Privacy policy

Last updated: 7 September 2026

This is a courtesy translation. The German version is the legally binding one.

This policy applies to the website umgangszeit.app. The mobile app is covered by the app privacy policy.

Controller

Marc Pribbernow
Urbanstr. 175
10961 Berlin
Germany

Email address: datenschutz@umgangszeit.app

Overview of processing operations

The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects concerned.

Types of data processed

Inventory data.
Contact details.
Content data.
Usage data.
Meta, communication and procedural data.
Log data.

Categories of data subjects

Communication partners.
Users.

Purposes of processing

Communication.
Security measures.
Direct marketing.
Reach measurement.
Organisational and administrative procedures.
Feedback.
Profiles with user-related information.
Provision of our online offering and user-friendliness.
Information technology infrastructure.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection rules may apply in your or our country of residence or establishment. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

Consent (Art. 6(1) sentence 1 point (a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6(1) sentence 1 point (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection rules in Germany: In addition to the data protection rules of the GDPR, national data protection rules apply in Germany. These include in particular the Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG). The BDSG contains in particular special rules on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated individual decision-making including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Security measures

In accordance with the statutory requirements and taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

These measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access to, input of, transfer of, availability of and separation of the data. We have also established procedures to ensure that data subjects' rights are exercised, that data is erased and that we respond to threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect users' data transmitted via our online services against unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signalled by HTTPS being shown in the URL. This serves as an indicator to users that their data is transmitted securely and in encrypted form.

Transfer of personal data

In the course of our processing of personal data, it may happen that the data is transferred to, or disclosed to, other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers entrusted with IT tasks or providers of services and content that are embedded in a website. In such cases, we observe the statutory requirements and in particular conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or if this happens in the course of using third-party services or disclosing or transferring data to other persons, bodies or companies (which is recognisable from the postal address of the respective provider or when the privacy policy expressly refers to a data transfer to third countries), this is always done in accordance with the statutory requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This two-fold safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes occur within the framework of the DPF, the standard contractual clauses take effect as a reliable fallback option. In this way, we ensure that your data remains appropriately protected even in the event of political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, corresponding safeguards apply, in particular standard contractual clauses, explicit consent or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete the personal data we process in accordance with the statutory provisions as soon as the underlying consents are withdrawn or no other legal bases for the processing exist. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where statutory obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for reasons of commercial or tax law, or whose storage is necessary for the pursuit of legal claims or to protect the rights of other natural or legal persons, must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

Where several retention periods or deletion deadlines apply to a piece of data, the longest period always prevails. Data that is no longer retained for its originally intended purpose but due to statutory requirements or other reasons is processed by us exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply to retention and archiving under German law:

10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organisational documents required to understand them (§ 147(1) no. 1 in conjunction with (3) AO (German Fiscal Code), § 257(1) no. 1 in conjunction with (4) HGB (German Commercial Code)).
8 years - Accounting documents, such as invoices and expense receipts (§ 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO, § 14b(1) UStG (German VAT Act) and § 257(1) no. 4 in conjunction with (4) HGB).
6 years - Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating cost sheets, costing documents, price labelling, as well as payroll documents insofar as they are not already accounting documents, and till receipts (§ 147(1) nos. 2, 3, 5 in conjunction with (3) AO, § 257(1) nos. 2 and 3 in conjunction with (4) HGB).
3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, and to process related enquiries, based on previous business experience and customary industry practice, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB (German Civil Code)).

Period begins at the end of the year: If a period does not expressly begin on a specific date and is at least one year long, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the triggering event is the date on which the termination or other ending of the legal relationship takes effect.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, arising in particular from Art. 15 to 21 GDPR:

Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1) point (e) or (f) GDPR; this also applies to profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
Right of access: You have the right to obtain confirmation as to whether data concerning you is being processed, and to access that data as well as further information and a copy of the data in accordance with the statutory requirements.
Right to rectification: In accordance with the statutory requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
Right to erasure and restriction of processing: In accordance with the statutory requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively to request a restriction of the processing of the data in accordance with the statutory requirements.
Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the statutory requirements, or to request its transmission to another controller.
Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

Provision of the online offering and web hosting

We process users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.

Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). Log data (e.g. log files concerning logins or the retrieval of data or access times.).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers etc.)). Security measures.
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Further notes on processing operations, procedures and services:

Provision of the online offering on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called a "web host"); Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).
Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files retrieved, the date and time of retrieval, the volume of data transferred, notification of successful retrieval, browser type and version, the user's operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure the servers' capacity utilisation and stability; Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally resolved.
Cloudflare: Content delivery network, web hosting (Cloudflare Workers) and cookie-free reach measurement (Cloudflare Web Analytics); Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR). Website: https://www.cloudflare.com; Privacy policy: https://www.cloudflare.com/privacypolicy/; Basis for third-country transfer: Data Privacy Framework (DPF), standard contractual clauses; Data processing agreement: the provider's Data Processing Addendum.

Contact and enquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the details of the enquiring persons are processed insofar as this is necessary to respond to the contact enquiries and any requested measures.

Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Communication partners.
Purposes of processing and legitimate interests: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via an online form; for details of the app's anonymous feedback form, see the section "Plug-ins and embedded functions and content" below). Provision of our online offering and user-friendliness.
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR).

Further notes on processing operations, procedures and services:

Contact form: When you contact us via our contact form, by email or other communication channels, we process the personal data transmitted to us in order to respond to and handle the respective matter. This usually includes details such as name, contact information and, where applicable, further information that is communicated to us and is necessary for appropriate handling. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR), legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Newsletter and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter "newsletter") exclusively with the consent of the recipients or on a statutory basis. Where the contents of the newsletter are described when you sign up for it, those contents are decisive for the users' consent. To sign up for our newsletter, it is normally sufficient to provide your email address. However, in order to offer you a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter, or for further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to prove that consent was once given. The processing of this data is restricted to the purpose of a potential defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a block list (so-called "blocklist").

The sign-up procedure is logged on the basis of our legitimate interests for the purpose of proving that it was carried out properly. Where we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.

Contents: Information on the availability of the Umgangszeit app, the start of the test phase and new features.

Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); contact details (e.g. postal and email addresses or telephone numbers); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
Data subjects: Communication partners.
Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post).
Legal bases: Consent (Art. 6(1) sentence 1 point (a) GDPR).
Option to object (opt-out): You can cancel receipt of our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably email, for this purpose.

Web analytics, monitoring and optimisation

The only web analytics tool we use is Cloudflare Web Analytics. This service works without cookies, without recognising individual users and without user profiles. For this reason, no consent is required and no cookie banner is used.

Web analytics (also referred to as "reach measurement") serves to evaluate the visitor flows of our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, see at what time our online offering or its functions or content are used most frequently, or invite reuse. We can also identify which areas need optimisation.

In addition to web analytics, we may also use testing procedures, for example to test and optimise different versions of our online offering or its components.

Only aggregated information about the page view is collected, such as the page visited, the referring website, the time of the visit and technical details such as browser, operating system and approximate country of origin. No information is stored on or read from the user's device, no profiles are created and no location data is processed.

The user's IP address is not stored for the evaluation; it is used only transiently to generate a non-traceable identifier for the individual page view. Directly identifying data such as names or email addresses is not processed in the course of reach measurement. Neither we nor the provider can identify individual users or recognise them across multiple visits.

Notes on legal bases: Since the reach measurement works without cookies, without recognition and without user profiles, the data is processed on the basis of our legitimate interests (i.e. an interest in a data-minimising evaluation of visitor numbers). Consent is not required for this.

Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing and legitimate interests: Reach measurement (aggregated access statistics without recognition of returning visitors).
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". No cookies and no comparable storage methods are used on users' devices.
Security measures: No storage of the IP address for evaluation purposes.
Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Plug-ins and embedded functions and content

We embed functional and content elements in our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").

The embedding always requires that the third-party providers of this content process the user's IP address, since without the IP address they could not send the content to the user's browser. The IP address is therefore necessary for the display of this content or these functions. We endeavour to use only content whose respective providers use the IP address solely to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other details about the use of our online offering, and may also be combined with such information from other sources.

Notes on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for the data processing is that permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. an interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness.
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
Legal bases: Consent (Art. 6(1) sentence 1 point (a) GDPR). Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Further notes on processing operations, procedures and services:

Tally: Embedding of the waiting list form; data processed: email address, platform, whether you want to take part in testing, free-text answer, IP address, origin page of the sign-up (which page of our website led to the form); Service provider: Tally Forms BV, Belgium (EU); Legal bases: Consent (Art. 6(1) sentence 1 point (a) GDPR). Website: https://tally.so; Privacy policy: https://tally.so/help/privacy-policy; Retention: until consent is withdrawn, at the latest twelve months after the app is published in the store.
Draft - not a final legal text, to be reviewed by a lawyer before publication. Tally (feedback form): Embedding of an anonymous feedback form from the app (category, free text, app version/platform; no email address, no name); data processed: form content, IP address; Service provider: Tally Forms BV, Belgium (EU); Legal basis: Consent (Art. 6(1) sentence 1 point (a) GDPR), as for the waiting list sign-up above - embedding Tally when the page is loaded is the same operation, regardless of whether the form contains an email field. Legal basis to be checked during legal review. Website: https://tally.so; Privacy policy: https://tally.so/help/privacy-policy; Retention: period to be determined during legal review; the intention is to delete each item of feedback once it has been dealt with, at the latest twelve months after receipt. The form submissions are additionally forwarded automatically by Tally to an internal, non-public Notion database of the operator (triage/handling of the reports); as a result, Notion Labs, Inc. (USA) acts as a further processor; the data transfer to the USA takes place on the basis of the standard contractual clauses or the EU-US Data Privacy Framework, and here too exclusively for the form content and IP address, no contact or email data.

Changes and updates

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact details of companies and organisations in this privacy policy, please note that the addresses may change over time, and please check the details before making contact.

Definitions

This section gives you an overview of the terms used in this privacy policy. Where the terms are defined by law, their statutory definitions apply. The following explanations are intended above all to aid understanding.

Inventory data: Inventory data comprises essential information required for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, institutions or systems by enabling unambiguous assignment and communication.
Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
Contact details: Contact details are essential information that enables communication with persons or organisations. They include telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Metadata, also known as data about data, comprises information that describes the context, origin and structure of other data. It may include details of file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used to track and verify operations.
Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data covers a broad range of information showing how users use applications, which features they prefer, how long they stay on certain pages and which paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. Usage data also plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings
Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, covers any form of automated processing of personal data that consists of using that personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and may cover the behaviour or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, operators of online offerings can, for example, see at what times users visit their web pages and which content they are interested in. This allows them, for example, to better adapt the content of their web pages to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, evaluation, storage, transmission or erasure.

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