Privacy Policy
Datenschutzerklärung — how makethemcall handles personal data under the GDPR (DSGVO), and the UK GDPR where it applies.
Last updated: 27 August 2026
We process personal data in accordance with the General Data Protection Regulation (GDPR / DSGVO) and the German Federal Data Protection Act (BDSG). Where a client business or an enquirer is in the United Kingdom, the UK GDPR applies to that data as well.
This notice covers our own processing: visitors to this website, and businesses who become our clients. Where we run advertising and answer enquiries for a client business, that business publishes its own notice naming itself and us — see Enquiry data below.
1. Controller / Verantwortlicher
CC Upturn Ventures UG (haftungsbeschränkt) c/o Engelnest Coworking Wilhelm-Kabus-Straße 24 10829 Berlin, Germany Email: hello@makethemcall.com
For data-protection enquiries, write to the address above with the subject line "Datenschutz". We have not appointed a Data Protection Officer; we are below the threshold in § 38 BDSG.
2. This website
| Data | Purpose | Legal basis |
|---|---|---|
| Server log data (IP, user agent, page, timestamp) | Deliver and secure the site | Art. 6(1)(f) — legitimate interest in a working, secure website |
| Contact form: name, email, business name, message | Answer your enquiry and prepare a possible contract | Art. 6(1)(b) — pre-contract steps |
Server logs are deleted after 14 days. Contact enquiries are kept for as long as the conversation is live and for up to 12 months afterwards.
We do not use advertising cookies, analytics or tracking pixels on this website. Fonts are loaded from Google Fonts, which means your IP address is transmitted to Google — if you would rather that did not happen, block third-party requests to fonts.gstatic.com.
3. Meta advertising, run on behalf of clients
We plan, build and manage advertising campaigns on Facebook and Instagram inside our clients' own Meta Business accounts. We do not operate our own ad account on their behalf and we do not upload customer lists or build custom audiences from client data.
Where we hold access to a client's Meta Business Portfolio, Facebook Page, ad account or WhatsApp Business account, that access is granted by the client and can be withdrawn by them at any time.
Meta Platforms Ireland Ltd. acts as an independent controller for the platform data it holds. See Meta's Privacy Policy.
4. WhatsApp Business Platform
Enquiries generated by our clients' campaigns are answered by WhatsApp from the client's own business number, using the WhatsApp Business Platform.
- Messages sent and received on that number are processed to answer the enquiry.
- When a client first connects their number, existing conversation history on it may be synced so that a conversation already in progress is not lost or duplicated.
- Message content is visible to the client and to us in the client's dashboard.
WhatsApp is operated by Meta Platforms Ireland Ltd. Legal basis: Art. 6(1)(b) — performing the service the enquirer asked for — and Art. 6(1)(f) for the client's interest in answering their own enquiries quickly.
5. Enquiry data, and who controls it
When someone submits an enquiry to one of our client businesses, that enquiry contains personal data: usually a name, phone number, email address, and answers to a few qualifying questions.
For that data, we and the client business are joint controllers under Art. 26 GDPR. We are not merely a processor: we decide, with the client, how enquiries are captured, how quickly and by what means they are answered, and how long they are kept.
- The client business is the point of contact for a data subject exercising their rights, and is named in the notice shown at the point of capture.
- We operate the systems, and will action a request received directly.
- Enquiry data is held separately per client. It is never shared with, sold to, or mixed into another client's data.
Each client business has its own privacy notice naming both parties, published at a per-client address and linked from the advert that collected the enquiry.
6. Retention
| Data | Kept for |
|---|---|
| Enquiries that never converted | 12 months from capture, then deleted |
| Enquiry and conversation data after a client leaves | Exported to the client on request, then deleted within 30 days |
| Opt-out (suppression) records | Kept indefinitely |
| Website contact enquiries | Up to 12 months |
| Invoices and accounting records | 10 years (§ 147 AO, § 257 HGB) |
Deletion means deletion, not flagging. The one deliberate exception is the opt-out list: if someone asks not to be contacted, we keep the minimum record needed to honour that — deleting it would cause them to be contacted again. That record is used for nothing else.
7. Recipients and sub-processors
| Recipient | Purpose | Location |
|---|---|---|
| Meta Platforms Ireland Ltd. | Advertising delivery, lead forms, WhatsApp Business Platform | EU / US |
| Hosting provider | Running this website and our application | EU |
| Contracted campaign specialists | Building and reviewing campaigns. Access is limited to campaign and advert data — never enquiry or conversation data | EU |
Where a transfer outside the EEA or UK takes place, it is covered by the European Commission's Standard Contractual Clauses or an adequacy decision.
8. Your rights
You have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20) and objection (Art. 21), and the right to withdraw consent at any time without affecting processing already carried out.
Write to hello@makethemcall.com. If your enquiry concerns data held for one of our client businesses, tell us which business you contacted and we will handle it with them.
You may also complain to a supervisory authority. Ours is the Berliner Beauftragte für Datenschutz und Informationsfreiheit. In the UK, the Information Commissioner's Office (ICO).
9. Changes
We update this notice when the service changes. The date at the top always reflects the current version.