Privacy Policy

Responsible

Overview of processing activities

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

Types of data processed

• Contact details
• Content data
• Usage data
• Metadata, communication data and process data
• Log data

Categories of affected persons

• Communication partner
• Users

Purposes of processing

• Communication
• Security measures
• Organizational and administrative procedures
• Feedback
• Provision of our online services 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 under the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Furthermore, should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)

The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 protection of personal data.

National data protection regulations in Germany

In addition to the GDPR data protection regulations, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific provisions regarding 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 data transfers, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.

Security measures

In accordance with legal requirements, 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 threat to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services from unauthorized access, we rely on 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), thus protecting the data from unauthorized 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 with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

General information on data storage and deletion

We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are withdrawn or no further legal basis for processing exists. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

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

Our privacy policy contains additional information on the storage and deletion of data, which applies specifically to certain processing operations.

In cases where multiple retention periods or deletion deadlines for a given date are specified, the longest period always applies. Data that is no longer retained for its originally intended purpose, but is retained due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.

Data retention and deletion

The following general retention periods apply to data storage 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 organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
• 8 years — Accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
• 6 years — Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. timesheets, operating statements, costing documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register tapes (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
• 3 years — Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Commencement of a time limit at the end of the year

If a time limit does not expressly begin on a specific date and is at least one year long, it starts automatically at the end of the calendar year in which the event triggering the time limit occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the time limit is the effective date of the termination or other end of the legal relationship.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

Right to object

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data which is based on Article 6(1)(e) or (f) of the GDPR, including profiling based on those provisions. Where your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which 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 your consent at any time.

Right of access

You have the right to request confirmation as to whether data concerning you are being processed, and to obtain access to such data and other information in accordance with the statutory provisions, as well as to obtain copies of the data.

Right to rectification

You have the right, in accordance with the statutory provisions, to request the completion of data concerning you or the rectification of inaccurate data concerning you.

Right to erasure and restriction of processing

You have the right, in accordance with the statutory provisions, to request the immediate erasure of data concerning you, or, alternatively, in accordance with the statutory provisions, to request the restriction of the processing of the data.

Right to data portability

You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, or to request the transmission of such data to another controller, in accordance with the statutory provisions.

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 your personal data infringes the provisions of the GDPR.

Requesting deletion of your data

You can request deletion of your Cevmo data at any time.

This includes:

• Connected bank access
• Stored subscription records
• Associated account information

Uploaded bank statements remain on your device and are not stored by Cevmo.

During the beta period, deletion requests are handled manually. Contact hello@cevmo.com to request deletion.

Provision of the online service and web hosting

We process user data in order to make our online services available to them. 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 end device.

Types of data processed

Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved). Log data (e.g. log files concerning logins or data retrieval or access times).

Data subjects

Users (e.g. website visitors, users of online services).

Purposes of processing and legitimate interests

Provision of our online services 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 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing procedures, processes and services

Provision of online services on rented storage space

For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a "web hoster"); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Collection of access data and log files

Access to our online services is logged in the form of so-called "server log files." Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server capacity and stability. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Data Deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.

Contact and inquiry management

When contacting us (e.g. by post, contact form, e-mail, telephone or via social media) and in the context of existing user and business relationships, the details of the inquiring persons are processed, insofar as this is necessary to answer the contact inquiries and any requested measures.

Types of data processed

Contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as the information relating to them, such as information on authorship or time of creation). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).

Data subjects

Communication partners.

Purposes of processing and legitimate interests

Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services 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 para. 1 sentence 1 lit. f) GDPR). Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further notes on processing procedures, processes and services

Contact form

When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us in order to respond to and process the respective concern. This generally includes information such as name, contact details and, if applicable, other information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal bases: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Changes and updates

We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you if any changes require action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.

Definitions of terms

In this section, you will find an overview of the terminology used in this privacy policy. Where terms are legally defined, their statutory definitions apply. The following explanations are intended primarily to aid understanding.