Terms.
Fairly set out.

This English translation is provided for convenience only. The German version is legally binding; in the event of any discrepancy, the German version prevails. Read the German version

§ 1 Scope, provider

(1) These General Terms and Conditions (Terms) apply to all contracts for the use of the software platform “Finaure” (hereinafter the “Platform”) between JSLM Products & Services GmbH, Thurn-und-Taxis-Platz 6, 60313 Frankfurt am Main, registered office: Alt-Schwanheim 36, 60529 Frankfurt am Main, entered in the commercial register of the Local Court (Amtsgericht) of Frankfurt am Main under HRB 92798 (hereinafter the “Provider”), and its customers. The Finaure software is developed by the Provider; the customer’s sole contractual partner is the Provider.

(2) Customers may be consumers within the meaning of § 13 of the German Civil Code (BGB) and entrepreneurs within the meaning of § 14 BGB. Provisions that apply only to consumers or only to entrepreneurs are identified as such.

(3) Deviating, conflicting or supplementary terms and conditions of the customer do not become part of the contract, even if the Provider does not expressly object to them.

(4) The language of the contract is German. The user interface is available in other languages; the German version of these Terms is authoritative.

(5) These Terms, including Annexes 1 to 5, form part of the contract. The privacy policy for the Platform provides information on the processing of personal data; it does not form part of the contract.

§ 2 Subject matter of the services

(1) The Provider makes the Platform available to the customer via the internet as web-based software (software as a service) for the self-directed management of the customer’s own wealth, in particular for mapping wealth and company structures, connecting bank accounts, managing documents with AI-assisted analysis, evaluations and reports, and handing over receipts to the customer’s adviser. The functions are described in detail in Annex 1.

(2) The Platform is provided on servers operated by the Provider or its sub-processors. The Provider is not obliged to supply the software for installation at the customer’s premises.

(3) The Platform does not calculate taxes and does not reflect the tax rules of any country. Country-specific notes (for example on caps on rental deposits, notice periods or lists of recoverable service charges) are non-binding guidance based on publicly accessible legal sources as at the date stated in each case; they do not replace review by an adviser admitted in the country concerned. Outside Germany, wealth projections are shown exclusively without taxes (gross). Suggestions made by the Platform for recording securities account transactions and scenario simulations at asset class level are made exclusively at the customer’s request and without reference to individual financial instruments; they do not constitute investment advice.

(4) The Provider does not provide financial services, investment, tax or legal advice, and does not keep books for the customer. Key figures, projections, account suggestions, categorisations and AI outputs are computational or automated processing of the customer’s data and are not a recommendation to buy, sell or hold assets. Receipt exports for the adviser are working aids; responsibility for bookkeeping, tax returns and retention obligations remains with the customer and the customer’s advisers.

(5) The Provider continuously develops the Platform. For consumers, the Provider supplies the updates, including security updates, required to maintain conformity with the contract in accordance with §§ 327f et seq. BGB. Changes to the scope of services are governed by § 18.

§ 3 Registration, conclusion of contract, trial period

(1) Use requires registration. The customer is obliged to provide truthful and complete information on registration and to keep it up to date. The email address is verified before the account is activated; to protect against automated registrations, the Provider uses bot protection. Country-specific format checks (for example for postcodes) are merely plausibility notices.

(2) The presentation of the Platform and of the prices on the website does not constitute a binding offer. By completing registration, the customer submits an offer to conclude a contract of use; the contract is concluded when access is activated. The customer receives a confirmation by email. These Terms can be accessed at any time at finaure.eu/en/terms and can be saved and printed.

(3) Trial period: New customers can try the Platform free of charge for 14 days with the full range of functions. On registration, the customer selects a licence tier and a billing period and completes the order using the button “zahlungspflichtig bestellen” (order with obligation to pay). No charges are incurred for the first 14 days.

(4) If the customer does not cancel before the end of the trial period, the contract automatically continues as the selected paid subscription; the first charge is made on the 15th day. Cancellation during the trial period is possible at any time free of charge using the “Vertrag kündigen” (cancel contract) button in the Platform.

(5) Consumers have a right of withdrawal (§ 17, Annex 5).

§ 4 Users, roles, access credentials

(1) The customer is the owner of its tenant and may invite further users and assign them roles per entity, in particular Admin, Manager, Assistant, Member, Adviser and Trusted Person. The scope and visibility of the roles are enforced on the server side. The customer remains the sole contractual partner, is responsible for selecting its users and assigning rights, and is responsible for the conduct of its users as for its own.

(2) Access credentials must be kept secret and protected against access by third parties. The Platform offers two-factor authentication (TOTP); the customer can make it mandatory for its tenant. Money movements and administrative actions require authentication with a second factor. If misuse is suspected, the customer must inform the Provider without undue delay and block the affected access.

(3) The customer may share individual tasks, data rooms or reports with external parties (e.g. adviser, notary, family) via time-limited, revocable links. The choice of recipients is the customer’s responsibility.

(4) A trusted person nominated by the customer may be granted emergency access in accordance with the rules set out in the Platform. The customer decides on the nomination and the scope.

(5) Support access to the tenant by the Provider’s staff takes place only insofar as it is necessary to provide the services; it is logged and displayed to the owner in the Platform. The Provider has no access to the customer’s payments or bank connections.

§ 5 AI functions

(1) The Platform contains AI-assisted functions, in particular the analysis of uploaded documents and images (SmartUpload), an assistant for questions about the customer’s own data (SmartAssist), help with setup (SmartGuide) and the structuring of support requests. The customer is informed in the user interface when interacting with an AI system; AI-generated exports are labelled as such.

(2) AI results are suggestions. They may be incomplete or incorrect and are only adopted after review and confirmation by the customer. For document uploads, a manual entry route without AI is available. SmartAssist can only be used after the express consent of the respective user and can be deactivated at any time.

(3) For AI processing, the Provider uses the Anthropic Claude API as a sub-processor. Under the contract with Anthropic applicable from time to time, content is not stored after processing and is not used to train AI models (currently: Zero Data Retention). For each function, the Provider transmits only the data required and pseudonymises it where possible. Details are set out in the privacy policy for the Platform.

(4) Value indications for assets displayed by the AI are non-binding, automatically generated estimates without reference to current market data. They do not constitute a valuation, an expert opinion or investment, insurance or tax advice; for purposes of insurance, taxation, succession or disposal, the customer must obtain an expert valuation.

(5) The Provider is entitled to detect, by technical means, automated use of the Platform without its consent (for example by bots or AI agents) and to terminate the sessions concerned. Only signals that contain no user content are used for this purpose.

§ 6 Bank connection and payment runs

(1) Bank accounts are connected via finAPI GmbH, Munich, an account information service supervised by BaFin. Authorisation, including strong customer authentication, takes place directly between the customer, finAPI and the customer’s bank; the Provider at no time receives or stores online banking credentials. The terms of finAPI, which the customer accepts during the connection process, may additionally apply to the use of the account information service.

(2) The availability, completeness and timeliness of the account information transmitted depend on the respective bank and on finAPI. The Provider gives no warranty in this respect unless the cause lies within its area of responsibility.

(3) Payment runs are prepared in the Platform and approved in accordance with the approval procedure set up by the customer (four-eyes principle, approval limits, authentication with a second factor). A payment order is executed exclusively in the authorisation procedure of the customer’s bank; the Provider does not itself execute any payments.

§ 7 Prices, licence tiers, payment

(1) The fees are set out in the price list (Annex 2). All licence tiers include the full range of functions; the licence tier depends solely on the customer’s gross assets.

(2) Gross assets are the sum of the values of all of the tenant’s assets recorded in the Platform, without deduction of liabilities.

(3) If the gross assets recorded in the Platform exceed the upper limit of the booked licence tier by more than 10% (buffer), the Platform notifies the customer and offers a change to the appropriate licence tier. The higher fee is charged only after express confirmation by the customer. Until confirmation, no new assets can be created; all existing data and functions remain fully usable. If the gross assets fall below 90% of the upper limit again, the notice is withdrawn. A paid licence tier is not downgraded automatically; if the gross assets fall permanently below the limit of a lower tier, the customer may change tier with effect from the next billing period.

(4) The fees are payable in advance for each billing period (monthly or annually). Billing is carried out via the billing service provider Fynn; the available payment methods are displayed during the ordering process. Invoices are provided electronically.

(5) For consumers, the prices stated are final prices including statutory VAT. For entrepreneurs, the prices are exclusive of statutory VAT.

(6) If the customer is in default of payment, the Provider may block access after prior notice in text form and after setting a grace period of at least 14 days. The customer’s data is retained during the block. Further statutory rights remain unaffected.

(7) For entrepreneurs, the Provider may adjust the fees with six weeks’ notice with effect from the start of a new billing period; in this case the customer may terminate with effect from the date on which the adjustment takes effect. For consumers, price changes only take effect with their express consent.

§ 8 Obligations of the customer, prohibited use

(1) The customer uses the Platform only within the scope of the applicable laws and these Terms. The customer ensures that it uploads and processes data and documents of third parties (e.g. of tenants, employees or contractual partners) only insofar as it is entitled to do so.

(2) Files may be uploaded in PDF, JPG and PNG formats. The customer does not upload any content that contains malware or infringes the rights of third parties.

(3) The following in particular are prohibited: automated use of the Platform (bots, scraping, AI agents) without the Provider’s consent, circumventing or interfering with security measures, overloading the systems, attempting to access other customers’ data, and decompiling or modifying the software unless this is mandatorily permitted under § 69e of the German Copyright Act (UrhG).

(4) Images from uploaded property brochures (exposés) are adopted only upon the customer’s express selection and are stored exclusively for the customer’s own, non-public use within the Platform. Rights of third parties (e.g. of estate agents or photographers) remain unaffected; the customer indemnifies the Provider against third-party claims based on an infringement of rights for which the customer is responsible.

(5) If the customer materially breaches these obligations, the Provider may temporarily block access, as a rule after a prior warning; in the case of serious breaches or a threat to the security of the Platform, also without a warning. The right to terminate for cause (§ 14 (3)) remains unaffected.

(6) The Provider backs up the Platform’s data regularly. The customer is advised to additionally back up important data itself using the export functions.

§ 9 Rights of use

(1) For the term of the contract, the customer receives the simple (non-exclusive), non-transferable and non-sublicensable right to use the Platform within the scope of these Terms and to enable its users to do so.

(2) All rights to the data and documents uploaded by the customer remain with the customer. The Provider receives only those rights therein that are necessary to provide the contractual services.

(3) The rights to the software are held by the Provider as developer.

§ 10 Availability and support

(1) The Provider makes the Platform available with an availability of 98.5% on a monthly average. Not included are announced maintenance windows, which are scheduled as far as possible at times of low usage, and disruptions outside the Provider’s sphere of influence, in particular disruptions of the internet, the banks or the account information service, and force majeure.

(2) The customer receives support by email at info@finaure.eu and via the Platform. Service requests such as resetting two-factor authentication, password questions or ending sessions are handled after identity verification by confirmation email, without accessing the content of the tenant for this purpose.

§ 11 Rights in respect of defects

(1) For consumers, the statutory rights in respect of defects in digital products apply (§§ 327 et seq. BGB).

(2) Entrepreneurs must notify defects without undue delay in text form with a comprehensible description. The Provider remedies defects within a reasonable period by rectification or a workaround. If this is unsuccessful, the entrepreneur may reduce the fee or terminate in accordance with § 543 BGB. Strict liability (irrespective of fault) for defects existing at the time the contract is concluded (§ 536a (1) first alternative BGB) is excluded in relation to entrepreneurs.

§ 12 Liability

(1) The Provider is liable without limitation for intent and gross negligence, for injury to life, body or health, under the German Product Liability Act (Produkthaftungsgesetz) and to the extent of any guarantee assumed.

(2) In the case of slight negligence, the Provider is liable only for breach of a material contractual obligation, the fulfilment of which is essential for the proper performance of the contract and on compliance with which the customer may regularly rely (cardinal obligation). In this case, liability is limited to the foreseeable damage typical for the contract.

(3) In relation to entrepreneurs, liability under paragraph 2 is additionally limited to the amount of the fees paid by the customer in the twelve months preceding the event giving rise to the damage. In relation to entrepreneurs, the Provider is liable for the loss of data only in the amount of the effort that would have been required for its restoration had the customer backed up its data properly.

(4) The Provider accepts no liability for decisions taken by the customer on the basis of key figures, projections, country notes or AI outputs, unless liability is mandatory under paragraph 1; § 2 (3) and (4) apply accordingly.

(5) The above limitations also apply in favour of the Provider’s corporate bodies, staff and vicarious agents.

§ 13 Data protection, data processing

(1) Insofar as the Provider processes personal data for its own purposes (for example customer account, billing, security), it is the controller; details are set out in the privacy policy for the Platform.

(2) Insofar as the customer processes personal data of third parties via the Platform, the Provider processes this data as a processor. The data processing agreement (Annex 3), which forms part of the contract with every customer, applies to this.

(3) All permanently stored data is held on servers in the European Union (Supabase, Frankfurt region). The sub-processors used and the safeguards for transfers to third countries are set out in Annex 4.

§ 14 Term and termination

(1) The subscription runs for the selected billing period (month or year) and is renewed for the same period in each case unless it is terminated by the end of the current period. The customer may terminate at any time with effect from the end of the current billing period.

(2) The Provider may terminate the subscription by ordinary notice with three months’ notice to the end of a billing period.

(3) The right of both parties to terminate for good cause without notice remains unaffected. Good cause exists for the Provider in particular if the customer materially breaches § 8 despite a warning or is in default with the payment of two consecutive fees.

(4) Consumers: If an annual subscription has been renewed after the end of the initial term, it continues for an indefinite period and may be terminated at any time with one month’s notice; fees already paid for the period after the end of the contract are refunded pro rata.

(5) Notice of termination may be given in text form (e.g. by email to info@finaure.eu) or via the termination function in the Platform. Termination is confirmed in text form.

§ 15 End of contract, export, deletion

(1) After the end of the contract, the customer has read-only access to its data for 90 days (export window) and can retrieve a complete export package (all documents in a folder structure and the core data as CSV files) and download receipts in the available export formats. The Provider sends reminders at the start of the export window and 30 and 7 days before it expires.

(2) After the export window has expired, the Provider permanently deletes all of the tenant’s data, including the documents and the access set up with the account information service. The deletion is logged.

(3) Exempt from deletion are (a) data that the Provider must retain on the basis of its own statutory retention obligations, in particular its own invoices and accounting records (eight years), (b) a data-minimised deletion log without content data as evidence of the deletion (six years) and (c) backup copies, which are overwritten in the regular backup cycle after 14 days at the latest.

(4) At the customer’s request, the Provider deletes the data before the export window expires.

§ 16 Confidentiality

The Provider treats all of the customer’s data and information confidentially and uses it exclusively to provide the contractual services. The Provider does not sell any data and discloses it only to the sub-processors named in Annex 4, insofar as this is necessary to provide the services, or insofar as it is obliged to do so by law or by order of an authority or court.

§ 17 Right of withdrawal for consumers

(1) Consumers have a statutory right of withdrawal of 14 days from the conclusion of the contract on registration. Details are set out in the withdrawal information (Annex 5).

(2) If the consumer expressly requests that performance begin before the end of the withdrawal period, the consumer owes, in the event of withdrawal, pro rata compensation for the value of the services provided up to that point (§ 357a BGB). No compensation for value is payable for the free trial period.

§ 18 Changes

(1) Changes to the services: The Provider may change the Platform beyond what is necessary to maintain conformity with the contract if there is a valid reason for doing so (for example changes in the law, security requirements, technical development or changes among sub-processors), the customer incurs no additional costs and the customer is informed clearly and comprehensibly. If a change impairs use for consumers more than insignificantly, the Provider informs them in good time in advance in text form; the consumer may then terminate the contract free of charge within 30 days of receipt of the information or of the change (§ 327r BGB).

(2) Changes to these Terms in relation to consumers only take effect with their express consent. If the consumer does not consent, the previous Terms continue to apply.

(3) Changes to these Terms in relation to entrepreneurs are notified by the Provider in text form at least six weeks before they take effect. If the entrepreneur does not object within this period, the changes are deemed accepted; the Provider draws specific attention to this consequence in the notification. If the entrepreneur objects, either party may terminate the contract with effect from the date on which the change takes effect.

§ 19 Final provisions

(1) The law of the Federal Republic of Germany applies, excluding the UN Convention on Contracts for the International Sale of Goods (CISG). For consumers, this choice of law applies only insofar as it does not deprive them of the protection afforded by mandatory provisions of the law of the state in which the consumer has their habitual residence (Art. 6 (2) Rome I Regulation).

(2) If the customer is a merchant (Kaufmann), a legal entity under public law or a special fund under public law, the exclusive place of jurisdiction for all disputes arising from the contract is Frankfurt am Main. For consumers, the statutory places of jurisdiction apply.

(3) The Provider is neither willing nor obliged to participate in dispute resolution proceedings before a consumer arbitration board (§ 36 of the German Consumer Dispute Resolution Act, VSBG).

(4) Should individual provisions of these Terms be or become invalid, the validity of the remaining provisions remains unaffected. The invalid provision is replaced by the statutory provision.

Annex 1 – Service description

In all licence tiers, the Platform includes in particular the following functions. A current overview is available at finaure.eu/en/features; changes are governed by § 18.

• Wealth and structure overview: mapping of persons, companies, foundations and shareholding ratios with proportionate consolidation; wealth dashboard across all asset classes.
• Multibanking: connection of bank accounts and securities accounts via finAPI (§ 6); payment runs with four-eyes approval.
• Documents and data room: filing, search, time-limited sharing with external parties.
• SmartUpload: AI-assisted recognition of receipts, contracts, securities account statements, annual financial statements, fund reports, property brochures (exposés) and property photos (§ 5).
• SmartAssist and SmartGuide: AI assistant for questions about the customer’s own data and help with setup.
• SmartWealth: long-term wealth and life planning (projection, retirement, withdrawals, scenario simulation at asset class level).
• SmartFinance: operational financial management (liquidity, fixed items, plan/actual, one-off effects).
• Handover to the adviser: collection of receipts and export in formats customary in the respective country (e.g. DATEV EXTF, BMD, RZL, FEC, CSV) as a working aid, without bookkeeping.
• Real estate and rents, investments, securities account tranches (for information purposes), tasks and deadlines, reports (PDF).
• Country profiles: country-specific notes on tenancy law, service charges and retirement provision without tax mechanics. Individual functions are not available in all countries (e.g. tax allowance calculator for Germany only, service charge statements not in all countries).
• Roles and security: role and visibility model per entity, two-factor authentication, audit log.

Annex 2 – Price list

All licence tiers include the full range of functions and unlimited users, bank accounts and entities. The licence tier depends solely on gross assets (§ 7).

• Billing periods: monthly or annually. The annual fee is ten times the monthly price. Payment in advance in each case.
• XL: in addition to the full range of functions, a personal onboarding session.
• Buffer: A change to the next higher tier is only offered once the upper limit has been exceeded by more than 10%, and is only charged after confirmation by the customer (§ 7 (3)).
• Trial period: 14 days free of charge; if the customer does not cancel during the trial period, the contract continues as the selected subscription (§ 3 (3) and (4)).
• The gross prices apply to consumers resident in Germany. For consumers in other EU member states, the VAT rate of the respective state may apply; the final price is displayed during the ordering process.

Annex 3 – Data processing agreement (Art. 28 GDPR)

Part A – Contractual provisions

1. Subject matter, duration, roles

(1) This agreement specifies the parties’ data protection obligations arising from the contract of use for the Platform (main contract). The customer is the controller for the personal data that it processes or has processed via the Platform; the Provider processes this data as a processor exclusively for the purpose of providing the contractual services.

(2) The duration corresponds to the term of the main contract plus the export window and deletion in accordance with § 15 of the Terms.

(3) For data that the Provider processes for its own purposes (customer account, billing, own retention obligations), the Provider is the controller; in this respect the privacy policy applies.

2. Nature and purpose of processing, data, data subjects

(1) Purpose: provision of a digital wealth management platform, including document management, AI-assisted analysis, bank data connection, evaluations, reports and export.

(2) Categories of data: master and contact data, contract and financial data (contracts, receivables and liabilities, bank transactions, balances, receipts), document content including personal information contained therein, usage and log data. No bank access credentials.

(3) Data subjects: the customer and its users, and third parties whose data the customer provides, in particular tenants, employees, contractual partners, family members and advisers.

(4) Special categories of personal data (Art. 9 GDPR) are not the subject matter of this agreement. If the customer provides such data in documents, the customer is responsible for its lawfulness.

3. Instructions

(1) The Provider processes the data only on documented instructions from the customer. The instructions result from the main contract and from the use of the Platform functions (configuration, uploads, sharing, exports, deletion requests). Individual instructions require text form.

(2) If the Provider considers an instruction to be unlawful, it informs the customer without undue delay and may suspend execution until confirmation.

4. Confidentiality

The Provider commits all persons involved in the processing to confidentiality (Art. 28 (3)(b), Art. 29 GDPR) and instructs them in the requirements of data protection.

5. Technical and organisational measures

(1) The Provider takes the measures described in Part B in accordance with Art. 32 GDPR.

(2) The Provider may further develop the measures, provided that the level of protection is not reduced. Material changes are documented.

6. Sub-processors

(1) The customer approves the sub-processors listed in Annex 4.

(2) The Provider informs the customer in text form at least four weeks before engaging or replacing a sub-processor. The customer may object for good cause relating to data protection. If an amicable solution is not possible, both parties have a special right of termination with effect from the date on which the change takes effect.

(3) The Provider contractually imposes essentially the same data protection obligations on sub-processors. For transfers to third countries, the safeguards named in Annex 4 are in place.

7. Assistance, data subject rights

(1) The Provider assists the customer in fulfilling data subject rights (Art. 12 to 22 GDPR), primarily through the Platform functions: export package (access, portability), rectification via self-service, restriction without deletion, logged final deletion and consent management for AI functions with an alternative route without AI.

(2) If data subjects address requests directly to the Provider, it forwards them to the customer without undue delay.

(3) The Provider assists the customer, within reasonable limits, with data protection impact assessments and prior consultations (Art. 35, 36 GDPR).

8. Notification of personal data breaches

The Provider notifies the customer of personal data breaches affecting the customer’s data without undue delay, at the latest within 48 hours of becoming aware of them, with the information available under Art. 33 (3) GDPR, and assists the customer with its notification and communication obligations.

9. Evidence and inspections

(1) The Provider demonstrates compliance with this agreement through the description of the measures (Part B), its continuously updated security and compliance documentation and certifications of its infrastructure sub-processors (in particular SOC 2 Type 2 of the hosting provider).

(2) Further on-site inspections are possible with four weeks’ notice, during business hours, without disrupting operations and no more than once a year, unless there is a specific reason. The Provider may replace them with equivalent evidence from independent third parties. Each party bears its own costs.

10. Deletion and return

After the end of the contract, the procedure set out in § 15 of the Terms applies: a 90-day export window with a complete export package, followed by final deletion in a documented sequence (evidence log, removal of the access set up with the account information service, database, document storage, access account), logged in a data-minimised deletion register (six years). Backup copies are overwritten after 14 days at the latest.

11. Liability, precedence

The liability provisions of the main contract (§ 12 of the Terms) and Art. 82 GDPR apply. In the event of conflicts between this agreement and the main contract, this agreement takes precedence in matters of data protection law.

Part B – Technical and organisational measures

1. Confidentiality

• Infrastructure: operation on managed cloud infrastructure (Supabase on AWS, Frankfurt region; SOC 2 Type 2); physical security provided by the infrastructure operator.
• Access to systems: login by email and password (stored only as a hash), two-factor authentication (TOTP) available for all users and configurable as mandatory per tenant, recovery codes only as a hash, sessions with expiry and user-configurable inactivity logout, bot protection on registration; the Provider’s administrative access with two-factor authentication and a minimal group of persons.
• Access to data: server-side enforced tenant separation (row level security) on all tenant tables; visibility control per user and entity; role model with threefold enforcement (interface, route protection, database policy); four-eyes principle for payment approvals; authentication with a second factor for money movements and administration; support access that is logged and visible to the owner, without access to payments and bank connections.
• Documents: storage paths separated by tenant; retrieval only when authenticated via short-lived signed links; uploads restricted to PDF, JPG and PNG.
• External sharing: links with a 256-bit random token (stored only as a hash), limited to one matter, time-limited, with lockout after failed attempts and rate limiting, revocable at any time, complete access log.

2. Integrity

Server-side validation of all write operations; verification of the signatures of incoming billing webhooks; audit log of user actions (viewable only by owner and admin); handover workflows for receipts with logged cancellation; no user content in technical logs.

3. Encryption and pseudonymisation

Encryption at rest (AES-256) and in transit (TLS 1.2 or higher); Content Security Policy, HSTS and further security headers; enforced HTTPS. Data minimisation for AI functions: anonymised contexts for the AI assistant (no real names of contacts, no IBANs, tax numbers or dates of birth), samples instead of complete files for import recognition, no identifiers as metadata in document analyses, anonymisation of support texts, removal of location data and metadata from photos before transmission.

4. Availability and resilience

Daily backups with point-in-time recovery at the database operator; globally distributed delivery of the application interface; rate limits on sensitive paths; documented operating routines and regular key rotation.

5. Regular review

Security-by-design rules for every further development (including a tenant policy for every new table, no secrets in the frontend with a check step for each deployment, authentication checks in every server function, recording of every new integration in the data flow register); internal security reviews with documented follow-up; monthly review of software dependencies; tests against prompt injection for AI functions.

6. Organisation

Documented instruction of the persons involved in the processing; deletion and retention concept with export window, logged final deletion and deletion register; continuously updated security and compliance documentation with version history.

Annex 4 – Sub-processors

A. Sub-processors with access to personal data

B. External data sources without personal data

Price, precious metal and exchange rate data and public news feeds are retrieved exclusively on the server side (including Twelve Data, Metals-API, Frankfurter API/ECB and public news sources). Only security symbols or feed requests are transmitted, no user data. These providers are not processors.

Annex 5 – Withdrawal information and model withdrawal form

The following information applies to consumers.

Last updated: October 2026