プライバシーポリシー

Preamble

This privacy policy informs you about which personal data (hereinafter "data") we process at MeterGate, for what purposes and to what extent. It applies to all processing carried out in connection with our services and the operation of our website (hereinafter "online offering").

All person designations in this policy are gender-neutral.

Last updated: September 28, 2026

Table of Contents

• Preamble
• Controller
• Overview of Processing Activities
• Applicable Legal Bases
• Security Measures
• Transfer of Personal Data
• International Data Transfers
• General Information on Data Retention and Deletion
• Rights of Data Subjects
• Business Services
• Provision of the Online Offering and Web Hosting
• Use of Cookies and Comparable Technologies
• Registration, Login, and User Account
• Payment Processing via Stripe
• Changes and Updates
• Definitions

Controller

Jan Ebert
MeterGate
Hainholzweg 63a,
21077 Hamburg, Germany

Email address: info@metergate.dev

Imprint: https://metergate.dev/impressum

Overview of Processing Activities

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

Types of Data Processed

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

Categories of Data Subjects

• Service recipients and clients.
• Prospective customers.
• Users.
• Business and contractual partners.
• Third parties.

Purposes of Processing

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Security measures.
• Office and organizational procedures.
• Organizational and administrative procedures.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.
• Business processes and operational procedures.

Applicable Legal Bases

Applicable legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6(1)(a) GDPR) — The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
• Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) — Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation (Art. 6(1)(c) GDPR) — Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6(1)(f) GDPR) — Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated decision-making in individual cases including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Security Measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, input, disclosure, availability, and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data, and responses to data threats. We also take the protection of personal data into account in the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transfer of Personal Data

In the course of our processing of personal data, it may occur that such data is transferred to other entities, companies, legally independent organizational units, or persons, or disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, entities, or companies (as indicated by the postal address of the respective provider or if the privacy policy explicitly refers to data transfer to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), recognized as an adequate legal framework by the EU Commission's adequacy decision of July 10, 2023. In addition, Standard Contractual Clauses compliant with EU Commission requirements have been concluded with the respective providers, establishing contractual obligations to protect your data. Should changes occur within the DPF, the Standard Contractual Clauses serve as a reliable fallback.

For individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses exist. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, corresponding security measures apply, in particular Standard Contractual Clauses, explicit consents, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing ceases or the data is no longer required. Exceptions to this rule exist when legal obligations or special interests require longer retention or archiving of the data.

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

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

Where multiple retention periods or deletion deadlines are specified for a particular piece of data, the longest period always applies. Data that is no longer needed for the originally intended purpose but is retained due to legal requirements or other reasons will be processed by us exclusively for the reasons justifying its retention.

Retention and deletion of data: The following general periods apply for retention and archiving under German law:

• 10 years — Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the working instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
• 8 years — Accounting records, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO, § 14b para. 1 UStG as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
• 6 years — Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g., hourly wage slips, operating accounting sheets, calculation documents, price labels, as well as payroll documents insofar as they are not already accounting records, and cash register tapes (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
• 3 years — Data required to consider potential warranty and compensation claims or similar contractual claims and rights as well as to process related inquiries, based on previous business experience and customary industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

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

Rights of Data Subjects

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

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. If personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw your consent at any time.
• Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to such data as well as further information and a copy of the data in accordance with legal requirements.
• Right to rectification: You have the right to obtain the rectification of inaccurate personal data concerning you or to have incomplete personal data completed in accordance with legal requirements.
• Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to obtain the erasure of personal data concerning you without undue delay or, alternatively, to obtain restriction of processing of the data in accordance with legal requirements.
• Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, or to request that it be transmitted to another controller, insofar as this is legally permissible.
• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Business Services

We process data of our contractual and business partners, e.g., customers and prospective customers (collectively referred to as "contractual partners"), in the context of contractual and comparable legal relationships as well as associated measures and in communication with the contractual partners (or pre-contractually), e.g., to answer inquiries.

We process this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any updating obligations, and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for purposes of the administrative tasks associated with these obligations and for company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., for the involvement of telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the scope of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about other forms of processing, e.g., for marketing purposes, in the context of this privacy policy.

We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g., in online forms, by special labeling (e.g., colors) or symbols (e.g., asterisks or similar), or in person.

We delete the data once it is no longer required for the purposes stated above, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (typically 10 years for tax purposes). Data disclosed to us by the contractual partner in the context of an order is deleted in accordance with the specifications and requirements of the order, generally after the order has been completed.

Stripe for Payment Processing: For processing our postpaid payments we use the payment service provider Stripe (Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; for European data subjects: Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland). The buyer stores a payment method (card) once; upon storage and upon billing at the end of the billing period, the payment data (e.g. card data) is transmitted directly to Stripe and processed there; we ourselves neither receive nor store full card data. No prepaid credit is topped up or held; payments do not pass through any MeterGate account. Billing is a direct payment to the provider's account at the payment service provider (Direct Charge); the provider is the payee within the meaning of payment services law. The contractual supply relationship exists between the buyer and MeterGate (commission business, § 3 of the Terms). For the provider's required Stripe Connect onboarding, Stripe processes the provider's identity and account data; we store only a Stripe account identifier and the onboarding status. Stripe may process the following categories of data: inventory data (e.g., names, addresses), payment data (e.g., bank details, credit card numbers, transaction amounts), contract data, and usage data (e.g., IP addresses). The processing is carried out for the purpose of payment and payout processing, fraud prevention, and compliance with legal obligations. The legal bases are the performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) as well as legitimate interests (Art. 6(1)(f) GDPR) in a secure, efficient, and reliable payment and payout process. For transfers to the USA, Stripe relies on the EU-U.S. Data Privacy Framework, under which Stripe, Inc. is certified; in addition, EU standard contractual clauses are in place as a supplementary safeguard. Further information can be found in Stripe's privacy policy: https://stripe.com/de/privacy.

• Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., pages visited, duration of visit, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features).
• Data subjects: Service recipients and clients; prospective customers; business and contractual partners; users (e.g., website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures; business processes and operational procedures.
• Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion". Deletion after termination of the contract.
• Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Services and Procedures Used in Detail:

• E-Commerce and Fulfillment of Services: We process the data of our customers in order to enable them to select, purchase, or order the selected services as well as to pay for them and have them provided. Our services are provided exclusively digitally (provision and use of application programming interfaces via our platform); no physical shipment takes place. For the processing of payment transactions we use the services of payment service providers. The required information is identified as such in the context of the order or comparable acquisition process and comprises the information required for provision and billing as well as contact information in order to be able to consult where necessary; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Provision of the Online Offering and Web Hosting

We process user data in order to provide our online services to them. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.

• Types of data processed: Usage data (e.g., pages visited, duration of visit, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons). Log data (e.g., log files concerning logins or the retrieval of data or access times.).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems). Security measures.
• Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Services and Procedures Used in Detail:

• Provision of the Online Offering on Rented Storage Space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a "web hoster"); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
• Collection of Access Data and Log Files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to avoid an overload of the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure the utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
• Hetzner: Services in the field of the provision of information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Website: https://www.hetzner.com; Privacy Policy: https://docs.hetzner.com/de/general/company-and-policy/data-protection-at-hetzner. Data Processing Agreement: https://docs.hetzner.com/de/general/company-and-policy/data-protection-at-hetzner.

Use of Cookies and Comparable Technologies

Cookies are functions that store information on the user's end device or read information from it. Storage and access are governed by Section 25 of the German Telecommunications Digital Services Data Protection Act (§ 25 TDDDG); the subsequent processing of personal data is additionally governed by the GDPR. § 25 TDDDG is technology-neutral and covers not only cookies but also the browser's local storage (localStorage).

We use only technologies that are strictly necessary for the service you have requested (§ 25(2) No. 2 TDDDG). No consent is required for these, and we therefore do not use a consent banner. We do not use any analytics, reach measurement, or advertising technologies.

In detail:

• mg.sid (cookie) — session identifier. It maintains the login state, the selected language, one-time status messages, and the security token against cross-site request forgery (CSRF). The cookie contains only a random identifier; the associated data is held on our server. Lifetime: 7 days. Attributes: HttpOnly, SameSite=Lax, and Secure in production.
• lang (cookie) — stores the display language you selected. Lifetime: 1 year. Attributes: HttpOnly, SameSite=Lax, and Secure in production.
• theme (localStorage) — stores your choice between light and dark appearance. It is set only when you operate the toggle and is not transmitted to us.
• mg_verify_cooldown_until (localStorage) — prevents repeated sending of the same confirmation email. It is not transmitted to us.

Payment pages: You store a payment method on a Stripe page (Stripe Checkout) to which we redirect you. On the page where you confirm a payment (3-D Secure), we embed the Stripe.js library. Stripe sets its own cookies there for fraud detection and to secure the payment process; they are necessary for the payment process you requested. Stripe.js is not loaded on any other page. Details: Stripe's cookie policy.

Objection: You can prevent storage through your browser settings and delete entries already stored. Login and language selection will then no longer work.

• Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers).
• Data subjects: Users (e.g., website visitors, users of online services).
• Legal bases: § 25(2) No. 2 TDDDG for storage and access; legitimate interests (Art. 6(1)(f) GDPR) for the subsequent processing.

Registration, Login, and User Account

Users can create a user account. As part of the registration process, users are informed of the required mandatory information and this information is processed for the purpose of providing the user account on the basis of contractual performance. The data processed includes, in particular, login information (username, password, and an email address).

In the context of using our registration and login functions as well as the use of the user account, we store the IP address and the time of each user action. This storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a general rule, this data is not passed on to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so.

Users can be informed by email about processes that are relevant to their user account, such as technical changes.

• Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or pictorial messages and posts as well as the information concerning them, such as authorship or time of creation); usage data (e.g., pages visited, duration of visit, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Log data (e.g., log files concerning logins or the retrieval of data or access times.).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; organizational and administrative procedures. Provision of our online offering and user-friendliness.
• Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion". Deletion after termination.
• Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Services and procedures in detail:

• Closure of the user account: If users close their user account, it is taken out of service: logging in is no longer possible, API keys are deactivated, and any offerings are removed from the catalogue. The inventory, contract, and billing data stored for the account are not deleted in the process: we are required by law to retain invoices, self-billing invoices, and the associated accounting records (§ 147 (1) no. 4 AO (German Fiscal Code), § 14b UStG). To that extent, the right to erasure under Art. 17(1) GDPR is excluded pursuant to Art. 17(3)(b) GDPR. After the retention periods have expired, and provided that no outstanding claims exist, the personal data of the account are removed or anonymised; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legal obligation (Art. 6(1)(c) GDPR).
• Sending of system emails: For sending confirmation and security emails (e.g., email verification, password reset), we use the email service of mailbox.org. The email address and the content of the respective message are transmitted to the provider. The server location is Germany; Service provider: mailbox.org / Heinlein Support GmbH, Schwedter Str. 8/9b, 10119 Berlin, Germany; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Website: https://mailbox.org; Privacy Policy: https://mailbox.org/de/datenschutzerklaerung.

Payment Processing via Stripe

Payments on the Platform are processed by Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (“Stripe”).

• Buyers: You enter a means of payment directly with Stripe; we receive only an identifier, the card brand and the last four digits. For each settlement your means of payment is made available to the Stripe account of the respective Provider and charged there (direct charge). The Provider is the payee: in its Stripe account it sees the payment with amount, date, the details of the means of payment (including the cardholder stored with Stripe) and the MeterGate settlement identifier.
• Providers: Providers open their own Stripe account with their own Stripe Dashboard via MeterGate and conclude their own contract with Stripe for this purpose. Stripe collects identity verification and bank details directly. We receive from Stripe the account identifier and its activation status (whether payments and payouts are enabled); Stripe invoices its fees directly to the Provider.
• Responsibility: Stripe processes payment data as an independent controller (privacy policy: stripe.com/privacy). The Provider processes the Buyer details visible in its Stripe account as an independent controller for handling and documenting its incoming payments.
• Legal bases: performance of a contract (Art. 6(1)(b) GDPR); legal obligations (Art. 6(1)(c) GDPR), at Stripe in particular for the prevention of money laundering and fraud.
• Transfers to third countries: Stripe may transfer data to Stripe, Inc. in the USA; Stripe, Inc. is certified under the EU-U.S. Data Privacy Framework, and standard contractual clauses apply in addition.

Changes and Updates

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

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

Competent supervisory authority:

HmbBfDI (Hamburg Commissioner for Data Protection and Freedom of Information):
Ludwig-Erhard-Straße 22,
20459 Hamburg, Germany
Tel: +49 40 428544040

Definitions

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

• Inventory data: Data used to identify and manage contractual partners and user accounts — such as name, address, contact details or unique identifiers like a user ID. They enable a person to be uniquely assigned to an account or process.
• Content data: Data generated when creating, editing or publishing content — e.g. text, images or files — including associated information such as title, description or creation time.
• Contact data: Information through which a person can be reached, such as telephone number and postal and email addresses.
• Meta, communication, and procedural data: Data describing how other data is processed, transmitted or managed. This includes technical accompanying information (e.g. timestamps, IP addresses, involved identifiers), details of the communication process, and logs of processes and transactions.
• Usage data: Data arising when people use a digital offering — e.g. pages visited, access times, frequency of use, and technical information about the device used.
• Personal data: Any information relating to an identified or identifiable natural person (the "data subject"). A person is regarded as identifiable if they can be directly or indirectly assigned, in particular via an identifier such as a name, an identification number, location data or an online identifier.
• Log data: Records of events and activities in a system, typically with timestamp, IP address and details of the operation. They primarily serve error analysis and security monitoring.
• Controller: The natural or legal person or entity that alone or jointly with others decides on the purposes and means of processing personal data.
• Processing: Any operation relating to personal data — with or without automated procedures. The term is broad and covers practically any handling of data, such as collection, storage, use, transmission or deletion.
• Contract data: Data documenting an agreement between the parties — such as contract subject matter, term, agreed services, prices and payment terms.
• Payment data: Data required for processing payments, e.g. payment method details, billing and transaction data, and information on payment status or chargebacks.