Privacy policy

Operator

Name

Sergio Amenta

Service address

Kellerswiesen 3, 76707 Hambrücken

Country

Deutschland

Contact

sergioamenta@protonmail.com

Controller and contact

The controller responsible for processing your personal data within the meaning of the General Data Protection Regulation (GDPR) is the operator named above. For any questions about data protection and to exercise your rights, contact us using the contact details given above, by e-mail or via the support function in the app. We have not appointed a data protection officer because we are not legally required to do so (Art. 37 GDPR, Section 38 BDSG).

Details in the processing overview

Some details depend on which service providers we use and may change. We therefore list them together in the processing overview on this page: – hosting provider and server location, – service providers and processors we use, including the push services that may be involved in push notifications, – transfers to countries outside the European Union and the European Economic Area and the safeguards in place, – the specific retention periods for server logs, account data, backups and support requests, – a summary of purposes and legal bases, – the data protection supervisory authority competent for us. The processing overview on this page forms part of this privacy policy.

No ads, no tracking

We do not show ads, do not sell data and do not use any analytics, tracking or marketing tools. The website and the app do not embed any third-party content: we serve fonts, program files and graphics ourselves, and a strict Content Security Policy prevents the pages from loading content from other servers. We do not analyse your financial data for our own purposes. We calculate overviews, reports and analyses solely to show them to you and to the people you share a book with.

Visiting the website and server logs

When you open the website or the app, your browser sends technically necessary data to our server. An upstream web server (reverse proxy) logs every request, in particular: – the IP address of your device, – the date and time of the request, – the requested address (path) and the type of request, – the HTTP status code and the amount of data transferred, – information about your browser and operating system (user agent). We need this data to deliver the pages, to detect and fix faults and to fend off attacks. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the secure and stable operation of minea. We delete the logs automatically after a short fixed period, which is stated in the processing overview on this page. Only if individual entries are needed to investigate a specific security incident do we keep those entries longer, until the incident has been resolved. Error logs of our application contain no content of your books and no passwords. In individual cases, for example when an e-mail could not be delivered, they contain your internal account ID.

Protection against attacks and misuse

To prevent passwords from being guessed by mass trial and to keep the service from being overloaded, we limit requests: – Our sign-in service counts in memory how many requests come from an IP address within a short time. These counters are discarded after a short time and are not stored permanently. – After repeated failed sign-in attempts, a protection program on the server automatically blocks the IP address concerned for a limited time. It uses the server logs for this. – Certain functions have limits, for example for invitations, confirmation e-mails and support requests. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is protecting your account, the accounts of other users and the service.

Registration, account and sign-in

To use minea you need an account. For this we process: – your e-mail address, for signing in, for messages about your account and so that others can invite you to shared books, – your display name, if you provide one; it is optional and visible to people you share books with, – your password, but only as a hash (bcrypt with an individual salt); we do not store the password itself and cannot see it, – a randomly generated internal account ID, the times of registration and changes, the confirmation status of your e-mail address and counters we use to limit the number of confirmation e-mails, – which version of the terms of use you accepted and when, and your confirmation that you are at least 16 years old. When you register and when you change your e-mail address, we send you a confirmation link. Until you confirm, we store a new address as pending; your existing sign-in remains unchanged in the meantime. Some functions, such as sharing books, are only available once your e-mail address is confirmed. When you sign in, we check your e-mail address and password and set a session cookie (see “Storage on your device”). In the app you can sign out all other devices using your password. You can change your display name, e-mail address and password in your profile at any time. The legal basis is Art. 6(1)(b) GDPR (performance of the contract of use). Storing your acceptance of the terms of use is additionally based on Art. 6(1)(f) GDPR; our legitimate interest is being able to prove that the contract was concluded.

E-mails from minea

We only write to you when it is necessary for your account or the service: – to confirm your e-mail address when you register and when you change it, – to reset your password when you request it, – when someone invites you to a shared book and your e-mail address is confirmed, – in individual cases, about important changes to the service, this privacy policy or the terms of use, and about decisions on reported content or on your account. We do not send newsletters or advertising. Links for confirming or resetting contain a random one-time code and are only valid for a limited time. We store the code only as a hash and delete it after use or expiry. We use a provider of transactional e-mails as a processor to send e-mails. It receives your e-mail address, the content of the message and technical delivery data. Who this provider is and whether data is transferred to a third country is stated in the processing overview on this page. The legal basis is Art. 6(1)(b) GDPR; for notifications about decisions on reported content, additionally Art. 6(1)(c) GDPR in conjunction with Art. 16 and 17 DSA.

Household books and entries

Your household books are at the heart of minea. We store what you record in them: – entries with amount, date, label, category, note and tags, – recurring entries, fixed costs, budgets, goals, carry-overs and your own categories, – names, settings and order of your books, – for each entry, who recorded it (internal account ID and display name), and technical data such as modification times, versions and receipts of recent changes that we need to synchronise your devices. From this data we calculate overviews, reports and analyses. You can change or delete entries, budgets and goals at any time. A deleted entry disappears from your book immediately. So that it cannot return via another device or as a recurring entry, we keep an internal deletion marker in the book until you delete the book or your account; this marker may contain the previous details of the entry and is not visible in the app. You can delete additional books individually; your main book is deleted together with your account. Your books are stored on our server so that you can use them on several devices and together with others. Transfers are encrypted, but the content is not end-to-end encrypted on the server. We only look at content where this is necessary for operating the service, answering your support request, reviewing a report or complying with a legal obligation. Please note: household data can allow conclusions about sensitive areas of life, for example your health, your religious affiliation (for example via church tax) or memberships (for example via trade union fees). You decide what you record. We do not analyse content to draw such conclusions. The legal basis is Art. 6(1)(b) GDPR.

Receipts and attachments

You can upload receipts for entries as images (JPG, PNG) or as PDF files. We store the file unchanged on our server with the book concerned. Everyone with access to the book can view and download it. Receipts often contain further personal data such as names, addresses, customer numbers or bank details, and photos can contain metadata such as where and when they were taken. We do not remove such information. So only upload what you really need, and black out information you do not need beforehand. Files that are not attached to any entry, for example after you cancel saving or when you remove a receipt, are deleted automatically after a short time. If you delete a whole book, we delete its receipts immediately. The legal basis is Art. 6(1)(b) GDPR.

Shared books and invitations

As the owner of a book you can invite other people with read or write access. To do this, you enter their e-mail address. You can only invite people who already have a minea account under that address; the inviting person learns whether an account exists for the address entered. The invitation appears in the invited person's app and, if they wish, also as a push notification. If their e-mail address is confirmed, we also send them an e-mail with the inviting person's display name, the name of the book, the intended access, the expiry date and a link to the invitation. The invitation is only accepted after signing in to minea. For an invitation we store the book, the display name of the inviting person, the e-mail address of the invited person, the intended access right, the status and the period of validity. If the person accepts, we store their membership with access right, display name, e-mail address and time of acceptance. Who sees what: – All members of a shared book see all content of that book, including the receipts and the display name of the person who recorded an entry. – The owner additionally sees the display names, e-mail addresses and access rights of the members, as well as pending invitations. – The invited person sees the name of the book and the display name of the inviting person. – Participants receive notifications about changes in the book, for example that an item was changed. Access rights can be changed or withdrawn at any time, and members can leave a shared book at any time. After that there is no more access; entries a member recorded remain in the book. We delete invitations automatically some time after they expire. The legal basis is Art. 6(1)(b) GDPR. Where we process the e-mail address of an invited person before they have accepted the invitation, and show the inviting person whether an account exists for an address, this is based on Art. 6(1)(f) GDPR; the legitimate interest is enabling shared household books. The invited person decides whether to accept the invitation.

Notifications and push notifications

In the app we show you notifications about activity in shared books, such as new invitations, changed access rights or changed items, as well as notes about budgets and savings goals, for example when a budget for the current month is 80% used or a savings goal has been reached. In shared books, all members receive these notes. Notifications contain the name of the book and a short description, such as the name of the category or savings goal, but no amounts. We store them with your account and delete them automatically after a fixed period. Push notifications are optional. Only if you enable them in the app and allow them in your browser does your browser create a push address (endpoint) with associated keys, which we store with your account. Push messages are delivered via the push service of your browser or operating system vendor; your browser determines which service that is. Each message is encrypted so that only your browser can read it, and it only contains a general note about new activity, no names, amounts or booking details. The push service receives the push address, the encrypted message and technical data such as time and size. Which push services may be involved and whether data is transferred to third countries is stated in the processing overview on this page. You can disable push at any time in the app or in your browser settings. When you sign out, the app disables push for that device. We automatically delete push addresses that have not been renewed for a long time or that the push service reports as invalid. The legal basis is Art. 6(1)(b) GDPR, because you request the function yourself. The storage in your browser required for it is permitted without consent under Section 25(2) No. 2 TDDDG.

Support, reports and blocking

Support requests: When you write to us via the support function in the app, we store the subject, message, time and processing status with your account, as well as our reply, which you see in the app. We only store what you write yourself, no copies of your books. Please do not send us passwords, full bank details or sensitive receipts. When you write to us by e-mail or through the contact form on the help page, we process your e-mail address, your name if you provide it, and the content of your message. Messages from the contact form are sent to our mailbox via our transactional e-mail provider; we do not store them in minea. We also forward requests and reports from the app to our mailbox by e-mail via the same provider, with the subject, message, reference number and your account e-mail address as the reply address, so that we can also answer you by e-mail. Reports: Using “Report / Block” you can report a person you share a book with or from whom you received an invitation. In addition to the subject and message, we store which person and which book the report concerns. A human reviews every report. We only disclose your identity to the reported person if this is strictly necessary to explain a decision (Art. 17(3)(b) DSA). Blocking: When you block a person, we store this together with the name or e-mail address under which the person was shown to you and the time. Sharing between the two of you and pending invitations end, and you can no longer invite each other. The blocked person does not receive a separate message about this, but loses access to your books. You can lift a block at any time. The legal bases are Art. 6(1)(b) GDPR for support requests and blocking and, for reports and their handling, Art. 6(1)(c) GDPR in conjunction with Art. 16 and 17 DSA and Art. 6(1)(f) GDPR; our legitimate interest is protecting users and preventing misuse. How long we keep support requests and reports is stated in the processing overview on this page. When you delete your account, we remove the link to your account from your requests and reports and from reports concerning you. We keep the subject, message and status until the period stated in the overview expires, so that reports and our decisions on them remain traceable (Art. 6(1)(f) GDPR); after that we delete them.

Storage on your device

minea stores some information in your browser. In each case this is strictly necessary to provide the service you have expressly requested. Under Section 25(2) No. 2 TDDDG we do not need your consent for this, which is why there is no cookie banner. We do not use cookies or similar technologies for analytics, advertising or tracking. The public website only stores the colour scheme you explicitly choose there; it then also applies in the app. Cookie: – “mona_session” is a session cookie set by our sign-in service when you sign in. It contains a signed statement of which account is signed in and when the sign-in expires, as well as a check value that makes sessions invalid, for example after a password change. Without the “stay signed in” option it only lasts for the current browser session, and the sign-in ends after 12 hours at the latest. With “stay signed in” it is kept for up to 90 days. It is deleted when you sign out. Scripts cannot read the cookie (HttpOnly), and it is only sent over encrypted connections. Local browser storage: – settings such as colour theme and language, your choice about automatic sign-in by a password manager, and the most recently selected book and month, – a copy of your session data (for example display name and list of your books) and a cache of the most recently viewed monthly overviews and reports of your books, so that minea starts quickly and you can read them offline, – a queue of entries you saved offline until they are synchronised with the server, – a note of which account push is enabled for on this device, – the app's program files (service worker and cache) so that minea also starts without a connection; they contain no personal data. When you sign out, the app deletes the cached book data of your account from that device. Only entries that have not yet been synchronised are kept so they are not lost; the app points this out before you sign out. They are transferred as soon as you sign in again on that device. When you delete your account, the app removes that account's data from the device on which you carry out the deletion. You can also delete all stored data at any time in your browser settings; entries that have not been synchronised will then be lost. Please always sign out after use on other people's or shared devices. The legal basis for the further processing of this data is Art. 6(1)(b) GDPR.

Recipients and service providers

We only pass on your data where this is necessary for minea or where we are legally obliged to do so: – Hosting: a hosting provider operates our server and stores the data on our behalf (processing on behalf under Art. 28 GDPR). – E-mail delivery: a provider of transactional e-mails as processor (see “E-mails from minea”). – Mailbox: support requests, reports and contact messages arrive in our mailbox at Proton AG (Geneva, Switzerland), which operates it for us as a processor. – Push services: only if you enable push, the push service of your browser or operating system vendor (see “Notifications and push notifications”). – Other users: people you share a book with see its content as described above. – Authorities and courts: only where we are legally obliged to (Art. 6(1)(c) GDPR), for example on the basis of an order under Art. 9 or Art. 10 DSA, or where we must report a suspected criminal offence involving a threat to the life or safety of persons under Art. 18 DSA. – Advisers: where necessary to establish, exercise or defend legal claims, to advisers bound by professional secrecy such as lawyers (Art. 6(1)(f) GDPR). Processors only process your data on our instructions. The processing overview on this page names the service providers we use. We do not sell data or pass it on for advertising purposes.

Transfers to third countries

If personal data is transferred to a country outside the European Union and the European Economic Area, this only happens under the conditions of Art. 44 to 49 GDPR, in particular on the basis of an adequacy decision of the European Commission (Art. 45 GDPR) or standard contractual clauses (Art. 46(2)(c) GDPR). Whether this happens at minea, to whom and on what basis is stated in the processing overview on this page. You can request a copy of the relevant safeguards using the contact details given above. For push notifications, your browser determines which push service is used and where it is based.

Retention, backups and deletion journal

We store personal data only for as long as necessary for the respective purpose. The specific periods are stated in the processing overview on this page. – We store account and book data for as long as your account exists. If you delete a book, we remove it from the live system together with all its entries and receipts. If you delete individual entries, an internal deletion marker remains in the book until you delete the book or your account (see “Household books and entries”). – We delete server logs automatically after a short fixed period. – We keep support requests and reports as long as necessary to handle them and for follow-up questions, at most until the end of the period stated in the overview. If you delete your account, we remove the link to you before then. – We automatically delete short-lived data such as links for confirming or resetting, invitations, notifications and push addresses once they have expired or a fixed period has passed. Backups: To make sure no data is lost in the event of a technical fault, we regularly back up the entire data set. Each backup is deleted after a fixed period while new backups take its place (rotation). Deleted data may therefore remain in older backups until that period ends. We use backups only to restore operation after a fault. Deletion journal: So that a deleted account does not come back if we have to restore an older backup, we keep a deletion journal. For each deleted account it only contains a pseudonymous check value (hash) of the internal account ID, the time of deletion and check values of the related storage folders, but no e-mail address, no name and no financial data. When we restore a backup, we use the journal to immediately remove any deleted accounts still contained in it. The entries in the deletion journal are chained to one another and are therefore not deleted individually. Once no backup containing the account exists any more, an entry can no longer be linked to any person. The legal basis is Art. 6(1)(c) GDPR in conjunction with Art. 17 GDPR, because we must keep deletions permanently effective, and Art. 6(1)(f) GDPR.

What happens when you delete your account

You can delete your account in the app at any time. The deletion is carried out immediately after you confirm it: – Your access data (e-mail address, display name, password hash) is deleted, as are any open links for confirming or resetting. Your session ends. – Your own books are deleted with all entries, budgets, goals and receipts. This also applies to books you shared with others, including entries other people recorded in them; the members lose access. – Your memberships in other people's books, your invitations, notifications, push addresses and blocks are deleted. – For support requests and reports that you submitted or that concern you, we remove the link to your account; their content is deleted when the period stated in the overview expires (see “Support, reports and blocking”). – Entries you recorded in other people's books belong to their household book and remain there. However, we remove the link to you: instead of your name, it only says “Deleted account”. Content you entered or uploaded yourself, such as labels, notes, tags or receipts, remains unchanged. The legal basis for keeping these entries is Art. 6(1)(f) GDPR; the legitimate interest of the other members is a complete and traceable household book. – Your data remains in backups until they are rotated. The deletion journal ensures that your account does not return when a backup is restored. Export anything you want to keep beforehand. On the device on which you carry out the deletion, the app removes your account's stored data; on other devices you can delete cached data in the browser settings.

Your rights

You have the following rights regarding personal data concerning you: – Access (Art. 15 GDPR): you can find out which data we process about you and receive a copy. – Rectification (Art. 16 GDPR): you can change your display name, e-mail address and password yourself in your profile, and entries directly in your books. – Erasure (Art. 17 GDPR): you can delete entries, books and your entire account yourself in the app. – Restriction of processing (Art. 18 GDPR). – Data portability (Art. 20 GDPR): you can export your books yourself at any time as a CSV file and as a complete backup in JSON format including receipts. We provide further data on request in a common, machine-readable format. – Objection (Art. 21 GDPR): see the next section. – Withdrawal of consent (Art. 7(3) GDPR): where processing is based on your consent, you can withdraw it at any time with effect for the future. This does not affect the lawfulness of processing carried out before the withdrawal. To exercise your rights, use the contact details given above. So that we do not disclose data to unauthorised persons, we may ask you to verify your identity, for example by writing to us from your account's e-mail address or by making the request via the support function in the app. We usually respond within one month (Art. 12(3) GDPR).

Your right to object

Where we process data on the basis of Art. 6(1)(f) GDPR (legitimate interests), you have the right to object at any time on grounds relating to your particular situation (Art. 21(1) GDPR). We will then no longer process the data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims. Send your objection to the contact details given above. We do not carry out direct marketing.

Complaint to a supervisory authority

If you believe that we are not processing your data lawfully, you can lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement. The supervisory authority competent for us is named in the processing overview on this page. We would appreciate it if you contacted us first so that we can resolve your concern.

Do you have to provide data?

You are not legally or contractually obliged to provide us with personal data. However, without an e-mail address and password we cannot set up an account for you, and without an account you cannot use the app. When you visit the website, processing the log data is technically necessary. The display name is optional, and you decide which entries and receipts you store.

No automated decisions and no profiling

We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (Art. 22 GDPR), and we do not create profiles. Reports and analyses in minea are calculations for you, not an assessment of you as a person. The automatic, temporary blocking of an IP address after repeated failed attempts serves security only and has no further consequences. Reports and decisions about content or accounts are always reviewed by a human.

Data security

We protect your data with technical and organisational measures under Art. 32 GDPR, including: – encrypted transmission via HTTPS (TLS), – passwords and one-time codes stored only as hashes, – signed session cookies that scripts cannot read, – access control for each book with read and write rights, – request limits and automatic blocks after repeated failed attempts, – a strict Content Security Policy without third-party content, – restrictive access permissions for data files on the server, – regular backups whose completeness we check with checksums. No system is completely secure. You can help by using a strong password only for minea, signing out on other people's devices and reporting anything unusual to us. If you suspect that someone has access to your account, change your password and sign out all other devices in the app.

Minimum age

minea is intended for people aged 16 and over. Anyone younger may not create an account. If we learn that an account was created by a younger person, we will delete it.

Changes to this privacy policy

We update this privacy policy when minea, our service providers or the legal situation change. The version published on this page applies. We will inform you in good time in the app or by e-mail about material changes.

Data processing details

Hosting

Virtual server at DeinServerHost, located in Germany

Email delivery

Resend (delivered via the EU region Ireland) for verification, password and invitation emails and for support requests and contact messages to our mailbox; mailbox for support requests, reports and contact messages: Proton AG, Geneva (Switzerland)

Push notifications

Only if you enable them: push service of your browser vendor, for example Google, Mozilla, Apple or Microsoft; content is transmitted in encrypted form

Transfers to third countries

Resend is a company based in the United States; the transfer is covered by a data processing agreement with standard contractual clauses. Push services may use servers outside the EU. Our mailbox is hosted by Proton AG in Switzerland; the European Commission has adopted an adequacy decision for Switzerland (Art. 45 GDPR).

Server logs

14 days

Account data and budget books

until your account is deleted

Backups

30 days, then overwritten

Support requests

until resolved, then at most 12 months

In-app notifications

90 days, at most the latest 100 notifications

Push addresses

90 days from the last renewal by your browser, then deleted

Book invitations

valid for 14 days

Confirmation and reset links

e-mail confirmation link 24 hours, password reset link 30 minutes

Unassigned receipts

24 hours after upload if they are not attached to an entry

Deletion journal

pseudonymous check value of deleted accounts; can no longer be linked to any person once the backup period has expired

Legal bases

Art. 6(1)(b) GDPR (account and budget books), (f) (security, abuse prevention, support), (c) (legal obligations)

Competent supervisory authority

The State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg (Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg); you may also contact any other supervisory authority