Privacy policy
Translation provided for convenience. In case of discrepancies, the German version prevails.
Last updated: 28 September 2026
This privacy policy complies with the GDPR and German data protection law
A plain, honest account of the little data we process
1. Controller and legal basis
Controller
Florian Hofmann
Flowcontrol by Florian Hofmann
Johannisstraße 13a
93059 Regensburg, Germany
Email: datenschutz@flowcontrol.de
Phone: +49 174 6010390
Legal basis for processing
We process your personal data on the following legal bases under Article 6 GDPR:
- Legitimate interest (Art. 6(1)(f)) — business communication and service provision
- Performance of a contract (Art. 6(1)(b)) — performance of our service agreements
- Consent (Art. 6(1)(a)) — marketing communication and optional services
- Legal obligation (Art. 6(1)(c)) — compliance with German and EU regulations
2. Information we collect
We only collect the information you provide to us voluntarily through our contact form :
Contact form data
When you fill in our contact form, we collect:
- Name (required field)
- Email address (required field)
- Phone number (optional)
- Company (optional)
- Message text (required field)
In addition, the form technically transmits your IP address, your browser identifier as well as the page and language from which the enquiry is sent. We use this information to prevent misuse and to match your enquiry.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in handling your enquiry) and Art. 6(1)(b) GDPR (steps prior to entering into a contract)
Retention period: See section 7, “Data retention”
Server log files
Each time our website is accessed, our system automatically records data and information from the requesting device. The following data is collected:
- IP address of the user
- Date and time of the request
- Page or file requested
- HTTP status code (success/error)
- Referrer URL (previously visited page)
- Browser type and version
- Operating system of the user
- Volume of data transferred
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the technical provision and security of the website)
Purpose: System security, error analysis, spam prevention, protection against misuse
Retention period: 7 days, then deleted automatically
Server location: Germany — hosting by Hetzner Online GmbH
Website and Cloud-Platform. We operate both on servers of Hetzner Online GmbH in Germany. For logging in to the Cloud-Platform we use Firebase Authentication by Google, Google Workspace for sending emails and Firebase Cloud Messaging for push notifications. Details are set out in the Cloud-Platform privacy notice.
Contact by email
If you contact us directly by email (info@flowcontrol.de or datenschutz@flowcontrol.de), we store:
- Email address
- Name (if provided)
- Content of the message
- Date and time of the message
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in handling your enquiry)
Retention period: See section 7, “Data retention”
3. How we use your information
We use the information collected through the contact form exclusively for:
Primary use
- Handling enquiries: replying to your enquiry by email or telephone
- Preparing quotes: providing information about our services
- Arranging appointments: coordinating consultation or service appointments
- Business communication: discussing potential business relationships
Legal basis
Processing is based on your legitimate interest in initiating a business relationship (Art. 6(1)(f) GDPR) and on steps prior to entering into a contract (Art. 6(1)(b) GDPR).
No marketing without consent
We do not use your data for advertising or newsletters unless you expressly agree to it. Contact form data is used only to handle your enquiry directly.
4. Sharing and disclosure of information
We do not sell, trade or rent your personal data to third parties.
Recipients of your data
Your contact form data is passed on to the following recipients:
-
Hosting provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany
Purpose: technical provision of the website and server operation -
Email provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Google Workspace)
Purpose: delivering your enquiry to our team and the confirmation of receipt to you - Authorised staff: to handle your business enquiry
All recipients are contractually bound to comply with the GDPR (data processing agreements under Art. 28 GDPR). The hosting provider is based in Germany. Google may also process emails in the USA; the legal basis is the EU-US Data Privacy Framework (Art. 45 GDPR) and the European Commission’s standard contractual clauses (Art. 46 GDPR). These recipients relate solely to the website and email. The systems operated for customers are covered by separate data processing agreements. Which service providers are used there is set out in section 10 and in the Cloud-Platform privacy notice.
No data transfer to third-party providers
We use exclusively self-hosted resources. Your IP address is not passed to external providers such as Google Fonts, CDN services or other tracking services. All website resources are loaded from our own server. There is one exception: if you explicitly load a YouTube video on a product page, a connection to Google is established — the details are in section 9.
Legal obligations
We may only disclose your information where this is required by law (for example in response to official requests or court orders).
5. Data security
We take the security of your personal data seriously and implement appropriate measures to protect it:
Technical safeguards
- Encryption of data in transit and at rest
- Secure servers and database protection
- Regular security updates and patches
- Access controls and authentication systems
- Network security monitoring
Organisational safeguards
- Staff training on data protection
- Limited access to personal data on a need-to-know basis
- Regular security audits and assessments
- Incident response procedures
Important note
Although we implement robust security measures, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security, but we undertake to protect your information using standard industry practices.
6. Your data protection rights (GDPR)
You have a number of rights regarding your personal data:
Your rights under the GDPR
Right of access (Art. 15)
Request access to your personal data and information about the processing
Right to rectification (Art. 16)
Correction of inaccurate or incomplete personal data
Right to erasure (Art. 17)
Request deletion of your personal data under certain conditions
Right to data portability (Art. 20)
Receive your data in a structured, commonly used format
Right to object (Art. 21)
Object to processing based on legitimate interests or to direct marketing
Right to restriction of processing (Art. 18)
Restrict the use of your personal data in certain circumstances
Right to lodge a complaint
You have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been infringed. The authority responsible for us is the Bavarian Data Protection Authority (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA), Promenade 18, 91522 Ansbach: www.lda.bayern.de. You may also contact the supervisory authority in your country of residence.
Communication preferences
- Unsubscribe from marketing communication at any time
- Choose your preferred communication channels
- Update your preferences for how often we get in touch
How to exercise your rights
To exercise any of these rights, please contact us at:
- Email: datenschutz@flowcontrol.de
- Phone: +49 174 6010390
- Post: Flowcontrol by Florian Hofmann, Data Protection Officer, Johannisstraße 13a, 93059 Regensburg
We will respond to your request within 30 days.
7. Data retention
We keep your contact form data only for as long as it is needed to handle your enquiry:
Retention periods
- Enquiries without a resulting contract: 2 years after the last communication
- Business communication resulting in a contract: 10 years (under section 257 of the German Commercial Code)
- Email correspondence: according to the business relationship in question
- Contact details without business interest: deleted on request
No permanent storage on your device
Because our website itself uses no user accounts, cookies or tracking, no data is stored permanently on your device. Exception: if you load YouTube videos, YouTube sets cookies (see section 9).
8. Third-party services and cookies
✅ Privacy-friendly hosting — no third parties loading automatically
This website itself uses no automatically loading external third-party services. All resources (fonts, styling, JavaScript) are loaded exclusively from our own server.
No cookies: This website sets no cookies or tracking tools of its own. The only exception: if you explicitly click “load video” on a YouTube video (see section 9).
9. YouTube videos (opt-in)
As a rule, our website uses no external third-party services. The exception is YouTube videos, which you can load on some product pages with your explicit consent :
⚠️ YouTube videos (consent required)
On some product pages we offer the option of loading YouTube videos with your consent. Important: Videos are only loaded after you explicitly click “Accept and play”.
- Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (parent company: Google LLC, USA)
- Data transfer: Your IP address, browser information and device data are transmitted to Google/YouTube
- Third-country transfer: Data may be transferred to the USA (adequacy decision under Art. 45 GDPR — EU-US Data Privacy Framework)
- Cookies: Once the video has loaded, YouTube sets tracking cookies in your browser (for example CONSENT, VISITOR_INFO1_LIVE, YSC)
- Purpose of the processing: Video playback, analysis of user behaviour, personalised advertising by Google
- Legal basis: Art. 6(1)(a) GDPR (your explicit consent by clicking “Accept and play”)
✅ Privacy-friendly implementation
- No automatic loading: videos are NOT loaded automatically when the page opens
- No thumbnails from YouTube: we show only a generic placeholder, no YouTube preview images
- Explicit consent: contact with YouTube is made only after you click “Accept and play”
- Privacy notice: before every video we inform you about the data transfer to Google
- Link to Google's privacy policy: https://policies.google.com/privacy
🔒 Your rights and withdrawal
- Withdrawing consent: you can withdraw your consent at any time by deleting the YouTube cookies in your browser settings
- Alternative: videos do not have to be loaded — all information is available without them
- Google account: if you are signed in to Google/YouTube, further data may be linked to your account
- Your controls: you can manage advertising settings and data use in your Google account settings
⚠️ Note on data processing by Google
Google may combine the data collected via YouTube with other Google services (for example Search, Gmail, Android) and use it for its own purposes (advertising, profiling). This processing takes place outside our control and in accordance with Google's privacy policy.
10. Cloud-Platform: Google reviews and Google user data
This section applies to our web application Cloud-Platform (appv1.flowcontrol.de), registered with Google as “Flowcontrol - Cloud-Platform”, and its module “Reviews”. It describes which data we obtain from Google services (“Google user data”) and how we use, store, share and delete it. All other processing in the Cloud-Platform is described in our Cloud-Platform privacy notice.
10.1 Who connects, and on whose behalf we act
The module is used by car wash operators that have concluded a contract for the Cloud-Platform with Flowcontrol by Florian Hofmann. An administrator of the operator signs in through Google’s sign-in procedure (OAuth) with the Google Account that manages the business’s Google Business Profile. In doing so, they grant permission to manage the Google Business Profile (https://www.googleapis.com/auth/business.manage). We do not request any other Google permission.
For the review data, the respective operator is the controller within the meaning of the GDPR. Flowcontrol by Florian Hofmann processes it as a processor (Art. 28 GDPR) solely on its instructions.
10.2 Which Google user data we access
- From the connected Google Account: the account ID and display name, and for the Business Profiles managed by the account: name, ID, store code, Place ID and the link for leaving a review. In addition, an access key (OAuth token) with which we access the Google interface on the operator’s behalf.
- For the Business Profiles that the operator maps to one of its sites: all reviews, including existing ones, each with the reviewer’s display name, star rating, review text (original and, where Google provides it, Google’s translation), time of creation and update, the business’s existing reply with its moderation status at Google, and the number and average of reviews. We do not take over profile pictures.
We do not access any other profile data, for example no posts, photos, questions and answers, opening hours, user or owner data. We change nothing on the Business Profile except replies to reviews.
10.3 What we use the data for
Exclusively for features that the operator sees and uses in the Cloud-Platform:
- displaying, filtering and searching reviews in an inbox;
- classifying reviews by topic, area (tunnel car wash, self-service bay) and sentiment, and flagging reviews that allege vehicle damage;
- creating draft replies. For the classification and the drafts, a self-hosted language model on a server in Germany processes the review text and the rating, and for the salutation in the draft also the reviewer’s display name. There is no external AI provider involved;
- publishing, editing or deleting replies on behalf of the business. This only happens at the instigation of an authorised user of the operator or, if the operator has separately and explicitly switched it on, automatically within the scope it has set. Reviews alleging vehicle damage are never answered automatically;
- notifying users of the operator who have switched this on by email about new reviews (rating and an excerpt of up to 180 characters, without the reviewer’s name);
- showing statistics per site of the operator (count, average, reply rate).
We do not use Google user data for advertising, do not sell it, do not build profiles of individual reviewers, do not analyse it across operators and do not use it to train AI models.
10.4 Where and for how long we store the data
The data is kept in our database at Hetzner Online GmbH in Germany. It is stored and transmitted in encrypted form. We additionally encrypt the OAuth access key (AES-256-GCM) and use it only on our server.
- If a person deletes their review on Google, we remove the name, text, draft reply, reply text and internal notes within eight days at the latest. We keep the rating, date, classification and the fact that a reply was given for the statistics.
- Retention period: We delete names and texts 24 months after the review was received. Reviews that allege vehicle damage or are linked to a damage claim are kept until three years after the end of the year in which they were received. We keep the rating, date and classification for the statistics for as long as the contract runs.
- Deletion requests: If a reviewer requests deletion, the operator can immediately delete the name, text, draft, reply text and notes of that review in our system. The review on Google is not affected; only the person themselves can delete it there.
- If the operator disconnects, we no longer retrieve reviews for that site. If it was the last connection of that Google Account, we delete the access key and revoke it with Google. We delete names and texts of reviews already retrieved after 30 days unless the site is reconnected by then.
- When the contract ends, we delete all data of the module within 30 days. Encrypted backups are overwritten within a maximum of 90 days after that.
- Log: We keep a record of who published, edited or deleted which reply and when, and who authorised the connection or the automatic replies, for 4 years as evidence for the operator and towards Google. Where we use these records for our own purposes, the legal basis is our legitimate interest (Art. 6(1)(f) GDPR).
10.5 Who we share data with
- With Google, as far as necessary to publish, edit or delete replies.
- With service providers, which we use as processors: Hetzner Online GmbH (hosting, Germany) and Google (email delivery via Google Workspace; the notifications contain the rating and an excerpt, transfer to the USA possible). The language model runs on a computer in Germany, without an external AI provider.
- With authorities or courts where the law requires us to.
We do not share Google user data beyond this. Our staff only view review content, namely if the operator asks us to in a specific case (for example in support), if it is necessary to investigate a security incident or error, or if the law requires it.
10.6 Revoking access and requesting deletion
- In the Cloud-Platform: Einstellungen › Bewertungen › Verknüpfung › „Trennen“ (Settings › Reviews › Connection › Disconnect; the application is in German).
- In your Google Account: at myaccount.google.com/permissions, entry “Flowcontrol - Cloud-Platform”. This ends our access immediately.
- Deletion or access: with the respective operator as controller or with us at datenschutz@flowcontrol.de. We forward requests from reviewers to the operator without delay and support it in responding.
10.7 Compliance with Google’s policies
The use and transfer to any other app of information that the Cloud-Platform receives from Google APIs complies with the Google API Services User Data Policy, including the Limited Use requirements.
Flowcontrol - Cloud-Platform's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Google and Google Business Profile are trademarks of Google LLC. Flowcontrol by Florian Hofmann is not a partner of Google and is not sponsored by Google.
11. International data transfers
As a German company we process your data in principle in Germany or the EU:
Processing in Germany and the EU
- Website and server log files: processed exclusively in Germany
- Contact form and email communication: via Google Workspace (Google Ireland Limited); a transfer to the USA is possible, see below
⚠️ Third-country transfers (YouTube and email)
The website itself processes your data exclusively in Germany. In two cases, data may reach the USA:
- YouTube videos: if you click “Accept and play”, data is transmitted to Google/YouTube and may be processed in the USA
- Legal basis for the transfer to the USA: adequacy decision of the EU Commission under Art. 45 GDPR (EU-US Data Privacy Framework)
- Your control: by clicking “Accept and play” you decide whether a transfer takes place
- Alternative: all information is available without loading the videos
- Enquiries and emails: We receive and send emails via Google Workspace. Google may also process this data in the USA; the legal basis is the EU-US Data Privacy Framework (Art. 45 GDPR) and the European Commission’s standard contractual clauses (Art. 46 GDPR).
Important: When you visit this website, no data is transferred to the USA unless you click “Accept and play”.
For our Cloud-Platform: login (Firebase Authentication), email delivery (Google Workspace) and push notifications (Firebase Cloud Messaging) run via Google; data may be transferred to the USA in the process. The legal basis is the EU-US Data Privacy Framework (Art. 45 GDPR) and the European Commission’s standard contractual clauses (Art. 46 GDPR). Details are set out in section 10 and in the Cloud-Platform privacy notice.
12. Changes to this privacy policy
We may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. When we make changes, we will:
- update the “last updated” date at the top of this policy
- notify you of material changes by email or by a notice on the website
- give you reasonable time to review the changes
We encourage you to review this privacy policy regularly to stay informed about how your information is protected.
13. Contact details
If you have questions, concerns or requests regarding this privacy policy or our data protection practices, please contact us:
Flowcontrol by Florian Hofmann
Data protection contact: Florian Hofmann
Email: datenschutz@flowcontrol.de
Phone: +49 174 6010390
Business hours: Monday to Friday, 9am–4pm
Response time: We aim to answer all data protection enquiries within 30 days
We undertake to address your concerns and to protect your data protection rights in accordance with applicable data protection law.