Privacy policy

1. Controller

Marko Krstic
Forsthofstr. 18
90461 Nürnberg
Germany
E-mail: kontakt@erechnung-erstellen.net

We have not appointed a data protection officer because we are not required to.

2. Overview

• No tracking: no analytics tools, no Meta Pixel, no fonts or content from third parties.
• The free generator does not store your invoice data. It is processed in memory only, to create and check the invoice.
• We do not archive invoices, not in Pro either. Archiving is your duty as the invoice issuer.
• We set a cookie for advertising purposes only if you come from an ad with a promo code and agree.

3. Hosting and server logs

The website and the application run on servers of Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, in Germany. Hetzner processes the data on our behalf (Art. 28 GDPR).

For every request our web server stores in its access log: IP address, date and time, the requested address, status code, amount of data transferred, your browser's identification (user agent), the processing time and a random ID of the request, with which we find an error in the application's logs. We need this to run the website securely and to detect attacks and errors. The legal basis is Art. 6(1)(f) GDPR. The access log is deleted after 14 days. The application's logs contain no IP addresses and no invoice content and are also deleted after 14 days.

To protect against abuse we count requests per IP address in memory only and for at most 15 minutes. These counters are not stored.

4. Free generator

We process what you enter in the generator (your company details, customer details, line items, bank details) only to create the invoice, calculate it and check that it is valid. It stays in memory only for the duration of the request and is stored neither in a database nor in logs. You receive the finished file as a download. The legal basis is Art. 6(1)(b) GDPR (use of the generator under our terms of use).

We count how many invoices are created per day and format, and with a promo code also for which campaign. This count contains no time of day, no IP address and no invoice content and cannot be linked to a person.

5. Cookies

We set only these cookies:

• Session cookie (JSESSIONID): only in Pro after login and on the registration and login pages, so you stay logged in and forms are protected against foreign senders. Deleted when you log out or after 30 minutes without activity.
• Stay logged in (remember-me): only if you choose it at login. Valid for 30 days from the login.
• Promo code (campaign): only if you come from an ad with a promo code and choose "Yes" in the prompt. It stores only the code, so we can fill it in when you register. Valid for 90 days.
• Your answer to the prompt (campaign-consent): stores yes or no, so we do not ask again. Valid for 6 months.

The first two cookies are strictly necessary for the service you asked for (Section 25(2) no. 2 TDDDG, Art. 6(1)(b) GDPR). The cookie with your answer is necessary to respect your decision (Section 25(2) no. 2 TDDDG, Art. 6(1)(f) GDPR). We set the promo code cookie only with your consent (Section 25(1) TDDDG, Art. 6(1)(a) GDPR). You can withdraw it at any time by deleting this website's cookies in your browser. With "No" you can use everything just the same.

6. Advertising on Facebook and Instagram

We run ads on Facebook and Instagram. The ads run on Meta's platform and are subject to Meta's privacy policy. We do not embed any Meta tools and do not send any data to Meta. If you come from an ad, the link contains a promo code. We count visits per campaign only as a number per day, without reference to you. If you register with a promo code, we store the code and the length of your trial with your account, to grant the trial and to measure the success of our advertising (Art. 6(1)(b) and (f) GDPR). This information is deleted with your account. Our evaluation per campaign contains only totals, never individual accounts.

7. Contact form and e-mail

If you write to us using the contact form or by e-mail, we process your name, e-mail address and message to answer your request (Art. 6(1)(b) GDPR for questions about a contract, otherwise (f)). The contact form stores nothing in our database but sends the message by e-mail to our mailbox. We keep messages as long as statutory retention duties require (commercial and business letters 6 years, Section 257 HGB, Section 147 AO). We delete other messages once the request is settled.

Our mailbox is operated by Titan (titan.email). [To be added before the launch: provider with address and storage location.] Where data is processed outside the EU, this is based on the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR).

8. Pro: account

Pro requires an account. For it we store your e-mail address, your password only as an irreversible hash (Argon2id), your language, the time of registration and confirmation, which version of the terms, the privacy policy and the data processing agreement was accepted and when, and, with "stay logged in", a hashed login key. Links in e-mails (confirmation, new password) contain a single-use key that we store only as a hash. The legal basis is Art. 6(1)(b) GDPR.

We send you e-mails that belong to the account: confirmation, new password, security notices (for example after a password change), warnings before deletion and the confirmation of a deletion. We do not send advertising e-mails.

We delete unconfirmed accounts after 7 days. After several wrong passwords we block the login for 15 minutes. We keep track of this in memory only.

9. Pro: your business data (processing on your behalf)

In Pro you store your company details, bank details, invoice settings, your logo and your customers. Of the last invoice created we store only its number, date and customer name, so you know the next number. We do not store created invoices.

For this data, in particular the data of your customers, you as the invoice issuer are the controller. We process it only on your behalf and on your instructions, on the basis of the data processing agreement (AVV) you conclude at registration. We do not look at this data. Our administration view shows only account data (e-mail address, company name, subscription dates, number of customers and of created invoices), never customers, addresses, bank details or tax numbers.

10. Pro: subscription and payment

For payments we use Stripe Payments Europe, Limited, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland. When you choose "Subscribe" for the first time, we create a customer at Stripe with your e-mail address and the number of your account with us, even if you do not pay afterwards. You enter your name, billing address and payment details (card) directly on Stripe's page. We never receive the card number. Stripe receives no invoice or customer data from your account. Stripe may also process data in the USA. This is based on the European Commission's adequacy decision for the EU-US Data Privacy Framework, under which Stripe is certified (Art. 45 GDPR), and on standard contractual clauses. Stripe processes part of the data under its own responsibility, for example for fraud prevention and legal duties. Stripe's privacy policy applies to that (stripe.com/privacy).

From Stripe we receive the status of your subscription, the paid period, the payment method (card) and, for our invoice, your name and billing address. For every payment we issue an invoice and send it to you by e-mail. We keep these invoices for 8 years, also after your account is deleted (Section 14b UStG, Section 147 AO; Art. 6(1)(c) GDPR). The legal basis for the subscription is Art. 6(1)(b) GDPR.

When your account is deleted, we cancel a running subscription and delete your customer at Stripe together with the saved payment methods. Stripe keeps the payment transactions as far as it is required to by law.

11. Sending e-mails

We send e-mails to you (account, security, invoices for the subscription) through Amazon Simple Email Service of Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg, from its data centre in Frankfurt am Main. Amazon processes the e-mails on our behalf (Art. 28 GDPR). Because Amazon belongs to a group in the USA, access from the USA cannot be ruled out. This is based on the adequacy decision for the EU-US Data Privacy Framework, under which Amazon is certified (Art. 45 GDPR), and on standard contractual clauses.

12. Usage statistics

To see the load of the server, we count requests per minute by type of request, function called, result and duration. For logged-in users we store the number of the account with it, likewise with the number of invoices created per day and format. We store no IP addresses and no content. The legal basis is Art. 6(1)(f) GDPR (operation, planning and detecting abuse). We delete the requests per minute after 6 months. After your account is deleted, the counts refer to no account any more and can no longer be linked to you.

13. Retention and deletion

• You can delete your account in Pro at any time. We then delete your account and all stored data at once (company details, logo, customers, last invoice, settings, promo code).
• After the end of the trial or of the paid period we keep your data for 6 months, so you can read and export it or renew the subscription. We warn you by e-mail 30, 7 and 1 day before. Then we delete the account as above.
• Excepted are our invoices for your subscription (8 years, see section 10) and counts without reference to a person.
• Backups of the database are stored encrypted. [To be added before the launch: provider and location of the backups.] Deleted data disappears from the backups when they are overwritten after [to be added before the launch] days.

14. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on Art. 6(1)(f) (Art. 21). You can withdraw a consent at any time with effect for the future (Art. 7(3)).

In Pro you can download your data yourself as a file ("Export my data"). The file does not contain your logo (you see it on the "Company details" page) nor the requests per minute; you get information about them on request by e-mail. For all requests write to kontakt@erechnung-erstellen.net.

You can lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is the Bayerisches Landesamt für Datenschutzaufsicht, Promenade 18, 91522 Ansbach, Germany.

15. Obligation to provide data and automated decisions

The details for an invoice and for an account are needed to create the invoice or to use Pro. Without them this is not possible. We make no automated decisions and create no profiles (Art. 22 GDPR).