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User Data

Affected persons: Numbrs App users.

With the exception of the account information and payment initiation services, all services, especially the technical provision of the App, are provided by Numbrs.

The numbered sections below contains the following information:

All of the data being collected by Numbrs is stored in our servers in German data centers which carry the highest security certifications. We encrypt all network communication with SSL/TLS at a minimum of 2048-bit encryption.

The legal basis for the processing of personal data is generally the fulfilment of the contract between the user and Numbrs. The legal basis for the processing of personal data in connection with the improvement of the Numbrs App (point 14 below) and Marketing emails (point 15 below) is subject to the explicit consent of the user.

The data collected by Numbrs is provided by the user, the device used by the user or from the bank connected to the Numbrs App.

1. Provision of cloud-based server and processing services

Purpose

Personal data is only collected in secure and certified computer centers. The data centers are, without exception, located in Frankfurt, Germany. The data centers are operated by Amazon Web Services, a leading global service provider.

Amazon Web Services is subject to German data protection laws and is also contractually obliged to process the personal data exclusively on our behalf and according to our strict security standards.

Personal data

This includes the data categories in points 2 - 13 below.

Name and address of recipient

Amazon Web Services Inc., 410 Terry Avenue North, Seattle, Washington 98109-5210, USA (Country outside of the European Union for which no adequacy decision of the European Commission exists, but where appropriate and/or adequate safeguards were put in place (e.g. use of standard contractual clauses, 2010/87/EU and/or 2004/915/EC)).

2. Creating user accounts

Purpose

In order to use all of the functions provided by the Numbrs App, users are required to provide some information when creating a user account and when concluding their subscription. We require this information in order to be compliant with the EU Money Laundering Directive and the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (§ 27 MLR17) and other regulations we are subject to.

We collect certain personal data when you subscribe for the Numbrs App. The exact personal information we collect will vary depending on the payment method (e.g. directly through your Apple ID), and may include the information below.

Lastly, we integrated the autocomplete function provided by Google into the Numbrs App, which will make the entry of your address during registration even easier.

Personal data

The Numbrs user account requires you to provide an email address and a password. Furthermore, the following data is collected in order to comply with the relevant anti-money laundering requirements:

When you create a user account, Numbrs stores the above mentioned personal data that you provide. In accordance with the legal obligations as laid down in the MLR17, Numbrs will retain the personal data for a period of six years after the end of the business relationship, notwithstanding potentially longer retention periods prescribed by the local supervisory authority or by local law. In any case, your data will never be stored for more than 10 years.

Name and address of recipient

In order to benefit from the autocomplete function in the Numbrs App, the entered search terms, your IP addresses, and your latitude/longitude coordinates will be forwarded to Google: Google Inc. (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043 (Country outside of the European Union for which no adequacy decision of the European Commission exists, but where appropriate and/or adequate safeguards were put in place (e.g. use of standard contractual clauses, 2010/87/EU and/or 2004/915/EC)).

3. The Numbrs Timeline (applicable for non-payment accounts)

Purpose

The Numbrs App also allows you to view your accounts (e.g. your credit card accounts or crypto accounts) that are not considered payment accounts under the definition of PSD2. For this purpose, Numbrs uses technical services, for example from the Financial Transaction Services Association of the German Banking Industry (FinTS).

Personal data

Transaction data (see point 4 below for the definition of this term).

Name and address of recipient

The data is not transferred to any other party.

4. Payment Initiation Services

Purpose

Through the system integrated in the Numbrs App, which is operated by PISP, the Numbrs App offers the possibility to initiate payments. You can initiate payments by giving your consent for the payment initiation and by entering the information and customer ID that your bank requires from you. The data entered for a transaction are transmitted in encrypted form to the PISP.

Personal data

In order for Numbrs to initiate the payment and display the details of the payment initiation in the Numbrs App, Numbrs records the following data (“Transaction Data”):

Name and address of recipient

The personal data is transmitted to the PISP. The data is not transferred to any other third parties.

5. Address book

Purpose

The Numbrs App allows you to initiate payments without manually entering the bank code and account number. To ease the use of the payment initiation function, Numbrs offers an address book. The address book stores a list of the user's preferred recipients. If the user wishes to use this function, Numbrs will store the necessary data. For details regarding payment initiation, see point 4 above.

Personal data

After a payment initiation, the following data will be stored in the Numbrs App address book:

Name and address of recipient

The data is not transferred to any other party.

6. Account Information Services

Purpose

The Numbrs App offers you the possibility to connect your bank accounts to the Numbrs App. This is done using your bank's online banking access data, through a system integrated in the Numbrs App, which is operated by the AISP. Your online banking access data is not stored by Numbrs.

The Numbrs App provides an overview of all transactions made with all accounts that are connected with the Numbrs App. Depending on the respective bank, it is possible that Numbrs may also display data of transactions that took place prior to registration, so that these transactions also appear in the overview.

The AISP collects your transaction data directly from your bank and then forwards it to Numbrs to display it in the Numbrs app.

Personal data

Transaction data (see point 4 above for the definition of this term).

Name and address of recipient

The personal data is transmitted to Numbrs via the AISP. The data is not transferred to any other third parties.

7. Automatic categorisation of account transactions

Purpose

The automatic categorisation function sorts users’ income and expenses into various groups such as “Food” and “Insurance”. This allocation of income and expenses enables users to optimise their finances and to gain a better overview of their financial situation.

Personal data

Name and address of recipient

The data is not transferred to any other party.

8. Loyalty Card

Purpose

Users can link a loyalty card to the Numbrs App and use the relevant barcode as a digital copy through the Numbrs App.

The data concerned will be processed for the contractually agreed purposes in order to display the corresponding barcode within the Numbrs App.

Personal data

Numbrs collects the customer card number for the purpose of providing this service.

Name and address of recipient

The data is not transferred to any other party.

9. Financial assets

Purpose

Some of the Numbrs App features, such as the “Analysis” feature, help users gain a better overview of their overall financial situation and to optimise their expenses. Users can, for instance, enter and monitor individual saving targets.

Personal data

Data you input about financial assets.

Name and address of recipient

The data is not transferred to any other party.

10. Notifications

Purpose

Users can obtain information on their financial situation (such as daily income and expenses, budget alarms, scheduled money transfers and account balance updates) through the “Notifications” function.

This function uses the Push Notifications Service from Apple Inc. respectively Google Firebase Service (see also recipients section below).

If you would like more information on how these push services work, please contact the respective provider of this function.

Depending on the operating system of the device, Numbrs sends a notification to the user via the Apple Push Notification Service or Google Firebase Service.

Users can also decide whether the notifications should be enabled and whether these notifications should contain sensitive transaction data or not. In any case, the notification is transmitted over an encrypted channel.

Personal data

Transaction data, if applicable

Name and address of recipient

Apple Inc. (“Apple”), One Infinite Loop, Cupertino, California 95014, USA respectively Google Firebase (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Country outside of the European Union for which no adequacy decision of the European Commission exists, but where appropriate and/or adequate safeguards were put in place (e.g. use of standard contractual clauses, 2010/87/EU and/or 2004/915/EC)).

11. Customer support

Purpose

Numbrs saves the exchange between you and our customer support team when you communicate with us via chat, in order to continuously improve our support services, thus giving users an improved experience when contacting us in the future.
This will allow us to support you better should you have questions in the future. You can, of course, ask us to delete this exchange at any time.
Numbrs uses Google Mail to manage the support enquiries.

Personal data

Communication between users and Numbrs
Email address
If users contact Numbrs Support Chat, only the information provided by users in their requests will be processed in addition to the App version and the version of the operating system. Our customer support team has no access to your banking data.

Name and address of recipient

Google Inc. (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043 (Country outside of the European Union for which no adequacy decision of the European Commission exists, but where appropriate and/or adequate safeguards were put in place (e.g. use of standard contractual clauses, 2010/87/EU and/or 2004/915/EC)).

12. Numbrs PayDay

As part of Numbrs PayDay, users of the Numbrs App are invited to recommend the Numbrs App to others. If you participate, we will collect the data that is necessary to process your reward. The legal basis for the data processing is the fulfilment of the contract. The provision of the required data is voluntary. If you do not provide the required data, we will not be able to provide our services.

Within the realms of Numbrs PayDay, we use the attribution tracking technologies of AppsFlyer. This technology is used to allocate the new user with your referral code. The legal basis for the processing is the fulfilment of the contract: AppsFlyer provides the necessary technical infrastructure to be able to allocate the successful referral to the respective user.

Personal data

The personal data collected and processed includes: First name, surname, address and the bank account details. Due to the requirements under the Anti-Money Laundering Regulations, our bank may request additional information about you (i.e. date of birth, address). Should this be the case, our support team will contact you to obtain the relevant information and will then forward this to the bank.

Furthermore, the Numbrs support team may request a copy of the identity card and, if applicable, the residence permit of the winner of Numbrs PayDay before the bonus is paid out. The winner's first name, place of residence and social media username may be published in the advertising media used by Numbrs. This includes the announcement of the winner on the Numbrs website, blog and social media platforms.

All data collected by Numbrs is processed in order to provide Numbrs PayDay. Numbrs stores your full name, address and the information required for a payout. We store the accounting records of the payouts, including the payout data they contain, for a period of ten years in order to comply with our legal retention obligations under Art. 958f Swiss Code of Obligations, whereby the period begins at the end of the financial year in which the accounting record was created. The legal basis for this processing is Art. 6 para. 1(c) GDPR, the fulfilment of our legal obligations.

Name and address of recipient

13. Receive information on the functionalities of the Numbrs App

Purpose

Numbrs also provides a free information service that allows you to receive email updates about the Numbrs App and related benefits and services. Numbrs uses the service provider MailChimp for the purpose of providing this service.

Personal data

Email address.

Name and address of recipient

MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA (The recipients are located in a country outside of the European Union for which no adequacy decision of the European Commission exists, but where appropriate and/or adequate safeguards were put in place (e.g. use of standard contractual clauses, 2010/87/EU and/or 2004/915/EC)).

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