Privacy Policy – Numbrs App

Numbrs believes that data protection is a fundamental human right, which is why we take the protection of our users’ personal data and privacy very seriously. Numbrs is subject to the provisions of the General Data Protection Regulation (GDPR) of the European Union and the Data Protection Act. We put a lot of effort into ensuring that these regulations are implemented correctly.

The Numbrs App enables users to conduct all of their banking business in a simple, secure and neutral manner. Our business model is based on the brokerage of various financial products and not on the selling of personal data. Numbrs does not record personal data with the intention of selling it to advertisers or to other companies.

We want all of our users to be informed about what type of personal data Numbrs collects and how this data is being used by Numbrs. This privacy policy describes what type of personal user data Numbrs Personal Finance AG (hereinafter “Numbrs”, “we”, “us”) as the data controller collects and processes when using the Numbrs App.

1. Numbrs protects your data and privacy

We place the utmost priority on the security of the data that we collect. We have implemented technical and organisational measures which aim to ensure compliance with the data protection regulations by us as well as external service providers. Cutting-edge security technology protects the data and privacy of each Numbrs’ user.

All information recorded is exclusively stored in protected data centres. Our data centers that are located in Germany are all PCI-DSS and ISO27001 certified.

Furthermore, Numbrs is subject to the strict data protection laws and uses the TLS 1.2 protocol with 2048-Bit SSL for the encryption of data during data transfers on all connections. Several German authorities and certifying bodies (e.g. TÜV Saarland) have carefully reviewed the security and privacy practices of Numbrs and certified the Numbrs App as highly trustworthy.

2. Personal Data

It is our promise that all users can easily and securely conduct their banking business via the Numbrs App. It is our goal that every user can use the Numbrs App at any time, with the best possible quality and with the highest security standard. Each individual user can choose whether to enter their personal data in the Numbrs App, so as to be able to utilise more useful and personalised information provided by our functions. Numbrs only collects and processes the data once the user has given his consent to do so.

Numbrs solely collects data (e.g. IP address and email address) that is necessary to offer you the features of the Numbrs App. A detailed list outlining the personal data that we collect and the purpose for such collection can be found here: User Data Appendix. We do not collect data that is not directly required for the use of the Numbrs App.

We do not conduct user specific analysis. We reserve the right to analyse pseudonymised and anonymised data sets for statistical purposes. In the case of anonymised data, all personal data is removed and replaced with a fully encrypted token. It is therefore not possible to identify individual users. For instance, the analysis of pseudonymised or anonymised data can help us improve the automatic categorisation function. The automatic categorisation function sorts users’ income and expenses into various categories such as “food” and “insurance”.

We limit access to your personal data that is collected by Numbrs to only those who absolutely need access to it, in order to carry out their professional tasks.

3. Retention Period

Numbrs only collects personal data to the extent necessary to fulfil our contractual obligations and only for the time necessary to achieve the purposes for which the personal data is collected, in accordance with applicable data protection laws. If Numbrs no longer requires your personal data, we shall delete it and/or take the necessary measures to anonymise your personal data. This does not apply if we are obliged to keep the data for a longer period of time, in particular to comply with legal retention obligations.

4. Transfer of personal data to third parties

Numbrs exclusively uses personal data for the purpose of offering the Numbrs App. Numbrs does not transfer personal data to third parties without the consent of the user.

In the event of data being transferred to third parties within the scope of data processing activities, then such third parties are obliged to adhere to the Data Protection Act or other legal provisions and have been contractually obliged to comply with this privacy policy.

Insofar as we are bound by law or court order to do so, we shall transfer personal data to instances authorised to request such information (e.g. courts or law enforcement agencies). We will inform you should this ever be the case, unless we are prohibited to do so by law or official order.

Furthermore, we cooperate, in strictest compliance with legal provisions, with external parties which provide us with services, for example for the purpose of App analysis or marketing.

Click here for a detailed list of all third parties: User Data Appendix.

5. International exchange of personal data

Numbrs is a Swiss company with its registered office in Switzerland. The data collected will therefore be processed at least partly outside the United Kingdom e.g. in Switzerland, whereby the data remains protected by very strict data protection laws. The EU Commission has confirmed with an adequacy decision that Switzerland has an appropriate level of data protection (Decision of the EU Commission 2000/518/EC).

Furthermore, some of our service providers have their registered office outside the EU or Switzerland, so that the applicable laws guarantee a different national level of data protection than that provided for in European or Swiss data protection law. In this case, we shall ensure (e.g. by concluding appropriate contracts) that the service providers concerned guarantee an appropriate level of data protection comparable to that in the United Kingdom.

We are committed to making sure that all of our service providers comply with technical and organisational measures to ensure the protection of personal data.

6. Your rights

Users who have entered personal data into the Numbrs App can request to have their data deleted at any time, unless Numbrs is obliged to store this data for a certain period of time on the grounds of statutory retention periods, e.g. for tax or accounting purposes.

Should this be the case, the data is deleted as soon as the retention period has expired. Users may also request the correction of incorrectly recorded data at any time. Click here for a detailed list of all of your rights: Appendix Your Rights.

7. Amendments to the privacy policy

This privacy policy may require updating from time to time, e.g. due to the introduction of new technologies or functions. We reserve the right to change or supplement this privacy policy at any time. We will publish the changes on our website and/or inform users accordingly (e.g. by email).

8. Contact

Please do not hesitate to contact our support team at support@numbrs.com, or send a letter to the publisher of this privacy policy: Numbrs Personal Finance AG, Edenstrasse 20, 8045 Zurich, Switzerland, should you have any questions or suggestions.

The address of our representative in the European Union is: Numbrs Personal Finance AG, Lohnerhofstrasse 2, 78467 Konstanz, Germany.

You may also choose to contact our data protection officer at any time. Email: email@iitr.de. Address: Attorney at Law Dr. Sebastian Kraska, Marienplatz 2, 80331 Munich, Germany.

We are registered in the Information Commissioner’s Office Public Register of Data Controllers (at https://ico.org.uk) under registration number ZA202503.

This data privacy policy was last updated on 24 May 2018.

Download “Privacy Policy – Numbrs App” as PDF
Download “Your Rights” as PDF
Download “User Data” as PDF