Terms of Service

Version 1.0 — Effective from 1 November 2026

1. Who we are and what these Terms cover

1.1 Fleetless is a service of Dehne Robotik GmbH, Rosentwiete 1, 25355 Groß Offenseth-Aspern, Germany, registered with the commercial register of Amtsgericht Pinneberg under HRB 14906 PI (“Fleetless”, “we”, “us”).

1.2 These Terms govern your use of the Fleetless service: the cloud platform that connects robots to applications, the console, the APIs, the MCP endpoint, the hosted sign-in pages for your apps, and the documentation (together the “Service”).

1.3 “You” means the business or the person that registers an organisation on the Service. If you register for a business, the person who accepts these Terms confirms that they are authorised to do so for that business.

1.4 Software that we publish under an open-source licence (the SDK, the contracts package, the bridge and the app starter) is licensed to you under the licence shipped with it. These Terms govern the Service, not that software. Section 8 applies whenever that software is used together with the Service.

1.5 If documents conflict, this order applies: (a) an Order Form signed by both parties, (b) the Data Processing Agreement (section 9.3), for the processing of personal data, (c) these Terms, (d) the plan description under section 4.1.

1.6 Your own terms and conditions do not apply, even if we do not object to them.

2. Who may use the Service

2.1 Paid plans are available only to entrepreneurs within the meaning of § 14 of the German Civil Code (BGB), meaning natural or legal persons acting in the exercise of their trade, business or profession, and to legal entities under public law. We do not enter into contracts for paid plans with consumers (§ 13 BGB). When you order a paid plan, you confirm that you act as an entrepreneur.

2.2 The Basic plan is open to everyone, including consumers. Section 2.4 applies to consumers.

2.3 We may ask an organisation that orders or holds a paid plan for evidence of its business status, such as a VAT identification number, a tax number or a register extract, and may refuse the order or end the paid plan if it is not provided.

2.4 If you use the Basic plan as a consumer:
(a) we process the personal data that you provide to us only to provide the Service and to meet our legal obligations, and for no other purpose; in particular, we do not send you advertising and do not analyse your use for marketing;
(b) the mandatory consumer protection law of the country in which you have your habitual residence remains unaffected (section 21.4);
(c) to move to a paid plan, you must act as an entrepreneur under section 2.1.

If you are a consumer, sections 14.2, 15.2, 15.3 and 16 do not apply. Your statutory rights concerning defects and liability remain unaffected.

2.5 If you lack full legal capacity, you may register only with the consent of your legal representative where required by applicable law.

3. Accounts, organisations and users

3.1 You give accurate and complete information when you register and when you order, and you keep it up to date. If you register for a business, this includes its company name, address and billing details.

3.2 An organisation holds your robots, apps, members and plan. The owner of the organisation acts for you and may invite members, order, change and cancel plans, and delete the organisation.

3.3 You make sure, as far as you can reasonably do so, that your members, the users of the apps you build on Fleetless (“App Users”) and any software or AI agent that acts with your credentials comply with these Terms. You are responsible for your own breaches and for acts and omissions attributable to you under applicable law.

3.4 You keep passwords, API keys and bridge tokens secret, use the security features we offer, and tell us without undue delay if you suspect misuse.

3.5 Your relationship with your App Users is yours alone. You give them your own terms and your own privacy information. We do not become a party to that relationship.

3.6 While the Service is in closed beta, registration is by invitation. There is no entitlement to an account.

4. Plans, limits and changes to the Service

4.1 What a plan includes (seats, robots, apps, App Users, live-video time, storage, history, features and support level) is set out in the plan description published at https://docs.fleetless.dev/concepts/plans-and-limits/ and in the documentation (“Plans and Limits”), in the version in force when you order or renew.

4.2 Limits are enforced technically. The Service may refuse or stop an action that exceeds a limit of your plan. We do not charge for use above a limit unless you have ordered it.

4.3 The Basic plan is free of charge. We may change its scope or discontinue it with 30 days’ notice. We may delete an organisation on the Basic plan that has not been used for 12 months, after 30 days’ notice by e-mail.

4.4 We develop the Service continuously. We may change it where the change is reasonable for you, in particular to improve it, to keep it secure, to comply with the law or to follow technical developments. If a change materially reduces the functions of a paid plan, we tell you at least 30 days in advance. You may then terminate with effect from the date of the change and receive a pro rata refund of the fees you prepaid for the time after that date.

4.5 Features marked as beta, preview or experimental may be changed, limited or withdrawn at any time. They carry no availability commitment and are not meant for production use. Where such a feature forms part of the agreed scope of a paid plan, section 4.4 applies to its withdrawal. Sections 14.3 and 15.4 apply to these features.

5. Fees, payment and taxes

5.1 The prices shown when you order apply. All prices are in euros and exclude value added tax.

5.2 Fees are charged in advance for each billing period, monthly or yearly, using the payment methods offered at checkout through our payment provider. You authorise the recurring charges.

5.3 A paid plan renews automatically for a further billing period of the same length unless it is cancelled before the period ends.

5.4 If you move to a higher plan or add add-ons during a billing period, the change takes effect at once and you are charged the difference pro rata for the rest of the period. A move to a lower plan, fewer add-ons or a change from yearly to monthly billing takes effect at the end of the current period. There is no credit or refund for the current period.

5.5 We issue invoices electronically, in euros, and make them available in the console. You agree to receive invoices in electronic form, including structured electronic invoices.

5.6 If a payment fails, we tell you by e-mail and try again. If the amount is still unpaid 14 days after it fell due, we may lock the organisation until it is paid. A lock does not affect your rights under section 11. Statutory default interest and the statutory lump sum apply. Section 6.4 remains unaffected.

5.7 Value added tax is added where it applies. If you are established in another EU member state, you give us a valid VAT identification number, which we verify with the EU’s VIES service; where the legal requirements are met, the reverse-charge procedure applies. If you are established outside the EU, you give us your business tax identification; where the legal requirements are met, the supply is then not taxable in Germany. You are responsible for all taxes, duties and levies that arise in your country in connection with your purchase, other than taxes on our income. You tell us without delay if your details change. You reimburse us for losses caused by incorrect tax information for which you are responsible, to the extent legally recoverable. This does not include losses attributable to our own fault or penalties that cannot lawfully be shifted to you.

5.8 You pay all fees without deduction. If the law requires you to withhold tax, you increase the payment so that we receive the full amount invoiced, and you send us the tax certificate.

5.9 We may offer a new price for a future billing period by e-mail at least 30 days before that period begins. The new price applies only if you expressly accept it. Otherwise, the existing price continues to apply unless the paid plan is terminated in accordance with section 6.3. Fees already agreed for the current billing period do not change. If you accept after the billing period stated in the offer has begun, the new price applies from the beginning of the following billing period. The offer remains open until we withdraw it.

5.10 You may set off only claims that are undisputed, have been finally adjudicated or arise from the same contractual relationship.

6. Term, cancellation and termination

6.1 The contract begins when your registration is complete and runs for an indefinite time. A paid plan runs for the billing period you chose and renews under section 5.3.

6.2 You may cancel a paid plan in the console at any time, with effect at the end of the current billing period. Until then you may withdraw the cancellation. After that your organisation continues on the Basic plan with its limits. You may delete your organisation at any time.

6.3 We may terminate a paid plan with at least 30 days’ notice to the end of a billing period, and the Basic plan with 30 days’ notice.

6.4 Either party may terminate for good cause without notice. Good cause for us includes a serious or repeated breach of sections 2, 7, 8 or 18, and a payment that remains unpaid 30 days after the organisation was locked. Where a breach can be remedied, we first set a reasonable deadline, unless the matter is urgent.

6.5 If we terminate under section 6.3 during a period you have prepaid, or if you terminate for good cause for which we are responsible, we refund the prepaid fees pro rata for the time after the contract ends.

6.6 When the contract ends, your access ends, except for retrieving your data under this section and section 11. Unless you deleted your organisation yourself, you can still export your data for 30 days after the contract ends, whichever party terminated it, unless we terminated it for a reason that makes this unreasonable for us. If you delete your organisation and confirm the deletion, we erase Customer Data without a retrieval period, and the contract ends when the deletion is confirmed. Fees already due remain payable; there is no pro-rata refund, except under sections 6.5 and 11.6. Residual copies in backups are deleted no later than 35 days after erasure from the active systems. Records that we must keep by law, such as invoices, are kept for the statutory period. Section 11 remains unaffected.

6.7 Notice of termination must be given in text form; e-mail is sufficient. A cancellation made in the console is sufficient.

7. Acceptable use

7.1 You must not, and must not allow anyone to:

(a) use the Service in breach of the law or of the rights of others, or store or transmit unlawful content with it;

(b) use the Service to develop, operate or control weapons, for military end use, or to harm people;

(c) use robots, cameras or other sensors to monitor people in a way that is unlawful where it takes place, including covert recording;

(d) access robots, accounts or data without authorisation, or connect a robot that you are not entitled to control;

(e) probe, scan or test the security of the Service without our prior written consent, except as our vulnerability disclosure policy at https://fleetless.dev/security/ allows, or circumvent limits or security measures;

(f) overload or disrupt the Service, or use it by automated means beyond the documented rate limits;

(g) offer the Service to third parties as a hosted service of your own, or create several organisations to avoid the limits of a plan; building apps for your own customers and their App Users is permitted;

(h) send malware or unsolicited messages through the Service, including through the e-mails your apps send.

7.2 Automation and AI agents. If you let software or an AI agent use the Service, for example through the API or the MCP endpoint, you decide which data it may read and which commands it may send. You supervise it appropriately, and you are responsible for every command it issues. AI agents that control robots through Fleetless can make mistakes. Use an AI agent to move a robot only while a person supervises every motion and can stop the robot at once. Do not let AI agents move robots unattended.

7.3 Cameras and people. You are responsible for complying with the laws on video recording, workplace monitoring and employee participation that apply where your robots operate, and for informing the people who may be seen or recorded.

7.4 Section 17 sets out what we may do if these rules are broken.

8. Safety and intended use

8.1 The Service lets software read data from robots and send commands to them over the internet. It is a tool for developers and operators of robots. It is not a safety component, a safety function or an emergency-stop system, and it is neither designed nor certified for functional safety.

8.2 Connections over the internet can be delayed, interrupted or lost. A command may arrive late, more than once or not at all, and data shown may be out of date.

8.3 You are responsible for the safe operation of your robots at all times. In particular you:

(a) carry out the risk assessment and comply with the safety laws and standards that apply to your robots and to the places where they operate;

(b) keep safety functions in place that work independently of the Service and of any network connection, such as a local emergency stop, a defined response to the loss of the connection and limits on speed and force, and validate them for the specific robot and its hazards; which state is safe follows from your risk assessment;

(c) expose through the Service only commands whose late, repeated or missing execution cannot endanger people;

(d) restrict which persons and which software, including AI agents, may send commands;

(e) test in a safe environment before operating a robot near people.

8.4 You must not use the Service where its failure or delay could lead to death, personal injury or severe damage to property or the environment unless the independent measures under section 8.3 are in place. Human supervision and an emergency stop do not replace the required protective measures.

8.5 The instructions of the robot’s manufacturer take precedence over anything in our documentation.

8.6 Nothing in this section limits our liability under section 15.1 or under other mandatory law.

9. Your data and data protection

9.1 “Customer Data” means all data that you, your members, your App Users and your robots put into the Service or generate in it, such as configuration, telemetry, camera images, job history, App User records and files. As between you and us, Customer Data is yours.

9.2 You grant us the non-exclusive right to host, process, transmit and display Customer Data as far as this is needed to provide, secure and support the Service and to comply with the law. We do not sell Customer Data and do not use it to train AI models. We do not allow anyone who processes Customer Data on our behalf to use it to train AI models.

9.3 Where Customer Data contains personal data that we process on your behalf, the Data Processing Agreement published at https://fleetless.dev/dpa/ applies and forms part of the contract. Depending on your use, you act as controller or as a processor for another controller; the DPA also addresses purely personal or household use. Where data protection law applies to your use, you make sure, within your role, that there is a legal basis for the processing and that the persons concerned, including App Users, employees and people in view of a camera, receive the information the law requires.

9.4 We process personal data as a controller for our own purposes, in particular account administration, billing, support contact and the security and operation of our infrastructure. Customer Data that you give us for technical support remains subject to the Data Processing Agreement where we process it on your behalf. Our Privacy Policy at https://fleetless.dev/privacy/ explains how we process personal data as a controller. For consumers on the Basic plan, section 2.4(a) also applies.

9.5 Customer Data is hosted in Germany. How long each kind of data is kept depends on your plan and your configuration. You are responsible for exporting in good time any data that you need to keep for longer.

9.6 We may compile aggregated statistics on the use of the Service that contain no personal data, in order to operate, bill and improve it. For consumers using the Basic plan, section 2.4(a) takes precedence. We do not process their personal data to create statistics for purposes beyond providing the Service or meeting our legal obligations.

10. Availability, maintenance and support

10.1 We operate the Service with the care that is customary for comparable online services. A specific level of availability is owed only where an Order Form says so.

10.2 We announce planned maintenance that is likely to interrupt the Service in advance on our status page at https://status.fleetless.dev/. Urgent security work may take place without prior notice.

10.3 We are not responsible for interruptions that lie outside our control, such as your internet access, the connectivity of your robots or third-party networks.

10.4 Support follows your plan as described in Plans and Limits. Response times are owed only where an Order Form says so. You can reach our support by e-mail at support@fleetless.dev.

10.5 At the request of you or your members, or where this is necessary to provide, secure or restore the Service for you, administrators whom we have specifically authorised may open a support session in your organisation and act in it with the rights of its owner. We notify the owner of your organisation, by e-mail or in the Service, before we open a support session. Where immediate action is necessary to secure the Service or to prevent harm, we notify the owner without undue delay after opening the session. A support session lasts as long as the support matter requires. A support session starts in a view-only mode; viewing alone is not recorded in your organisation’s audit log. Actions taken after switching to editing appear in your organisation’s audit log and job history as “Fleetless Support”. In a support session, we send commands to your robots, start jobs or publish configuration to them only at the express request of a member of your organisation who is authorised to operate the robot concerned, and only within the scope of that request. You ensure that the robot can be operated safely at that time (section 8.3). These actions appear in your audit log and job history as “Fleetless Support”. Section 3.4 of the Data Processing Agreement governs this access. Support sessions are not available for dedicated instances under an Order Form.

11. Switching and data export

11.1 You may at any time ask us to help you move your data to another provider or to your own systems, or to erase it. The notice period for this is no more than two months.

11.2 After the notice period we complete the switch within 30 days. If this is technically not feasible, we tell you within 14 working days of your request, give reasons and name a longer period, which will not exceed seven months. During the switch we keep the Service running for you, maintain its security and give you reasonable assistance. You may extend the transitional period once by a period you consider more appropriate for your purposes. We explain the available switching methods and known continuity risks and cooperate in good faith with you and your destination provider.

11.3 On every plan, you may export your exportable data and digital assets, including the Customer Data and configuration described in our Data Export Schedule. That Schedule forms part of this contract, identifies the exportable categories, available formats and interfaces, and expressly identifies any lawfully excluded categories. It is available before you enter into the contract in a form you can retain. The Data Export Schedule is set out in Annex 1 to these Terms.

11.4 After the switch you can retrieve your data for at least 30 more days. We then erase it, except where the law requires us to keep it, and confirm the erasure on request. Residual copies in backups are deleted no later than 35 days after erasure from the active systems; until then they are protected and not used for ordinary processing.

11.5 We do not charge for switching.

11.6 The contract ends when the switch has been completed or, if you only ask for erasure, at the end of the notice period. We confirm this to you. Ordinary service fees remain payable until the contract ends. We charge no switching or early termination fee for a switch under this section and refund prepaid service fees for the period after termination pro rata. Mandatory switching and retrieval rights take precedence over conflicting access restrictions in section 6.6.

12. Intellectual property

12.1 We and our licensors keep all rights in the Service and the documentation. For the term of the contract we grant you the non-exclusive, non-transferable right to access and use the Service within the limits of your plan, including making it available to App Users through your apps.

12.2 You do not copy, decompile or reverse engineer the Service, except where mandatory law allows it.

12.3 If you give us suggestions or feedback, we may use them freely and without payment. You do not include confidential information of your own in them.

12.4 If a third party claims that your use of the Service in line with the contract infringes its rights, you tell us without undue delay. We will, at our choice, obtain the right for you to continue, change the Service so that it no longer infringes, or, if neither is reasonable, terminate the contract and refund prepaid fees pro rata. Section 15 applies to claims for damages.

13. Confidentiality

Each party keeps the other’s non-public information confidential where it is marked as confidential or is evidently confidential, uses it only for the contract, and protects it with appropriate care. This applies for three years after the contract ends. It does not apply to information that is public, was already known, was developed independently or must be disclosed by law. Section 9 and the Data Processing Agreement govern Customer Data.

14. Defects

14.1 We remedy defects of a paid plan within a reasonable time after you report them with a description that lets us reproduce them.

14.2 Liability without fault for defects that already existed when the contract was concluded (§ 536a (1) alternative 1 BGB) is excluded.

14.3 For services supplied free of charge, statutory rules on defects and liability apply. A feature is not supplied free of charge merely because it is labelled beta, preview or experimental.

15. Liability

15.1 We are liable without limit for intent and gross negligence, for injury to life, body or health, for defects we fraudulently concealed, under a guarantee we have given, and under the German Product Liability Act and other mandatory law.

15.2 For slight negligence we are liable only if we breach a material obligation, meaning an obligation whose fulfilment makes the proper performance of the contract possible and on which you may regularly rely. In that case our liability is limited to the damage that is foreseeable and typical for this kind of contract.

15.3 Liability under section 15.2 is limited to the loss that was foreseeable and typical for this type of contract when the contract was concluded. No fixed annual monetary cap applies.

15.4 Section 14.3 also applies to liability.

15.5 If damage was caused or increased because the measures under section 8.3 were not in place, this is taken into account as contributory fault to the extent provided by law (§ 254 BGB). This does not limit liability that cannot be excluded or limited under mandatory law.

15.6 The limits in this section also apply in favour of our legal representatives, employees and agents.

15.7 Statutory limitation periods apply.

16. Claims by third parties

If you act as a business, you indemnify us against legally enforceable third-party claims and reasonable defence costs to the extent caused by a breach of this contract for which you are responsible. This does not cover losses attributable to our own breach, fault or statutory responsibility, or fines and penalties imposed on us. We notify you promptly, allow you to participate in the defence and do not agree to a settlement at your expense without your consent, which must not be unreasonably withheld. This section does not apply to consumers.

17. Suspension and removal of content

17.1 We may suspend your access in whole or in part, or remove or disable content, if (a) you breach sections 2, 7, 8 or 18 and the measure is needed to stop the breach, (b) there is a security risk to the Service or to others, for example compromised credentials, (c) a law or an authority requires it, or (d) a payment is overdue as described in section 5.6.

17.2 We keep the measure proportionate and limit it to what is needed, for example to a single robot, app or key. Where it is reasonable we warn you first and set a deadline. Otherwise we tell you immediately afterwards, with the reasons and how you can respond. We lift the measure as soon as its reason has ended.

17.3 Fees remain due while access is suspended for a reason for which you are responsible.

18. Export control and sanctions

18.1 When using the Service you comply with the export control and sanctions laws of the European Union and Germany and with any other such laws that apply to you.

18.2 You must not use or make the Service available in a way prohibited by applicable German or European Union export control or sanctions law, including applicable measures implementing United Nations sanctions and restrictions concerning ownership, control, destinations or end use. Other jurisdictions’ restrictions apply only to the extent legally applicable and compatible with mandatory European Union law.

18.3 You do not use the Service for military end use or in connection with weapons of mass destruction or their delivery systems, and you do not make it available to anyone in breach of section 18.2.

18.4 We may refuse, suspend or end performance without liability where performing would breach such laws. This does not exclude liability under section 15.1 or any non-excludable rights.

19. Changes to these Terms

We publish changes to these Terms in the console. The owner can accept them until the end of the current term for a paid plan, or within 7 days of publication for the Basic plan. Until the owner accepts them, the existing Terms continue to apply. If the changes have not been accepted by that date, access to the console and to the console tools of the MCP server is limited to accepting the changes; robots, apps and app users are not affected. The console shows a pending restriction prominently. Accepting the changes lifts the restriction immediately, and the new Terms apply from acceptance.

20. Reporting unlawful content

Anyone may report content on the Service that they consider unlawful to support@fleetless.dev. Please explain why you consider the content unlawful, identify its exact location in the Service and provide your name and e-mail address unless the law permits an exception. Please state that you believe in good faith that the information in your report is accurate and complete. We acknowledge reports and communicate our decision and available redress as required by law. Reports are assessed by people. You may contact us at support@fleetless.dev in German or English.

We decide on reports in a timely, diligent, non-arbitrary and objective manner. If we restrict content or access, we inform the customer concerned of the restriction, its reasons and the available redress as required by law. If information comes to our attention that gives rise to a suspicion that a criminal offence involving a threat to the life or safety of persons has taken place, is taking place or is likely to take place, we inform the competent authorities. Our point of contact for authorities and users is named in the Legal Notice.

21. Governing law and disputes

21.1 German law applies. The UN Convention on Contracts for the International Sale of Goods (CISG) does not apply.

21.2 If you are not a consumer and your registered office is in the European Union, the European Economic Area, Switzerland or the United Kingdom, the courts with jurisdiction for our registered office have exclusive jurisdiction, provided that the parties may validly agree on that jurisdiction under applicable law. In exclusively domestic German cases, this applies only if you are a merchant (Kaufmann), a legal entity under public law or a special fund under public law. Otherwise, statutory jurisdiction applies.

21.3 If you are not a consumer and your registered office is outside the European Union, the European Economic Area, Switzerland and the United Kingdom, all disputes arising from or in connection with the contract are finally settled under the Arbitration Rules of the German Arbitration Institute (DIS), without recourse to the ordinary courts. This includes disputes about the validity of the contract. German law governs the arbitration agreement. The tribunal consists of one arbitrator. The seat of the arbitration is Hamburg, Germany, and its language is English. Either party may still ask a competent court for interim relief.

21.4 If you are a consumer, sections 21.2 and 21.3 do not apply to you. The choice of German law in section 21.1 does not deprive you of the protection of the mandatory provisions of the law of the country in which you have your habitual residence, and you may bring proceedings in the courts that have jurisdiction under the applicable law.

22. General

22.1 We send notices to the e-mail address of the organisation’s owner or to your billing address. You send notices to the contact named in the Legal Notice.

22.2 You may transfer the contract or rights under it only with our consent; § 354a of the German Commercial Code remains unaffected. We may transfer the contract to an affiliated company or to a successor to the Fleetless business. We tell you in advance, and you may terminate with effect from the transfer if it is unreasonable for you. If you are a consumer, a transfer of this contract by us requires your consent. Statutory rights to assign claims remain unaffected.

22.3 Neither party is liable for a failure to perform that is caused by events beyond its reasonable control, for as long as they last. The affected party tells the other without undue delay.

22.4 These Terms, the documents named in section 1.5 and your order form the entire agreement on the Service. Changes to an Order Form must be made in text form. Individually agreed terms take precedence over these Terms.

22.5 If a provision is or becomes invalid, the rest remains effective.

22.6 These Terms are written in English. Where a German legal term is given in brackets, that term determines the meaning.

Annex 1 — Data Export Schedule

A1.1 This Schedule forms part of the contract (section 11.3) and applies on every plan, including the Basic plan. It identifies the data and digital assets you can export, the formats and interfaces, and the categories that are excluded.

A1.2 You can export the following data and digital assets of your organisation:

A1.3 Every export contains a description of its structure and the version of that structure.

A1.4 You can request an export in the console under Settings › General (“Organization data export”) or by e-mail to support@fleetless.dev.

A1.5 The following are not exportable or are excluded:

(a) live video and camera images that the Service transmits but does not store; they cannot be exported afterwards;

(b) passwords, API keys, server keys and bridge tokens in readable form; you create new credentials with your destination provider or in your own systems ;

(c) the software of the Service, our documentation and other assets protected by our intellectual property rights or constituting our trade secrets, to the extent the law permits their exclusion;

(d) data of other customers;

(e) data that was deleted before the export under your plan, your configuration or your instructions;

(f) records we keep for our own purposes, in particular routine server logs and our internal operator audit records. A routine server log entry cannot be retrieved from 30 × 24 hours after its event time; active copies are physically erased within the following 24 hours, and backup copies are deleted no later than 35 days after active deletion. Changes made and jobs started in your organisation during a support session appear in your audit log and job history as “Fleetless Support” and are exported with them. Information about personal data in these records is available under Article 15 GDPR.

A1.6 Retrieval and erasure:

(a) after a switch, you can retrieve your data for at least 30 days (section 11.4); when the contract ends for another reason, section 6.6 applies;

(b) after the retrieval period we erase the exportable data and digital assets, except records that we must keep by law, and confirm the erasure on request;

(c) residual copies in backups are deleted no later than 35 days after erasure from the active systems; until then they are protected and not used for ordinary processing ;

(d) if a backup is restored, data that had already been erased is erased again ;

(e) immediate erasure without a retrieval period takes place only if you delete your organisation and confirm the deletion.

A1.7 Infrastructure and governmental access:

(a) the infrastructure on which we store and process Customer Data is located in Germany and is subject to German and European Union law ;

(b) we give authorities of third countries access to non-personal Customer Data, or transfer such data to them, only where Chapter VII of Regulation (EU) 2023/2854 (Data Act) permits it. We inform you of such a request before complying with it, except where and for as long as this is necessary to preserve the effectiveness of law enforcement;

(c) the technical and organisational measures that protect Customer Data are described in Annex 2 to the Data Processing Agreement.

Permanent version 1.0

last updated 2026-11-05