Privacy policy

How we process personal data under the EU General Data Protection Regulation (GDPR).

1. Controller

upup.berlin GmbH
Hauptstraße 13
10317 Berlin
Deutschland
Email: ezbts@upup.berlin
Phone: +49 151 285 98 131

2. Hosting

This website is hosted by ALL-INKL.COM – Neue Medien Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany. The host processes data on our behalf as a processor under a data processing agreement (Art. 28 GDPR). Servers are located in Germany. Legal basis: Art. 6 (1) (f) GDPR.

3. Access data / server log files

When you visit the website, the host automatically stores information in server log files: IP address, date and time, the requested page, browser type/version and operating system. This data is not merged with other sources and is used only for secure operation. Legal basis: Art. 6 (1) (f) GDPR.

4. Purchase & license delivery

When you buy a license we process the data you enter at checkout: email address, name/company (where provided), country, and — for business or larger orders — your billing address and VAT ID, together with order and tax details, to perform the contract, deliver your key by email and issue an invoice.

• Performance of the contract: Art. 6 (1) (b) GDPR.
• Invoicing and statutory retention: Art. 6 (1) (c) GDPR with § 147 AO, § 257 HGB.

Payment — PayPal

Payments are processed by PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, under its own responsibility; appropriate safeguards (EU standard contractual clauses) apply to any third-country transfer. See paypal.com/…/privacy. Legal basis: Art. 6 (1) (b) GDPR.

Invoicing — sevDesk

Invoices are created and stored in sevDesk (sevDesk GmbH, Hauptstraße 115, 77652 Offenburg, Germany), our processor under Art. 28 GDPR. Legal basis: Art. 6 (1) (c) GDPR.

VAT ID validation

If you enter an EU VAT ID, we validate it against the European Commission’s VIES service. Legal basis: Art. 6 (1) (c) GDPR.

5. Free trial & contact consent (ezBTS app)

If you start the optional 10-day free trial, we process the email address you enter and a device identifier of your remote, and record your consent to be contacted by upup.berlin GmbH (ezBTS) by email about ezBTS (consent text, time and IP stored for proof).

• Enabling/validating the trial: Art. 6 (1) (b) GDPR.
• Contacting you by email: your consent, Art. 6 (1) (a) GDPR.

You can withdraw your consent at any time with effect for the future, e.g. via ezbts@upup.berlin or the unsubscribe link. This does not affect prior lawful processing.

6. License activation

To activate a license or trial, the app sends your key (if any) and a stable per-app device identifier (Android ID) to our server, to bind the license to one device and prevent misuse. Legal basis: Art. 6 (1) (b) and (f) GDPR.

7. Cookies & reach measurement

Our website uses no tracking or advertising cookies and builds no cross-device profiles. For basic reach measurement we keep an anonymous, cookieless statistic (page visited, referrer/origin, optional UTM campaign parameters, device type and completed purchases). Recognition relies solely on a daily-rotating anonymous token (a hash of IP address and user agent with a per-day key); the IP itself is not stored, and identifying individuals or tracking beyond a single day is not possible. This statistic is stored only on our own server and not shared with third parties. Legal basis is our legitimate interest in privacy-friendly reach measurement (Art. 6 (1) (f) GDPR). The PayPal module at checkout may set cookies that are technically necessary to process the payment and prevent fraud.

8. Recipients

Data is shared only with the processors and payment/tax providers named above, only as necessary. We do not sell your data.

9. Retention

Invoice/accounting data is kept for the statutory periods (generally 10 years, § 147 AO / § 257 HGB); other data is deleted once no longer required or upon withdrawal of consent, unless a legal retention obligation applies.

10. International transfers

Where a provider (in particular PayPal) processes data outside the EU/EEA, this is based on an adequacy decision or appropriate safeguards such as the EU standard contractual clauses.

11. Your rights

You have the rights to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20) and objection (Art. 21); where processing is based on consent you may withdraw it any time (Art. 7 (3)). Contact ezbts@upup.berlin.

12. Right to complain

You may lodge a complaint with a supervisory authority, e.g. the Berlin Commissioner for Data Protection and Freedom of Information, or the authority of your residence.

Last updated: 2026-08-17. ← back