App privacy policy

Last updated: 20 October 2026

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

This policy applies to the mobile app Umgangszeit for iPhone and Android. The website umgangszeit.app is covered by the website privacy policy.

The essentials in brief

All content you record in the app – contact times, check-ins, moments, receipts, photos, locations – stays on your device. The only exception concerns location: if you switch on location for a check-in, the coordinates of that one check-in are sent to the operating system's map service so that a place name can be shown (see Access to device features).
There is no user account, no registration, no server and no cloud synchronisation.
We have no access to your content. We can neither read it, nor restore it, nor delete it.
The app sends usage data to us only if you expressly consent to the pseudonymous usage statistics. The default setting is "off". If you open the privacy policy or the imprint in the app, the app loads that page from umgangszeit.app (see Opening this page from the app). If you send us feedback via "Give feedback", it reaches us through a form (see Feedback from the app).
On Android, text recognition for receipts uses Google ML Kit. Recognition runs on the device, but the library sends usage and diagnostic data to Google, no image content (see Text recognition on Android). On the iPhone, text recognition runs without any outside connection.
There is no advertising, no third-party tracking and no sharing of data for advertising purposes.

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. It covers only those processing operations in which data actually reaches our company. Content that the app stores only locally on your device is not processed by us.

Types of data processed

Usage data (only with consent to the usage statistics).
Origin details in the requested address (only if you open the privacy policy or the imprint in the app).
Feedback details: category, free text, app version and platform (only if you submit the feedback form).
Contact details (only if you write to us).
Content data (only if you write to us).

Categories of data subjects

Users of the app.
Communication partners.

Purposes of processing

Provision of the app and user-friendliness.
Reach measurement (pseudonymous usage statistics with consent).
Communication.
Feedback.
Security measures.

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.

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.

Note on access, rectification and erasure: The content you record in the app is stored exclusively on your device. We have no access to it and can therefore neither provide access to this content nor rectify or erase it. You can view, change and export the data yourself in the app at any time and remove it completely via "Delete all data"; removing the app also deletes all locally stored content. Your rights towards us relate to the processing operations listed above that actually reach us.

Processing exclusively on the device

The Umgangszeit app is built so that your content does not leave the device. Contact times and arrangements, check-ins for handovers, moments and notes, receipts and receipt photos, recorded amounts and details about your child are stored exclusively in the local storage of your device.

There is no server to which this data is transmitted, no user account, no registration and no synchronisation across multiple devices. We as the provider never receive this data and cannot view it.

The text recognition on receipt photos also runs on the device (on-device text recognition). No image and no recognised text is sent to us or to third parties. On the iPhone, the app uses Apple Vision for this, without any outside connection. On Android, it uses Google ML Kit; this library sends usage and diagnostic data to Google (see Text recognition on Android).

From a legal perspective, purely local storage is processing that you carry out yourself on your device. We are not the controller for it within the meaning of the GDPR, because we neither hold nor decide on this data.

Types of data processed: Content data, image data, appointment details, amounts, optionally location details – all local only.
Data subjects: Users of the app; third parties recorded by users (e.g. their own child, the other parent).
Purposes of processing: Provision of the app's features on the device.
Retention and deletion: The data remains on the device until you delete it in the app or remove the app.
Legal bases: No processing by the provider; the content is not transferred. The cases in which data leaves the device are described under Access to device features (place name for a location) and Text recognition on Android.

Access to device features

The app asks for a permission only when you use a feature that needs it. You can revoke any permission at any time in your device's system settings; the remaining features of the app continue to work.

Camera: Only for photographing receipts and moments. The photos are stored locally.
Photos and media library: Only when you select an existing image from your media library or save an image there. The app does not read your media library on its own.
Location: Only if you switch on location for an individual check-in. The location of your own device is then determined once and stored locally with the check-in. To show a place name (street and town) for it, the device sends the coordinates of that one check-in to the operating system's map service: on the iPhone to Apple, on Android to the system's geocoding service, which on devices with Google services means Google. The app passes on only these coordinates, no other content. There is no background location tracking or background lookup, no movement profiles and no locating of other people.
Notifications: Reminders for upcoming contact times are scheduled locally on the device. No push messages are sent via a server.

The data recorded in this way remains on the device and is not transferred to us. The only transfer to third parties is the place-name lookup with the operating system's map service described above. The respective provider processes this lookup under its own responsibility; we receive no data from it.

Types of data processed: Location data (coordinates of the respective check-in).
Data subjects: Users of the app.
Purposes of processing: Showing a place name for the check-in.
Legal bases: Consent (Art. 6(1) sentence 1 point (a) GDPR) by switching on location for the respective check-in.
Map service on the iPhone: Apple; Privacy policy: https://www.apple.com/legal/privacy/en-ww/.
Map service on Android: the operating system's geocoding service, on devices with Google services Google; Privacy policy: https://policies.google.com/privacy.

Text recognition on Android (Google ML Kit)

So that you do not have to type in the date, amount and merchant of a receipt, the app reads the text on receipt photos. To crop the photo, it also detects where QR codes and barcodes are located; it does not read their content. On the iPhone, both happen with Apple Vision entirely on the device, without any outside connection.

On Android, the app uses the text and barcode recognition of Google ML Kit for this. Recognition runs on the device there too: receipt images and recognised text do not leave the device. After a recognition, however, the library sends usage and diagnostic data to Google, for example device information, details about the app and performance metrics. This transfer cannot be switched off in the app; it is triggered only when text recognition runs for a receipt.

Types of data processed: Usage and diagnostic data (device information, details about the app, performance metrics); no image content, no recognised text.
Data subjects: Users of the app on Android.
Purposes of processing: Provision of text recognition on the device.
Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR) in text recognition that evaluates receipts on the device without sending images to a server.
Google ML Kit: Service provider: Google; Website: https://developers.google.com/ml-kit; Privacy policy: https://policies.google.com/privacy.

Backups

The app offers to export your data as a backup. You create this backup yourself and save it in a place of your choice, for example in a Files app, in your provider's cloud storage or on a computer.

Once the backup has left the app, you decide where it is stored and how it is protected. The respective provider is responsible for the conditions that apply there, not us. Please bear in mind that a backup may contain sensitive details about your child, and choose the storage location with corresponding care.

Independently of this, depending on your system settings, your device data may be included in the device backup by Apple or Google. You control this backup in your device's settings; we have no influence on it and no access to it.

Details about the child

The app is aimed at adult parents, not at children. In it, you record details about your child, such as first name, date of birth, photos and notes on shared moments.

These details remain exclusively on your device. We do not process them, do not receive them and do not pass them on. You, as the parent with custody, are responsible for how these details are handled.

Usage statistics with consent

To understand which features of the app are used and where users get stuck, we may collect pseudonymous usage statistics. These are switched off by default. We ask you once during onboarding whether you consent. Without your consent, no usage data is transmitted.

Only event names (for example "receipt recorded") with additional details that contain only categories, counters or yes/no values (for example whether a check-in was recorded with location, but not the location itself), a timestamp rounded to the full hour, a pseudonymous identifier of the app installation, a random identifier of the respective session and an automatic signal when a session starts, as well as technical context such as app version, operating system version and device type are transmitted. Content, names, amounts, places, photos or free text are never transmitted.

The service used, TelemetryDeck, does not store IP addresses – neither in the database nor in log files – and does not use cookies. The SDK creates the pseudonymous identifier on the device as a one-way hash (SHA-256) of a device identifier: on the iPhone from the identifier for vendor (identifierForVendor), on Android from a random identifier that the SDK generates and stores on the device. On receipt, TelemetryDeck additionally adds a salt to the hash and hashes it again. The identifier stays the same for the installation. It makes it possible to count events from the same installation together, but contains neither names nor content. Advertising identifiers are not used.

You can withdraw your consent at any time in the app's settings. The withdrawal takes effect for the future; the lawfulness of the processing carried out up to that point remains unaffected.

Types of data processed: Usage data (event names with categories, counters and yes/no values, time, pseudonymous identifier of the installation, session identifier, app version, operating system version, device type).
Data subjects: Users of the app.
Purposes of processing: Reach measurement, improvement of the app.
Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion".
Legal bases: Consent (Art. 6(1) sentence 1 point (a) GDPR); for access to information on the end device, § 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act).
Opt-out: App settings, privacy section.
TelemetryDeck: Pseudonymous usage statistics without cookies and without storage of IP addresses; Service provider: TelemetryDeck GmbH, Von-der-Tann-Str. 54, 86159 Augsburg, Germany; Website: https://telemetrydeck.com; Privacy policy: https://telemetrydeck.com/privacy/; Further information: the provider's privacy FAQ; Data processing agreement: https://telemetrydeck.com/avv/; Server location: European Union (Germany and the Netherlands).

Opening this page from the app

In the app's settings, you can read the privacy policy and the imprint. The app then loads these pages from umgangszeit.app, and only if you open them yourself. Nothing is loaded unless you open them.

The requested address contains origin details: an indication that the request comes from the app, the app version and the platform (iOS or Android). They serve only to distinguish requests from the app from requests in a browser, and contain no user identifier and no device identifier. Because they are part of the requested address, they are transmitted regardless of your decision on the usage statistics and may appear in the hosting provider's server log files.

As with a request in a browser, the page loads the Cloudflare Web Analytics script for cookie-free reach measurement. Information on web hosting, server log files and reach measurement, including retention period and legal basis, can be found in the website privacy policy under "Provision of the online offering and web hosting" and "Web analytics, monitoring and optimisation".

Types of data processed: Origin details in the requested address (indication of the app, app version, platform); technical details of the page request as described in the website privacy policy.
Data subjects: Users of the app who open the privacy policy or the imprint.
Purposes of processing: Reach measurement (distinguishing requests from the app from requests in a browser).
Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR), as for the website's reach measurement.
Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; further details in the website privacy policy.

Feedback from the app

Under Settings → Give feedback, you can send us feedback without a name and without an email address. The app then opens the page umgangszeit.app/en/feedback in a view within the app, and only if you tap the entry yourself. The page embeds a form from the service Tally.

The category you choose and your free text are transmitted, together with the app version and the platform (iOS or Android), which the app includes in the requested address. Loading the page and the form also generates technical access data such as your IP address. Tally automatically forwards the submissions to an internal, non-public Notion database in which we handle the feedback.

Further information on Tally, on the forwarding to Notion and on retention can be found in the website privacy policy under "Plug-ins and embedded functions and content".

Types of data processed: Feedback details (category, free text), app version, platform, IP address.
Data subjects: Users of the app who send feedback.
Purposes of processing: Feedback, improvement of the app.
Retention and deletion: As stated in the website privacy policy.
Legal bases: Consent (Art. 6(1) sentence 1 point (a) GDPR), as in the website privacy policy.
Tally: Service provider: Tally Forms BV, Belgium (EU); Website: https://tally.so; Privacy policy: https://tally.so/help/privacy-policy.
Notion: Notion Labs, Inc., USA, as a further processor for handling the submissions; the transfer of data to the USA is based on the standard contractual clauses or the EU-US Data Privacy Framework.

Distribution via the App Store and Google Play

You obtain the app via the Apple App Store or Google Play. When you download, update and use the store features, these providers process data under their own responsibility, such as your store identifier, device details, time of download and crash reports, provided you have enabled their transmission in the operating system.

We have no influence on this processing. We receive only aggregated, non-personal evaluations from the stores, such as the number of installations.

Apple App Store: Service provider: Apple Distribution International Ltd., Hollyhill Industrial Estate, Cork, Ireland; Privacy policy: https://www.apple.com/legal/privacy/en-ww/.
Google Play: Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Privacy policy: https://policies.google.com/privacy.

External links and waiting list

In a few places, the app offers to open a web page, for example the waiting list for new features. Your device's browser is then opened with the address umgangszeit.app. From that moment on, the website privacy policy applies.

The app passes on only an indication of which feature the request comes from. No content from the app is transferred to the website.

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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