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

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

Categories of data subjects

Purposes of processing

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.

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:

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.

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.

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.

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.

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.

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:

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.

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.

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.

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.

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.

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

Based on a text created with Datenschutz-Generator.de by Dr. Thomas Schwenke.

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