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Privacy Policy

This is a courtesy translation. The German original is the legally binding version: Datenschutzerklärung.

Here you'll find information on how DolmiDesk handles your data in accordance with the GDPR.

Last updated: November 3, 2026

Preamble​

With this privacy policy we would like to inform you about which types of your personal data we process, for which purposes, and to what extent. This policy applies to all processing of personal data carried out by us — in particular in the context of providing our software-as-a-service application DolmiDesk (available at app.dolmidesk.com), our websites, and our communication with you.

DolmiDesk is an application for interpreters and translation service providers for managing assignments, clients, and cost bearers, as well as for creating and sending invoices, dunning notices, and e-invoices.

Controller​

Dmitry Dugarev

Address: Mombacher Weg 26, 65936 Frankfurt am Main, Germany

Email address: support@dolmidesk.com

Legal notice: dolmidesk.com/legal/imprint

Overview of Processing Operations​

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​

  • Master data (e.g. name, company name, address)
  • Contact data (e.g. email addresses, telephone numbers)
  • Payment data (e.g. bank details, invoice data)
  • Contract data (e.g. selected plan, contract term)
  • Content data (e.g. the assignments, client, and invoice data you enter in DolmiDesk)
  • Receipt data (e.g. the expense receipts you upload and the amounts, payment dates, and issuer names recorded from them)
  • Data of imported invoices (e.g. your own invoices from earlier programs that you upload for import, and the details on cost bearers, clients, assignments, and amounts read from them)
  • Usage data (e.g. features accessed, times of use — only with your consent)
  • Meta, communication, and procedural data (e.g. IP addresses, timestamps, device information)
  • Log data (e.g. log files, audit logs)

Categories of data subjects​

  • Customers (users of the application)
  • Prospective customers
  • Communication partners
  • Business and contractual partners
  • Persons whose data our customers enter in the application (see the section "Processing on behalf of our customers")

Purposes of processing​

  • Provision of contractual services and fulfilment of contractual obligations
  • Provision of our online service and ensuring its usability
  • Operation of the information technology infrastructure
  • Security measures
  • Communication
  • Office and organizational procedures
  • Automatic reading of the details on uploaded expense receipts
  • Reading our customers' own invoices from earlier programs when they import them
  • Showing the orders in our customers' Google Calendar on their instructions
  • Connecting an AI assistant to the account on our customers' instructions
  • Informing our customers about new developments in DolmiDesk (direct marketing)
  • Further development of DolmiDesk in the beta program (invitation, surveys, and conversations)
  • Product improvement and reach measurement (only with your consent)

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 this privacy policy.

  • Consent (Art. 6(1) sentence 1 point (a) GDPR): You have given your consent to the processing of your personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR): The processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract.
  • Legal obligation (Art. 6(1) sentence 1 point (c) GDPR): The processing is necessary for compliance with a legal obligation (e.g. retention obligations under commercial and tax law).
  • Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR): The processing serves to safeguard our legitimate interests or those of third parties, provided your rights do not override them.

National data protection rules in Germany: In addition, special rules apply in Germany, namely the Federal Data Protection Act (BDSG) — in particular regarding access, erasure, objection, the processing of special categories of personal data, and transfers and automated decision-making. Access to information on your terminal equipment (e.g. cookies) is additionally governed by § 25 of the German Telecommunications Digital Services Data Protection Act (TDDDG).

Security Measures​

In accordance with the legal requirements — taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing — we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

Key measures include in particular:

  • Encrypted transmission of all data between your browser and our servers (TLS/HTTPS).
  • Encrypted storage of the database with the hosting provider (encryption at rest); the application additionally encrypts particularly sensitive details itself, with separate keys for each customer account.
  • Encrypted storage of generated documents (e.g. invoice PDFs) with per-file keys in private storage systems that are not publicly accessible.
  • Tenant-separated data storage: your data is strictly logically separated from the data of other customers.
  • Access protection through server-side sessions, two-factor authentication, and passkeys.
  • Hosting exclusively in data centres within the European Union.
  • Consideration of data protection from the design stage through privacy-friendly default settings (Art. 25 GDPR).

A detailed description can be found in the document "Technical and Organizational Measures (TOM)", which you can download in the application under Settings → Privacy.

Transfer of Personal Data​

In the course of our processing of personal data, the data may be transferred to, or disclosed to, other bodies, companies, legally independent organizational units, or persons — for example, to IT service providers who operate our infrastructure. In doing so, we always comply with the legal requirements and conclude appropriate contracts with the recipients of the data (in particular data processing agreements pursuant to Art. 28 GDPR). A current list of the sub-processors we use can be found in the document "List of Sub-Processors" in the application under Settings → Privacy.

International Data Transfers​

Your data is generally processed in data centres within the European Union (France and the Netherlands); for the automatic reading of receipt data and when imported invoices are read, data centres of the provider named there in the European Union and in EFTA states may also be involved (see the section "Automatic Reading of Receipt Data and Imported Invoices"). Emails to our support mailbox (see the section "Contact and enquiry management"), details of booking and holding a demo (see the section "Booking a demo"), emails, conversations, and recordings of conversations in the beta program (see the section "Beta Program"), the sign-in with a Google account, which Google processes as an independent controller (see the section "Registration and user account"), the address details used for address suggestions and route calculation, which Google processes as an independent controller (see the section "Address Suggestions and Route Calculation (Google Maps Platform)"), orders that our customers have entered into their own Google Calendar and that Google processes there under their contract with Google (see the section "Showing Your Orders in Google Calendar"), and content retrieved by an AI assistant connected by our customers, which its provider receives (see the section "AI Assistant"), may also be processed in data centres outside the EU, in particular in the USA. Insofar as we have data processed in a third country (outside the EU/EEA) or this occurs in the context of using third-party services, this is done only in accordance with the legal requirements. If the level of data protection in a third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis — for providers from the USA, in particular certification under the EU-US Data Privacy Framework (DPF). Otherwise, data is transferred only if the level of data protection is otherwise secured, for example through standard contractual clauses (Art. 46(2)(c) GDPR).

Further information is available at commission.europa.eu/law/law-topic/data-protection_de and www.dataprivacyframework.gov/.

General Information on Data Storage and Erasure​

We erase your personal data 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 when the original purpose of the processing ceases to apply or the data is no longer required. Exceptions apply where legal obligations or special interests require longer retention.

Data that must be retained for commercial or tax law reasons or for the pursuit of legal claims is archived accordingly. Relevant retention and erasure periods include in particular:

  • 10 years: Retention period for books, records, annual financial statements, inventories, and related work instructions (§ 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: Retention period for accounting records, e.g. invoices and expense receipts (§ 147(1) no. 4 in conjunction with (3) AO, § 14b(1) UStG (German VAT Act), § 257(1) no. 4 in conjunction with (4) HGB).
  • 6 years: Retention period for commercial and business letters received, copies of commercial and business letters sent, and other documents insofar as they are relevant for taxation (§ 147(1) nos. 2, 3, 5 in conjunction with (3) AO, § 257(1) nos. 2 and 3 in conjunction with (4) HGB).
  • 3 years: Storage of data to account for potential warranty and damages claims (§§ 195, 199 BGB (German Civil Code)).

The retention periods under the AO, the UStG and the HGB begin at the end of the calendar year in which the document arose — for invoices, at the end of the year in which they were issued; for books, at the end of the year of the last entry (§ 147(4) AO, § 14b(1) sentence 3 UStG, § 257(5) HGB). For tax purposes, they do not expire as long as the documents are relevant for taxes whose assessment period has not yet expired (§ 147(3) sentence 5 AO).

Upon termination of your contract, we delete your user account and the content and receipt data you have entered no later than 90 days after the end of the contract, unless statutory retention obligations prevent this. The details are governed by the data processing agreement.

For the invoices and accounting receipts you create or record in the application, the retention periods above apply to you, not to us: they are your business records, which we merely store on your behalf. The application therefore provides a complete archive of all receipts and documents for download before the end of the contract; retaining it is your responsibility. If you delete your account yourself in the application and it contains invoices or receipts, the erasure is only carried out once you have retrieved that archive. If the contract ends in any other way, for example by termination, we delete your data no later than 90 days after the end of the contract, even if the archive has not been retrieved. The invoices we issue to you for your subscription are different: they are our own accounting records, which we keep for eight years, even after the contract has ended and your user account has been deleted. We keep your customer record at Stripe, to which they are linked, for just as long; we remove saved payment methods there when your user account is deleted (see the section "Payment processing").

Rights of Data Subjects​

Under the GDPR, you as a data subject are entitled in particular to the following rights:

  • Right to object: You may object at any time to the processing of your personal data carried out on the basis of Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. In particular, you have the right to object to processing for the purposes of direct marketing.
  • Right to withdraw consent: You may withdraw any consent you have given at any time with effect for the future — consent to product telemetry, for example, directly in the application via "Your privacy settings" in the account menu or under Settings → Privacy.
  • Right of access: You have the right to know whether and which of your data is being processed, and to receive a copy of this data and further information in accordance with the legal requirements. You can download a copy of the personal data stored for your user account yourself at any time in the application under Settings → Privacy.
  • Right to rectification: You may request the completion or correction of inaccurate data.
  • Right to erasure and restriction of processing: You may, in accordance with the legal requirements, request the erasure of your data or a restriction of its processing.
  • Right to data portability: You have the right to receive your data in a structured, commonly used, and machine-readable format, or to request its transmission to another controller. In the application, an export function is available for this purpose under Settings → Data export.
  • Complaint to a supervisory authority: You may lodge a complaint with a data protection supervisory authority if you believe that the processing of your data infringes the GDPR. The authority responsible for us is the Hessischer Beauftragter für Datenschutz und Informationsfreiheit (Hessian Commissioner for Data Protection and Freedom of Information), Gustav-Stresemann-Ring 1, 65189 Wiesbaden.

Business Services​

We process data of our contractual partners — that is, customers and prospective customers — in the context of contractual and comparable legal relationships as well as in communication (including pre-contractual communication), for example to respond to enquiries. This data serves to fulfil our contractual obligations — in particular the provision of DolmiDesk — as well as to safeguard our rights and for administrative tasks and the organization of our business.

Data is passed on to third parties only where this is necessary to fulfil the stated purposes or to comply with legal obligations. We erase this data upon expiry of the statutory retention periods; data not subject to retention obligations is erased as soon as it is no longer required for the performance of the contract.

Types of data processed: master data, payment data, contact data, contract data, usage data, and meta, communication, and procedural data. Data subjects: customers, prospective customers, business and contractual partners. Legal bases: performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR), legal obligation (Art. 6(1) sentence 1 point (c) GDPR), legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Registration and user account​

A user account is required to use DolmiDesk. During registration, we process your email address, your name, and a password chosen by you (which is stored exclusively in cryptographically secured form). Optionally, you can enable two-factor authentication or register passkeys; the data required for this (e.g. public keys) is stored to secure your account. Logins are managed as server-side sessions; you can view and terminate active sessions in the settings.

Instead of a password or passkey, you can also sign in with a Google account. This is possible only for an existing user account; no new one is created: with a Google account that has the same email address as your user account, or with a Google account you have connected to your user account in the settings under “Sign-in methods”. For this, the application redirects you to Google, where you sign in to your Google account and approve the transfer (OAuth). Google then sends us the identifier of your Google account, its email address and name and, where set, the address of your profile picture, together with sign-in tokens that contain these details. We store these details and tokens with your user account for as long as the connection exists. You can disconnect it in the settings at any time, provided another sign-in method remains to you afterwards; we then delete the stored details and tokens. Google processes your sign-in to Google itself as an independent controller under its privacy policy (policies.google.com/privacy); data may also be processed in the USA in the process.

Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR); for security measures additionally legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Payment processing​

For billing our services, we process the necessary invoicing and payment data (e.g. billing address, VAT identification number, payment status). Payments are processed by the payment service provider Stripe. When you start a payment, you are taken to a checkout page operated by Stripe; the payment credentials you enter there (e.g. card number, IBAN) are processed exclusively by Stripe and are not transmitted to us in clear text. From Stripe we only receive the information required to perform the contract (in particular the e-mail address and name given when ordering, with which we set up your user account, where provided the company name, billing address, VAT identification number and telephone number, as well as payment status, payment method and a transaction reference). We also enter the name, company name, billing address, VAT identification number and telephone number into the still empty fields of your company details in the application (Settings → Company), so that you do not have to enter them again; we do not change fields that are already filled in, and you can check and change the details there at any time. Stripe also processes the data as its own controller where this is necessary to meet its own regulatory and anti-money-laundering obligations.

Stripe issues the invoices, payment receipts and credit notes for your subscription in our name and on our behalf, in German, makes them available in the customer portal and sends them by e-mail to the address given when ordering or later stored in the customer portal. For this, Stripe processes your name or company name, your billing address, your e-mail address and, if provided, your VAT identification number; we set the language of these documents at Stripe to German for all customers. We, or Stripe on our behalf, keep invoices for eight years (§ 147(1) no. 4 in conjunction with (3) AO, § 14b(1) UStG); the period begins at the end of the calendar year in which the invoice was issued. We keep your customer record at Stripe (name or company name, e-mail address, billing address and, if provided, VAT identification number), to which these invoices are linked, for as long as the invoices themselves and delete it afterwards. We remove saved payment methods (e.g. a card or a SEPA Direct Debit mandate) at Stripe as soon as your user account is deleted.

  • Service provider: Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (for users in the EEA); parent company: Stripe, Inc., 354 Oyster Point Blvd, South San Francisco, CA 94080, USA
  • Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR), legal obligation (Art. 6(1) sentence 1 point (c) GDPR)
  • Website: stripe.com
  • Privacy policy: stripe.com/privacy
  • Data processing agreement: concluded with the provider (Stripe Data Processing Agreement)
  • Basis for third-country transfers: EU-US Data Privacy Framework (DPF) and standard contractual clauses (Art. 46(2) point (c) GDPR)

Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR), legal obligation (Art. 6(1) sentence 1 point (c) GDPR).

Account Set-up and Data Transfer​

In the packages Standard and Pro we set up your account together with you on request and transfer existing data. The call for this takes place as a video conference via Google Meet. In doing so, Google processes the data required to hold it, in particular your display name, connection data such as your IP address, picture and sound insofar as you switch on your camera and microphone, and screen content that you share. We agree the appointment with you and enter it in our calendar. We record a call only if you expressly agree before the recording starts; we store the recording in Google Drive and erase it no later than 30 days after the call. You can withdraw your agreement at any time with effect for the future; we then erase the recording without delay.

For the data transfer you share the files with us through Google Drive. We prepare them on an encrypted work device, import them into your account and erase the files and all working copies no later than 30 days after the transfer has been completed. Insofar as the files, shared screen content or a recording contain data of your own clients, we process that data on your behalf under the data processing agreement. The details of the service provider Google Workspace and of transfers to third countries are given below under "Contact and enquiry management".

Types of data processed: master data, contact data, content data, picture and sound recordings (only when a call is recorded), meta and communication data. Data subjects: customers. Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR); recording: consent (Art. 6(1) sentence 1 point (a) GDPR).

Processing on Behalf of Our Customers​

DolmiDesk is a tool with which our customers process personal data of third parties — such as the names and contact details of their clients, assignment locations, billing data, and the details on the expense receipts they upload and on the invoices they import from earlier programs. For this content data, our customers are the controllers under data protection law; we process it exclusively as a processor pursuant to Art. 28 GDPR on the basis of a data processing agreement, strictly bound by instructions and solely for the purpose of providing the application.

We do not analyse this content data for our own purposes, do not pass it on to third parties (except to the sub-processors named in the document "List of Sub-Processors" and — on our customers' instructions, when they use the respective function — address details for address suggestions and route calculation to Google as an independent controller, see "Address Suggestions and Route Calculation (Google Maps Platform)", and — when they switch on showing their orders in Google Calendar — these orders to Google into their own Google account, see "Showing Your Orders in Google Calendar", and — when they connect an AI assistant — the content the assistant retrieves to its provider, see "AI Assistant"), and erase it in accordance with the data processing agreement. Data subjects whose data has been entered in DolmiDesk by our customers should contact the respective controller to exercise their rights; we support our customers in responding to such requests.

Legal basis in relation to our customers: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR) in conjunction with the data processing agreement (Art. 28 GDPR).

Automatic Reading of Receipt Data and Imported Invoices​

Two functions of the application read uploaded files by themselves, so that you do not have to type the details: the recording of expense receipts and the import of your own invoices from earlier programs. For both, a file may be transmitted for text recognition to the same service provider named below; when that happens is governed differently.

Expense Receipts​

When you upload an expense receipt to DolmiDesk, the application tries to read the details bookkeeping needs — amount, date, VAT and issuer — by itself, so that you do not have to type them. It works through a fixed order of steps and stops as soon as one of them produces a result:

  • If the file contains an e-invoice (ZUGFeRD or XRechnung), the details are taken from its structured data part.
  • Otherwise the text contained in the PDF file is read according to fixed rules.
  • If that yields no amount, a till or payment QR code printed on the receipt is decoded.
  • Only if none of these steps produces anything is the receipt file transmitted for text recognition to the service provider named below. In practice this affects only photographs and scans without a text layer.

The first three steps run exclusively on our own servers; only the fourth leaves them. What is then transmitted is the receipt file itself — the image or PDF with everything printed on it — for the sole purpose of making the details printed on the receipt machine-readable. The result is always a proposal only, but it is entered straight away: the details read fill only those fields of the receipt that are still empty — fields already filled in are left unchanged — and the receipt is marked as machine-read. Nothing is confirmed in the process: the application merely enters the values it has read; the receipt is checked and released by a person and by no one else, and until then it waits for that. What waits for a confirmation is therefore not the adoption of the values but the receipt itself.

Importing Your Own Invoices​

You can import invoices that you wrote in another program or in another DolmiDesk account into DolmiDesk: your latest invoice when you set up your account, any number of them later under Settings → Data import, each as a PDF file (ZUGFeRD included) or as an XRechnung (XML file). The application reads each file and creates the invoice from it as an imported invoice, with the uploaded file as its original, together with the assignments, clients, and cost bearers the invoice names. It also continues your number sequences. During the set-up, before it imports the invoice and without asking, it enters your company, tax, and bank details from the invoice into the fields of your settings that are still empty, takes over the format of your invoice numbers and file names, and creates a billing model from the invoice's prices; you can change all of this in the following steps of the set-up and later in the settings. What is read is what the invoice states: invoice number, dates, amounts and VAT, the cost bearer with its address, your own details as the issuer (e.g. address, tax number, bank details) and, for each assignment, the date of service, times, the names of the clients — with date of birth and insurance number where the invoice states them —, the occasion, the place of the assignment, the starting address, the distance travelled and the travel time, and expenses such as tickets and parking fees. The application proceeds as follows:

  • An XRechnung as an XML file and a PDF file with an e-invoice whose items name the assignments — with the clients, the occasion, the place of the assignment, or the times — are read from the structured data part and, for a PDF file, from the text it contains, exclusively on our own servers. Such a file is transmitted to no one.
  • Every other PDF file — including an e-invoice from another program or from DolmiDesk whose items name only a description, quantity, and amount — is transmitted for text recognition to the service provider named below, so that the assignments such an invoice names only in its text are read as well. At most the first twelve pages are transmitted: the first eight to begin with, pages 9 to 12 only if the items of the first eight pages do not yet add up to the invoice's net amount. The requests do not overlap: each contains only the pages it is meant to read. If reading fails — for instance because the service provider does not answer in time or answers with an error —, the application may repeat it and transmit the same pages again; likewise, a file from which no invoice has been imported yet is transmitted again if you upload it once more in a later import. At the same time the application reads the text contained in the PDF file on our own servers according to fixed rules and completes the result with it; it takes the invoice number and invoice date from that text where the text contains them.
  • If the service provider cannot be used — for instance because your account's page quota for the invoice import is used up or text recognition fails —, the application reads the file according to these fixed rules alone. If the page quota is used up or text recognition fails entirely for an invoice, the import's summary under Settings → Data import names that invoice as one whose details were not read.

Unlike with expense receipts, nothing here waits for a confirmation: an invoice is imported only if its number, its date, and its amounts have been read and agree with one another; otherwise it is not imported, and the import's summary states the reason. The imported invoice stays as it was printed, and its assignments are fixed as billed; you can change the clients and cost bearers created at any time.

The application stores the uploaded files and what it has read from them, including the result of text recognition, encrypted and only for as long as the import needs them. An import accepts files for one day; once that day is over and the import is complete, the application erases the uploaded files, the result of text recognition, and the details read. Until 30 days after the import's last activity, only the following of them remain: the file of an invoice whose original could not be stored during the import, together with the result of its text recognition and the details read from it, so that storing it can be repeated; of the latest invoice you upload during the set-up, its kind, number, date, total, and cost bearer, so that the set-up can keep showing it; and the file names the import's summary shows. At the latest 30 days after an import's last activity, its files, the result of text recognition, and the details read from them are erased. The summary itself remains stored without the file names and is erased with your account's content data: for each file the invoice number, the outcome, where applicable the reason it was not imported, with the invoice numbers and the date of service it names, and a non-reversible check value of the file, by which the application recognizes a file already imported. What was imported — the invoice with the uploaded file as its original, its assignments, clients, and cost bearers — forms part of your account's content data and is stored and erased like it.

Invoices to health insurance funds and other social benefit providers often state details that allow conclusions about health (Art. 9 GDPR) — for instance the occasion of an assignment together with the name of a client and a health insurance fund as cost bearer. We process these details during the import exclusively on your behalf as well (Art. 28 GDPR, see "Processing on Behalf of Our Customers") and transmit them to the service provider only to the extent described here. Whether you may import such invoices and have them transmitted for that purpose is your decision as the controller of these data.

Transmission to the Service Provider​

The file is transmitted in the body of the request only; the application does not upload it to any file storage of the service provider and keeps no copy there. The transmitted receipts and invoices are not used to train AI models: we use the provider's paid programming interface, under which the provider acts as a processor for us, and we do not authorize any use of the content for the provider's own purposes. Under the provider's terms, it may store requests for up to 30 days for abuse monitoring, unless an arrangement for processing without storage ("zero data retention") applies to the account used.

The provider operates several endpoints for its programming interface. The application calls the European endpoint (api.eu.mistral.ai) only, for which the provider commits to processing in data centres in the European Union and in EFTA states. It does not call the general endpoint (api.mistral.ai), for which the provider makes no commitment as to the place of processing — not even as a substitute: if the European endpoint does not answer a request, for instance because it does not serve the model in use, text recognition stops with an error; a receipt is then left without machine-read details, an imported invoice is read according to the fixed rules alone, and the file is transmitted nowhere else. For every machine-read receipt and every transmitted invoice the application records in the audit trail which endpoint and which model answered, and for invoices also how many pages were transmitted and which kinds of details text recognition supplied, but not those details themselves; that trail is part of the GoBD data export you can download yourself.

  • Service provider: Mistral AI, 15 rue des Halles, 75001 Paris, France
  • Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR); as regards the details on our customers' receipts and invoices: processing on behalf of the controller (Art. 28 GDPR)
  • Website: mistral.ai
  • Privacy policy: legal.mistral.ai/terms/privacy-policy
  • Data processing agreement: the provider's Data Processing Addendum forms part of the usage agreement under the provider's own terms (legal.mistral.ai/terms/data-processing-addendum)
  • Third-country transfer: none on our side — we call the European endpoint only, so processing takes place in the European Union and in EFTA states, for Switzerland on the basis of the European Commission's adequacy decision (Art. 45 GDPR). For transfers to the provider's own sub-processors outside the EU its Data Processing Addendum provides for standard contractual clauses (Art. 46(2)(c) GDPR)

Types of data processed: receipt data (the uploaded file and the details read from it); data of imported invoices (the uploaded file and the master, contact, payment, order, and assignment data read from it, including names, dates of birth, and insurance numbers of clients and the occasion of assignments, which may allow conclusions about health). Data subjects: users and persons named on the receipt or the invoice. Purposes: automatic reading of the details on uploaded expense receipts; reading our customers' own invoices from earlier programs when they import them. Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR); as regards the details on receipts and invoices: processing on behalf of the controller (Art. 28 GDPR).

Address Suggestions and Route Calculation (Google Maps Platform)​

The application uses programming interfaces of the Google Maps Platform for two functions. The requests are always made by our server with our own access credentials; your browser does not connect to Google for this, so Google does not receive your IP address this way.

  • Address suggestions (Places API): While you type an address, for example an assignment location, the application sends the text entered so far to Google and shows the suggestions returned. If you select a suggestion, the application retrieves its full address. If the set-up takes your own address from an invoice you import, the application looks that address up with Google once in the same way, to check that it exists and to store it as Google writes it.
  • Route calculation (Routes API): To determine the distance and travel time of a journey to an assignment, the application sends the start and destination addresses, the means of transport and, where applicable, the planned departure or arrival time. We store the result on our servers for a limited period (currently 30 days) so that the same route does not have to be requested again. The application determines distance and travel time in the same way, after the import, for the on-site assignments it creates when you import invoices (see “Automatic Reading of Receipt Data and Imported Invoices”), where the invoice does not state them: it sends the assignment's start address (the departure address printed on the invoice, otherwise the start address from your settings), the place of assignment, where applicable the destination address of the return journey, and the means of transport — for journeys by car without date or time, for journeys by public transport with the day of the assignment and its start or end as the arrival or departure time — and only where the result can fill a detail of the assignment that is still empty. Routes already calculated are not requested again while they are stored.

Only these address and time details are sent — no names, contact details or other details of orders or clients. An address may nevertheless relate to a person, for example when an assignment takes place in a private home. Where the addresses come from our customers' orders, we process them as a processor (see "Processing on Behalf of Our Customers") and transmit them to Google on their instructions.

Google does not process the transmitted data on our behalf but as an independent controller under the Google Controller-Controller Data Protection Terms, which form part of the Google Maps Platform terms. In accordance with its privacy policy, Google may also use the data for its own purposes, for example to provide and improve its services. The controller for data from the European Economic Area and Switzerland is Google Ireland Limited; our contracting party is Google Cloud EMEA Limited. Google explains how it uses data from sites and apps that use its services at policies.google.com/technologies/partner-sites.

  • Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland (contracting party); independent controller of the transmitted data: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
  • Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR); for the addresses in our customers' orders: processing on their behalf and transmission to Google on their documented instructions (Art. 28(3)(a) GDPR); our customers, as controllers, are responsible for the legal basis of this transmission
  • Website: mapsplatform.google.com
  • Privacy policy: policies.google.com/privacy
  • Contract terms: Google Maps Platform Terms of Service (cloud.google.com/maps-platform/terms); for a billing address in the European Economic Area, in the version of the Google Maps Platform EEA Terms of Service (cloud.google.com/terms/maps-platform/eea)
  • Data protection terms: Google Controller-Controller Data Protection Terms (business.safety.google/controllerterms/); under them Google acts as an independent controller, not as a processor, so there is no data processing agreement
  • Basis for third-country transfers: none by us — we transmit to Google Ireland Limited in Ireland; for transfers within the Google group to the USA: EU-US Data Privacy Framework (DPF)

Types of data processed: address data (address fragments entered, your own address taken from an imported invoice, start and destination addresses), appointment data (planned departure or arrival time). Data subjects: users and persons at whose address an assignment takes place. Purposes: address suggestions and the calculation of distances and travel times for planning and invoicing. Recipient: Google as an independent controller. Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR).

Connection with Google Calendar​

In the settings you can connect your Google Calendar to DolmiDesk so that the application takes over appointments as draft orders and, if you switch this on separately, shows your orders in your Google Calendar (see "Showing Your Orders in Google Calendar"). You set up the connection yourself by signing in to your Google account and granting access (OAuth). You can disconnect it at any time in the application's settings or in your Google account.

To take over appointments, the application receives read-only access only; for this it does not create or change anything in your calendar. It reads:

  • the list of your calendars, so that you can choose which one appointments are taken from;
  • the appointments in the selected calendar with their title, start and end, location, description and colour;
  • file attachments of these appointments from Google Drive, which are stored with the order when the appointment is taken over; the application does not retrieve any other files from Google Drive;
  • the email address and the identifier of your Google account, so that the settings can show which account is connected and so that the application can tell whether a later permission comes from the same account.

We store the access credentials for your Google account in encrypted form. So that new appointments appear without delay, the application can have Google notify it when the selected calendar changes; these notifications contain no appointment content. Appointments and attachments taken over become content data of your account, which we process as a processor (see "Processing on Behalf of Our Customers"). Your Google account itself is governed by Google's terms and privacy policy (policies.google.com/privacy); for users in the European Economic Area the provider is generally Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

DolmiDesk's use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy (developers.google.com/terms/api-services-user-data-policy) and the Google Workspace API User Data and Developer Policy (developers.google.com/workspace/workspace-api-user-data-developer-policy), including the Limited Use requirements.

Types of data processed: appointment data, content data (appointment contents and attachments), contact data and identifiers (email address and identifier of the Google account), access data (encrypted access credentials). Data subjects: users and persons named in appointments taken over. Purposes: taking over appointments as draft orders. Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR); as regards the appointment contents taken over: processing on behalf of the controller (Art. 28 GDPR).

Showing Your Orders in Google Calendar​

If you switch it on in the settings (Settings → Connectors), DolmiDesk shows your orders in your Google Calendar. For this you separately allow, at Google, that the application may create a calendar of its own. This permission covers only calendars that DolmiDesk created itself; it gives the application no write access to your other calendars and appointments.

When you switch it on, the application creates the calendar "DolmiDesk" in your Google account. From then on it enters there every order you create or change — whether in the browser, in the iPhone app, through the AI assistant or by an import —, keeps its appointment up to date with every change, and deletes it when you delete the order. Upcoming orders that already exist are transferred when you switch it on only if you expressly choose so, otherwise with their next change. An order whose assignment day has already passed is not transferred for the first time; an appointment that is already in the calendar, however, keeps following its order after the assignment day. A cancelled order stays as "Abgesagt: …" and is shown as free time. If you delete an appointment in Google, the order stays in DolmiDesk; the appointment reappears as soon as you change the order.

What is written into the appointment is your choice when you switch it on, and you can change it at any time:

  • Complete: the kind of assignment and its occasion (or the label of the first client), date and time, for on-site assignments and no-shows the assignment address and the means of transport, the labels of the clients and of the cost bearer as you entered them in DolmiDesk, a note that the appointment is managed by DolmiDesk, and a link to the order in DolmiDesk.
  • Time + order number only: the kind of assignment, "Auftrag" with the order number, date and time, the note and the link — no names, no occasion, no address.

In both cases the appointment gets the colour you chose and invisible technical identifiers (the identifiers of the order and of your DolmiDesk account) by which the application recognises its own appointments, so that it never takes them over as an order again. Prices, invoices, cost estimates, contact details of your clients, travel times and attachments are never written to Google.

Please note: names of clients together with a health insurance fund as cost bearer and the occasion of an assignment may allow conclusions about health data (Art. 9 GDPR). Whether you may transfer this information to your Google Calendar is your decision as the controller of these data; in such cases we recommend the setting "Time + order number only".

The transfer is made on your instructions as part of the processing on your behalf (see "Processing on Behalf of Our Customers") into your own Google account. What Google does with the appointments in your calendar is governed by your contract with Google and Google's privacy policy; Google may also process the data in the USA.

On our side we store for this only the identifier and the name of the "DolmiDesk" calendar, the identifiers of the appointments of the orders, the chosen colour and setting, the permissions granted at Google, the time of the last transfer, transfers still pending and the state of the connection; we store the access credentials in encrypted form.

You can switch the display off in the settings at any time and choose whether the "DolmiDesk" calendar is deleted in Google with all its appointments; if you keep it, its appointments are no longer updated. If you disconnect Google entirely in the application, the display ends too; the application asks beforehand whether the calendar is to be deleted, otherwise it stays in your Google account until you delete it there. If your DolmiDesk account is deleted, the application tries to delete the "DolmiDesk" calendar as well; if that fails (for example because you have already withdrawn the access at Google), you can delete it in Google yourself.

Types of data processed: appointment data (date and time of the orders), content data of the orders to the extent chosen (kind and occasion of the assignment, assignment address, means of transport, labels of clients and cost bearers, order number), identifiers (calendar, appointments, order, account), access data (encrypted access credentials). Data subjects: users and persons named in the orders. Purposes: showing the orders in our customers' Google Calendar on their instructions. Recipient: Google, into the customer's own Google account. Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR); as regards the content data of the orders: processing on behalf of the controller and transfer into the Google account on our customers' instructions (Art. 28 GDPR).

AI Assistant​

In the Pro plan, our customers can connect an AI assistant of their choice to their account via the Model Context Protocol (MCP); at present, the applications of Claude (provider: Anthropic) can be connected. The function is switched off until it is switched on in the application; even then, a connection to an AI assistant only comes into being when it is confirmed in the application (sign-in using the OAuth procedure) or a key for the assistant is created there. The function can be switched off at any time under Settings → Connectors, and each connection can be disconnected there at any time.

A connected assistant retrieves content of the account through our interface — such as orders, invoices, cost estimates and the names and details of clients and of cost bearers — and can create and change data there and create and cancel invoices. It can send invoices, cost estimates and dunning notices by email, to the address stored in the record or to another address that the user names to it, with a subject and a text for that one email. It can show documents as PDF in a viewer within its provider's application — invoices, cancellation invoices, correction invoices, cost estimates and dunning notices as well as previews of them and of templates; for this, the PDF file is transmitted to that application. What it retrieves, such a PDF file included, we transmit to the provider of the assistant. This transmission takes place on the instructions of our customers, who are the controllers for this content data (see "Processing on Behalf of Our Customers"). They choose the provider themselves, and they conclude the contract with it themselves. It is not our sub-processor and does not act on our behalf; it processes the data under its contract with the respective customer and under its own privacy policy. Whether it acts as that customer's processor or as an independent controller, and where it processes the data, including outside the EU, depends on that contract.

We ourselves store for each connection its name, the type of sign-in, the times of its creation, its last use and its disconnection, and the number of invoices and emails created or sent through it on a given day. We store keys and sign-in credentials only as irreversible check values. Before creating, sending or cancelling, the assistant retrieves a preview; of it we store what it refers to and a check value of its content, which becomes invalid after ten minutes. For the preview of an email we additionally store the chosen recipient address, the subject and the text, encrypted and only until the preview is used; we erase an unused preview with the account's next preview or confirmation, at the latest with the content data of the account. Orders, cost estimates and invoices that the assistant creates or issues, as well as payments it records and emails it sends, are marked in the application with "via AI assistant", and we record each of its changes in the change log together with the connection. The details of the connections form part of the content data of the account and are erased with it. The logs of our server name, for each call, the tool, the connection, the outcome and the duration, but not the content transmitted (see "Collection of access data and log files").

Types of data processed: content data of the account, insofar as the assistant retrieves or changes it; details of the connection (name, type of sign-in, times, daily counters); recipient address, subject and text of an email preview; log data. Data subjects: users and persons whose data is recorded in the account. Purposes: connecting an AI assistant to the account on our customers' instructions. Recipient: the provider of the assistant chosen by the customer. Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR); for the content data: processing on behalf and transmission to the provider on our customers' documented instructions (Art. 28(3)(a) GDPR); our customers, as controllers, are responsible for the legal basis of this transmission.

Provision of the Online Service and Web Hosting​

We process users' data in order to provide our online services. This includes in particular the IP address, which is necessary to deliver the content and functions to your browser or device.

Types of data processed: usage data, meta, communication, and procedural data, log data. Data subjects: users. Purposes: provision of the online service, operation of the IT infrastructure, security measures. Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR), legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Collection of access data and log files​

Access to our services is recorded in server log files, which may contain, among other things, the IP address, the time of access, and browser information. The log files serve operational security, error analysis, and protection against overload and abuse. Log files are deleted or anonymized after no more than 30 days, unless they are still required to investigate a specific incident.

Legal bases: legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Hosting with Scaleway​

Our application, the database, the document storage, and the dispatch of system emails are operated with Scaleway. Processing takes place exclusively in data centres within the European Union (France and the Netherlands).

  • Service provider: Scaleway SAS, 8 rue de la Ville l'Évêque, 75008 Paris, France
  • Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR), legitimate interests (Art. 6(1) sentence 1 point (f) GDPR)
  • Website: www.scaleway.com
  • Privacy policy: www.scaleway.com/en/privacy-policy/
  • Data processing agreement: concluded with the provider (part of the Scaleway contractual terms)
  • Third-country transfer: none — processing exclusively in the EU

Delivery via Cloudflare​

The web application is delivered via the Cloudflare network, which also serves as a content delivery network (CDN) and provides protection against attacks (e.g. DDoS). In addition, our website dolmidesk.com is hosted entirely with Cloudflare (Cloudflare Pages), and our self-operated Notifuse service (see "Information about new developments in DolmiDesk") is also reached via this network. In this context, Cloudflare processes technically necessary connection data (in particular the IP address).

  • Service provider: Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA
  • Legal bases: legitimate interests (Art. 6(1) sentence 1 point (f) GDPR) — secure and performant delivery of the online service
  • Website: www.cloudflare.com
  • Privacy policy: www.cloudflare.com/privacypolicy/
  • Data processing agreement: concluded with the provider (Cloudflare Data Processing Addendum)
  • Basis for third-country transfers: EU-US Data Privacy Framework (DPF) and standard contractual clauses (Art. 46(2)(c) GDPR)

Use of Cookies​

On the one hand, we use cookies and comparable technologies (e.g. your browser's local storage) to the extent required for the operation of the application:

  • Session cookie: After you sign in, a cookie stores your session identifier so that you remain signed in. It is strictly necessary for the provision of the service and becomes invalid when you sign out or when the session expires.
  • Language setting: Your selected language is stored in your browser's local storage so that the application starts in your language.
  • Consent status: The choice you make in the consent dialog (see below) is stored in your browser's local storage so that you are not asked again on future visits.
  • Remembered details in the JVEG claim generator: On our website you can tick, in the free generator for JVEG claims, that your own details (name, address, email address, phone number, tax number, bank details) are remembered for your next visit. They are then stored exclusively in your browser's local storage and not transmitted to us; "Gemerkte Angaben löschen" removes them again. Everything you enter in the generator and the calculators on our website is processed in your browser and not transmitted to us.

In these cases, storing and accessing information on your terminal equipment is strictly necessary in order to provide the service you have expressly requested (§ 25(2) no. 2 TDDDG); no consent is required for this.

Beyond that, we use cookies and comparable storage technologies only with your consent (§ 25(1) TDDDG; Art. 6(1) sentence 1 point (a) GDPR). When you first open the application, a consent dialog (cookie banner) asks for your choice for the categories "Functional", "Statistics", and "Marketing". At present we use consent-based technologies in the "Statistics" category (the analytics service PostHog, see the section "Web analytics") and, on our website only, in the "Marketing" category: if you have allowed "Marketing", the JVEG claim generator counts in your browser's local storage how many claims you have created in it, in order to highlight an offer from DolmiDesk from the third one on; only this number is stored, and nothing is transmitted. We do not use any other cookies or comparable identifiers for advertising purposes. You can change or withdraw your choice at any time with effect for the future — via "Your privacy settings" in the application's account menu or via "Datenschutz-Einstellungen" on our website.

Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR), legitimate interests (Art. 6(1) sentence 1 point (f) GDPR), consent (Art. 6(1) sentence 1 point (a) GDPR); § 25(1) and (2) no. 2 TDDDG.

Email Dispatch and Contact Management​

Dispatch of system and document emails​

Emails are sent from within the application — for example confirmation links, security notifications, and document emails initiated by you (e.g. sending invoices to your clients). Dispatch takes place via Scaleway's transactional email infrastructure (see above); the recipient address, subject, content, and delivery information are processed.

Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR).

Information about new developments in DolmiDesk​

If you have taken out a paid subscription, we inform you by email about new developments in DolmiDesk, for example new functions and changes to the application. For this we use your email address and your name, which we received when you took out your subscription. We rely on the exemption for existing customer relationships under § 7(3) UWG (German Act against Unfair Competition): when you take out the subscription, we already point out on the checkout page that we will inform you about new developments by email and that you can object to this at any time. Every one of these emails contains an unsubscribe link. Objecting costs you nothing beyond the transmission costs at the basic rates.

To manage the mailing list and send these emails we use the software Notifuse. We operate Notifuse ourselves, on our own hardware at our business address in Germany (see the "Controller" section). Notifuse itself is therefore not a third party's cloud service; the contact and mailing-list data is stored exclusively on our own hardware. Our Notifuse service is, however, reached via the Cloudflare network (see "Delivery via Cloudflare"); in transit, Cloudflare processes connection data as well as the details transmitted to the mailing list (email address, name) and clicks on the unsubscribe link. Access to the administration interface is protected by an upstream access control and two-factor authentication; transmission is exclusively encrypted (TLS). The emails themselves are delivered through the same sending infrastructure as our other system emails (see "Hosting with Scaleway").

You can object to the use of your email address for these emails at any time — via the unsubscribe link in every email or by informally contacting us. We keep your details on the mailing list until you object or your contract ends; after that we delete them from the list.

Types of data processed: master data (name), contact data (email address). Data subjects: customers. Purposes: information about new developments in DolmiDesk (direct marketing for our own similar services). Legal bases: legitimate interests (Art. 6(1) sentence 1 point (f) GDPR) in conjunction with § 7(3) UWG.

JVEG change alert​

On our website you can subscribe to the "JVEG-Änderungsalarm" (JVEG change alert). We then email you when the rates of the German Judicial Remuneration and Compensation Act (JVEG) change, when we publish new guides, and now and then about news from DolmiDesk. For this we only need your email address.

Subscription uses the double opt-in procedure: after you submit the form you receive an email with a confirmation link; only when you open it do we add you to the mailing list. Until you have confirmed, we send you no further emails. To be able to prove the subscription, we store the times of subscription and confirmation. Your address is transmitted through a function of our website (Cloudflare Pages, see "Delivery via Cloudflare") to our self-operated Notifuse service (see "Information about new developments in DolmiDesk"); in doing so we pass on neither your IP address nor any other details about your device. The mailing list is managed and the emails are sent as described there.

We evaluate whether and when you open our emails and which links in them you click, to learn which topics interest our readers. For this, every email contains an invisible image (tracking pixel) that is loaded from our Notifuse service when you open it, and the links in the email first lead through our Notifuse service and from there to their destination. We store the time of opening and the link clicked, linked to your email address; on the way, Cloudflare processes connection data (in particular the IP address). This evaluation is part of your consent and ends when you unsubscribe. You can also prevent the tracking pixel by turning off the loading of images in your email program.

You can withdraw your consent at any time with effect for the future — via the unsubscribe link in every email or by informally contacting us. We keep your address on the mailing list until you unsubscribe; after that we delete it from the list.

Types of data processed: contact data (email address), log data (times of subscription and confirmation), usage data (opening of the emails, links clicked). Data subjects: prospective customers. Purposes: information about changes to the JVEG, new guides and news from DolmiDesk (direct marketing); evaluating which content is read; proof of consent. Legal bases: consent (Art. 6(1) sentence 1 point (a) GDPR, § 7(2) no. 2 UWG, § 25(1) TDDDG); for proof of consent, legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Contact and enquiry management​

If you contact us — by email, contact form, or by other means — we process your information insofar as this is necessary to handle your enquiry.

We operate our support mailbox support@dolmidesk.com with Google Workspace. Your emails to that address arrive there, as do the enquiries from the application's contact form with the details and attachments they contain; we handle and answer them there.

  • Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
  • 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)
  • Website: workspace.google.com
  • Privacy policy: policies.google.com/privacy
  • Data processing agreement: concluded with the provider (Cloud Data Processing Addendum, part of the Google Workspace terms)
  • Basis for third-country transfers: EU-US Data Privacy Framework (DPF) and standard contractual clauses (Art. 46(2) point (c) GDPR)

Types of data processed: master data, contact data, content data. Data subjects: communication partners. 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).

Booking a demo​

On our website you can book a free demo of DolmiDesk — a 15-minute online call. For the booking we use the appointment booking of Google Calendar, which is part of our Google Workspace account. The booking page is operated by Google (calendar.google.com; the link on our website leads there via the short address calendar.app.google). Only when you follow the link does your browser open that page; Google then receives the technically necessary connection data, in particular your IP address. There you choose a free slot and enter your first and last name and your email address. These fields are required; without them no booking is possible. We process these details and the chosen time in order to arrange and hold the demo with you; the appointment is entered in our calendar, and you receive the booking confirmation by email. On the booking page Google uses its own cookies and the reCAPTCHA service to prevent abuse; Google is itself responsible for this processing, and Google's privacy policy applies (policies.google.com/privacy).

The call itself takes place as a video conference via Google Meet. In doing so, Google processes the data required to hold it, in particular your display name, connection data such as your IP address, and picture and sound insofar as you switch on your camera and microphone. The call is not recorded.

We delete the details of your booking and the calendar entry six months after the call, unless statutory retention obligations apply. If you then conclude a contract with us, further processing is governed by the section "Business Services".

  • Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
  • Legal bases: pre-contractual measures taken at your request (Art. 6(1) sentence 1 point (b) GDPR); where the demo does not serve to prepare a contract, legitimate interests (Art. 6(1) sentence 1 point (f) GDPR) in answering your questions
  • Website: workspace.google.com
  • Privacy policy: policies.google.com/privacy
  • Data processing agreement: concluded with the provider (Cloud Data Processing Addendum, part of the Google Workspace terms)
  • Basis for third-country transfers: EU-US Data Privacy Framework (DPF) and standard contractual clauses (Art. 46(2) point (c) GDPR)

Types of data processed: master data, contact data, content data (picture and sound of the call), appointment data, meta, communication, and procedural data. Data subjects: prospective customers and customers. Purposes: arranging and holding the demo. Legal bases: pre-contractual measures (Art. 6(1) sentence 1 point (b) GDPR), legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Beta Program​

Only personally invited persons take part in the beta program. In this context we additionally process the following data.

Invitation​

For the invitation we use your email address and, if provided, your name. We invite only persons who have told us beforehand that they would like an invitation; we record when and by what means you told us this. The invitation contains a personal order link and a personal beta code. The order link contains your email address so that it is pre-filled on the checkout page; if you open the link, our payment service provider Stripe receives this address even before an order is placed. From our email delivery service provider we retrieve whether the invitation was delivered. If you order, we delete the address and name from the invitation; they are then part of your customer account. If you do not order, we delete both 30 days after the invitation has expired or been withdrawn. After that, what remains is an irreversible check value of the address and the information on whether the invitation was redeemed with the same address and with the beta code. We need the check value in order to recognize whether an order arrives under the invited address and whether an open invitation already exists for an address. You can withdraw your request to be invited at any time; to do so, write to support@dolmidesk.com.

Legal bases: your consent to the invitation by email (§ 7(2) no. 2 UWG, Art. 6(1) sentence 1 point (a) GDPR); pre-contractual measures taken at your request (Art. 6(1) sentence 1 point (b) GDPR).

Surveys and conversations​

In the beta program, we invite you to surveys and to conversations by video. We process your answers, our notes from the conversations, and the appointment data in order to develop DolmiDesk further. The answers and notes are attributed to you and are therefore not anonymous; we treat them confidentially. Participation is voluntary. It is required neither by law nor by contract; if you do not take part, this has no consequences for your contract, your plan, or your price. Independently of this, we may end your participation in the beta program, and with it the personal contact channel, with one month's notice.

We conduct surveys by email: you receive the questions in an email and reply to them by email. We do not use a third-party survey tool. We hold conversations via Google Meet, which is part of our Google Workspace account. In doing so, Google processes the data required to hold them, in particular your display name, connection data such as your IP address, and picture and sound insofar as you switch on your camera and microphone. We arrange the appointment with you and enter it in our calendar. The details of the service provider and of data transfers to third countries can be found below under "Personal contact".

We record a conversation only if you give your express consent before the recording starts (Art. 6(1) sentence 1 point (a) GDPR); this also applies to an automatic transcript. Consent is voluntary: if you do not consent, we take our own notes, and you suffer no disadvantage as a result. For the recording and the transcript we use the functions of Google Meet in our Google Workspace account. The recording contains the picture and sound of the conversation, the transcript the spoken text. Both are placed in the storage of this account (Google Drive), which Google operates as our processor; we do not pass them on to third parties. We use them solely to evaluate the conversation. We delete recordings and transcripts no later than 12 months after the evaluation, and in any case when your user account is deleted. You can withdraw your consent at any time with effect for the future, including during the conversation: tell us during the conversation or write to beta@dolmidesk.com. We then stop the recording and delete the recording and the transcript of that conversation.

Please do not mention any personal data of your clients in surveys and conversations.

We delete or anonymize answers and notes no later than 12 months after the evaluation, and in any case when your user account is deleted.

If you ordered via your personal order link, we send invitations to surveys and conversations to the email address you gave when placing that order. We rely on the exemption for existing customer relationships under § 7(3) UWG: the invitations concern DolmiDesk and thus our own service, which you have booked with us. When you place your order, we already point out on the checkout page of your personal order link that we invite you by email to surveys and conversations in the beta program and that you can object to this at any time; every invitation contains the same notice. Objecting costs you nothing beyond the transmission costs at the basic rates. You can object informally, for example by replying to an invitation or by email to support@dolmidesk.com. Whether you object has no effect on your contract, your price, or your personal contact channel. After an objection, we no longer invite you by email. If you did not order via your personal order link, we send you these invitations by email only with your consent; it is voluntary, and you can withdraw it at any time with effect for the future. Whether you consent likewise has no effect on your contract, your price, or your personal contact channel.

Legal bases: legitimate interests in the further development of the product (Art. 6(1) sentence 1 point (f) GDPR); for invitations by email after an order via the personal order link, legitimate interests (Art. 6(1) sentence 1 point (f) GDPR) in conjunction with § 7(3) UWG; without such an order, your consent (§ 7(2) no. 2 UWG, Art. 6(1) sentence 1 point (a) GDPR); for recordings and transcripts, your consent (Art. 6(1) sentence 1 point (a) GDPR). You can object to the processing under Art. 21 GDPR.

Personal contact​

If you write to us at beta@dolmidesk.com or speak with us in an arranged video call via Google Meet, we process the content of this communication in order to handle your matter. The mailbox and Google Meet are part of our Google Workspace account (see the section "Contact and enquiry management"). Via this mailbox we also send the invitations to surveys and conversations and receive your answers. The same account includes the calendar in which we enter the appointments for conversations and the storage for recordings (Google Drive).

  • Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
  • Legal bases: performance of a contract (Art. 6(1) sentence 1 point (b) GDPR), legitimate interests (Art. 6(1) sentence 1 point (f) GDPR); for recordings and transcripts, your consent (Art. 6(1) sentence 1 point (a) GDPR)
  • Website: workspace.google.com
  • Privacy policy: policies.google.com/privacy
  • Data processing agreement: concluded with the provider (Cloud Data Processing Addendum, part of the Google Workspace terms)
  • Basis for third-country transfers: EU-US Data Privacy Framework (DPF) and standard contractual clauses (Art. 46(2) point (c) GDPR)

No additional analysis of your use or your content​

In the beta program, too, we do not link web analytics to your user account and do not evaluate it per participant; it takes place only with your consent (see the section "Web Analytics, Monitoring, and Optimization"). We do not make session recordings of your work in the application. We do not analyse content data that you enter in DolmiDesk for our own purposes.

Web Analytics, Monitoring, and Optimization​

To improve the product, we use the analytics service PostHog — exclusively with your consent. You give your consent via the "Statistics" category of the consent dialog (cookie banner, see the section "Use of Cookies"). In addition, you can switch off the collection independently via the "Anonymous usage statistics" toggle in the application under Settings → Privacy; analysis takes place only if both are enabled. Without your consent, no analysis takes place.

Usage events (e.g. features accessed, click paths) and technical information (e.g. browser, operating system) are recorded. The collection is anonymous: no user profiles are created, events are not linked to your user account, and session recordings are disabled. We use PostHog in the EU cloud: the data is stored exclusively on servers in the European Union (Frankfurt am Main, Germany). Content data you enter in DolmiDesk (e.g. the names of your clients) is not part of the analysis.

  • Service provider: PostHog, Inc., 2261 Market Street #4008, San Francisco, CA 94114, USA (data residency: EU cloud, Frankfurt am Main)
  • Legal bases: consent (Art. 6(1) sentence 1 point (a) GDPR; § 25(1) TDDDG)
  • Website: posthog.com
  • Privacy policy: posthog.com/privacy
  • Data processing agreement: concluded with the provider (PostHog Data Processing Agreement)
  • Basis for third-country transfers: data residency in the EU; for any support access by the provider: EU-US Data Privacy Framework (DPF) and standard contractual clauses (Art. 46(2)(c) GDPR)
  • Withdrawal (opt-out): at any time via "Your privacy settings" in the account menu (cookie banner) or the toggle under Settings → Privacy

Changes and Updates​

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

Where this privacy policy provides addresses and contact information of companies and organizations, please note that these may change over time; we ask you to verify the details before contacting them.

Definitions​

Below you will find an overview of the terms used in this privacy policy. Where statutory definitions exist, they apply; the following explanations are intended to aid understanding:

  • Master data: Essential information required for the identification and management of contractual partners and user accounts (e.g. name, contact information, customer number).
  • Content data: Information generated in the creation and editing of content — in DolmiDesk in particular the assignment, client, and invoice data entered by customers.
  • Receipt data: Expense receipts uploaded as files by customers, together with the details recorded about them (e.g. payment date, amount, issuer).
  • Contact data: Information that enables communication (e.g. telephone numbers, email addresses, postal addresses).
  • Meta, communication, and procedural data: Data about the handling of information (e.g. timestamps, IP addresses, communication histories, audit logs).
  • Usage data: Information about how and when digital services are used (e.g. features accessed, times of use, device information).
  • Personal data: Any information relating to an identified or identifiable natural person (e.g. name, identification number, location data, online identifier).
  • Log data: Records of events or activities in a system (e.g. timestamps, IP addresses, error messages).
  • Controller: The person or organization that determines the purposes and means of the processing of personal data.
  • Processing: Any operation performed on personal data — collection, analysis, storage, transmission, or erasure.
  • Contract data: All details of an agreement between parties (e.g. services, term, payment terms).
  • Payment data: Information required for processing transactions (e.g. bank details, invoicing information).

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