Privacy policy
Last updated: 3 August 2026
This policy is governed by German and EU law. The English version is a translation for convenience. In case of doubt, the German version applies.
This privacy policy explains how Seruno LLC (“dein-smart CFO”, “we”, “us”) collects, uses and protects personal data when you visit dein-smartcfo.com or otherwise get in touch with us. We comply with the applicable data protection laws, in particular the EU General Data Protection Regulation (GDPR).
1. Controller
Seruno LLC7901 4th St N, Ste 300
St. Petersburg, FL 33702, USA
Owner: Claus Winkelmann
Email: info@dein-smartcfo.de
Phone: +49 1511 8400470
2. What data we collect
- Contact details you provide voluntarily, such as your name, phone number, email address and the content of your message, when you call or write to us.
- Documents you make available to us in the course of working together, for example for the Smart CFO Check or your financial plan.
- Technical data collected automatically in the server log files when you visit the website: IP address, browser type and version, operating system, referrer URL, pages visited, and the date and time of access.
This website contains no contact form. You reach us via the phone number and email address given above.
3. Purposes and legal bases
- Operating, securing and providing the website: legitimate interests (Art. 6(1)(f) GDPR).
- Responding to your enquiries and preparing possible cooperation: pre-contractual measures (Art. 6(1)(b) GDPR) or legitimate interests (lit. f).
- Carrying out an existing mandate, including working with your documents: performance of a contract (Art. 6(1)(b) GDPR).
- Passing information to experts in the network when you agree to a specific implementation: your consent (Art. 6(1)(a) GDPR) or performance of a contract (lit. b).
- Meeting statutory retention and documentation obligations: Art. 6(1)(c) GDPR.
4. Sharing with third parties
We do not sell your personal data. Information is passed to experts in our network, such as tax advisers, insurers, banks or wealth managers, only when you agree to a specific implementation, and only to the extent required for it. In every single case you decide whether and to whom your documents are passed on.
For the technical operation of the website we use the following processors:
| Service | Purpose | Basis |
|---|---|---|
| Lovable (hosting) | Serving the website, server log files | Data processing agreement under Art. 28 GDPR |
We use no Google Fonts, no Google Analytics, no Meta Pixel and no other advertising or tracking services on this website. The fonts are served from our own server, so no connection to a font provider is made. Should any of this change, we will update this policy and, where required, obtain your consent in advance.
5. Retention
We store personal data only for as long as it is needed for the purposes described above or required by law. Server log files are kept for a maximum of 30 days and then deleted or anonymised. Correspondence relating to enquiries is generally deleted within 24 months unless a longer retention period applies. Statutory retention periods apply to mandate documents.
6. Cookies and similar technologies
This website sets no cookies, neither our own nor third-party ones. We also use no localStorage, no sessionStorage, no browser fingerprinting and no other technologies that would require consent under § 25 TDDDG.
| Category | Used? | Details |
|---|---|---|
| Strictly necessary cookies | No | Not required to operate this website. |
| Functional cookies | No | None. |
| Analytics and measurement | No | No analytics tools embedded. |
| Marketing and advertising | No | No advertising or remarketing trackers. |
Since no consent-requiring technologies are in use, this site deliberately shows no cookie banner. Should cookies or tracking be introduced in future, we will add a GDPR-compliant consent banner and obtain your consent in advance.
7. Transfers to the United States
Seruno LLC is based in the United States. Where personal data is transferred there, we rely on your consent, on the necessity for the performance of a contract, or on the European Commission's standard contractual clauses. The United States does not provide a level of data protection comparable to the EU; in particular, US authorities may access data under certain conditions.
8. Your rights
Subject to applicable law, you have the right to:
- access the data stored about you (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 (Art. 21 GDPR)
- withdraw consent with effect for the future
- lodge a complaint with a competent supervisory authority
To exercise these rights, write to us at info@dein-smartcfo.de.
9. Confidentiality
We treat documents you entrust to us in the course of working together as confidential and use them solely to build and implement your financial plan. On request we sign a confidentiality agreement in advance.
10. Security
Data is transmitted using TLS encryption. Beyond that we take appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access.
11. Children
The website is not directed at children under the age of 16. We do not knowingly collect personal data from children.
12. Changes
We may update this privacy policy from time to time. The current version is always available at this URL together with the date of the last update.