Privacy Policy
1. Data Controller
pong & pengo e.V.
Creative Hub am Volkstheater
Tumblingerstraße 23
80337 Munich, Germany
Supervisory Authority:
Bavarian State Office for Data Protection Supervision (BayLDA)
Promenade 18, 91522 Ansbach, Germany
2. Hosting & Server Logs
Our website and all services named here run on a virtual server provided by Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen, Germany) in a data centre in Germany. Hetzner processes the data on our behalf (Art. 28 GDPR). We use Caddy as our web server.
The web server does not keep access logs of individual page views. Your IP address is processed briefly with every request so the website can be delivered. It is only stored in two cases:
- in error logs, if a technical error occurs during your request (with date, time and page requested)
- in the failed-attempt lock, if a wrong PIN is entered for a PIN-protected internal area
This data is used exclusively for ensuring technical operation, defending against attacks and troubleshooting.
Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in technical security and stability)
Storage duration: error logs at most 7 days, failed-attempt lock entries until the lock expires (usually 20 minutes)
3. Web Analytics (Umami)
We use Umami, a privacy-friendly, open-source web analytics tool hosted on our own servers (analytics.pong-pengo.de).
Umami collects anonymous usage statistics such as page views, time on page, and country of origin. In doing so:
- No cookies are set
- No personal data is stored
- No IP addresses are stored (they are only used at the moment of the request to determine the country)
- No data is shared with third parties
- No user profiles are created
Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in anonymous analysis of usage behavior to improve the website)
Data processing: Entirely on our server in Germany (see section 2). No third-party access.
4. Newsletter (Self-Hosted)
For our newsletter, we use Listmonk, an open-source newsletter software hosted on our own servers in Germany (newsletter.pong-pengo.de).
Registration with Double Opt-In
When you subscribe to our newsletter, we store:
- Your email address
- Your name (optional)
- Time of registration
After registration, you will receive a confirmation email (double opt-in). Only after clicking the confirmation link will newsletters be sent to you.
Legal basis: Art. 6 para. 1 lit. a GDPR (consent)
Data processing: The subscriber list is stored on our server in Germany (see section 2). The emails are sent via the mail server of STRATO GmbH (Otto-Ostrowski-Straße 7, 10249 Berlin, Germany), which processes your email address and the content of the email on our behalf. There is no transfer to third countries.
Open and click counting: We count how often a newsletter is opened in total and how often links in it are clicked. For this, the emails contain an invisible counting image and redirect links via newsletter.pong-pengo.de. The counting is anonymous and is not linked to you. If your email program does not load images automatically, no opens are counted.
Legal basis for counting: Art. 6 para. 1 lit. f GDPR (legitimate interest in knowing whether the newsletter is read)
Cookies: No cookies are set for the newsletter service.
Unsubscribe: At any time via the link in each email or by message to info [at] pong-pengo.de. After unsubscribing you will not receive any more emails. Your address remains stored as blocked so that it is not contacted again by mistake. You can delete your data completely at any time yourself via the page the unsubscribe link opens, or by sending us a message.
Storage duration: Until unsubscription or withdrawal of consent; after that as a blocked address until you request deletion
5. Fonts (Local Hosting)
We use the font "Sora", which is stored locally on our server.
No data is transmitted to external services like Google. The font files are loaded directly from our servers.
Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in uniform and appealing presentation)
Data processing: No transmission of personal data to third parties
6. YouTube Videos (Two-Click Solution)
We embed videos from the platform YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland).
To protect your privacy, we use a two-click solution: YouTube videos are initially displayed only as a preview image. Only when you actively click "Load video" is a connection to YouTube servers established. We use the enhanced privacy mode (youtube-nocookie.com).
Without your explicit click, no data is transmitted to YouTube/Google.
Legal basis: Art. 6 para. 1 lit. a GDPR (consent through active click)
Data transfer to the USA: Google is EU-US Data Privacy Framework certified.
More info: Google Privacy Policy
7. Cookies and Local Storage (No Tracking)
Our website does not use tracking cookies and does not use third-party cookies.
We only store what the website needs to work:
- Cookie banner preference in your browser's localStorage. This storage stays on your device and is not transmitted to any server.
- Notice pop-up: If we show a notice pop-up, a cookie remembers for 7 days that you have already seen it.
- Internal areas (kiosk tally, material, tracker), for club members only: after entering the PIN, a session cookie keeps you signed in for up to 30 days. The kiosk tally briefly keeps entries in localStorage while there is no network connection, until they are transmitted.
Legal basis: § 25 para. 2 no. 2 TDDDG (technically necessary storage) and Art. 6 para. 1 lit. f GDPR (legitimate interest in storing preferences and sign-ins)
Storage duration: as stated above; the cookie banner preference until you clear your browser data
Newsletter and web analytics are self-hosted and do not set any cookies.
8. External Content
Our website blocks all external scripts and content that do not originate from our own servers by default. External content (e.g., YouTube videos) is only loaded after your explicit consent. The only exception is the live map (section 9).
The following services are operated entirely on our own servers and require no data transfer to third parties:
- Web analytics (Umami)
- Newsletter (Listmonk)
- Content management and images (Directus)
- Fonts (Sora, locally hosted)
9. Live Map at Performances (OpenStreetMap)
At some performances we show on a map at pong-pengo.de/verfolgen/… where the performers currently are. Your browser loads the map images directly from the servers of the OpenStreetMap Foundation (St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom). In doing so, your IP address is transmitted to the OpenStreetMap Foundation. An adequacy decision of the EU Commission applies to the United Kingdom.
Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in displaying the map)
More info: OpenStreetMap Foundation Privacy Policy
10. Your Rights
Under the GDPR, you have the following rights:
Access (Art. 15 GDPR)
You can request information about the data we process.
Rectification (Art. 16 GDPR)
You can request the correction of incorrect data.
Erasure (Art. 17 GDPR)
You can request the deletion of your data, provided there are no legal retention obligations.
Restriction (Art. 18 GDPR)
You can request the restriction of processing.
Data Portability (Art. 20 GDPR)
You can receive your data in a common format.
Objection (Art. 21 GDPR)
You can object to the processing of your data at any time.
Withdrawal (Art. 7 para. 3 GDPR)
You can withdraw your consent (e.g., newsletter) at any time.
Complaint (Art. 77 GDPR)
You can file a complaint with the competent supervisory authority (see above).
11. Data Security
We implement technical and organizational measures to protect your data:
- SSL/TLS encryption for all data transmissions
- Server in a data centre in Germany
- Regular security updates
- Access restrictions and authorization concepts
- Services self-hosted, third parties only as described above
12. Contact
If you have questions about data protection or want to exercise your rights, please contact us:
Email: info [at] pong-pengo.de
Mail: pong & pengo e.V., Tumblingerstraße 23, 80337 Munich, Germany
13. Changes
This privacy policy may be updated as needed. You can always find the current version on this page.
Last updated: October 2026