Privacy notice for the HEJSFJ social media profiles
The German version of this notice is the legally binding original. This English text is a translation for convenience. If the two differ, the German text prevails.
This notice explains how SFJ Capital UG ("we") processes personal data in connection with the public profiles we operate under the name HEJSFJ. It does not replace the privacy notice of hejsfj.com, of Fred, or of Sunny Days Ahead, and it does not replace the privacy notice of the platform.
1. Controller
For the processing described as ours below, the controller is SFJ Capital UG (haftungsbeschränkt), Dhauner Straße 42, 67067 Ludwigshafen am Rhein, Germany, represented by the managing director Sebastian Frederik Jacobsen, commercial register HRB 67315, Amtsgericht Ludwigshafen am Rhein, email hello@hejsfj.com.
2. Who decides what
When you open a platform, the platform decides the purposes of most processing: your account, the feed, cookies, recommendations, and advertising. Read the platform’s privacy notice for that processing. We decide the purposes of the following:
- Content we publish on the profile
- Comments and direct messages we read and answer
- Moderation we carry out with the tools the platform gives us, such as hiding or reporting a comment
- Audience statistics the platform shows us about our own profile
3. Profiles
The platform operator is an independent controller of processing on that platform. EU-facing operators currently include Meta Platforms Ireland Limited (Instagram and Threads), LinkedIn Ireland Unlimited Company (LinkedIn), TikTok Technology Limited for users in the EEA (TikTok), GitHub B.V. (GitHub), Pinterest Europe Ltd. for users in the EEA (Pinterest), and the operator of Unsplash. Their notices govern their processing. Our profiles are:
- Instagram: https://instagram.com/hejsfj (@hejsfj)
- Threads: https://www.threads.net/@hejsfj (@hejsfj)
- LinkedIn: https://www.linkedin.com/in/hejsfj (hejsfj)
- TikTok: https://www.tiktok.com/@maybesfj (@maybesfj)
- Unsplash: https://unsplash.com/hejsfj (hejsfj)
- GitHub: https://github.com/hejsfj (hejsfj)
- Pinterest: https://pinterest.com/hejsfj (hejsfj)
4. Insights and joint controllership
Some platforms designate the operator of a professional profile and the platform as joint controllers under Art. 26 GDPR for statistics about that profile, for example Meta’s insights addendum where it applies to the account type we use. That arrangement covers those statistics only. It does not make us the controller of the platform’s advertising, cookies, or recommendations. You can exercise your rights with us or with the platform. The platform’s addendum says which of us must inform you and answer the request. We forward a request that the addendum assigns to the platform.
5. No social plugins on hejsfj.com
hejsfj.com does not embed social plugins, tracking pixels, or like buttons. An icon on the website is an ordinary link. The platform receives data from your device when you follow the link or when you use the platform, not merely because the website is open. We do not upload customer lists from the website and we do not buy followers.
6. Purposes and legal bases
- Running a public presence and publishing our own content: Art. 6(1)(f) GDPR (legitimate interest in communication). You may object under Art. 21 GDPR.
- Reading and answering a comment or message: Art. 6(1)(f) GDPR, or Art. 6(1)(b) GDPR if the message is about a contract or a step before a contract.
- Hiding or reporting unlawful or abusive interactions: Art. 6(1)(f) GDPR and, where the law requires removal, Art. 6(1)(c) GDPR.
- A specific optional action, such as a competition that needs consent: Art. 6(1)(a) GDPR only, and never as a condition hidden in the platform’s own consent.
7. What not to send us there
Do not send special-category data (for example health, religion, or political opinions), passwords, card numbers, or copies of identity documents in a comment or a direct message. Comments may be visible to other people and to the platform. For a privacy request use hello@hejsfj.com.
8. Synthetic media
Where Art. 50 of Regulation (EU) 2024/1689 (the AI Act) requires it, we label realistic AI-generated or manipulated image, audio, or video that we publish, including content that would appear to a viewer to show a real person or a real event. Text that is obviously ours, and ordinary editing of a photograph we took, is not presented as a synthetic record of an event.
9. Retention
We keep a message only as long as we need it to handle the conversation or a legal claim, and then we delete it from our own inboxes. How long the platform keeps the same message is governed by the platform. Statistics shown in a dashboard remain available for as long as the platform provides them to us.
10. International transfers
The platform carries out its own transfers when you use it. Where we receive a copy, for example a message in an inbox we control, we store it in our own environment. If that environment is outside the EEA, we use an adequacy decision where one applies, including the EU–U.S. Data Privacy Framework where the recipient is certified, and otherwise the EU Standard Contractual Clauses with supplementary measures as required by Chapter V GDPR. You can ask hello@hejsfj.com for a summary of those safeguards.
11. Your rights
Subject to the statutory conditions, you have the right to:
- Access your personal data (Art. 15 GDPR)
- Rectification of inaccurate data (Art. 16 GDPR)
- Erasure (Art. 17 GDPR)
- Restriction of processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR)
- Object to processing based on legitimate interests, and object at any time to direct marketing (Art. 21 GDPR)
- Withdraw consent at any time with effect for the future, where processing is based on consent (Art. 7(3) GDPR)
- Not be subject to a decision based solely on automated processing that produces legal effects or similarly significant effects (Art. 22 GDPR)
To exercise these rights, email hello@hejsfj.com. We may ask you to confirm your identity before we disclose data. We reply within one month, extended only in the cases Art. 12(3) GDPR allows.
You may lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, your place of work, or the place of the alleged infringement (Art. 77 GDPR). The authority competent for SFJ Capital UG is:
Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz
Hintere Bleiche 34
55116 Mainz
Germany
Website: https://www.datenschutz.rlp.de
12. Security
We protect messages we hold with access controls and transport encryption where the channel provides it. A platform inbox is only as private as that platform. Please use hello@hejsfj.com for confidential requests. If a breach in processing we control requires notification, we notify the supervisory authority and, where Art. 34 GDPR requires it, the people affected.
13. Children
Our profiles are not directed at children under 16. Please do not contact us through a social network if you are under 16.
14. Changes
We update this notice when the profiles, the platforms’ roles, or the law change. The date on the page is the date of the current version. Where a change materially affects you and the law requires further notice, we provide it.