privacy-policy

Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes, and to what extent, in connection with the provision of our website.

The terms used are not gender-specific.

Last updated: October 21, 2026

Table of Contents

Controller

Lukas Konstantin Faber
Fasoltstraße 23
80639 Munich, Germany

Email address: support@appdna.de

Legal notice (Impressum): https://appdna.de/legal/appdna/imprint/

Overview of Processing

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

Types of Data Processed

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

Categories of Data Subjects

  • Service recipients and clients.
  • Employees.
  • Users.
  • Third parties.
  • Whistleblowers.

Purposes of Processing

  • Security measures.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Whistleblower protection.

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 regulations may apply in your country or in our country of residence or establishment. Furthermore, should more specific legal bases apply in individual cases, we will inform you of these in this privacy policy.

  • Consent (Art. 6(1)(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Legal obligation (Art. 6(1)(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(1)(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, fundamental rights, and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG). The BDSG contains special provisions 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, transmission, and automated individual decision-making, including profiling. In addition, state data protection laws of the individual German federal states may apply.

Security Measures

In accordance with legal 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 risks 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, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input, disclosure, availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to threats to data. We also take the protection of personal data into account already during the development and selection of hardware, software, and processes, in accordance with the principle of data protection by design and by default.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via 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), thereby protecting the data from unauthorized access. TLS, as the more advanced and more 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 indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

Transmission of Personal Data

In the course of processing personal data, it may happen that the data is transmitted or disclosed to other bodies, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks, or providers of services and content that are embedded in a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data 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 occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies, or companies (which becomes apparent from the postal address of the respective provider or when the privacy policy expressly refers to data transfers to third countries), this always takes place in accordance with legal requirements.

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

This dual 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 DPF, the standard contractual clauses act as a reliable fallback. In this way, we ensure that your data remains adequately 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 U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding safeguards apply, in particular standard contractual clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the European 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 personal data that we process in accordance with legal requirements as soon as the underlying consents are withdrawn or there are no further legal bases for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer needed. Exceptions apply where statutory 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 the pursuit of legal claims or for the protection of 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 multiple retention periods or deletion deadlines are specified for a data item, the longest period always applies. Data that is no longer retained for its originally intended purpose but due to legal 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 organizational documents required to understand them (Sec. 147(1) no. 1 in conjunction with (3) of the German Fiscal Code (AO); Sec. 257(1) no. 1 in conjunction with (4) of the German Commercial Code (HGB)).
  • 8 years – Accounting vouchers, such as invoices and expense receipts (Sec. 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO; Sec. 14b(1) of the German VAT Act (UStG); and Sec. 257(1) no. 4 in conjunction with (4) HGB).
  • 6 years – Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, and other documents insofar as they are relevant for taxation, e.g., hourly wage slips, operating accounting sheets, calculation documents, price labels, as well as payroll accounting documents insofar as they are not already accounting vouchers, and cash register receipts (Sec. 147(1) nos. 2, 3, 5 in conjunction with (3) AO; Sec. 257(1) nos. 2 and 3 in conjunction with (4) HGB).
  • 3 years – Data required to take into account potential warranty and damages claims or similar contractual claims and rights, and to process related inquiries, based on previous business experience and common industry practices, is stored for the duration of the regular statutory limitation period of three years (Sec. 195, 199 of the German Civil Code (BGB)).

Start of the period 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 event triggering the period is the time at which the termination or other end of the legal relationship takes effect.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of your personal data which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of 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 request confirmation as to whether data concerning you is being processed, and to request access to this data as well as further information and a copy of the data, in accordance with legal requirements.
  • Right to rectification: In accordance with legal 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 legal requirements, you have the right to demand that data concerning you be erased without undue delay or, alternatively, to demand restriction of the processing of the data in accordance with legal requirements.
  • Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal 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 data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR. The complaint may be lodged in particular with a supervisory authority in the Member State of your habitual residence, place of work, or the place of the alleged infringement.

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 features); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); log data (e.g., log files relating to 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)(1)(f) GDPR).

Further information 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 hoster”). Legal bases: Legitimate interests (Art. 6(1)(1)(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”. Server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes 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 avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and to ensure the load capacity and stability of the servers. Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is exempt from deletion until the respective incident has been finally resolved.
  • Content delivery network: We use a “content delivery network” (CDN). A CDN is a service that helps deliver the content of an online offering, in particular large media files such as graphics or program scripts, faster and more securely by means of regionally distributed servers connected via the internet. Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Changes and Updates

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

Where we provide addresses and contact information of companies and organizations in this privacy policy, please note that addresses may change over time, and please verify the information before contacting them.

Definitions of Terms

This section provides an overview of the terms used in this privacy policy. Where terms are legally defined, their legal definitions apply. The following explanations, by contrast, are intended primarily to aid understanding.

  • Employees: Employees are persons who are in an employment relationship, whether as workers, salaried staff, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It includes the employer’s obligation to pay the employee remuneration while the employee performs their work. The employment relationship comprises various phases, including its establishment, in which the employment contract is concluded; its performance, in which the employee carries out their work; and its termination, when the employment relationship ends, whether by notice of termination, termination agreement, or otherwise. Employee data is all information relating to these persons in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank data, working hours, vacation entitlements, health data, and performance evaluations.
  • 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 information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs), among other things. 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 data: Contact data is essential information that enables communication with persons or organizations. It includes, among other things, 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 containing information about how data is processed, transmitted, and managed. Meta data, also known as data about data, comprises information describing the context, origin, and structure of other data. It may include details on file size, creation date, the author of a document, and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and reviewing operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data covers a wide range of information showing how users use applications, which features they prefer, how long they stay on certain pages, and by what paths they navigate 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 analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and possible 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.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes 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 for analyzing system problems, for security monitoring, or for creating performance reports.
  • 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 performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether collecting, analyzing, storing, transmitting, or deleting.

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