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Privacy Policy

Datenschutzerklärung

This policy explains what this service does with your data, why, on what legal basis, and for how long. It follows Articles 13 and 14 of the GDPR.

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The controller's identity and contact details below are placeholders and must be completed before launch.

1. Who is responsible

The controller within the meaning of Art. 4 (7) GDPR is:

Panas Vadim
Digeni Akrita 28, 3035 Limassol, Cyprus
Email
Vadim123.pv@gmail.com

No data protection officer has been appointed. One is required under § 38 BDSG only where at least twenty people are permanently engaged in the automated processing of personal data, or where the processing is otherwise subject to a data protection impact assessment. Neither applies here.

2. What is collected

The assessment asks for figures about your finances. These are processed in your browser to compute the plan and are not written to any database at any point.

Your assessment answers are held in your browser only, in this tab, so that moving between pages or refreshing does not discard them. They are cleared when you close the tab or press Start over, and they never leave your device unless you ask for the plan by email.

Categories of data
DataWhere it comes fromIs it stored?
AgeYou enter itNo
Net monthly incomeYou enter itNo
Monthly essential expensesYou enter itNo
Monthly amount you want to investYou enter itNo
Cash savings heldYou enter itNo
Debts: type, balance, interest rate, minimum paymentYou enter themNo
Goals: description, target amount, horizon in yearsYou enter themNo
Three risk attitude answersYou enter themNo
Optional start dateYou enter itNo
Email addressYou enter it to receive the planYes — see section 3
Whether you ticked the waitlist box, and the exact wording you were shownYour choice on the formYes — see section 3
IP address and timestampYour connectionYes — see section 3
Contact form: your message, and your name if givenYou type it into the contact formNo — emailed to the operator, see section 3

3. Why, on what legal basis, and for how long

Computing and showing your plan

Data
All the assessment answers
Legal basis
Art. 6 (1) (b) GDPR — carrying out, at your request, the thing you asked for
Retention
Not stored. The answers exist in your browser for the length of the session and are discarded when you close or restart it.

Writing the plain-language summary at the top of your plan

Data
Computed plan figures, generic debt and goal types, your age and your language. Not your name, not your email address, and not any text you typed.
Legal basis
Art. 6 (1) (b) GDPR — producing, at your request, the plan you asked for
Retention
Not stored. The figures are sent for the one request and the answer is held in your browser for the session only.

Emailing you the plan as a PDF

Data
Email address; the plan is recomputed from the answers your browser sends with the request
Legal basis
Art. 6 (1) (b) GDPR — fulfilling the request you just made
Retention
The answers are used to render the document and are then discarded. They are never written to a database and are not logged.

Sending you updates about the app in development (waitlist)

Data
Email address
Legal basis
Art. 6 (1) (a) GDPR — your consent, given by ticking a box that is never pre-ticked, and confirmed by clicking a link in a separate email (double opt-in)
Retention
Until you withdraw consent or unsubscribe. Every email carries an unsubscribe link.

Being able to demonstrate that consent was given

Data
Email address, timestamp, IP address, the exact consent wording shown, the version of this policy in force at the time
Legal basis
Art. 6 (1) (c) GDPR together with Art. 7 (1) GDPR — the controller must be able to demonstrate consent
Retention
For as long as the consent is relied on, and for three years after it is withdrawn, matching the ordinary limitation period under § 195 BGB.

Stopping the send endpoint from being used to email strangers

Data
IP address, recipient address, timestamp
Legal basis
Art. 6 (1) (f) GDPR — our legitimate interest in the security and integrity of the service, and in not becoming a vehicle for unsolicited mail
Retention
Counters are kept for the length of the rate-limit window (up to 60 minutes) and are then no longer read.

Feedback on the app being built

Data
A rating, and — only if you choose to give them — your name, your email address and whatever you write in the comment box
Legal basis
Art. 6 (1) (f) GDPR — our legitimate interest in improving a product, balanced by the fact that you volunteered it and none of it is required
Retention
Kept while the app is in development and deleted at the latest 24 months after it is sent. It is never added to any mailing list, and it is never published or quoted anywhere without asking you first.

Replying to a message sent through the contact form

Data
Your email address, your message, and your name if you choose to give one
Legal basis
Art. 6 (1) (b) GDPR — steps taken at your own request — and Art. 6 (1) (f) GDPR — our legitimate interest in answering enquiries
Retention
Not stored by this service. The message is delivered to the operator's email inbox and kept there only as long as the enquiry requires, then deleted.

4. Who else processes your data

Each of the following acts as a processor under Art. 28 GDPR, on the basis of a data processing agreement. No data is sold, and none is shared for anyone else's advertising.

Vercel Inc.

What it does
Hosting and delivery of the website and its API routes
Data
IP address and standard request metadata
Where
United States, with EU edge regions
Safeguard
EU Standard Contractual Clauses and Vercel's Data Processing Addendum

Neon Inc.

What it does
The database holding the consent audit record and the rate-limit counters
Data
Email address, timestamp, IP address, consent wording and version, the identifier of the contact in the email system
Where
European Union — Frankfurt (eu-central-1)
Safeguard
Processing takes place in the EU; Neon's Data Processing Agreement applies

Brevo (Sendinblue GmbH, Germany; Brevo SAS, France)

What it does
Sending the plan email, sending the confirmation email, delivering contact form messages, and holding the waitlist
Data
Email address, subscription status, the PDF attached to your plan email, and the contents of any contact form message
Where
European Union — Germany and France
Safeguard
Processing takes place in the EU; Brevo's Data Processing Agreement applies

Google (Google Ireland Limited — Gemini API, paid service)

What it does
Writing the plain-language summary and the three tips at the top of your plan
Data
Computed plan figures only: amounts, dates, months to clear, targets, projections, shortfalls, your age and your language. Debts and goals are sent as generic types (“credit card”, “home”), never the labels you typed. No name, no email address, no text you wrote.
Where
European Union — Ireland
Safeguard
Used under Google's paid Gemini API terms, which do not permit the data to be used to improve Google's products. If the summary cannot be produced, the card is written by a rule instead and nothing is sent.

5. Cookies and tracking

This service uses no analytics, no advertising pixels, no session recording and no cross-site tracking of any kind.

One cookie is set: NEXT_LOCALE, which remembers whether you are reading the English or the German version. It holds nothing else, expires after a year, and is strictly necessary to provide the language you asked for, so it is exempt from the consent requirement under § 25 (2) TDDDG.

Fonts are served from this site's own domain. They are not loaded from Google Fonts or any other third party, so opening a page here sends your IP address to nobody but the host.

6. Your rights

Under the GDPR you have the right to:

  • Art. 15AccessAsk what data about you is held, and get a copy.
  • Art. 16RectificationHave inaccurate data corrected.
  • Art. 17ErasureHave your data deleted, subject to any legal obligation to keep it.
  • Art. 18RestrictionRequire that processing be paused while a dispute is resolved.
  • Art. 20PortabilityReceive your data in a machine-readable form.
  • Art. 21ObjectionObject to processing based on legitimate interest.
  • Art. 7 (3)WithdrawalWithdraw consent at any time, as easily as it was given. Withdrawal does not affect the lawfulness of what was done beforehand.
  • Art. 77ComplaintLodge a complaint with a supervisory authority — for us, the Office of the Commissioner for Personal Data Protection (Cyprus). You may also complain to the authority where you live or work, wherever that is in the EU.

To exercise any of these, write to Vadim123.pv@gmail.com. We answer within one month, as Art. 12 (3) requires.

To unsubscribe from the waitlist without writing to anyone, use the unsubscribe link at the bottom of any email we send. That is the fastest route and it takes effect immediately.

7. Automated decision-making

The plan is produced by a deterministic calculator: the same answers always produce the same plan. It is not profiling within the meaning of Art. 22 GDPR, it produces no legal effect and no similarly significant effect, and no decision about you is taken on the basis of it. It is information for you to read.

Some of the explanatory sentences beside the figures are generated by an AI language model. They describe numbers the calculator has already produced; they never decide one. Text produced this way is labelled where it appears.

8. Changes to this policy

Every consent record stores the version of this policy that was in force when the consent was given, so an old record still says what it agreed to rather than silently inheriting today's wording.

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Educational information, not personalised financial advice.

Nothing on this website is an offer, invitation, or instruction to buy or sell a financial product.