German compliance answers / Privacy notice

Privacy notice

Last updated: 27 October 2026

Who is responsible for your data?

The controller is Hakkaart B.V., a private limited company (besloten vennootschap) under Dutch law, trading as 欧关合规 Euguan, KvK 87948974, Nieuwe Uilenburgerstraat 82-1, 1011 LW Amsterdam, Netherlands. Contact: hello@euguan.com.

What do you leave behind when you browse this site?

• This site sets no cookies and uses no advertising or third-party scripts, and no external fonts. The only count it keeps is the anonymous usage count described below.
• Your language choice and your progress in the free check are kept only in your own browser (localStorage) and are not sent to us automatically. Clearing this site's data in your browser deletes them.
• The site is hosted by Cloudflare. To deliver pages to your browser, Cloudflare processes your IP address and technical request data (time, browser, page requested) on our behalf, as our processor. We keep no access logs ourselves. Legal basis: our legitimate interest in delivering the site safely and reliably (GDPR Art. 6(1)(f)).

Where does your data go when you run the free check?

• The product details, store link and anything you paste are evaluated in your browser and are not sent to us. The options you pick in multiple-choice questions (for example the product category, or whether it has a battery) are sent as part of the anonymous count, never any text you type. Only a save or payment you start yourself sends more, described below.
• Your store link is never visited.
• A share link keeps its summary after the #, which browsers do not send to a server; it holds no product names and no store link.

When is your information stored?

Only when you submit it yourself, and only on euguan.com/check/ and euguan.com/book/ (booking, see the next section):

• Saving your result: once you tick the consent box, we store the channel you chose (WeChat, phone or email), your contact details, your consent, whether you want rule-change alerts, the result summary, the language and the time. We use them only to send you the result, to contact you to help, and, if you ticked it, to tell you when German rules change. No marketing. Legal basis: your consent (GDPR Art. 6(1)(a)), which you can withdraw at any time by e-mail to hello@euguan.com.
• Contact details you leave after your result (WeChat ID, mobile number, optional e-mail): used to send you the result and to offer help, which includes Rick Hakkaart (founder) adding you on WeChat or calling you. When you save, your contact, the channel, the language, your alert choice and the result summary are e-mailed to the founder's mailbox and stored in Cloudflare KV. Cloudflare Email Routing delivers the e-mail to a Gmail mailbox, so Google processes it as a mail provider. Kept for 12 months after our last contact with you, then deleted, unless you become a customer (then the periods in the booking section below apply). You can ask for earlier deletion at any time at hello@euguan.com. Legal basis: your consent (GDPR Art. 6(1)(a)), which you can withdraw at any time by e-mail.
• Confirming payment: we record your intent to pay: the contact details you left, the payment method you chose, the invoice title, the quoted amounts, the missing items, the number of products, the store link, the language and the time. No payment service is connected and nothing is charged. Legal basis: steps taken at your request before a contract (GDPR Art. 6(1)(b)).
• These records are kept in Hakkaart B.V.'s Cloudflare account for the period stated above, or until you ask us to delete them via hello@euguan.com. We do not sell this data or give it to anyone other than Cloudflare and the mail provider named above.
• To stop abuse of these two forms, we count submissions per IP address: we store only a keyed hash of it (HMAC-SHA256), never the address itself, and the count is deleted automatically after at most 61 minutes. Legal basis: our legitimate interest in protecting the service (GDPR Art. 6(1)(f)).
• Leaving contact details is optional; the free check works fully without them. We do no profiling and make no automated decisions with legal effect about you.
• Cloudflare and Google may process data in the United States. Cloudflare and Google state that they are certified under the EU-U.S. Data Privacy Framework (European Commission adequacy decision of 10 July 2023); where that does not apply, the EU standard contractual clauses in their data processing terms apply. Ask us for a copy at hello@euguan.com.

Booking a package (euguan.com/book/)

• What we store: your shop link and seller ID, your company's name, address, country and business registration number (Unified Social Credit Code or Hong Kong BR number), your contact (WeChat ID or e-mail), the name and role of the person who signs the authorisation (Vollmacht), the package and payment period you chose, the payment reference, the invoice, and the steps of your booking. We also keep a hash (fingerprint) of the exact authorisation and booking-terms text you agreed to, your ticks and the time, as proof of what you agreed. If you paste or link your Amazon seller page, we read the company details from that public page (source: the seller information page Amazon publishes).
• Purpose and legal basis: to set up and run the service you booked, to order your legal texts from the law firm and to invoice you. Legal basis: the contract with you and the steps before it (GDPR Art. 6(1)(b)); for invoices and payment records, our legal duty to keep accounts (Art. 6(1)(c), Dutch AWR art. 52); for the proof of what you agreed, our legitimate interest in being able to show how the contract came about (Art. 6(1)(f)). Without the company details and a contact we cannot provide the service.
• Recipients: a German law firm (our partner; the authorisation you sign names it), which writes your legal texts and receives your company name, legal form, address, registration and VAT number, representative, customer-service contact, marketplace and seller ID and your return-policy choices; Cloudflare (hosting and storage, our processor); our bank. We never give the firm your WeChat ID or payment data.
• Retention: bookings that are never paid are deleted after 180 days. For a paid booking, invoices and payment records are kept 7 years (Dutch tax law); the authorisation and hand-over documents for the contract term plus 3 years; the proof of consent (hashes, ticks) as long as the authorisation.
• Required or not: the company details, the registration number and a contact are needed to conclude the contract and to issue the invoice; without them the booking cannot be completed.

If you received an introductory e-mail from us

• We may send one introductory e-mail to an address a seller company publishes. We take the address and company details from a page the seller itself publishes (for example Amazon's seller information page or the company website); they were not collected from you personally before. Legal basis: our legitimate interest in direct marketing (GDPR Art. 6(1)(f), recital 47). You can object at any time to our using your data for this kind of contact: reply "退订" (unsubscribe) or write to hello@euguan.com; we stop within 1 business day and put the address on a do-not-contact list.
• Retention: leads that never reply are deleted after 12 months; an address that objected stays on the do-not-contact list for as long as we send mail, so that we do not contact it again.

Anonymous usage counts

• When a page of this site opens, or a step of the free check, of a tool (notice reader, register check, declaration of conformity, compliance calendar) or of the booking form opens, or you pick an option, see your result, save, see a QR code, switch language, subscribe to the calendar, submit a booking or click a partner link, the page sends one small message to euguan.com: what happened, the check's version, the page, the name of the step (for a booking also the name of the chosen package), the page language, whether it runs inside WeChat, the value of the option you picked (never text you type, never a name, an amount or a contact), where the visit came from as a category (for example "WeChat group", "AMZ123", "Google" or the campaign tag in the link) and a random number created for this page view only.
• That number is not stored on your device and is gone when you close or reload the page; we use it only to see which screens belong to one visit. We store no IP address, no browser details, no cookie and no identifier that lasts beyond the page view.
• The counts are kept in Hakkaart B.V.'s Cloudflare D1 database, processed in the EU (Western Europe region), and deleted after 13 months.
• Purpose: to see which parts of the site and the free check help sellers and where people drop out, so we can improve them. Legal basis: our legitimate interest (GDPR Art. 6(1)(f)). Under Dutch law (Telecommunicatiewet art. 11.7a) this counting needs no consent because it has little or no impact on your privacy. You can object at any time by e-mail; blocking scripts also stops it and changes nothing else on the site.
• The site and its data are run and kept by Hakkaart B.V. (the Netherlands); data is processed outside China.

What are your rights?

Under the GDPR you can ask for access to your data, its correction or deletion, restriction of processing and a copy of it (portability), and you can object to processing based on legitimate interest; where processing is based on consent, you can withdraw it at any time, without affecting what was done before. Write to hello@euguan.com; we answer within one month.

You can also complain to the Dutch supervisory authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), or to the supervisory authority where you live or work.