Privacy policy
1. Controller
Alfred Spencer III, Founder, AS3 Compliance Consulting, Reifenstuelstrasse 2, 80469 Munich, Germany
Telephone: +49 1516 883 2801
Email: alfredspencer@as3complianceconsulting.com
2. What this website processes
Hosting and server logs. The site is hosted and delivered through Cloudflare (Cloudflare, Inc., USA, and its affiliates). When you visit, Cloudflare processes technical data such as your IP address, the date and time, the pages requested and your browser type in order to deliver and secure the site. Cloudflare also provides us with aggregated traffic statistics derived from these server logs. The legal basis is our legitimate interest in a secure and reliable website (Art. 6(1)(f) GDPR). Cloudflare acts as our processor and may process data outside the EU, based on the safeguards described in its data processing terms.
Contact by email or telephone. If you email or call us, we process your message, your contact details and the content of the conversation to answer you. The legal basis is Art. 6(1)(b) GDPR where your enquiry concerns a contract or pre-contractual steps, and otherwise our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR). We delete this data once your enquiry is resolved, unless statutory retention duties apply.
Request form (demo or assessment license). If you use the request form, you enter your name, work email, company, role, country, an optional message, the request type and your consent. The form does not send this data to a server of this website. When you submit it, your email program opens with a prepared message addressed to us, and the data reaches us only if you send that email; it then passes through your email provider and ours like any other email. We use the data only to handle your request, including contacting you about a demo or a paid license, and to send you an access code if your request is approved. The legal basis is Art. 6(1)(b) GDPR (steps at your request prior to a contract) and your consent given by ticking the box (Art. 6(1)(a) GDPR), which you can withdraw at any time by emailing us. We delete request data once the request is resolved, unless statutory retention duties apply. Providing the data is voluntary, but we cannot handle a request without it. The page contains a hidden field used only to deter automated spam; it stores nothing.
Web analytics. We use Cloudflare Web Analytics to understand how many people visit the site. It does not use cookies, does not track individual visitors across sites or sessions, and reports only aggregate page views and visits. It is provided and processed by Cloudflare, which loads a small script from Cloudflare when you open a page. The legal basis is our legitimate interest in the secure and effective operation of the website (Art. 6(1)(f) GDPR).
Cookies and tracking. The site sets no cookies and uses no advertising or social-media plug-ins.
Fonts and external content. The site uses system fonts and loads no third-party fonts or embeds. The only third-party script is the Cloudflare Web Analytics script described above.
3. FCPA Self-Assessment
The FCPA Self-Assessment is not publicly accessible. Access is provided by code after approval of a request. This policy will be updated before the tool is released and, in particular, to describe any data the tool processes.
4. Your rights
Under the GDPR you may have the right to access, rectification, erasure, restriction, data portability and objection, and the right to complain to a supervisory authority. The competent authority for Bavaria is the Bavarian State Office for Data Protection Supervision (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA).
5. Changes
Last updated: 1 November 2026