Privacy policy
Last updated: 5 November 2026
Introduction
This privacy policy explains which kinds of personal data ("data") we process, for which purposes and to what extent. It applies to all processing of personal data carried out by us, both when providing our services and, in particular, on our website and within external online presences such as our social media profiles (together, our "online offering"). The Paperfield app has its own privacy policy, which we provide in the app and in the App Store.
This privacy policy is also available in German, with the same content: Datenschutzerklärung (Deutsch).
Contents
- Controller
- Overview of processing
- Legal bases
- Security measures
- Disclosure of personal data
- International data transfers
- Retention and deletion
- Your rights
- Business services
- Hosting and provision of the website
- Protection against abuse (Cloudflare Turnstile)
- Cookies and similar technologies
- Contact and enquiries
- Beta waitlist and emails
- Web analytics
- Social media presences
- Embedded content (YouTube)
- Organisational tools
- Changes to this policy
- Definitions
Controller
Jan Schüler
Paperfield
Havemannstraße 5
30165 Hannover
Germany
Email: hello@paperfield.de
Phone: +49 177 7290167
Imprint: Imprint
Overview of processing
Types of data processed
- Master data (e.g. name)
- Contact data (e.g. email address)
- Content data (e.g. messages, optional survey answers)
- Contract data
- Usage data
- Meta, communication and process data (e.g. IP address, time stamps)
- Log data
Categories of data subjects
- Customers and beta testers
- Prospective users (e.g. people on the beta waitlist)
- Communication partners
- Users of our website
- Business partners
Purposes of processing
- Providing contractual services
- Communication
- Security
- Direct marketing (emails with consent)
- Audience measurement
- Office and organisational procedures
- Feedback
- Providing our website and making it easy to use
- IT infrastructure
- Public relations
Legal bases
We process personal data on the following legal bases of the General Data Protection Regulation (GDPR). Where a more specific legal basis applies, we name it in the relevant section.
- Consent (Art. 6(1)(a) GDPR): you have given consent to the processing of your data for one or more specific purposes.
- Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR): the processing is necessary for a contract with you or for steps you request before entering into a contract.
- Legal obligation (Art. 6(1)(c) GDPR): the processing is necessary to comply with a legal obligation.
- Legitimate interests (Art. 6(1)(f) GDPR): the processing is necessary for our legitimate interests or those of a third party, unless your interests or fundamental rights and freedoms override them.
German law: In addition to the GDPR, the German Federal Data Protection Act (BDSG) applies. For storing information on your device and accessing it (e.g. cookies or the browser's local storage), § 25 of the German Telecommunications Digital Services Data Protection Act (TDDDG) applies: we ask for your consent (§ 25(1) TDDDG) unless the storage or access is strictly necessary to provide a service you have explicitly requested (§ 25(2) no. 2 TDDDG).
Security measures
Taking into account the state of the art, implementation costs and the nature, scope, context and purposes of processing as well as the risks to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of security appropriate to the risk. These include protecting the confidentiality, integrity and availability of data by controlling physical and electronic access, input, disclosure and separation, as well as procedures for exercising data subject rights, deleting data and responding to threats. We consider data protection already when developing or selecting hardware, software and procedures (data protection by design and by default).
Specifically, we do not store IP addresses on our own systems. To limit the number of requests (protection against abuse), the IP address is used only briefly in an encrypted, non-reversible form (a cryptographic hash with a secret key). In our own data store, email addresses are kept only as such a hash (pseudonym); the email address itself is held only by our email service provider Brevo.
All connections to our website are encrypted with TLS (HTTPS).
Disclosure of personal data
In the course of processing, data may be transferred to or disclosed to other bodies, companies or persons. Recipients are in particular the service providers named in this policy that act on our behalf (Cloudflare, Brevo, Plausible), and, only if we embed their content and you load it, providers of embedded content (YouTube). We have concluded data processing agreements with our processors pursuant to Art. 28 GDPR.
International data transfers
Where we transfer data to a third country (outside the EU or the European Economic Area), or where this happens through the use of third-party services, we do so only in accordance with the legal requirements.
For transfers to the USA we rely primarily on the EU-US Data Privacy Framework (DPF), recognised as providing an adequate level of protection by the European Commission's adequacy decision of 10 July 2023. Where we use providers as processors (e.g. Cloudflare), their data processing agreements additionally include the European Commission's Standard Contractual Clauses (SCCs), which serve as a fallback should the DPF change.
For each provider we state whether it is certified under the DPF and whether SCCs apply. Further information and a list of certified companies: https://www.dataprivacyframework.gov/. Information on third-country transfers and adequacy decisions: European Commission.
Retention and deletion
We delete personal data in accordance with the law as soon as consent is withdrawn or no other legal basis for processing exists, in particular when the original purpose no longer applies. Exceptions apply where statutory obligations or legitimate reasons require longer retention, e.g. retention for commercial or tax reasons, or to establish, exercise or defend legal claims. Where several retention periods apply, the longest one prevails. Data that is only retained for such reasons is processed solely for those reasons.
Statutory retention periods under German law include: 10 years for books, records and annual accounts (§ 147 AO, § 257 HGB); 8 years for accounting vouchers such as invoices (§ 147 AO, § 14b UStG, § 257 HGB); 6 years for other business correspondence relevant for tax purposes (§ 147 AO, § 257 HGB); 3 years for data needed to handle possible warranty or similar claims (regular limitation period, §§ 195, 199 BGB). Periods of at least one year start at the end of the calendar year in which the triggering event occurred.
The individual sections below contain further information on retention for specific processing.
Your rights
Under the GDPR, in particular Art. 15 to 21, you have the following rights:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to processing of your data based on Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where your data is processed for direct marketing, you have the right to object at any time to such processing, including profiling related to such direct marketing.
- Right to withdraw consent: You can withdraw any consent you have given at any time with effect for the future.
- Right of access: You can request confirmation as to whether we process your data, and access to that data and further information, including a copy.
- Right to rectification: You can request that incomplete data be completed or inaccurate data be corrected.
- Right to erasure and restriction: You can request that your data be erased without undue delay or, alternatively, that its processing be restricted, in accordance with the law.
- Right to data portability: You can receive the data you have provided to us in a structured, commonly used and machine-readable format, or request its transfer to another controller.
- Right to lodge a complaint: Without prejudice to any other remedy, you can lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work or the place of the alleged infringement. The authority responsible for us is: Die Landesbeauftragte für den Datenschutz Niedersachsen, Prinzenstraße 5, 30159 Hannover, Germany, www.lfd.niedersachsen.de.
Business services
We process data of our contractual and business partners, such as customers, beta testers, prospective users and other partners, to initiate, carry out and handle contractual and similar relationships, including pre-contractual steps on request and related communication. This includes providing the beta version and handling feedback and support requests. We process in particular master data such as name, contact data such as email address, contract data and communication content. The app is sold through Apple's App Store; we do not receive payment data. We also process data to comply with legal obligations, in particular commercial and tax retention requirements, which may involve external bodies such as tax advisers.
- Legal bases: Art. 6(1)(b), (c) and (f) GDPR.
- Retention: as described under "Retention and deletion".
Hosting and provision of the website
To deliver our website to your browser we need to process your IP address. We serve fonts and the trailer video from our own server; no data is sent to third parties such as Google Fonts for this.
- Hosting and content delivery network (Cloudflare): Our website and its server functions (e.g. signing up for the waitlist) run on Cloudflare Workers. Cloudflare delivers the content through a worldwide network of data centres and protects the website against attacks, processing your IP address and technical connection data on our behalf. We store pseudonymous waitlist records (see below) in Cloudflare's data store (Workers KV). Provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Legal basis: legitimate interests (Art. 6(1)(f) GDPR) in a secure and efficient website. Privacy policy: cloudflare.com/privacypolicy; data processing agreement: cloudflare.com/cloudflare-customer-dpa. Third-country transfers: DPF and SCCs (in the data processing agreement).
- Access data and log files: When you visit our website, Cloudflare processes access data such as the requested address, date and time, amount of data transferred, status codes, browser type and operating system, referrer URL and IP address. This data is used for delivery, security (e.g. defending against denial-of-service attacks) and stability. Our own server logs contain only technical events (e.g. error messages) without IP addresses or email addresses and are deleted automatically after a few days (at most 30 days). Data required as evidence is kept until the incident has been resolved. Legal basis: Art. 6(1)(f) GDPR.
- Email forwarding (Cloudflare Email Routing): Emails to our contact address are received by Cloudflare and forwarded to our mailbox; Cloudflare processes sender, recipient, content and technical metadata of the email. Legal basis: Art. 6(1)(f) GDPR.
Protection against abuse (Cloudflare Turnstile)
To protect our sign-up form against automated submissions (spam, bots), we use Cloudflare Turnstile. Turnstile is loaded only when you start using the sign-up form (when you click into or type in the email field, tick the consent box or submit the form); merely visiting our website does not load it. Turnstile then checks technical characteristics of the connection and browser (e.g. IP address, browser and device information, interaction signals) to tell whether a request comes from a human. Usually you do not need to solve a picture puzzle. According to Cloudflare, Turnstile does not use the data for advertising. Turnstile stores an entry named cf.turnstile.u in the local storage of challenges.cloudflare.com in your browser (see "Cookies and similar technologies"). In addition, we use our own measures (a hidden field, a minimum completion time and a limit on requests per period) for which we do not store any data permanently.
- Legal bases: legitimate interests (Art. 6(1)(f) GDPR) in protecting against abuse; where information is stored on or read from your device, § 25(2) no. 2 TDDDG, as this is strictly necessary for the sign-up you have started.
- Provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Privacy information: cloudflare.com/turnstile-privacy-policy. Third-country transfers: DPF, SCCs.
Cookies and similar technologies
"Cookies" here means any technology that stores information on your device or reads it from there, including the browser's local storage. We do not use cookies for analytics or advertising ourselves.
- Appearance setting (pf-thema): The page always opens in light mode. If you choose dark yourself, we store this choice in your browser's local storage so it is kept on your next visit. If you switch back to light, we delete the entry; if you never choose, nothing is stored. The entry contains only the chosen value, is not sent to us and remains until you change the setting or delete it in your browser. Legal basis: § 25(2) no. 2 TDDDG, as the storage is strictly necessary for the function you explicitly requested, and Art. 6(1)(f) GDPR.
- Spam protection (cf.turnstile.u): When you start using the sign-up form, Cloudflare Turnstile stores this entry in the local storage of challenges.cloudflare.com in your browser (see "Protection against abuse"). Nothing is stored if you only visit the website. Legal basis: § 25(2) no. 2 TDDDG and Art. 6(1)(f) GDPR.
- YouTube: We currently do not embed any YouTube content; the trailer is served from our own server. If we embed the YouTube version later (see "Embedded content"), YouTube can use cookies or similar technologies on your device only after you actively load the video, and only with your consent (§ 25(1) TDDDG, Art. 6(1)(a) GDPR).
Two-click consent: If we embed external content such as a YouTube video, we load it only after you click the placeholder and thereby consent. Before that click, no connection to YouTube is made; we serve the preview image ourselves. Your consent applies only to the current page view and is not stored; you will be asked again on your next visit. You can withdraw it by not loading the video again and deleting YouTube's cookies in your browser. You can also object to processing at any time, including through your browser's privacy settings.
Contact and enquiries
When you contact us (e.g. by email or via social media), and within existing user and business relationships such as feedback from beta testers, we process the information you provide to the extent necessary to answer your enquiry and take any requested action. This typically includes your contact details, the content of your message and time stamps. We delete enquiries once they have been fully dealt with and no statutory retention obligations apply.
- Legal bases: legitimate interests (Art. 6(1)(f) GDPR); performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR).
Beta waitlist and emails
We send emails about the Paperfield beta ("newsletter") only with the recipient's consent. All you need to provide is your email address. The content described when you sign up is what your consent covers: a confirmation email (double opt-in), updates on development and the beta (at most one email a week) and an invitation when a test spot becomes available.
Double opt-in: After signing up you receive an email with a confirmation link. Only after you click it are you added to the list, so that nobody can sign up with someone else's email address. To prove your consent we store the time of sign-up and confirmation, the version of the consent text and the place on the website where you signed up.
Data processed when you sign up:
- At our email service provider Brevo: your email address, the time and version of your consent, the source of the sign-up, campaign parameters from the link you followed, if any (so-called UTM parameters, e.g. "instagram"), and a pseudonymous identifier.
- In our own data store at Cloudflare: a pseudonymous record without your email address. It contains a non-reversible hash of your email address, the time and version of your consent, language, the version of the start page shown, campaign parameters if any and, if you answer them, your answers to the optional short survey.
Optional short survey: Right after signing up you can choose to answer a few questions (e.g. whether you study, which devices and apps you use, which problem you want to solve and how you heard about us; optionally free text). We use the answers to plan the beta and to give test spots preferably to the people the app is made for (e.g. students with an iPad or Mac). We decide on test spots ourselves; there is no decision based solely on automated processing within the meaning of Art. 22 GDPR. Not answering has no disadvantage for your sign-up. For analysis we use the answers only in aggregated form and without email addresses. Please do not enter sensitive data (e.g. about your health) in the free text.
Open and click measurement: Our emails contain a so-called web beacon, a tiny image retrieved from Brevo's server when the email is opened, and links in the emails are routed through Brevo. This lets Brevo record whether and when an email was opened and which links were clicked, together with technical information such as browser, system and IP address. We use this to see which content is of interest and to improve our emails. The measurement is covered by your consent to receive the emails; you can only withdraw it by unsubscribing from the emails as a whole. You can also prevent it by not loading images in your email program.
Deletion: Brevo adds your address to our recipient list only after you confirm it. We delete the pseudonymous record of a sign-up that was not confirmed at the latest 30 days after the sign-up (we check this every week). If you unsubscribe, we delete your data at Brevo (except the block list entry described below) and, within one week, the pseudonymous record including your survey answers. When the beta phase ends, we delete your data at Brevo and the pseudonymous record. We may keep proof of your earlier consent (email address, time stamps, version of the consent text) for up to three years based on our legitimate interests, so that we can demonstrate the consent (Art. 17(3)(e) GDPR); processing of this data is limited to defending against possible claims. You can request earlier individual deletion at any time if you also confirm that the consent existed. So that we do not email you after you have unsubscribed, we may keep your email address solely for this purpose in a block list.
- Legal bases: consent (Art. 6(1)(a) GDPR, for open and click measurement also § 25(1) TDDDG); for logging the sign-up process and proving consent, and for using an email service provider: legitimate interests (Art. 6(1)(f) GDPR).
- Withdrawal (opt-out): You can stop receiving the emails at any time, i.e. withdraw your consent, using the unsubscribe link at the end of every email or by sending us an informal message.
- Brevo: sending emails and managing the recipient list; data is processed on servers in the EU. Provider: Brevo SAS, 17 rue Salneuve, 75017 Paris, France. Privacy policy: brevo.com/legal/privacypolicy. A data processing agreement is concluded as part of Brevo's terms. Where Brevo's sub-processors process data outside the EU, this is based on SCCs or the DPF.
Web analytics
To understand how our website is used and to improve it, we use Plausible Analytics. Plausible works without cookies and without storing anything on your device. It does not create user profiles and does not use data for advertising.
Plausible records aggregated information such as pages viewed, referring website, campaign parameters, country, device type, browser and operating system, and certain events (e.g. playing the trailer or submitting the sign-up form). To count unique visitors, Plausible creates a hash from the IP address and browser identifier together with a random value that changes daily. The IP address itself is not stored, and the random value is deleted daily, so visits cannot be linked across days.
When a sign-up to the waitlist succeeds, our server may send a corresponding event to Plausible. It transmits the same technical data as a page view (IP address and browser identifier, used only to compute the hash described above), but no email address and no survey answers.
We may compare different versions of the start page (e.g. different headlines). Nothing is stored on your device for this; we only evaluate which version was shown.
- Retention: Plausible keeps only aggregated statistics without personal reference, which we keep as long as we use the service.
- Legal basis: legitimate interests (Art. 6(1)(f) GDPR). As nothing is stored on or read from your device, no consent under § 25 TDDDG is required.
- Objection: You can object at any time with effect for the future, e.g. by email to us. You can also prevent the measurement with a content blocker in your browser.
- Provider: Plausible Insights OÜ, Västriku tn 2, 50403 Tartu, Estonia; servers in the EU. Privacy policy: plausible.io/privacy; data processing agreement: plausible.io/dpa.
Social media presences
We maintain profiles on social networks to communicate with users there and to inform them about us. Links on our website to these networks are plain links; data is only transmitted when you click them.
User data may be processed outside the European Union, which may make it harder to enforce your rights. Social networks generally process user data for market research and advertising, e.g. by creating usage profiles from your behaviour and interests, often using cookies, also across devices (in particular if you are logged in). For details and opt-out options, please refer to the networks' own privacy policies. Requests for access and other data subject rights are most effectively addressed to the providers, as only they have access to the data; you are nevertheless welcome to contact us.
- Legal basis: legitimate interests (Art. 6(1)(f) GDPR) in communication and public relations.
- Instagram: We are jointly responsible with Meta for the statistics on our profile ("Insights"); Meta has agreed to fulfil data subject rights (controller addendum). Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Privacy policy: privacycenter.instagram.com/policy. Third-country transfers: DPF.
- Threads: Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Privacy policy: Threads privacy policy. Third-country transfers: DPF.
- TikTok: Provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland. Privacy policy: tiktok.com/legal/privacy-policy-eea. Third-country transfers: SCCs (according to TikTok).
- LinkedIn: Where we operate a LinkedIn page, we are jointly responsible with LinkedIn Ireland Unlimited Company for collecting the visitor data used for "Page Insights" (joint controller addendum); further processing is LinkedIn's sole responsibility. Provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland. Privacy policy: linkedin.com/legal/privacy-policy. Third-country transfers: DPF, SCCs. Opt-out: retargeting opt-out.
- X: Provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. Privacy policy: x.com/en/privacy. Third-country transfers: SCCs (according to X).
- YouTube (channel): Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy policy: policies.google.com/privacy. Third-country transfers: DPF. Ad settings: myadcenter.google.com.
Embedded content (YouTube)
At present we do not embed any YouTube content: the trailer is served only from our own server, and no connection to YouTube is made. The following applies only if we enable the YouTube version of the trailer. To ensure that no data is sent to YouTube when you merely visit our website, we then use a two-click solution: at first you only see a preview image provided by us, with a notice. Only when you click "Play on YouTube" and thereby consent is the YouTube player loaded in privacy-enhanced mode (youtube-nocookie.com). Alternatively, you can watch the same trailer from our own server without YouTube.
From that moment, YouTube receives your IP address and technical information about your browser and device and may use cookies or similar technologies on your device. If you are logged in to a Google account, YouTube can associate the view with your account. YouTube/Google may also process this data for its own purposes, e.g. statistics, service improvement and advertising, for which Google is solely responsible.
- Legal basis: consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG).
- Retention: We do not store any data ourselves. According to Google, YouTube's cookies can remain on your device for up to two years unless you delete them earlier.
- Withdrawal: Your consent applies only to the current page view. You can withdraw it by not loading the video again and deleting YouTube's cookies in your browser.
- Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy policy: policies.google.com/privacy. Third-country transfers: DPF. Ad settings: myadcenter.google.com.
Organisational tools
We use services, platforms and software from other providers for organisation, administration and providing our services. Personal data, in particular contact data, message content and information about beta testers, may be processed and stored on their servers.
- Gmail (Google): the mailbox in which we receive and answer enquiries. Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy policy: policies.google.com/privacy. Third-country transfers: DPF. Legal basis: Art. 6(1)(f) GDPR.
- Apple TestFlight and App Store Connect: distributing the beta version to invited testers. To invite you, we pass your email address (and your name, if given) to Apple. Apple provides us with information on installation, device and system version, crash reports and feedback you send via TestFlight. Provider: Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland. Privacy policy: apple.com/legal/privacy. Third-country transfers: SCCs. Legal bases: Art. 6(1)(b) and (f) GDPR.
Changes to this policy
We update this privacy policy as soon as changes to our processing make it necessary, and we will inform you if a change requires action on your part (e.g. consent) or other individual notification. Addresses and contact details of companies named here may change over time; please check them before contacting them.
Definitions
- Personal data: any information relating to an identified or identifiable natural person, e.g. by reference to a name, an identification number, location data, an online identifier (e.g. a cookie) or other characteristic features.
- Processing: any operation performed on personal data, such as collecting, analysing, storing, transmitting or deleting it.
- Controller: the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
- Pseudonymisation: processing data in such a way that it can no longer be attributed to a specific person without additional information kept separately (e.g. replacing an email address by a hash).
- Audience measurement: analysing visitor flows on a website, e.g. which content is of interest and at which times.
- Tracking: following users' behaviour across several online services, usually by storing behavioural and interest data in cookies or on the provider's servers (profiling). We do not track you ourselves; it may be done by third parties such as YouTube if you load their content.
Based on a text created with Datenschutz-Generator.de by Dr. Thomas Schwenke.