Privacy Policy

Preamble

With the following privacy policy we would like to inform you about the types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

This privacy policy applies to aim-to-pace.ai and all products published under this brand, including the browser extension Pace Prepped Prompts (PPP).

The terms used are not gender-specific.

Last updated: July 2026

Table of Contents

• Preamble
• Controller
• Overview of Processing Operations
• Relevant Legal Bases
• International Data Transfers
• General Information on Data Retention and Deletion
• Rights of Data Subjects
• Provision of the Online Offer and Web Hosting
• Comments and Reviews
• Sale of Digital Products and License Keys
• Payment Procedure
• Newsletter and third-party content (Substack)
• Use of Cookies
• Changes and Updates
• Definitions of Terms

Controller

Andreas Schnorr
c/o Block Services
Stuttgarter Str. 106
70736 Fellbach
Germany

Email address: info@aim-to-pace.ai

Legal notice: https://aim-to-pace.ai/en/imprint/

Overview of Processing Operations

The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of Data Processed

• Inventory data
• Contact data
• Content data
• Contract data
• Usage data
• Meta, communication and procedural data
• Log data

Categories of Data Subjects

• Users
• Customers
• Interested parties
• Communication partners

Purposes of Processing

• Provision of contractual services and fulfilment of contractual obligations
• Obtaining and displaying feedback
• Security measures
• Provision of our online offer and user-friendliness
• Information technology infrastructure

Relevant Legal Bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

• Performance of a contract and pre-contractual inquiries (Article 6(1)(b) GDPR) — Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
• Consent (Article 6(1)(a) GDPR) — The data subject has given consent to the processing of their personal data for one or more specific purposes (applies to newsletter subscriptions via Substack).
• Legal obligation (Article 6(1)(c) GDPR) — Processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. commercial or tax law retention obligations).
• Legitimate interests (Article 6(1)(f) GDPR) — Processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject that require the protection of personal data do not override such interests.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains, in particular, special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Applicability of data protection regulations in the country of domicile: In the country in which the controller is domiciled, national data protection regulations apply in addition to the General Data Protection Regulation (GDPR).

International Data Transfers

Data processing in third countries: Insofar as we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies (which is evident from the postal address of the respective provider or where the privacy policy expressly refers to a data transfer to third countries), this is always done in accordance with the statutory requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This twofold safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should changes arise in the context of the DPF, the Standard Contractual Clauses apply as a reliable fallback. In this way we ensure that your data remain adequately protected even in the event of any political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, in particular Standard Contractual Clauses, explicit consent or transfers required by law.

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are withdrawn or there are no further legal bases for the processing. This concerns cases in which the original purpose of processing ceases to apply or the data are no longer required. Exceptions to this rule exist where statutory obligations or particular interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or the storage of which is necessary for legal prosecution or to protect the rights of other natural or legal persons, must be archived accordingly.

Where several indications of the retention period or deletion deadlines of a piece of data exist, the longest period is always decisive.

Rights of Data Subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

• Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions.
• Right of withdrawal for consents: You have the right to withdraw consents you have granted at any time.
• Right of access: You have the right to request confirmation as to whether data concerning you are being processed and to information about such data as well as further information and a copy of the data in accordance with the statutory requirements.
• Right to rectification: You have the right, in accordance with the statutory requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: You have the right, in accordance with the statutory requirements, to request that data concerning you be erased without delay, or alternatively, in accordance with the statutory requirements, to request a restriction of the processing of the data.
• Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used and machine-readable format in accordance with the statutory requirements, or to request its transmission to another controller.
• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Provision of the Online Offer and Web Hosting

We process users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.

• Types of data processed: Usage data (e.g. page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved); log data (e.g. log files concerning logins or the retrieval of data or access times).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures.
• Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
• Legal bases: Legitimate interests (Article 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

• Provision of the online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web host"); Legal bases: Legitimate interests (Article 6(1)(f) GDPR).
• Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files". The server log files may include the address and name of the retrieved web pages and files, the date and time of retrieval, the volume of data transferred, notification of successful retrieval, the browser type and version, the user's operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation and stability of the servers; Legal bases: Legitimate interests (Article 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes are exempt from deletion until the respective incident has been finally clarified.
• Content Delivery Network: We use a "Content Delivery Network" (CDN). A CDN is a service with the help of which the content of an online offer, in particular large media files such as graphics or program scripts, can be delivered more quickly and securely with the help of regionally distributed servers connected via the internet; Legal bases: Legitimate interests (Article 6(1)(f) GDPR).
• Cloudflare (hosting, CDN, DNS, email routing): We use services provided by Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. Cloudflare provides our web hosting (Cloudflare Pages), our content delivery network, the DNS resolution of our domain and the routing of incoming emails to us. In the context of these services, technically necessary user data are processed, in particular IP addresses, time of request, retrieved URL, browser type and referrer. To defend against automated attacks, Cloudflare sets a technically necessary cookie (__cf_bm, storage period approx. 30 minutes). Data processing may also take place in the USA; Cloudflare is certified under the EU-US Data Privacy Framework. In addition, a data processing agreement (Data Processing Addendum) has been concluded with Cloudflare that contains the EU Commission's Standard Contractual Clauses. Further information: https://www.cloudflare.com/privacypolicy/; Legal bases: Legitimate interests (Article 6(1)(f) GDPR).

Comments and Reviews

We offer users the option of leaving a review (star rating) and, optionally, a comment. Contributions are only published after prior examination and approval by us (moderation); approval is granted at our discretion, in particular in order to prevent unlawful or abusive content.

We collect a freely chosen pseudonym, the star rating and, where applicable, the comment text. An email address, a real name or a user account are not required. Contributions are stored in a database operated by our service provider Cloudflare; in this context, processing may take place in the USA (see the sections "Provision of the Online Offer and Web Hosting" and "International Data Transfers"). We do not store an IP address together with the contribution; for the general, technically required processing of IP addresses by Cloudflare, please see the section "Provision of the Online Offer and Web Hosting".

Published contributions remain visible until they are deleted – by us or at the request of the author. You may request the deletion of a contribution you have authored at any time.

• Types of data processed: Content data (pseudonym, rating, comment text); where applicable, further information you voluntarily provide within the comment text.
• Data subjects: Users.
• Purposes of processing: Obtaining and displaying feedback; security measures.
• Retention and deletion: Storage until the respective contribution is deleted.
• Legal bases: Legitimate interests (Article 6(1)(f) GDPR).

Sale of Digital Products and License Keys

We process our customers' data in order to enable them to purchase and use our digital products (downloadable software/tools). The contract is concluded and payment is made via our Merchant of Record (see the section "Payment Procedure"). From the Merchant of Record we receive the data required for order fulfilment, in particular your email address and order data (where applicable, name and country as well as an order or transaction reference).

After a successful purchase, our infrastructure automatically generates an individual license key. This is triggered by a notification from our Merchant of Record about the completed purchase; the key is generated by a server-side function (Cloudflare Workers) of our processor Cloudflare (see the section "Provision of the Online Offer and Web Hosting"). Your email address is technically embedded in the license key; this serves the recovery of lost keys (key recovery) and the granting of benefits in the event of a repeat purchase.

Your license key is displayed to you immediately after purchase on the confirmation page of our website. We do not send it by email. You can retrieve your key again at any time via a self-service function on our website by entering the email address used at purchase together with your order number (the number beginning with "ORD-" on the Merchant of Record's receipt) (key recovery). No user account or registration is required.

At purchase, we additionally record, via the Merchant of Record's checkout, the consent you give there to the immediate provision of the digital content (proof under § 356(5) of the German Civil Code (BGB)). We store this proof together with the other license data (legal bases: Article 6(1)(c) or (f) GDPR).

The license keys we generate — including the email address embedded in them — and the associated order reference are stored in a database operated by our service provider Cloudflare; processing may also take place in the USA (see the sections "Provision of the Online Offer and Web Hosting" and "International Data Transfers"). We store this data for as long as we offer key recovery and repeat-purchase benefits for the license concerned, and we review the necessity of continued storage at regular intervals. Because the email address is technically embedded in license keys that have already been delivered, we cannot subsequently remove it from the keys in your possession. Upon your request, we erase the copy stored by us, unless its storage is necessary for the establishment, exercise or defence of legal claims or on account of statutory retention obligations.

The extension itself verifies your license exclusively locally on your device and does not connect to our servers or third-party servers for this purpose. Server contact occurs only at purchase (display of the key on the confirmation page) and on optional re-retrieval (key recovery).

• Types of data processed: Inventory data (e.g. name); contact data (email address); contract data (order and transaction data, order reference, license key, proof of consent to immediate provision / waiver of withdrawal).
• Data subjects: Customers.
• Purposes of processing: Provision of contractual services (automated generation and provision of the license key); key recovery and repeat-purchase benefits.
• Retention and deletion: as described above.
• Legal bases: Performance of a contract (Article 6(1)(b) GDPR) for delivery of the key; legitimate interests (Article 6(1)(f) GDPR) for key recovery and repeat-purchase benefits; where applicable, legal obligation (Article 6(1)(c) GDPR) for documents subject to statutory retention.

Payment Procedure

We process sales and payments via a Merchant of Record (MoR). The MoR acts as the seller (reseller) towards you; the contract relating to payment is concluded with the MoR. The MoR processes the payment and billing data under its own responsibility, remits value added tax, handles fraud prevention as well as refunds and chargebacks, and issues your payment receipt. With respect to these processing activities, we and the MoR are independent controllers. Insofar as the MoR additionally processes data on our behalf, a data processing agreement is in place for that purpose.

As Merchant of Record we use: Armitage Labs OÜ, trading as Creem, Telliskivi 57b/1, 10412 Tallinn, Estonia (company number 16977866). For purchases from Germany or the EU, Armitage Labs OÜ is your contractual partner for payment. Creem's privacy information can be found at: https://www.creem.io/privacy.

From the MoR we receive the data required for order fulfilment, order processing, fraud prevention and product support, in particular your email address and your order data. We use this data exclusively for the purposes stated; we use it for marketing only where you have separately consented to this.

Third-country transfer: Armitage Labs OÜ is established in Estonia and therefore within the European Union; processing by the MoR itself takes place within the EU/EEA. Insofar as the MoR engages sub-processors outside the EU/EEA, such transfers are to be safeguarded under its data processing agreement by appropriate measures within the meaning of Chapter V GDPR (in particular EU Standard Contractual Clauses or an adequacy decision). For details and the current list of sub-processors, please refer to Creem's privacy information and data processing agreement: https://www.creem.io/dpa.

• Types of data processed: Contract data; contact data; where applicable, inventory data.
• Data subjects: Customers.
• Purpose of processing: Provision of contractual services (payment processing).
• Legal basis: Performance of a contract (Article 6(1)(b) GDPR).

Newsletter and third-party content (Substack)

This website embeds a subscription widget provided by the newsletter service Substack (Substack Inc., 548 Market St PMB 72296, San Francisco, CA 94104, USA). The widget only becomes active through deliberate user interaction — i.e. when you enter your email address and submit the form. No data is transferred to Substack on page load.

When you submit your email address, it is transmitted to Substack and stored there in order to send you the newsletter. Further data processing by Substack — including open and click statistics — is governed by Substack's own privacy policy. Substack is based in the USA. The transfer is based on your consent (Article 49(1)(a) GDPR), which you give by submitting the form.

The newsletter content itself is managed on the Substack platform (aimtopaceai.substack.com); the terms applicable there can be found directly on Substack.

• Types of data processed: Contact data (email address); usage data.
• Data subjects: Users who subscribe to the newsletter.
• Purposes of processing: Newsletter management; direct communication.
• Legal bases: Consent (Article 6(1)(a) GDPR).
• Right to withdraw: Consent may be withdrawn at any time by unsubscribing from the newsletter (unsubscribe link in every email).
• Further information: https://substack.com/privacy

Use of Cookies

The term "cookies" refers to functions that store information on users' devices and read information from them. Cookies may also be used for various purposes, e.g. for the functionality, security and comfort of online offers as well as the creation of analyses of visitor flows. We use cookies in accordance with the statutory provisions. Where necessary, we obtain the prior consent of users. Where consent is not necessary, we rely on our legitimate interests. This applies where the storage and reading of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings as well as ensuring the functionality and security of our online offer.

On this website, only one technically necessary cookie of our CDN provider Cloudflare (__cf_bm) is set to defend against automated attacks. No other cookies, in particular for tracking, analysis or marketing purposes, are used.

• Types of data processed: Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Legal bases: Legitimate interests (Article 6(1)(f) GDPR).

Changes and Updates

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or any other individual notification.

Insofar as we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and we ask you to verify the information before contacting them.

Definitions of Terms

In this section you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

• Inventory data: Inventory data comprise essential information for the identification and administration of contractual partners, user accounts, profiles and similar assignments. These data may include, among other things, personal and demographic information such as names, contact information (addresses, email addresses), dates of birth and specific identifiers (user IDs).
• Content data: Content data comprise information generated in the course of creating, editing and publishing content of all kinds. This category may include texts, images, videos, audio files and other contributions posted in online offers, such as comments and reviews.
• Contact data: Contact data are essential for communication and comprise, for example, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media or messenger services.
• Meta, communication and procedural data: Categories that contain information about the manner in which data are processed, transmitted and managed. These include, among other things, file size, creation date, author, modification histories, communication connections (sender, recipient, timestamp, transmission paths) and audit logs.
• Usage data: Information that records how users interact with digital products — e.g. page views, duration of visits, click paths, frequency of use, timestamps, IP addresses, device information and location data.
• Personal data: Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.
• Log data: Information about events or activities that have been logged in a system or network (e.g. timestamps, IP addresses, user actions, error messages).
• Controller: 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.
• Processing: Any operation performed on personal data, whether or not by automated means — be it collecting, analysing, storing, transmitting or deleting.
• Contract data: Contract data are specific information relating to the formalisation of an agreement between two or more parties. They comprise, for example, information on the type and subject matter of the contract as well as order and transaction data.

The legally binding German original was created with the free Datenschutz-Generator.de by Dr. Thomas Schwenke.