Privacy Policy

1. Data Controller

The entity responsible for processing personal data in connection with the HANAKA website and its services is:

JANNAH EVLOVLE LLC
Operating under the brand HANAKA
261 North University Drive, Suite 500
Plantation, FL 33324
United States of America
Authorized Representative: Hannah Kassel
Email: jannahevolve@gmail.com
Telephone: +49 171 1768016
Privacy Contact: jannahevolve@gmail.com
EU Representative under Article 27 GDPR:

[REVIEW BEFORE PUBLICATION: Determine whether the appointment of an EU representative is required. If so, provide the representative's name and contact details.]

2. Scope of Personal Data Processing

HANAKA processes personal data to the extent necessary to operate its website, communicate with visitors and clients, respond to enquiries, provide agreed services, and comply with legal obligations.

The personal data processed may include:

• First and last name
• Email address
• Telephone number
• Country of residence, where required
• Travel destinations and dates
• Travel budget
• Number of travelers
• Individual travel preferences
• Accommodation and activity preferences
• Contract and invoice information
• Payment information
• Communications and correspondence
• Technical connection data

HANAKA processes personal data only where there is a legitimate purpose and an appropriate legal basis.

Sensitive personal information, including health-related information, should only be provided and processed where necessary for an expressly agreed purpose and where the applicable legal requirements are satisfied.

3. Legal Bases for Processing

Where the European Union General Data Protection Regulation (GDPR) applies, HANAKA processes personal data primarily on the following legal bases:

Article 6(1)(b) GDPR: Processing necessary for pre-contractual measures or performance of a contract.

Article 6(1)(c) GDPR: Processing necessary to comply with a legal obligation.

Article 6(1)(f) GDPR: Processing necessary for legitimate interests, particularly maintaining a secure website, conducting business communications, and establishing, exercising, or defending legal claims.

Article 6(1)(a) GDPR: Processing based on consent where legally required.

Where special categories of personal data are processed, an additional appropriate condition under Article 9 GDPR is required.

4. Website Hosting

The HANAKA website is intended to be hosted using Vercel's infrastructure, provided the planned technical implementation remains unchanged.

When visitors access the website, the following information may be processed:

• IP address
• Date and time of access
• Pages requested
• Browser information
• Operating system
• Technical connection information
• Security and error logs

This processing supports the technical operation, security, and stability of the website.

Where the GDPR applies, Article 6(1)(f) GDPR may serve as the relevant legal basis.

[REVIEW BEFORE PUBLICATION: Confirm the actual hosting provider, contractual arrangements, server locations, data processing agreement, subprocessors, international data transfers, and retention periods.]

5. Contact Forms

HANAKA provides contact forms for:
Travel Design
The Yacht Concierge

When visitors submit a form, HANAKA processes the information provided to respond to the enquiry and, where applicable, prepare or perform a contract.

This may include names, contact details, travel preferences, budget information, and additional voluntarily submitted information.

Where the GDPR applies, processing is generally based on Article 6(1)(b) GDPR or, for general enquiries, Article 6(1)(f) GDPR.

Personal data is not used for unrelated purposes without an appropriate legal basis.

[COMPLETE BEFORE PUBLICATION: Actual form processing provider, email delivery service, storage locations, and retention periods.]

6. Email Communication

When an individual contacts HANAKA by email, the information provided is processed to respond to the enquiry.

This may include the sender's email address, message content, attachments, and related communication data.

Depending on the circumstances, processing may be necessary for pre-contractual measures, contractual performance, or legitimate interests, where the GDPR applies.

[COMPLETE BEFORE PUBLICATION: Actual email service provider, data processing arrangements, international transfers, and retention periods.]

7. WhatsApp

HANAKA offers visitors the option to communicate via WhatsApp.

Using WhatsApp is voluntary.

When using this communication channel, personal data may be processed by the relevant WhatsApp service provider.

Such information may include telephone numbers, profile information, message content, and technical communication data.

HANAKA processes received messages to respond to enquiries and, where applicable, perform agreed services.

Visitors may alternatively contact HANAKA by email or through the website's contact forms.

Visitors are encouraged not to send particularly sensitive personal information through WhatsApp without prior arrangement.

[REVIEW BEFORE PUBLICATION: WhatsApp product used, relevant service provider, data protection responsibilities, and any international data transfers.]

8. Calendly

HANAKA intends to offer appointment scheduling through Calendly.

When using the appointment booking service, the following data may be processed:

• Name
• Email address
• Requested appointment
• Time zone
• Voluntarily provided information
• Technical usage data

HANAKA processes this information to arrange and conduct the requested appointment.

Where the GDPR applies, Article 6(1)(b) GDPR may serve as the relevant legal basis.

Calendly's own privacy information applies to its independent processing activities.

[REVIEW BEFORE PUBLICATION: Actual integration method, cookies, international data transfers, contractual privacy arrangements, and any required consent mechanism.]

9. Payment Processing

Payments for HANAKA services are generally made by bank transfer.

HANAKA processes information necessary for invoicing, payment allocation, accounting, and compliance with legal obligations.

This may include:

• Payer's name
• Billing address
• Invoice amount
• Bank account information
• Payment date
• Payment reference
• Invoice number

Processing is carried out for contractual performance and compliance with applicable legal obligations.

10. Disclosure to Independent Travel Providers

HANAKA prepares travel plans and provides recommendations and, where appropriate, direct booking links.

Clients enter into contracts with recommended travel providers independently.

HANAKA does not automatically transmit clients' personal data to recommended travel providers.

Any disclosure will occur only where necessary, legally permitted, and supported by an appropriate legal basis.

11. Cookies and Similar Technologies

The website may use cookies and similar technologies.

Technically necessary technologies may support website security, functionality, and the storage of expressly selected preferences.

Non-essential technologies are used only where the applicable legal requirements have been satisfied.

Where prior consent is required, such consent will be obtained before activation.

Further details are provided in the Cookie Policy.

12. Analytics and Marketing

Under the currently agreed website concept, HANAKA does not use Google Analytics, Meta Pixel, or comparable advertising tracking services.

If such services are introduced in the future, the relevant privacy information and consent mechanisms will be updated before activation.

13. Newsletter

HANAKA does not currently offer a newsletter.

No newsletter subscription is available through this website.

14. International Data Processing

HANAKA is operated by a company established in the United States of America.

Personal data may therefore be processed outside the European Economic Area.

Where the GDPR applies, HANAKA will comply with the relevant legal requirements governing international data transfers.

[COMPLETE BEFORE PUBLICATION: Actual recipients, processing countries, and applicable transfer mechanisms.]

15. Data Retention

Personal data is retained only for as long as necessary for the relevant purposes or to comply with applicable legal retention obligations.

Relevant considerations may include:

• Duration of the client relationship
• Handling of outstanding enquiries
• Contractual obligations
• Accounting and tax requirements
• Establishment, exercise, or defense of legal claims

[COMPLETE BEFORE PUBLICATION: Specific retention and deletion periods for contact forms, communications, contracts, invoices, and technical logs.]

16. Data Security

HANAKA implements appropriate technical and organizational measures to protect personal data.

These measures may include access restrictions, secure transmission methods, and careful selection of service providers.

Absolute security of electronic data transmission cannot be guaranteed.

17. Rights of Data Subjects

Where the GDPR applies, individuals may have the following rights, subject to the applicable legal requirements:

• Right of access
• Right to rectification
• Right to erasure
• Right to restriction of processing
• Right to data portability
• Right to object
• Right to withdraw consent with future effect
• Right to lodge a complaint with a competent supervisory authority

Requests may be submitted to:
jannahevolve@gmail.com

Additional rights may arise under other applicable privacy laws.

18. Amendments

This Privacy Policy may be updated if legal requirements or actual data processing activities change.

Effective Date: November 1, 2026