Privacy Policy

1. Controller

Picsure GmbH, Heidenkampsweg 58, 20097 Hamburg, Germany. Represented by Enrico Bolloni. Email: support@fahrzeugschein24.de.

1a. Data protection officer

Our data protection officer is Florian Bischof. You can reach him at datenschutz@fahrzeugschein24.de, or by post at the address above marked "Datenschutzbeauftragter".

2. What data we process

• Account data: name, email address, company and login credentials.
• If you sign in with a Google account, additionally: the pseudonymous user identifier Google sends us, the email address transmitted with it, and your name (see section 7a).
• Usage and log data: IP address, browser type, requests and timestamps, to operate and secure the Service.
• Document data: the vehicle registration documents you upload and the structured fields extracted from them.
• Billing data: plan, usage counts and information required for invoicing.
• Reach measurement data: page views and interactions on our website, without cookies and without identifying you (see section 11).

3. Purposes & legal bases

We process data to provide the Service and perform our contract with you (Art. 6(1)(b) GDPR), to operate, secure and improve the Service and prevent misuse (legitimate interests, Art. 6(1)(f) GDPR), and to comply with legal obligations (Art. 6(1)(c) GDPR). Where we rely on consent, you may withdraw it at any time (Art. 6(1)(a) GDPR). Documents from the free plan are additionally processed to train, test and improve our recognition (legitimate interests, Art. 6(1)(f) GDPR; see section 4).

4. Documents you upload

Documents uploaded for extraction are processed to read and return the contained fields as structured data. On paid plans, uploaded images are processed in memory only and are not written to disk; only the extracted data and log records are stored. For the free plan, the following paragraph applies. If you enable the optional fraud detection, documents are additionally checked for manipulation; the cross-document duplicate check compares documents only within your own account and stores no documents for this, only a non-reversible fingerprint per submission: salted one-way hash values (SHA-256) of identifiers and content plus coarse image characteristics (a checksum of the image file, a compact similarity value and a heavily downscaled brightness grid of the page). The document cannot be reconstructed from these values.

On the free plan we store the files uploaded since this version took effect that we recognise as vehicle documents (mainly registration certificates) and use them to train, test and improve our recognition. For this we are the controller ourselves; it is not processing on your behalf. It concerns all details on the documents, such as the keeper's name and address, the registration number and the vehicle identification number, as well as the data extracted from them. We store the file unchanged, including any details embedded in it, such as when or where the picture was taken. For each document we record the time, access channel, file type, size and checksum, and until your account is deleted also its link to your account, afterwards only a pseudonymous identifier; we do not store the file name. The legal basis is our legitimate interest in reliable recognition of German vehicle documents (Art. 6(1)(f) GDPR). Only persons entrusted with this task have access; we do not pass the documents on to third parties. We keep them for up to five years from upload, even if you delete your account or object to the use; recognition models trained with them remain in place after that as well. The plan at the time of upload is decisive: on paid plans and for accounts with individually agreed terms, such as agreed PDF output, we store no uploaded documents and do not use them for these purposes. If no documents should be stored, use a paid plan.

If filled PDF forms are set up as the output for your account, we store the values entered into the form for 30 days so that you can download the PDF again from the dashboard during that time. We do not store the filled PDF itself; it is generated again from these values when you download it. After 30 days the values are deleted automatically.

5. Processing on your behalf (DPA)

Where uploaded documents contain personal data, we act as processor and you as controller. A data processing agreement pursuant to Art. 28 GDPR governs that processing (/avv). Excepted is the use of free-plan documents under section 4; for that we are the controller ourselves.

6. Hosting & location

The Service is hosted in Germany. Documents you upload for extraction are processed exclusively on servers within the European Union — text recognition runs against the EU regional endpoint of our OCR provider. Documents from the free plan are stored on our systems in Germany; backup copies and training runs are hosted by Google Cloud in the Frankfurt region (EU). Account and billing data, as well as operational logs and error reports, are additionally processed by providers in the United States (see sections 7, 7a and 7b); those transfers require appropriate safeguards under Art. 44 et seq. GDPR.

7. Disclosure & sub-processors

We do not sell personal data. We disclose data only to service providers acting on our instructions, where required by law, or with your consent. The sub-processors we currently engage are: Hetzner Online GmbH (Germany) — hosting of our servers (application and reach measurement); Google Cloud via its EU regional endpoint (EU processing location, US parent company) — text recognition on uploaded documents; Resend (USA) — transactional email; Lemon Squeezy (USA) — checkout, payment and invoicing; GitLab — source code, build and container registry (no customer data); Better Stack, Inc. (USA) — availability monitoring, status page, operational logs and error reports (see section 7b). Not part of this list is the optional sign-in with a Google account: there, Google does not act on our instructions but as a separate controller — see section 7a. We inform customers of intended changes to this list. For the processing under section 4 we engage Google Cloud as our own processor: backup copies and training runs are hosted in the Frankfurt region, and the text recognition this requires runs via its EU regional endpoint (EU processing location in each case, US parent company). Processing on your behalf is not affected by this.

7a. Signing in with a Google account

You may optionally register and sign in with a Google account. This is voluntary: signing in with an email address and password remains fully available, and as long as you do not click „Sign in with Google“, no data is transmitted to Google.

When you do, we redirect you to Google. In doing so, Google learns your IP address, technical details of your browser, and the fact that you wish to sign in to Fahrzeugschein24. For that processing Google is a separate controller (Art. 13(1)(e) GDPR); there is no processor relationship for it. The contracting entity for users in the European Economic Area is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; a transfer to Google LLC in the United States may occur. Google LLC is certified under the EU-US Data Privacy Framework; the transfer is based on the adequacy decision of the European Commission (Art. 45 GDPR). Google’s own privacy policy applies in addition (policies.google.com/privacy).

After you confirm at Google, we receive from them a pseudonymous user identifier issued for Fahrzeugschein24 only, your email address together with an indication of whether Google considers it verified, and the name held there. Of these we store only the identifier, the email address at the time of linking, and the times of linking and of the last sign-in. We do not store access or refresh tokens. We neither request nor receive access to your email, contacts, calendar or files.

The legal basis is the performance of the contract of use (Art. 6(1)(b) GDPR) — you choose this sign-in method yourself — together with our legitimate interest in a secure sign-in and in preventing account takeover (Art. 6(1)(f) GDPR). We neither need nor obtain consent under Art. 6(1)(a) GDPR for this.

The flow sets a short-lived cookie that serves solely to secure the sign-in and expires afterwards. It is technically necessary to protect the process against tampering (Section 25(2)(2) TDDDG).

You can disconnect the link at any time in your account under Settings → Security; if it is your only sign-in method, set a password first. Deleting your account removes the link as well.

7b. Operations monitoring & error analysis

So that we notice and fix outages and errors quickly, we use services of Better Stack, Inc. (USA). Better Stack regularly calls our website, web app and API from outside to check that they are reachable, and hosts our status page at status.fahrzeugschein24.de. In addition, our servers send operational logs and error reports to Better Stack.

Operational logs contain the time, the requested address without parameters, the status code, response times and technical messages of the application. Before transmission we shorten IP addresses by their last byte and remove email addresses, access keys and tokens. Error reports contain the type of error, the error message, the affected place in the program and technical details of browser, operating system and server, but no form input, cookies or request headers. Both are filtered so that they contain no content of uploaded documents.

If an error occurs in your browser while you use the web app, your browser sends the error report directly to Better Stack. Your IP address is transmitted for technical reasons but is not included in the report. The website (fahrzeugschein24.de) sends nothing from your browser. When you open the status page, Better Stack as its host processes your IP address and technical details of your browser.

The data is stored in data centres in the United States. Better Stack is certified under the EU-US Data Privacy Framework; the transfer is based on the adequacy decision of the European Commission (Art. 45 GDPR), and in the alternative on standard contractual clauses (Art. 46(2)(c) GDPR). Operational logs are deleted after 3 days, error reports after 90 days. The legal basis is our legitimate interest in the secure and uninterrupted operation of the Service (Art. 6(1)(f) GDPR); you may object at any time (Art. 21 GDPR).

8. Retention

We retain personal data only as long as necessary for the purposes described here, for the duration of your account, and as required by statutory retention obligations. Document images from paid plans are not retained at all — they exist only in memory for the duration of the request. Documents from the free plan are kept for up to five years from upload, even after you delete your account or object (see section 4); after that we delete them, and backup copies are finally erased within a further 30 days. Extraction records and log data are retained for the lifetime of your account. The values of filled PDF forms are kept for 30 days and then deleted automatically (see section 4).

9. Your rights

Subject to the conditions of the GDPR, you have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and to object (Art. 21), and to lodge a complaint with a supervisory authority. Two of these you can exercise yourself at any time in your account under Settings → Security: download the data held in your account as JSON (Art. 20) and delete your account (Art. 17). For everything else, contact datenschutz@fahrzeugschein24.de.

You and other data subjects, such as vehicle keepers, may object to the use of free-plan documents under section 4 on grounds relating to their particular situation (Art. 21 GDPR); an informal message to datenschutz@fahrzeugschein24.de is sufficient. After an objection we no longer store future uploads of your account. Documents already stored are kept until the period under section 8 has expired, even after an objection or the deletion of your account, and continue to be used for training.

10. Security

We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access, and continually review our safeguards.

11. Cookies, fonts & analytics

This website sets no cookies. The language follows from the page address (German without a prefix, English under /en), so nothing has to be stored on your device for it. Because we neither store nor read information on your device, no consent under Section 25 TDDDG — and therefore no cookie banner — is required. We use no advertising cookies, no third-party trackers and no cross-site tracking.

For reach measurement we use Umami, analytics software we host ourselves on our own server in Germany. Umami works without cookies and stores no data on your device. It records page views and interactions (for example which button was clicked), the referring page and the campaign parameters of the link you followed, plus technical data such as browser, operating system, screen size, language and — derived from your IP address — your country. Your IP address itself is neither stored nor passed on, and the data is not used to identify you personally. Nothing is transferred to third parties. The legal basis is our legitimate interest in the statistical evaluation and needs-based improvement of our website (Art. 6(1)(f) GDPR); you may object at any time (Art. 21 GDPR). We honour the "Do Not Track" setting of your browser: when it is enabled, no measurement takes place.

Web fonts are self-hosted on our own servers, so no data is transferred to third parties to display the site.

12. Changes

We may update this Privacy Policy to reflect changes to the Service or legal requirements. The current version is always available on this page.