Privacy Policy

Imprint (Angaben gemäß § 5 TMG)

Pandata GmbH
Köpenicker Str. 126, 10179 Berlin, Germany
Managing Directors: Marco Szeidenleder, Wolfgang Bernecker, Krisztina Kodó
Tel.: +49 030 555723270
Email: info@pandata.de
Amtsgericht Charlottenburg, HRB 176198

The full legal notice is available at pandaos.ai/impressum.

1. Introduction

In the following, we provide information about the collection of personal data when using our website https://pandata.de and our profiles in social media.

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Pandata GmbH, Köpenicker Str. 126, 10179 Berlin, Germany, email: info@pandata.de. We are legally represented by Wolfgang Bernecker, Marco Szeidenleder and Krisztina Kodó.

Our data protection officer is heyData GmbH, Gormannstr. 14, 10119 Berlin, www.heydata.eu, e-mail: info@heydata.de.

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

• Art. 6 para. 1 s. 1 lit. a GDPR — serves as our legal basis for processing operations for which we obtain consent.
• Art. 6 para. 1 s. 1 lit. b GDPR — is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
• Art. 6 para. 1 s. 1 lit. c GDPR — applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
• Art. 6 para. 1 s. 1 lit. f GDPR — serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Canada and Israel) (Art. 45 para. 3 GDPR).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

The transfer of data to third parties in the United Kingdom of Great Britain and Northern Ireland is currently based on the transitional arrangement in the trade and cooperation agreement between the European Union and the United Kingdom.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

• Right of access
• Right to correction or deletion
• Right to limit processing
• Right to object to the processing
• Right to data transferability
• Right to revoke a given consent at any time

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Data processing on our website

2.1. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status / HTTP status code
• Amount of data transferred in each case
• Website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

2.2. Web hosting and provision of the website

Our website is hosted by Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA (Privacy Policy). The provider processes the personal data transmitted via the website, in particular the server log data listed in section 2.1, in order to deliver the site. Vercel acts as a processor on our behalf under Art. 28 GDPR. The legal basis is our legitimate interest in providing a website, in accordance with Art. 6(1) sentence 1 lit. f GDPR.

International transfers: Vercel is established in the USA, so personal data is transferred to a third country. Transfers are governed by the EU standard contractual clauses concluded with the provider.

2.3. Vacant positions

We publish positions that are vacant in our company on our website, on pages linked to the website or on third-party websites.

The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. 1 GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act (Bundesdatenschutzgesetz). We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application. Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 s. 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR.

We pass on the applicants' data to the responsible employees in the HR department, to our data processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receiving the application.

2.4. Cookies, consent management and tag management

Our website uses Google Tag Manager (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). Tag Manager is itself a management tool that sets no analytics or advertising cookies of its own. It loads the services described in sections 2.5 to 2.7 in accordance with the consent choice you make.

When you first visit the site, a consent banner is displayed. No analytics or advertising cookies are set, and no data is transmitted to the services in sections 2.5 to 2.7, before you have made a choice. Google Consent Mode v2 is set to “denied” by default for all non-essential categories.

Your choice is stored in a cookie named pdos_consent (first-party, path “/”, SameSite=Lax, lifetime 180 days). It records two categories:

Strictly necessary cookies are used regardless of consent. These are limited to what is required to operate the site and to keep you signed in (session and authentication cookies set by Supabase Auth, the consent cookie itself, and the bot-protection token described below). The legal basis is Section 25(2) no. 2 TTDSG and Art. 6(1)(f) GDPR.

Withdrawing consent: you can change or withdraw your choice at any time by deleting the pdos_consent cookie in your browser, which causes the banner to be shown again on your next visit, or by writing to the contact address in section 1.1. Withdrawal does not affect the lawfulness of processing carried out before it.

Bot protection: forms on this site (waitlist, sign-up, contact) are protected by Cloudflare Turnstile (Cloudflare, Inc.). Turnstile processes your IP address and browser characteristics to distinguish humans from automated requests, and sets a temporary token for that purpose. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in protecting our forms against abuse).

Legal basis for non-essential cookies: Section 25(1) TTDSG in conjunction with Art. 6(1)(a) GDPR (consent).

2.5. Web analytics: Google Analytics 4

Subject to your consent, we use Google Analytics 4 (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), to understand how our website is used and which pages and campaigns lead to sign-ups.

Data processed: a randomly generated device identifier (user_pseudo_id) stored in cookies beginning with _ga, truncated IP address, pages viewed and time of access, referrer and campaign parameters (utm_source, utm_medium, utm_campaign, gclid), approximate location derived from the IP address at country and city level, device, browser and operating system, and interactions with the site such as registrations, downloads and purchases.

Linking to your user account: once you have registered or signed in, we transmit your PandaOS user ID (the identifier assigned by our authentication system) to Google Analytics in the “user_id” field. This allows us to recognise that visits from different devices or browsers belong to the same account, so that our reporting counts people rather than browsers. We do not transmit your email address, your name or any other directly identifying data to Google Analytics.

IP anonymisation: Google Analytics 4 truncates IP addresses before storage. Your full IP address is not stored by Google Analytics.

International transfers: Google Ireland Limited is the contracting party, but data may be transmitted to Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework; transfers additionally rely on the EU standard contractual clauses. Further information is available in Google's privacy policy.

Retention period: event and user-level data are retained for 14 months and then deleted automatically. Aggregated reports are not subject to this limit.

Legal basis: Art. 6(1)(a) GDPR and Section 25(1) TTDSG (consent). You can withdraw it as described in section 2.4.

2.6. Product analytics: PostHog

Subject to your consent, we use PostHog (PostHog, Inc.) as a product analytics service to understand how visitors move through our website and our sign-up and purchase flows. We use PostHog's European infrastructure; data is stored on servers in the European Union (eu.i.posthog.com) and is not stored in the USA.

First-party delivery: requests to PostHog are routed through a subdomain path of our own website (“/ingest”) rather than being sent directly from your browser to PostHog. This is done so that measurement is not silently broken by content blockers. It does not change what is collected, who receives it, or your ability to refuse it via the consent banner.

Data processed: a pseudonymous identifier stored in a first-party cookie, page views and page-leave events, the campaign parameters of the visit on which you first arrived (initial utm_source, utm_medium, utm_campaign and gclid), referrer, browser, operating system, device type, approximate location derived from the IP address at country and city level, and automatically recorded interactions with page elements such as clicks on buttons and links (“autocapture”). The text content of form fields is not recorded.

No session recording: session replay is disabled. We do not record your screen, your mouse movements or your keystrokes.

In the signed-in area we additionally record your progress through the subscription and credit-purchase flows and the associated metadata (plan status, selected package, price and currency).

Linking to your user account and to the desktop application: once you have registered or signed in, we set your PandaOS user ID as the identifier of the PostHog profile and store your email address as an attribute of that profile. The PandaOS desktop application uses the same identifier. As a result, your use of this website and your use of the desktop application are combined into a single profile. We do this in order to understand the path from the website to the installed product. If you do not consent to analytics, no profile is created and no such combination takes place. When you sign out, the identifier is reset in your browser.

Data processor role: PostHog processes the data described above solely on our behalf and on our instructions, as a processor within the meaning of Art. 28 GDPR.

International transfers: data is stored in the European Union. PostHog, Inc. is established in the USA, so access by the parent company for support and maintenance purposes cannot be excluded; such access is governed by the EU standard contractual clauses. Further information is available in PostHog's privacy policy.

Legal basis: Art. 6(1)(a) GDPR and Section 25(1) TTDSG (consent). You can withdraw it as described in section 2.4.

2.7. Advertising and conversion measurement

Subject to your consent to the “Advertising” category, our website loads measurement pixels operated by the advertising platforms on which we run campaigns. Their purpose is to measure which advertisements lead to a waitlist entry, a sign-up or a purchase, and to allow us to address visitors again on those platforms (remarketing) and to build audiences of comparable users.

Data processed: the fact that you visited a specific page or triggered a specific action (waitlist entry, sign-up, completion of onboarding, download of the application, purchase), your IP address, browser and device data, and the identifiers stored by the respective platform in its own cookies. Where you are simultaneously logged in to the relevant platform, that platform can assign the visit to your account there.

Joint controllership and transfers: for the collection and transmission of data through these pixels we and the respective provider act as joint controllers within the meaning of Art. 26 GDPR. The subsequent processing by the provider is carried out under its sole responsibility and in accordance with its own privacy policy, and we have no influence over it. All four providers are affiliated with US parent companies, so a transfer of data to the USA cannot be excluded; such transfers are based on the EU-US Data Privacy Framework and, in addition, the EU standard contractual clauses.

Legal basis: Art. 6(1)(a) GDPR and Section 25(1) TTDSG (consent). These pixels are not loaded at all unless you accept the “Advertising” category, and you can withdraw your consent as described in section 2.4.

3. Data processing for training and events

To participate in events, we process the data required for the respective event, namely the name and e-mail address of the participants.

The legal basis of the processing is Art. 6 para. 1 s. 1 lit. b, as the processing is necessary for the performance of the participation contracts.

Participants have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for the purpose of sending an email about further event announcements. Registration takes place by selecting the appropriate field on our website, by ticking the appropriate field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Consent can be withdrawn at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. In the event of the withdrawal, the lawfulness of the data processing remains lawful until the moment of withdrawal.

4. Data processing on social media platforms

We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

4.1. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.

7. Data processing in the PandaOS desktop application

7.1. Overview

PandaOS is a native desktop application that runs locally on the user's device. User content — including files, code, messages and knowledge base entries — created or stored by the user within PandaOS remains on the user's local device and is not collected, transmitted or processed by Pandata.

The data processing described below relates exclusively to operational and metadata required for authentication, operation of the application and product improvement.

7.2. Authentication

Use of PandaOS requires the creation of a user account. Authentication is handled via Supabase Auth using the following sign-in methods:

• Google (OAuth 2.0)
• GitHub (OAuth 2.0)
• Microsoft Azure AD (OAuth 2.0)
• Email (magic link / one-time password)

The following data is processed and stored: user ID, email address, authentication provider and last sign-in timestamp.

Retention period: Authentication data is stored for as long as the user account exists. Upon account deletion, the data is deleted without undue delay.

Third-country transfers: When using external authentication providers (e.g. Google, GitHub or Microsoft), personal data may be transferred to third countries, in particular the United States. Further information on data processing can be found in the respective provider's privacy policy.

Legal basis: Art. 6(1)(b) GDPR (performance of a contract).

7.3. Usage analytics

PandaOS collects pseudonymised usage events for the purpose of product improvement. Only metadata is collected: message content, source code, file contents or user-generated text is never collected.

Recorded are the opening of the application and its version, the starting of chats and the sending of messages together with the model used, the creation and deletion of projects together with the framework type, the enabling and disabling of integrations, and changes to settings. In each case only the fact of the action and the metadata named here are recorded, never the content.

Data is stored in a Supabase database and linked to the authenticated user ID. The same events are additionally transmitted to the product analytics service PostHog, under the same user ID; see sections 7.6 and 2.6.

Opt-out: Users can disable usage analytics entirely via a toggle in Settings.

Retention period: Usage analytics are stored for a maximum of 12 months and subsequently deleted or anonymised.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the improvement and further development of the application).

7.4. LLM request logging

AI requests are routed through a self-hosted LiteLLM proxy. The following data is logged:

Collected: Model name, token count (input/output), latency and status codes, timestamp and user ID.

Not collected: Prompt content, response content, any message text.

Purpose: Cost accounting, rate limiting and model usage analytics.

Retention period: LLM logs are stored for a maximum of 90 days and subsequently deleted.

Legal basis: Art. 6(1)(b) GDPR (performance of a contract) and Art. 6(1)(f) GDPR (legitimate interest in operation and cost management).

7.5. Third-party AI providers

AI requests are transmitted via Pandata's infrastructure to the AI provider selected by the user (e.g. Anthropic, OpenAI, Google, Fireworks AI, Together AI). The further processing of transmitted content is carried out by the respective provider under its own responsibility. Pandata does not process the content itself but merely provides the technical relay.

Data processing by these providers is governed by their own privacy policies and terms of service. The user is solely responsible for the selection and configuration of AI providers.

7.6. Third-party analytics in the desktop application

The desktop application transmits the usage events described in section 7.3 to PostHog, a product analytics service, in addition to storing them in our own database. The identifier used is your PandaOS user ID, which is the same identifier used on our website (section 2.6), so that use of the website and use of the application form a single profile. Details of the provider, the European storage location and the data processing agreement are set out in section 2.6.

Within the desktop application we do not use advertising trackers, device fingerprinting or cross-site tracking, and no advertising pixels are loaded. The application contains no advertising.

On our website we do use Google Analytics 4 and the advertising pixels of Meta, LinkedIn, Reddit and X, in each case only with your consent. These are described in sections 2.5 and 2.7 and are entirely separate from the application.

All other first-party data is stored on infrastructure operated by Pandata (Supabase, LiteLLM proxy).

Opt-out: transmission to PostHog from the desktop application is disabled together with usage analytics, via the toggle in Settings described in section 7.3.

7.7. Data explicitly not collected

The following data is not collected by PandaOS:

• Message or prompt content
• Source code or file contents
• Project names or file paths
• Browsing history
• Device fingerprinting
• Precise location data

Data is not sold or shared with third parties.

7.8. Storage and infrastructure

All data collected by PandaOS (authentication, usage events, LLM logs) is stored on infrastructure operated by Pandata (Supabase). Processing takes place within the EEA unless otherwise specified in Section 1.3 of this privacy policy.

7.9. Third-party integrations — Google Workspace

PandaOS allows users to connect their Google account to access Gmail and Google Contacts directly within the application. This connection is established via Google OAuth 2.0 and requires the user's explicit consent through the Google consent screen.

Scopes requested:

Data handling:

• Email content and contact data retrieved via these scopes are processed locally within the PandaOS application and are used solely to display information to the user or to perform actions explicitly initiated by the user (e.g. sending, archiving or starring an email).
• Pandata does not store, retain, cache or log any email content, email metadata, contact names or contact details on its servers.
• Google Workspace data is not transmitted to any third party, including AI providers, unless the user explicitly includes such content in an AI prompt. In that case, Section 7.5 (Third-party AI providers) applies to the transmitted content.

Revocation:

Users can revoke PandaOS's access to their Google account at any time via their Google Account settings (Security > Third-party apps with account access) or by disconnecting the integration within PandaOS Settings.

Legal basis: Art. 6(1)(a) GDPR (consent, granted via the Google OAuth consent screen).

7.10. Data protection and security measures

Encryption in transit:

All data transmitted between the PandaOS desktop application and Pandata's servers is encrypted using TLS 1.2 or higher (HTTPS). This applies to authentication requests, usage analytics, LLM proxy communication and third-party integration traffic.

Encryption at rest:

Personal data stored in the Supabase database (authentication records, usage events, LLM logs) is encrypted at rest using AES-256 encryption provided by the underlying cloud infrastructure.

Access controls:

Access to production databases and infrastructure is restricted to authorised Pandata personnel on a need-to-know basis. Administrative access requires multi-factor authentication.

Separation of data categories:

User content (files, code, messages) is processed and stored exclusively on the user's local device and never reaches Pandata's infrastructure. Operational metadata (authentication, analytics, LLM logs) is stored separately from any third-party integration data.

Incident response:

In the event of a personal data breach, Pandata will notify the competent supervisory authority within 72 hours in accordance with Art. 33 GDPR, and affected users without undue delay where required under Art. 34 GDPR.

Sub-processors:

Third-country transfers to AI providers (Anthropic, OpenAI, Google, Fireworks AI, Together AI) occur only when the user actively sends an AI request and are governed by each provider's own data protection measures (see Section 7.5).

7.11. AI/ML model training disclosure

Google Workspace user data obtained through Gmail or Contacts APIs is not used by Pandata to develop, improve or train generalised or non-personalised artificial intelligence or machine learning models. This data is processed solely for the purpose of providing the integration functionality to the user as described in Section 7.9.

7.12. Support chat — Intercom

PandaOS uses Intercom (Intercom R&D Unlimited Company / Intercom Inc.) to provide in-app support chat, the Fin AI agent, and product communications.

Data shared: account identifier, email address, name, account creation date, subscription/plan status, and the content of support conversations. Intercom's Messenger also collects device and usage metadata (IP address, browser/app version, session data) automatically.

Purpose and legal basis: customer support is processed on the basis of the performance of a contract or legitimate interest (Art. 6(1)(b)/(f) GDPR). Product communications (e.g. in-app messages, email notifications) are sent on the basis of consent (Art. 6(1)(a) GDPR); consent can be withdrawn at any time by unsubscribing or contacting us.

Data processor role: Intercom acts as a data processor / sub-processor under a Data Processing Addendum (DPA) signed with Pandata.

International transfers: Intercom is a US-affiliated company. Any transfer of personal data to Intercom infrastructure outside the EEA is governed by Standard Contractual Clauses (SCCs) in accordance with Art. 46(2)(c) GDPR.

Cookies and local storage: Intercom's Messenger sets cookies and uses browser local storage to maintain chat sessions and user identity. This is reflected in Pandata's cookie/consent notice. The Messenger is initialised only after the user has granted consent.

Retention: Support conversation data is retained for as long as the user account is active. Upon account deletion, the corresponding Intercom contact and conversation data is deleted without undue delay.

Data subject rights: Users can request access to or deletion of their support data by contacting info@pandata.de.

7.13. Payment processing: Stripe

Paid PandaOS subscriptions and usage top-ups are processed by Stripe Payments Europe, Ltd. (1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland) and its affiliates (“Stripe”).

Payment data is not processed by Pandata. Checkout takes place on a payment page hosted by Stripe. Card numbers, bank details and other payment credentials are entered directly into Stripe's systems and are never transmitted to, stored on or accessible from Pandata's infrastructure.

Data categories processed:

• Identification and contact data: name, email address, and the PandaOS user ID used to match a payment to an account
• Billing address and country, which also determine the applicable VAT rate
• Payment data: payment method type, the last four digits and expiry of a card, and Stripe's own customer, subscription and payment identifiers. Full card numbers are held by Stripe and are not disclosed to Pandata.
• Transaction data: amount, currency, tax, subscription plan, billing period, payment status, refunds and chargebacks
• Invoice data, and the VAT identification number where a business customer provides one
• Technical and fraud-prevention data collected by Stripe on its own checkout pages, including IP address, device and browser information

Purposes: concluding and performing the subscription contract, taking payment, recurring billing and renewal, issuing invoices and credit notes, processing refunds and cancellations, calculating and remitting VAT, fraud prevention, and compliance with statutory accounting and tax retention duties.

Legal bases: Art. 6(1)(b) GDPR (performance of the contract you enter into when you subscribe); Art. 6(1)(c) GDPR (compliance with legal obligations under tax and commercial law, in particular § 147 AO and § 257 HGB); and Art. 6(1)(f) GDPR (legitimate interest in preventing payment fraud and chargeback abuse).

Role of the parties: Stripe acts in part as a processor on Pandata's behalf under a Data Processing Agreement, and in part as an independent controller for its own purposes, in particular fraud prevention and compliance with the financial-services obligations that apply to it. Stripe's own privacy policy is available at stripe.com/privacy.

International transfers: the contracting entity is established in Ireland and processing takes place primarily within the EEA. Where Stripe transfers personal data to affiliates outside the EEA, in particular in the United States, the transfer is governed by Standard Contractual Clauses in accordance with Art. 46(2)(c) GDPR.

Customer Portal: subscriptions are managed, cancelled and invoiced through the Stripe Customer Portal. Opening the portal transmits the Stripe customer identifier associated with your account to Stripe.

[PLACEHOLDER: retention periods to be confirmed by counsel]
Suggested wording, subject to confirmation: invoices, booking records and the transaction data underlying them are retained for ten years in accordance with § 147(3) AO and § 257(4) HGB. Subscription and customer records that are not subject to a statutory retention duty are deleted without undue delay after the subscription ends and any limitation period for claims has expired. Confirm both periods against how Pandata actually keeps its books before publishing.