We appreciate your interest in our products, our company and our handling of the information you have entrusted to us.

1. Responsible Parties and Contact Information

The responsible party with regard to data protection laws is Star Finanz-Software Entwicklung und Vertriebs GmbH, Grüner Deich 15, 20097 Hamburg, Germany.

For questions related to data protection, please contact our data protection officer at: Star Finanz-Software Entwicklung und Vertriebs GmbH, Data Protection Officer, Grüner Deich 15, 20097 Hamburg, Germany; fax +49 40 23728-350

E-mail: datenschutz(at)starfinanz.de

1.1 First-time use of the app

When launching the app for the first time, after creating a password and setting up an optional biometric identifier to unlock the app in addition to the password, you will need to enter the name or routing number/BIC of the Sparkasse or bank where you administer one or more accounts that you want to use. The bank routing number you have entered will then be sent to the Star Finanz server one time in order to connect the app to the server of the respective Sparkasse/bank.

1.2 Ongoing use of the app and its features

After this one-time logging of the bank routing number, all data traffic takes place under the responsibility of the respective primary institution, that is, the institution where you administer the account(s) that you use in relation to the app.

2. Data Privacy Policies

As a matter of principle, the software products from Star Finanz are designed to favor data privacy by default. This means, for example, that only those personal data required for the product to function are collected (per a policy of data minimization).

We assure you of the lawful and responsible handling of all data that you transmit to us as the user of our products and would like to provide you hereinafter with a transparent description of what data we process in detail, what we use it for, and whether and to what extent it is stored by us and/or transmitted to third parties..

2.1 Which sources and information we use

We process personal data only within the scope authorized by you personally. In doing so, we only collect and process the data that is absolutely necessary for the maintenance and use of the services provided to you. Prior to use and transmission of your data, all services that transmit personal information indicate the precise scope of the data and require your confirmation of transmission. All of your data belongs to you, therefore we do not pass along any of the data transmitted to us to third parties without your consent unless we are legally obliged to do so, such as when presented with a corresponding court order.

We understand personal data to include, e.g., personal particulars (name, address and other contact information, date and place of birth and nationality), credentials (e.g., ID card information) and authentication information (e.g., signature sample). This may also include order information (e.g., payment order, securities order), data from the fulfillment of our contractual obligations (e.g., sales data in payment transactions), credit limits, product information (e.g., deposit, credit and portfolio transactions), information about your financial situation (e.g., credit information, scoring/rating information, source of assets), advertising and sales information (including ad scores), documentation information (e.g., consultation records), registry information, information about your use of the telemedia we offer (e.g., time at which our websites, apps or newsletter were accessed, clicks on our pages or entries as well as other comparable data).

2.2 Rules for data processing for the fulfillment of contractual obligations

We process the personal data you transmit to us in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG) for the provision of our services within the framework of the contractual relationship.

2.3 Processing based on your consent

Insofar as you have given us your consent to the processing of personal data for specific purposes (e.g., transfer of data within the network/group, analysis of payment transaction data for marketing purposes), the legality of this processing is based on your consent. The consent you have given can be revoked at any time.

Please note that the revocation only works with future effect. Any processing that occurred before the revocation is not affected.

2.4 Data protection rights

Per the EU GDPR, you have the right to information about your stored data free of charge (Article 15 GDPR), the right of rectification (Art. 16 GDPR), the right to delete your data (Art. 17 GDPR), the right to restrict processing (Art. 18 GDPR), and the right to data portability (Art. 20 GDPR).

Should you have any questions that this data privacy policy has not been able to answer, or if you would like information about the data that is stored about you, please contact us by e-mail at the address provided under the Contact section.

In addition, you have the right of appeal to a data protection authority (Art. 77 GDPR).

3. Collection, Storage and Use of Personal Data

3.1 Feedback and support queries

When you send us feedback or a support query, or use the support form on our website, your e-mail address will be used only for correspondence with you and only for the purpose of clarifying your support case. It is not disclosed to third parties.

As part of the support you have requested, you may need to provide us with some of your personal information so that we can fulfill our contractual obligation. In these cases, prior consent from you in accordance with Article 6 of the GDPR is not required.

3.2 Branding

When contacting the datacenter via the FinTS interface, the bank routing numbers used in the app are sent to us. The data is processed immediately to determine the possible credit institutions and consequently to create/verify your app license, as well as to display the logo of the institution from the Sparkasse group or the financial institution. The data is neither stored nor transmitted to third parties. The saved data does not allow any inferences to be drawn about specific users. The data is anonymized and then used to create usage statistics for our apps.

3.3 Setup of new bank accounts

When the app launches, the routing numbers or BICs of all financial institutions that are set up in the app are sent to us. The data is processed immediately and stored anonymously in order to send you available messages from your financial institutions or about your financial institutions via the app. Furthermore, via this service the app provides us with information about the possible length and makeup of the PIN and TAN of the institutions you have set up, the corresponding URL of the datacenter for direct HBCI communication, and the fingerprints, a short hash value, of the valid SSL certificate. The saved data does not allow any inferences to be drawn about specific users. The data is anonymized and then used to create usage statistics for our apps.

3.4 App launch

If in the app settings you have agreed to the transmission of the online-banking contract ID and the account numbers of the bank connections and accounts set up in the app, this data is sent to us when the app launches. The data is processed immediately and stored anonymously in order to send you available private messages from your financial institutions or about your financial institutions via the app. The data is neither stored nor transmitted to third parties.

3.5 Sending transactions and storing SEPA information

When manually storing an account's SEPA information in the app or when sending transactions, the IBAN and BIC are sent to us for validation. If account numbers and routing numbers are specified for transactions, they are sent to us for conversion to IBAN and BIC. The data is processed immediately in order to display an appropriate message in the event of an error, or to display the data that was converted into IBAN and BIC directly in the form. The data is neither stored nor transmitted to third parties.

3.6 Using webviews

The app offers various information in what are called "webviews." These are websites that are displayed in the app. This pertains, for example, to the license terms, (these) data privacy policies, FAQs and help, version history, and, in the case of a Sparkasse institution, inbox, stock information, account alerts, and the contact form for your savings bank that are viewable in the app. When using these pages, the data that is sent by the browser when a website is visited and that is necessary to use the site is automatically recorded. These are the web query, the user's IP address, the browser type, the browser language, and the date and time of the website visit. After the end of each use, the data is saved anonymously only in order to improve the quality of the services.

3.7 "giropay | Kwitt" feature

The "giropay | Kwitt" feature allows you to transfer money to or request money from your contacts and third parties. To do so, the app identifies you as well as other contacts and registered third parties on the basis of the respective mobile phone number and then shows you, your contacts, and registered third parties who is able to transfer and receive money through this feature, provided they also use the feature, have saved you as a contact and have explicitly authorized visibility for all users of the "giropay | Kwitt" service under the app settings.

3.7.1 Validation/registration

In order to use this feature, you must register, which is a two-step process. Should you want to use the feature, you will receive an SMS with a confirmation code sent to your mobile phone number. After you have correctly entered the code you have received into the app, the functionality is made available to you.

3.7.2 Synchronizing contacts

For the first time after registration and subsequently every time the feature is invoked or at your request, the feature synchronizes contact information from your smartphone's address book provided that you authorize the app to do so and do not disable automatic synchronization under the app settings. The app then creates checksums (called hashes) from the mobile phone numbers of your contacts and your mobile phone number and sends only the checksums to the server. The service matches these checksums and then displays registered users in the app with whom you can use exchange funds via the "giropay | Kwitt" feature. The app accordingly indicates which of your contacts are also registered to use the feature; your contacts can likewise identify your use of the feature.

3.7.3 Visibility to other "giropay | Kwitt" users

Other users might be able to see that you are participating in the "giropay | Kwitt" feature if either (1) you have stored the mobile phone number of the other user in your address book and the other user has stored your mobile number in their address book, or (2) you have explicitly specified under "Settings" that you would like to be visible to other users as a user of the "giropay | Kwitt" feature. By the same token, other users are only visible to you as users of the "giropay | Kwitt" feature if either (1) you have stored the mobile phone number of the respective user in your address book and the respective user has stored your mobile phone number in their address book, or (2) the respective user has indicated under "Settings" that they want to be visible to other users as a user of the "giropay | Kwitt" feature. An exception to this is participating in groups within "giropay | Kwitt". In this case, every group participant that is registered for "giropay | Kwitt" is visible as being registered to every other registered member of the same group.

3.7.4 Sending (transferring) money

3.7.4.1 Registered contacts

The app will ask you to select a contact from your address book. You then enter an amount of money to be transferred, an optional accompanying note, and can optionally attach a photo. These data will then be transmitted. A push notification informs the contact about the initiation of the payment.

3.7.4.2 Unregistered contacts

If you transfer money to contacts who have not yet activated the "giropay | Kwitt" feature, the app also collects information you have entered about the recipient, amount, and accompanying note. Your unregistered contact will then receive a message via your selected method (e.g., SMS, e-mail) about your intended payment coupled with the request to enter the account information of the recipient by following a link to a website. If the unregistered contact follows this request and enters their data accordingly, you will receive a push notification asking you to approve the order and thus complete the payment.

3.7.5 Requesting money

3.7.5.1 Registered contacts

If you request money from a registered contact, the app also collects information you have entered about the recipient, that is, the person from whom you are requesting money, the desired amount, and an optional accompanying note; you may also optionally attach a photo. The recipient of this request then receives a push notification and can transfer money per the protocol described above.

3.7.5.2 Unregistered contacts

If you would like to request money from unregistered contacts, the "giropay | Kwitt" feature will help you to provide a third party with the requested amount and the IBAN you have registered with "giropay | Kwitt". A pre-composed note will then be provided to you in a communication app of your choice in order to ask the third party via this communication app to transfer the requested amount to you as part of this specific monetary request. In addition, the third party is offered a link to a website where they can learn more about "giropay | Kwitt".

3.7.5.3 Confirmation of remittance

Before you can send money to contacts, the name of the account holder and the IBAN of the respective recipient as the recipient has entered that information in "giropay | Kwitt" will be provided to you for confirmation. By the same token, prior to the bank transfer your name and your IBAN are shown to contacts who would like to transfer money to you.

3.7.5.4 Confirmation of money request

Before you can request money from contacts, the name of the account holder of the respective remitter will be provided to you for confirmation. By the same token, prior to the request your name is shown to contacts who would like to request money from you. Before you can request money from contacts, the name of the account holder of the respective remitter will be provided to you for confirmation. By the same token, prior to the request your name is shown to contacts who would like to request money from you.

3.8 Photo transfer to automatically complete the transfer form

If you use the app's photo transfer feature, the photo of the invoice or the bank transfer form is transmitted to the Gini GmbH servers via a secure connection and processed there. The data that pertain to the fields of the bank transfer form are transmitted anonymously back to the app via a secure connection so that the fields of the bank transfer form are filled out automatically. After you have approved your bank transfer, the bank transfer data that were used are retransmitted to the service provider in order to verify and improve the quality of the document analysis. The transmitted photo and the data are stored with the service provider for up to four weeks for the purpose of verifiability and documentation and then deleted.

We have negotiated an order processing contract with Gini GmbH, Ridlerstraße 57, 80339 Munich, Germany, for processing the data pursuant to Article 28, Paragraph 3 of the GDPR.

3.9 Identification procedure S Video legitimation when opening an account

As part of the process of opening an account with a Sparkasse for the first time, S video legitimation is carried out for your identification. This process is operated by S-Markt & Mehrwert GmbH & Co. KG, Grenzstrasse 21, 06112 Halle. For this purpose, your personal data collected during the opening process and required for the identification process will be transmitted to S-Markt & Mehrwert GmbH & Co. KG. You can obtain detailed information on the processed personal data from the privacy policy of S-Markt & Mehrwert GmbH & Co. KG, which is made available to you during the process.

4. Collection, storage and use of non-personal data

4.1 App launch

When the app launches, the routing numbers or BICs of all financial institutions that are set up in the app are sent to us. The data is processed immediately and stored anonymously in order to send you available messages from your financial institutions or about your financial institutions via the app. Furthermore, via this service the app provides us with information about the possible length and makeup of the PINs and TANs of the institutions you have set up, the corresponding URL of the datacenter for direct HBCI communication, and the fingerprints of the valid SSL certificate. The saved data does not allow any inferences to be drawn about specific users. The data is anonymized and then used to create usage statistics for our apps.

4.2 App crashes

In the event of an app crash, it can manually or automatically send information to us about the features that had just been invoked provided you agree to do so. This information will allow us to respond more quickly to any problems that might occur and therefore offer you an improved version of the app more quickly through the app stores. The data transmitted in this event does not allow any inferences to be drawn about specific users.

5. Permissions Requested by the App and Their Use

Before you convey any information or permissions, you must allow this via your device. You can revoke this permission in the app settings.

5.1 Camera & photos

Photos can be taken or uploaded in order to attach photos to transactions or for use in connection with the "giropay | Kwitt" feature or photo transfer feature to automatically complete the transfer form. Photos are taken to read QR codes, for example, during GiroCode transfers or the push-notification registration for account alerts.

5.2 Mobile data

If there is no WiFi connection, the app uses the mobile data connection – for example, when using banking functions such as an account refresh or a bank transfer, viewing webviews, or searching for branches and ATMs.

5.3 Address book

The mobile phone number is used for synchronization as part of the "giropay | Kwitt" feature.

5.4 Bluetooth

Bluetooth is used for contacting customers at Sparkasse branches and ATMs.

5.5 Notifications

Features such as "giropay | Kwitt", account alerts or customer communication via Bluetooth in branches, at Sparkasse ATMs as well as for offers and services at your current location make use of the option to send you push notifications. The account alert feature also uses the name of your device so that you are able to use this to set up the alerts accordingly.

5.6 Location

The branch and ATM search feature requires your current location in order to show you nearby branches and ATMs.

5.7 Location-based customer communication

The app can provide you with special offers and services that are tailored to your current location via location-based customer communication. In doing so, we highlight both our own offers as well as offers from partners and third parties. If and when location-based services are available, they can determine the approximate location of your receiving device. Along with Bluetooth, we also use GPS and WiFi localization. To send location-based messages, it is also technically necessary to process your IP address.

You can only use these features after you have agreed that we may collect your location data and your IP address for the purposes of providing the service. You can enable or revoke this feature in the app settings at any time.

5.8 Other applications

We use Google Firebase for push notifications. HockeyApp is used to send us crash reports in order to improve the app. In both cases neither tracking nor transfer of personal data takes place.

The Radius Networks tool is used only to transmit location-based information as it relates to the use of beacons; this information does not allow the user to be personally identified. The user of the app can disable the use of this tool.

5.9 Google Analytics

This app uses Google Analytics for Mobile Applications, an analytics service of Google, Inc. ("Google"). We use an SDK (software development kit) to establish metrics that are stored in your app and that allow the analysis of your use of the app. This helps us to determine the type of usage and the number of users of our app, as well as to make our products and services as convenient and efficient as possible for you. The information obtained is transmitted to a Google server in the USA and stored there. Google uses this information to evaluate your use of the app, to compile reports on usage activity for Star Finanz, and to perform other services related to the usage of the app. Google also transfers this information to third parties if required by law or if third parties process this data on Google's behalf. To provide you with the best possible data protection, the data that is transmitted to Google is anonymized. You can prevent Google Analytics from collecting data by deactivating the switch under Settings > App functions > Improve app.

6. Data Protection

6.1 Technical safeguards

6.1.1 Star Finanz servers

All the servers we use are configured and installed in-house and operated in high-security datacenters in Germany. The hardware used is supplied by certified well-known manufacturers and is designed to be failsafe and redundant. The transport and installation of the servers to the datacenters is carried out by our own employees, not by subcontractors, logistics companies, or other third parties. We categorically do not store any data on other servers, especially not abroad.

We affirm that all security technologies we use are state-of-the-art and are continuously updated. Our security concepts are constantly being adapted to new findings and renewed to protect your data from theft and misuse. We handle all data that is transmitted to us responsibly and process said data according to all legal provisions on data protection, in particular the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG), and using the highest security standards for data processing and storage.

6.1.2 Data transfer

Your data is transferred exclusively via SSL-encrypted connections from your terminal device to our servers operated in high-security datacenters in Germany. During this process, the certificates are checked for validity and, if technically possible on the given platform, the fingerprints of the certificate are additionally verified in order to prevent misuse and man-in-the-middle attacks to the greatest possible extent.

Data transfer to third countries (countries outside the European Economic Area, or EEA) only takes place if it is required for the execution of your orders or by law, or if you have given us your consent. Insofar as it required by law, we will inform you of details separately.

6.1.3 Data processing, length of storage and deletion

Your data is processed and stored on servers that belong to Star Finanz-Software Entwicklung und Vertriebs GmbH in Germany and protected by us through comprehensive technical and organizational safeguards against access by third parties.

Where necessary, we process and store your personal data for the duration of our business relationship, which includes, for example, the initiation and execution of a contract. The data is then deleted afterwards.

In addition, we are subject to various filing and documentation obligations, which result, inter alia, from the German Commercial Code (HGB) and the German Tax Code (AO). The periods stated therein for storage or documentation are two to ten years, respectively.

Finally, the storage period is also assessed according to the statutory limitation periods, which can be up to thirty years, for example, according to §§ 195 et seqq. of the German Civil Code (Bürgerliches Gesetzbuch, BGB), for which the regular period of limitation is three years.

After the storage period expires, the data is routinely deleted.

6.2 Organizational safeguards

Within Star Finanz, only internal employees who are involved in the execution and fulfillment of the respective information processes have access to data. Through encryption and anonymization, even with physical access to the systems, the data cannot be read or assigned to particular users via different systems.

6.3 Use of external services

The use of third-party backup services shall be governed by the respective third party's own data protection policies, the content and compliance of which is beyond our control.

6.4 No disclosure to third parties

Data will be passed on to third parties without your consent only when we are legally obliged to do so, for example, in the event of a corresponding judicial decision.

Updated: February 2022