Privacy Policy

How Buddi processes personal data under the GDPR.

This is a translation for your convenience. Only the German version is legally binding (Maßgeblich ist die deutsche Fassung): Datenschutzerklärung. Also available in Español.

Last updated: 29.10.2026

1. CONTROLLER

Controller within the meaning of the General Data Protection Regulation (GDPR):

Daniel Fernando Garrido Liere
c/o flexdienst – #22281
Kurt-Schumacher-Straße 74
67663 Kaiserslautern
Germany

Email (data protection): datenschutz@buddiapp.de
Email (general): kontakt@buddiapp.de

2. GENERAL INFORMATION

We process our users' personal data only to the extent necessary to provide the Buddi app and its functions. As a rule, processing takes place only with the user's express consent or where it is permitted by law.

3. WHAT DATA WE PROCESS

3.1 Account data:

• Email address
• Encrypted password (bcrypt via Supabase Auth)
• Language setting (one of 12 supported languages)
• Date the account was created and last changed

3.2 Family data:

• Names of the family members (entered by the user)
• Dates of birth / age
• Relationship to the main user
• Optional: avatar

3.3 Health data (Art. 9 GDPR – SPECIAL CATEGORY):

• Food logs
• Weight history (optional)
• Medication reminders (optional)
• Cycle data (optional)
• Training data (optional)

We process this data EXCLUSIVELY on the basis of your express consent under Art. 9(2)(a) GDPR. You can withdraw this consent at any time with effect for the future.

3.4 Financial data:

• Expenses and budgets entered manually
• Uploaded receipts (OCR-processed via Google Cloud Vision)
• Contract data (uploaded by the user)
• NO bank details or direct payment data

3.5 Household data:

• Task allocation
• Inventory of household appliances
• Maintenance reminders

3.6 Chat data with Buddy (AI assistant):

• Content of the conversations
• Timestamps
• Language of the conversation

3.7 Technical data:

• Device information (anonymised)
• Browser type and version
• Anonymous usage statistics

3.8 Pension check NRW (free appointment request about the Altersvorsorgedepot):

On buddiapp.de/en/pension-check (German: buddiapp.de/vorsorge-check, Spanish: buddiapp.de/es/chequeo-jubilacion) you can work out the state top-ups for the Altersvorsorgedepot and request a free appointment. The calculator runs entirely in your browser. What you enter in the calculator is neither sent to us nor stored.

Buddi gives no advice and arranges no insurance or financial investments. With your consent we pass your appointment request on to an adviser registered under § 34d/§ 34f GewO (cooperation partner), who contacts you to arrange an appointment.

For the appointment request we process:

• first and last name
• email address
• optional: phone number
• postcode (only postcodes in North Rhine-Westphalia; for any other postcode we store nothing)
• preferred time for being contacted (mornings, afternoons, evenings or any time)
• language of the emails
• where the visit came from, if the link carries a campaign tag (e.g. "video"), with no link to you as a person
• time and version of your consent, time of confirmation and, if applicable, of withdrawal (proof of consent); every consent, confirmation and withdrawal is also kept in a log that cannot be changed afterwards
• to prevent abuse, a checksum (hash) of your IP address that changes every day; we do not store the IP address itself

The purpose is passing your appointment request on to the registered adviser (cooperation partner), so that they contact you by email or, if given, by phone to arrange an appointment. A confirmation link checks that the address is yours (double opt-in); only after the confirmation do we pass the request on. For that we receive the confirmed request by email in our Google Workspace mailbox (section 5.9) and forward it to the adviser. If an address makes a new request after a withdrawal, the earlier proof stays unchanged; the new details are only taken over when the new confirmation link is clicked, and are otherwise deleted after 30 days.

The legal basis is your consent under Art. 6(1)(a) GDPR; for the abuse protection, our legitimate interest in a secure form under Art. 6(1)(f) GDPR.

Recipient: an adviser registered under § 34d/§ 34f GewO (cooperation partner). Once received, the adviser processes your details under their own responsibility. Beyond that we do not pass the details on to anyone. They are stored separately from the data of the Buddi app and are not linked to a Buddi account or a family profile. Emails are sent through our processor Resend (section 5.8), storage is with Supabase (section 5.1), and confirmed requests are received through Google Workspace (section 5.9).

You can withdraw your consent at any time with effect for the future, through the link "Withdraw request" in every email or by email to datenschutz@buddiapp.de. If the request had already been passed on, we inform the adviser of the withdrawal. This does not affect the lawfulness of processing before the withdrawal. How long we keep the details is set out in section 6.

4. PURPOSES OF PROCESSING

• Providing the Buddi app and its functions (Art. 6(1)(b) GDPR – performance of a contract)
• AI-supported personalised recommendations (Art. 6(1)(a) GDPR – consent)
• Passing an appointment request on to a registered adviser (Pension check NRW, section 3.8) (Art. 6(1)(a) GDPR, consent)
• Processing health data for nutrition and wellness support (Art. 9(2)(a) GDPR – express consent)
• Improving our service (Art. 6(1)(f) GDPR – legitimate interest)
• Compliance with legal obligations (Art. 6(1)(c) GDPR)

5. PROCESSORS AND DISCLOSURE OF DATA

We do not sell your personal data and – apart from the random click ID described in section 5.6 – do not pass it on to third parties for advertising purposes. Processors (e.g. AI providers) receive data only to the extent necessary to provide the function.

We use the following processors (all GDPR-compliant):

5.1 Supabase Inc.

• Purpose: database hosting, authentication
• Region: Frankfurt (EU)
• Data processing agreement under Art. 28 GDPR concluded

5.2 Cloudflare Inc. (USA)

• Purpose: web hosting, CDN, DDoS protection
• Standard contractual clauses under Art. 46 GDPR

5.3 Anthropic PBC (USA)

• Purpose: AI processing with Claude for food photos and detailed advice answers, and as a fallback for chat, photos and plans when Google Gemini does not respond
• Data is NOT used for training
• Standard contractual clauses

5.4 Google LLC (USA)

• Purpose: Gemini for chat answers, the analysis of photos and the weekly plans; Google Cloud Vision for text recognition in letters and documents
• Standard contractual clauses

5.5 Groq, Inc. (USA)

• Purpose: converting voice messages into text and reading the answer aloud, and as the last fallback for food photos and nutrition plans when Google and Anthropic do not respond
• Standard contractual clauses

Automatic quality check of the answers: so that Buddy does not give wrong information, we check his answers automatically. For this, the answer is sent to Google or Anthropic a second time together with your question. We first replace first names, email addresses, phone numbers and account numbers with placeholders. We keep conspicuous answers in this form for at most 90 days and then delete them. Basis: Art. 6(1)(f) GDPR (our interest in correct answers).

5.6 Affiliate links and click statistics (Amazon, Awin, financeAds, CHECK24):

Links on which Buddi earns a commission are marked with "Werbung" (advertising) and *. Buddi shows no such links in children's profiles. Only when you actively tap such a link does the provider's page open in your browser or in its app.

• Click statistics at Buddi: for Amazon links we store only the provider, the partner, the place in the app, the link without personal parameters and the time, without any user, family or member ID. For links via Awin, financeAds and CHECK24 we additionally store a random click ID (SubID) and may store the ID of your account and your family in order to attribute a commission. Basis: Art. 6(1)(f) GDPR (settling the commissions that keep Buddi free).
• Passed to the partners: we share NO personal data with these partners other than the click-tracking parameter. For Amazon this is only our partner ID (tag) in the link; for Awin, financeAds and CHECK24 the random click ID.
• Third parties: Amazon (Amazon Europe Core S.a r.l., Luxembourg), Awin AG (Berlin), financeAds GmbH & Co. KG (Nuremberg) and CHECK24 Vergleichsportal GmbH (Munich) collect their own data and set their own cookies when their pages are opened. These companies are responsible for this themselves; their privacy policies apply.

5.7 Open Food Facts (France):

For barcode scanning we send ONLY the barcode, NO user data.

5.8 Resend, Inc. (USA)

• Purpose: sending the confirmation emails and the confirmed appointment requests of the Pension check NRW (section 3.8)
• Data: email address, content of the email, time and delivery status
• Data processing agreement under Art. 28 GDPR
• Transfer to the USA based on the EU Commission's adequacy decision on the EU-US Data Privacy Framework of 10.07.2023 (Art. 45 GDPR); Resend, Inc. is certified under the EU-US Data Privacy Framework

5.9 Google Workspace (Google)

• Purpose: Buddi's mailbox that receives confirmed appointment requests and withdrawals of the Pension check NRW (section 3.8) before we forward them to the adviser
• Data: content of these emails (name, email address, phone number if given, postcode, preferred time, times of consent and confirmation)
• Data processing agreement under Art. 28 GDPR (Google Workspace data processing terms)
• Transfer to the USA possible; based on the EU Commission's adequacy decision on the EU-US Data Privacy Framework of 10.07.2023 (Art. 45 GDPR)

5.10 Functional Software, Inc. (Sentry) (USA)

• Purpose: technical error and crash reports from the app and our server functions
• Data: error message and technical trace of the error, app version, device model and manufacturer, operating system and its version, name of the app screen, role in the family account and a random internal ID of the family (for errors in server functions also of the account or family member)
• NO names, email addresses, chat content or entries; we instruct Sentry not to store the IP address
• Standard contractual clauses

5.11 650 Industries, Inc. (Expo) (USA)

• Purpose: delivering push notifications
• Data: the device's push token, title and text of the notification (e.g. the title of a calendar appointment) and the random internal ID of the account the notification is meant for
• Standard contractual clauses

5.12 REWE Markt GmbH (Cologne) – passing the shopping list to the REWE shop

• Only when you tap «Liste an REWE schicken» / «Bei REWE einkaufen» in the shopping list
• Your device sends the open entries of the shopping list (item and quantity) and a random request ID directly to REWE, so that REWE can turn them into a product selection in its shop. As with any page request, REWE sees your device's IP address
• NO names, email addresses, family or account IDs
• The request contains our Awin partner ID (see 5.6)
• REWE processes the data under its own responsibility; REWE's privacy policy applies
• Legal basis: Art. 6(1)(b) GDPR (you request the hand-over yourself)

6. STORAGE PERIOD

• Account data: until the user deletes the account
• Family data: until the account is deleted
• Health and financial data: until the account is deleted
• Chat data: 90 days (to keep context), then deleted
• Technical logs: 30 days
• Pension check NRW, appointment requests not confirmed: 30 days after the last confirmation email, then deleted
• Pension check NRW, new request after a withdrawal, not confirmed: the new details 30 days after the last confirmation email, then deleted
• Pension check NRW, confirmed appointment requests: name, phone number, postcode, preferred time and origin deleted 6 months after confirmation
• Pension check NRW, after a withdrawal: name, phone number, postcode, preferred time and origin deleted at once
• Pension check NRW, proof of consent: the email address, the times of consent, confirmation and withdrawal and their log, 3 years (§ 195 BGB) after the withdrawal or after the 6 months, then deleted
• Pension check NRW, checksum of the IP address: 30 days; abuse counter: 1 day
• Pension check NRW, emails with confirmed requests in Buddi's mailbox (Google Workspace): deleted once the request has been forwarded to the adviser, at the latest after 6 months
• At the adviser (cooperation partner): according to their own privacy policy
• Statutory retention obligations: up to 10 years

7. YOUR RIGHTS UNDER THE GDPR

7.1 Right of access (Art. 15)

You can request information about the data we process about you.

7.2 Rectification (Art. 16)

You can have incorrect data corrected.

7.3 Erasure / right to be forgotten (Art. 17)

Directly in the app: Settings → Delete account.

7.4 Restriction of processing (Art. 18)

7.5 Data portability (Art. 20)

Directly in the app: Settings → Export data.

7.6 Objection (Art. 21)

7.7 Withdrawal of consent

You can withdraw any consent you have given at any time.

7.8 Right to lodge a complaint:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen Kavalleriestraße 2-4, 40213 Düsseldorf Email: poststelle@ldi.nrw.de Phone: +49 211 38424-0

8. CHILDREN AND MINORS

The Buddi app is designed for families. When family members under 16 are added, the express consent of the person with parental responsibility is required (Art. 8 GDPR). This consent is obtained in the app when a minor member is added.

We do NOT process data of children under 16 without the corresponding parental consent.

9. DATA SECURITY

We use industry-standard security measures:

• TLS/SSL encryption for all connections
• bcrypt-encrypted password storage
• Row-Level Security (RLS) at database level
• Regular security audits

10. INTERNATIONAL DATA TRANSFERS

Some of our processors are based outside the EU/EEA (in particular in the USA). The transfer is based on:

• EU standard contractual clauses (Art. 46 GDPR)
• GDPR-compliant safeguards

11. NO AUTOMATED DECISIONS

We use AI for recommendations and assistance, but make NO legally binding automated individual decisions about you (Art. 22 GDPR).

12. CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend this policy. Users will be informed by email of material changes.

13. CONTACT

Questions about data protection:

Email: datenschutz@buddiapp.de

Daniel Fernando Garrido Liere
c/o flexdienst – #22281
Kurt-Schumacher-Straße 74
67663 Kaiserslautern