Privacy Policy

Version: 1.2
Last updated: 2026-11-06

JTB UG (haftungsbeschränkt)
Birkenweg 6
66649 Oberthal
Germany
info@werkbook.app

We process personal data in two ways:

• As a controller for our own operations (e.g. accounts, website)
• As a processor on behalf of our customers, who use our service to collect and process data

• Account data (e.g. name, email, postal address, payment information)
• Usage data (e.g. login activity, IP address)
• Communication data (e.g. support requests)

We use a session cookie to maintain login sessions. This cookie is technically necessary for the operation of the service.

Contents submitted via forms including names, locations, signatures, photos, videos and other information.

We process such data on behalf of our customers, who are responsible for the collection and use of this data.

We process personal data to:

• Provide and operate the service (Art. 6(1)(b) GDPR)
• Ensure security and reliability (Art. 6(1)(f) GDPR)
• Communicate with users (Art. 6(1)(b) GDPR)

When acting as a processor, we process data solely on behalf of our customers.

On our website, not in the app, we measure visitor numbers with Pirsch Analytics, a service of Emvi Software GmbH, Nickelstraße 1b, 33378 Rheda-Wiedenbrück, Germany, with servers in Germany. Pirsch does not set cookies. To count visitors, Pirsch derives an identifier from the IP address, browser identifier (user agent), date and a random value that can no longer be linked to a visitor after 24 hours. The IP address is not stored, neither in whole nor in part.

Pirsch records:

• the page visited and the page you came from
• browser, operating system, device type and screen size
• language, country and city
• the time of the visit

The legal basis is our legitimate interest in measuring and improving the reach of our website (Art. 6(1)(f) GDPR). Pirsch keeps the user agent for no longer than three months.

To keep bots from creating accounts in bulk, we use Cloudflare Turnstile at signup to check that a human is filling in the form. Turnstile is a service of Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. For this, the signup form loads a script from Cloudflare. It sends your IP address and characteristics of your browser and device (e.g. user agent, language settings, screen size) to Cloudflare and evaluates how the browser behaves. When you submit the form, we ask Cloudflare for the result. Other pages, the login and the apps do not use Turnstile.

Cloudflare uses this data only to detect bots, not for advertising. The legal basis is our legitimate interest in protecting our service and our email delivery from abuse (Art. 6(1)(f) GDPR). Cloudflare is certified under the EU-US Data Privacy Framework.

• Our service offers optional AI-based features
• AI processing is performed only when triggered by users
• Data may be transmitted to Anthropic for this purpose
• We do not use customer data to train AI models
• Customers decide whether to use these features

We use service providers to operate our platform, including:

• Render.com (application hosting and database storage)
• Hetzner (object storage for uploaded files)
• Sentry (error monitoring and logging)
• Postmark (email delivery)
• Pirsch Analytics (website analytics)
• Cloudflare (protecting the signup from bots)
• Anthropic (AI processing, optional)
• Customers may also connect third-party integrations (e.g. Dropbox, Microsoft OneDrive).

Personal data may be transferred outside the EU/EEA (e.g. to the United States).

We use appropriate safeguards, including Standard Contractual Clauses (SCCs).

• Data is stored for the duration of the account
• Accounts can be deleted at any time
• Upon deletion, data is removed within 30 days
• Backups are retained for a limited period

We implement appropriate technical and organizational measures, including:

• Encryption in transit (HTTPS)
• Encryption at rest
• Access controls
• Backups

You have the right to:

• Access your data
• Request correction or deletion
• Request restriction of processing, where applicable
• Receive your data in a portable format, where technically feasible
• Lodge a complaint with a supervisory authority

If your data was submitted by one of our customers, please contact that customer directly, as they are responsible for handling your request.

For privacy-related inquiries, contact: info@werkbook.app