Privacy Policy
1. Privacy at a Glance
General Information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you.
Data Collection on This Website
Who is responsible for data collection? Data processing on this website is carried out by the website operator (see Imprint).
How do we collect your data? Your data is collected when you provide it to us (e.g., through the contact form). Other data is automatically collected by our IT systems when you visit the website. This mainly includes technical data (e.g., internet browser, operating system, IP address, or time of page access) as well as usage data from our own analytics software.
What do we use your data for? Some data is collected to ensure error-free provision of the website. Other data is used to analyze your user behavior and to facilitate requested services via local partners.
2. Hosting and Infrastructure
Hosting with Vercel
We host our website with Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA. The provider processes your IP address and technical access data to ensure website delivery (Content Delivery Network).
As Vercel is a US company, data is transferred to the USA. We have concluded a Data Processing Agreement with Vercel. The data transfer to the USA is based on the Standard Contractual Clauses (SCC) of the EU Commission and, where applicable, the Data Privacy Framework (DPF). The legal basis is Art. 6(1)(f) GDPR (legitimate interest in fast and secure provision of the online offering).
Database Hosting (Neon)
For storing application data (e.g., analytics data), we use the database service Neon Inc., USA. Here too, data is processed on servers in the USA. We have concluded appropriate agreements with the provider for data security and compliance with GDPR standards (SCCs).
3. General Information and Mandatory Disclosures
Data Protection
The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.
Information About the Responsible Party
The responsible party for data processing on this website is:
Palmara Reisekunst LLC
1209 Mountain Road PL NE STE N
Albuquerque, NM 87110 USA
Represented by: Taylor Newman
E-Mail: contact@newlifevietnam.de
Telefon: +84 83 211 4684
Notice Regarding Data Transfer to the USA
Our IT infrastructure (hosting, database) is partially located in the USA. The USA is currently considered by the European Court of Justice as a country with an inadequate level of data protection by EU standards. In particular, there is a risk that your data may be processed by US authorities for control and surveillance purposes without effective legal remedies available to you. We secure data transfers through Standard Contractual Clauses and technical measures (e.g., IP address hashing) to the best extent possible.
Revocation of Your Consent to Data Processing
Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The legality of data processing carried out before the revocation remains unaffected by the revocation.
Right to Lodge a Complaint
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority.
Right to Information, Deletion, and Correction
You have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing, as well as a right to correction or deletion of this data.
SSL/TLS Encryption
This site uses SSL/TLS encryption for security reasons. An encrypted connection can be recognized by the browser's address bar changing from "http://" to "https://" and by the lock icon in your browser bar.
4. Data Collection on This Website
Storage Technologies on End Devices (Local Storage & Cookies)
Our website uses local storage in your browser (Local Storage) and technically necessary cookies to provide basic functions (e.g., session management). This data is not shared with third parties and is used exclusively for the technical functionality of the site. The legal basis for this storage is § 25(2)(2) TTDSG (technical necessity) and Art. 6(1)(f) GDPR (legitimate interest in operating the website).
Server Log Files
The page provider (Vercel) automatically collects and stores information in server log files that your browser automatically transmits to us. These are:
- Browser type and version
- Operating system used
- Referrer URL (previously visited page)
- Host name of the accessing computer
- Time of server request
- IP address
This data is not merged with other data sources. This data is collected based on Art. 6(1)(f) GDPR.
Contact Form / Email
If you send us inquiries via contact form or email, your information including contact details will be stored for the purpose of processing the inquiry. We do not share this data without your consent. Processing is based on Art. 6(1)(b) GDPR (contract fulfillment/pre-contractual measures) or Art. 6(1)(f) GDPR (legitimate interest in processing inquiries).
5. Analytics Tools
Custom Analytics Software (Self-Hosted Custom Analytics)
We use a self-developed analytics function on this website to statistically evaluate website usage and optimize our offering. This tool operates in a particularly privacy-friendly manner ("Privacy First"):
- No Third Parties: Data is not transmitted to Google or Facebook.
- No Analytics Cookies: We do not use cookies for tracking purposes. Only a technical entry in Local Storage is used to recognize a session.
- Anonymization: Your IP address is irreversibly anonymized using a cryptographic procedure (SHA-256 hash) before storage. It is not possible for us to trace back to your person.
- Data Storage: The anonymized analytics data (e.g., pages visited, button clicks) is stored in our database at Neon Inc.
Data processing is based on Art. 6(1)(f) GDPR. Our legitimate interest lies in the anonymized analysis of user behavior to improve our web offering without violating user privacy through comprehensive tracking.
6. Plugins and Tools
Google Fonts (Local Hosting)
This site uses Google Fonts for consistent font display. We use "Next.js Font Optimization" technology. This means: The fonts are not loaded directly from Google's servers when you visit our site. Instead, the fonts are delivered locally from our own server (or our CDN). No connection to Google servers takes place, and thus no data (such as your IP address) is transmitted to Google in connection with font display.
The use of Google Fonts is in the interest of a uniform and appealing presentation of our online offerings. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR.
7. Data Transfer to Partners
Sharing Your Data with Service Partners
If you request concierge services (e.g., visa services, cleaning, wellness), we share your necessary data with our local partners in Vietnam for the purpose of contract fulfillment. NLV acts exclusively as an intermediary.
Partner Categories and Data Shared
We only share data if you explicitly request the corresponding service.
- Visa & Immigration: Name, passport data, email, phone to licensed visa agencies
- Medical Referrals: Name, email, phone to hospitals and doctors
- Housekeeping & Catering: Name, phone, address to cleaning services and caterers
- Transport: Name, email, phone, address to airport transfer services
- Banking & Finance: Name, email, phone, address to Vietnamese banks and financial advisors
Legal Basis
Data sharing is based on Art. 6(1)(b) GDPR (contract performance) or Art. 6(1)(f) GDPR (legitimate interest in providing requested services). We have Data Processing Agreements with all service partners.
Your Rights
You have the right to request information about data sharing, to restrict sharing for specific services, or to request deletion of your data from partner systems. Contact us at contact@newlifevietnam.com.