article 6(1) sentence 1 lit. a or lit. f GDPR).

Processing of contact form data is carried out to handle customer inquiries (legal basis: Article 6(1) sentence 1 lit. b or lit. f GDPR).

Processing of newsletter data is carried out for the purpose of sending the newsletter. When registering for our newsletter, you consent to the processing of your personal data (legal basis: Article 6(1) lit. a GDPR). We use the so-called double opt-in procedure for registration. This means that after you register, we send an email to the email address provided in which we ask you to confirm that you wish to receive the newsletter. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify possible misuse of your personal data. You can withdraw your consent to receive the newsletter at any time and unsubscribe. You can declare withdrawal by clicking the link provided in every newsletter email, by email to support@4982-studio.com, or by sending a message to the contact details provided in the imprint.

If, for data processing, storing information on your terminal device or accessing information already stored on the terminal device is required, § 25 (1), (2) TTDSG is the legal basis.

---

(4) Duration of data processing

Your data is processed only as long as necessary to achieve the processing purposes stated above; the legal bases specified in connection with the processing purposes apply accordingly. With regard to the use and storage duration of cookies, please refer to point A.(5) and the Cookie policy.

Third parties used by us will store your data on their systems for as long as necessary in connection with providing services for us in accordance with the respective assignment.

Further details on storage duration can also be found under A.(5) and the Cookie policy.

---

(5) Transfer of personal data to third parties; legal basis

The following categories of recipients, which as a rule are processors (see A.(7)), may have access to your personal data:

– Service providers for operating our website and processing data stored or transmitted by the systems (e.g., data center services, payment processing, IT security). The legal basis for disclosure is then Article 6(1) sentence 1 lit. b or lit. f GDPR, insofar as they are not processors;

– Government agencies/authorities insofar as this is necessary to fulfill a legal obligation. The legal basis for disclosure is then Article 6(1) sentence 1 lit. c GDPR;

– Persons used for conducting our business operations (e.g., auditors, banks, insurers, legal advisors, supervisory authorities, parties involved in company acquisitions or the formation of joint ventures). The legal basis for disclosure is then Article 6(1) sentence 1 lit. b or lit. f GDPR.

For safeguards ensuring an adequate level of data protection when transferring data to third countries, see A.(8).

In addition, we only transfer your personal data to third parties if you have given explicit consent pursuant to Article 6(1) sentence 1 lit. a GDPR.

---

(6) Use of cookies, plugins and other services on our website

a) Cookie

We use cookies on our websites. Cookies are small text files that are assigned to the browser you use via a characteristic character string and stored on your hard drive, through which certain information flows to the entity that sets the cookie. Cookies cannot run programs or transmit viruses to your computer and therefore cannot cause damage. They serve to make the internet offering overall more user-friendly and effective, i.e., more pleasant for you.

Cookies can contain data that enables recognition of the device used. In some cases, cookies contain only information about certain settings that is not personally identifiable. However, cookies cannot directly identify a user.

A distinction is made between session cookies, which are deleted as soon as you close your browser, and persistent cookies, which are stored beyond an individual session. In terms of function, cookies are further distinguished as follows:

– Technical cookies: These are strictly necessary to move around the website, use basic functions, and ensure the security of the website; they do not collect information about you for marketing purposes nor do they store which websites you have visited;

– Performance cookies: These collect information about how you use our website, which pages you visit and, for example, whether errors occur when using the website; they do not collect information that could identify you—any information collected is anonymous and is used only to improve our website and to find out what interests our users;

– Advertising cookies / Targeting cookies: These are used to offer website users advertising tailored to their needs on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;

– Sharing cookies: These are used to improve the interactivity of our website with other services (e.g., social networks); sharing cookies are stored for a maximum of 13 months.

The legal basis for cookies that are strictly necessary to provide you with the service you expressly request is § 25(2) no. 2 TTDSG. Any use of cookies that is not strictly technically necessary constitutes data processing that is permitted only with your explicit and active consent pursuant to § 25(1) TTDSG in conjunction with Article 6(1) sentence 1 lit. a GDPR. This applies in particular to the use of performance, advertising, targeting or sharing cookies. In addition, we only transfer your personal data processed via cookies to third parties if you have given explicit consent pursuant to Article 6(1) sentence 1 lit. a GDPR.

---

b) Cookie policy

Further information about which cookies we use and how you can manage your cookie settings and disable certain types of tracking can be found in our Cookie policy.

---

c) Social media plugins

We do not use social media plugins on our websites. If our websites contain icons of social media providers (e.g., Instagram, TikTok, Facebook, Pinterest), we use these only as passive links to the pages of the respective providers.

⚠️ The following section is a legally required notice under German law. An English translation is provided to assist understanding. In case of discrepancies or legal disputes, the German original text below shall prevail.