Privacy Policy

1. Controller

Responsible for this website is:
SW labs – Felix Winkel
Email: bearing@sw-labs.de

Full postal address and provider identification in the imprint: legal.sw-labs.de/imprint

2. General information

I process personal data only to the extent necessary to provide a functional website and my services. This website can generally be used without cookies and without registration. Personal data is processed in particular if you join the Bearing waitlist or contact me by email.

3. Hosting & infrastructure

This website and its server-side functions are provided through Cloudflare Workers (Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA). Cloudflare processes technical connection data such as IP address, date, time, requested page, and browser information for the delivery and protection of the website. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in secure and stable operation). Data transfers to the United States take place on the basis of the EU-U.S. Data Privacy Framework and other appropriate safeguards. Privacy policy: cloudflare.com/privacypolicy

The source code of this website is managed via GitHub (GitHub, Inc., 88 Colin P. Kelly Jr. Street, San Francisco, CA 94107, USA). GitHub is used only for version control and the build process; no personal data of website visitors is transferred to GitHub. Privacy policy: docs.github.com/privacy

4. Cookies and reach measurement

This website sets no cookies and uses no social media pixels or advertising networks.

To measure reach and loading performance, I use Cloudflare Web Analytics (provider as in section 3). It processes page views, referrer, country, browser, operating system, loading performance values, and, for this purpose, IP address and user agent. Nothing is stored on or read from your device. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in knowing whether the website is reached and loads well). The data is kept until it is deleted automatically by the service.

5. Bearing waitlist

If you join the Bearing waitlist, I process the information you submit to organize early access and contact you later on. This includes your email address and, where provided, your name, the agents you work with, the kinds of media that pile up for you, the subjects you follow, free-text details, and language preference.

This information is stored in a Cloudflare D1 database. In addition, I send confirmation and notification emails via Resend. Resend processes the email address and the contents of the messages sent.

To limit misuse of the form, a salted hash of your IP address is stored when you sign up, never the address itself. It is needed for one hour and deleted with the next sign-up after that. The legal basis is Art. 6(1)(f) GDPR (protecting the waitlist against automated mass sign-ups).

Resend / Plus Five Five, Inc., 2261 Market Street #5039, San Francisco, CA 94114, USA.
Privacy information: resend.com/legal/privacy-policy

The legal basis is Art. 6(1)(b) GDPR (handling your request for early access) and Art. 6(1)(f) GDPR (organizing the waitlist and direct communication with interested users).

Your entry is kept until Bearing opens and you have received the invitation. If you do not create an account, it is deleted at the latest six months after that. If you ask for deletion earlier, it is deleted right away. Emails sent via Resend are kept there until they are deleted automatically by the service.

6. Contact by email

If you contact me by email, I process the data you provide exclusively to handle your request. The legal basis is Art. 6(1)(f) GDPR or Art. 6(1)(b) GDPR if your request is aimed at initiating a contractual or usage relationship. The data is deleted once your request has been dealt with, unless statutory retention obligations require otherwise.

7. Your rights

You have the following rights vis-a-vis me:

– Right of access (Art. 15 GDPR)
– Right to rectification (Art. 16 GDPR)
– Right to erasure (Art. 17 GDPR)
– Right to restriction of processing (Art. 18 GDPR)
– Right to data portability (Art. 20 GDPR)
– Right to object (Art. 21 GDPR)
– Right to withdraw consent at any time (Art. 7(3) GDPR)

To exercise your rights, contact bearing@sw-labs.de.

Competent supervisory authority:
Bavarian State Office for Data Protection Supervision (BayLDA)
Promenade 18, 91522 Ansbach, Germany
www.lda.bayern.de

8. Last updated

October 2026