Controller
The controller responsible for data processing within the meaning of the DSGVO is Ebrahim Seyfi (Geschäftsbezeichnung „Senorit"), Seeschwalbentwiete 23, 22119 Hamburg, privacy@glenby.de. Full provider details can be found in the Legal notice.
End-to-end encryption
Content you share with friends (photos, notes about places) is encrypted on your device before it reaches our servers. Only the recipients you choose can decrypt it. We store exclusively the encrypted content and hold no key to it.
What stays visible: metadata
End-to-end encryption makes the content of your messages and photos unreadable to us, but not the fact that communication is happening at all. To deliver messages we necessarily process metadata: who sends to whom, timestamps, and delivery/read status. The legal basis is Art. 6 Abs. 1 lit. b DSGVO (performance of the usage contract); the retention period follows the lifetime of your account, see the Retention period section. In addition to the DSGVO, the telecommunications secrecy under § 3 TDDDG protects both the content and the closer circumstances of your communication and binds us as a provider of an interpersonal telecommunications service.
What data we process
- Account
- Display name and optionally an email address for sign-in. We store the password exclusively as a hash, never in plain text.
- Shared content
- Photos and notes about places - stored exclusively end-to-end encrypted. We hold no key to it.
- Video calls
- 1:1 video calls are transmitted directly between devices (WebRTC, encrypted) and are not recorded. Cloudflare acts solely as a TURN relay to broker the connection.
- Billing
- For a paid subscription, our payment provider Stripe processes the payment data. We ourselves store only the identifier needed for contract administration and the plan status.
- Friends and notifications
- Friend code, connections, and, if you enable reminders, a push token.
- Technical data
- Minimal data for operation and security, such as session and device identifiers and synchronization timestamps.
Location
When you complete a task, your location (GPS) is captured once as proof of authenticity and stored together with the completion. There is no background tracking and no movement profile. Your location is therefore not a special category of personal data within the meaning of Art. 9 DSGVO; the processing is based on Art. 6 Abs. 1 lit. b and lit. f DSGVO.
Services we use (processors)
Encrypted content and account data are processed by the following services:
| Service | Purpose | Location / transfer basis |
|---|---|---|
| Supabase Pte. Ltd. (Singapore) | Database & edge functions: accounts, chat metadata, entitlements. | Database region: AWS Frankfurt (eu-central-1). Transfer based on EU Standard Contractual Clauses (Singapore has no adequacy decision). |
| Cloudflare Inc. (USA) | Storage of end-to-end encrypted photos and voice notes (R2), chat delivery (Durable Objects), call connection brokering (TURN). | Content reaches Cloudflare only as ciphertext. Transfer based on the EU-US Data Privacy Framework. |
| Stripe Payments Europe Ltd. (Ireland) / Stripe Inc. (USA) | Payment processing for Glenby+ subscriptions: email address, name, payment data. | Transfer based on the EU-US Data Privacy Framework. |
| Google LLC (USA) | Google account sign-in (Google Sign-In: email address, name, profile picture), push notification delivery (Firebase Cloud Messaging, device token), map rendering (Google Maps SDK, direct device connection), app integrity checks (Play Integrity), crash reports (Firebase Crashlytics, only after opt-in in the app, off by default). | Transfer based on the EU-US Data Privacy Framework. |
| Vercel Inc. (USA) | Hosting of this website (glenby.de), access logs. | Transfer based on the EU-US Data Privacy Framework. |
| Resend / Plus Five Five Inc. (USA) | Sending of transactional emails (for example deletion and withdrawal confirmations), no marketing emails. | Transfer based on the EU-US Data Privacy Framework. |
| Norwegian Meteorological Institute (MET Norway) | In-app weather forecast (api.met.no, Locationforecast). | Device IP address and location coarsened to roughly 1 km are sent directly from the device. Data licensed under NLOD 2.0 and CC BY 4.0. |
| HeiGIT gGmbH (Germany) | Walking-route routing (openrouteservice). | Coarsened coordinates, relayed through our server; the device never contacts the service directly. |
| Overpass API instances (Germany/Austria, community-run) | Place and POI data. | Server-side queries without any user identifier. |
| Wikimedia Foundation (USA) | Place information and reference photos. | Server-side queries without any user identifier. |
| Hugging Face, Inc. (USA) | One-time download of the offline transcription model. | No content or account data is transmitted. |
We have the necessary agreements under Art. 28 DSGVO in place with all processors named.
Data sources
Map data, routes and photos in the app come from open sources such as OpenStreetMap and Wikimedia Commons - the purpose and role of each service is listed above under "Services we use". Information about animals and plants at a place additionally comes from the GBIF database (Global Biodiversity Information Facility, gbif.org), a worldwide network of museums, institutions and citizen-science projects. We only use records published under CC0 or CC BY, crediting the publishing institutions as the source. This data is not linked to any person and contains no information about you.
Transfers to third countries
Some of the services we use are based, or process data, outside the EU/EEA. Our database runs with Supabase Pte. Ltd. (Singapore, database region AWS Frankfurt), safeguarded by EU Standard Contractual Clauses, since the EU Commission has issued no adequacy decision for Singapore. Cloudflare, Stripe, Google, and Vercel are based (also) in the USA and are certified under the EU-US Data Privacy Framework, which the EU Commission has recognized as providing an adequate level of protection (Art. 45 DSGVO); Resend also transfers data on the basis of the Data Privacy Framework. All transfers to third countries take place exclusively on one of the bases provided for in Art. 44 ff. DSGVO. The full, continuously updated list is above under "Services we use".
Content you share with others (photos, voice notes, notes) leaves your device only end-to-end encrypted. Even though the encrypted ciphertext sits on servers outside the EU, nobody except the recipients you chose can read the content, not us and not the respective hosting provider.
Screening for harmful content on the device
Before a photo is encrypted and shared, the app screens it directly on your device for clearly harmful content. This screening runs locally - no images are uploaded for it. More on this on the Security & Transparency page.
Crash reports
- Purpose
- Error analysis and stability improvement of the app.
- Data
- App version, operating system version, device model and device state (free storage, for example), the crash report (stack trace), and a random Crashlytics installation ID. No link to your Glenby account. Google necessarily processes your device IP address on receipt; it does not become part of the report. Messages, photos and voice notes are never included.
- Legal basis
- Art. 6 Abs. 1 lit. a DSGVO (consent). The feature is disabled by default (opt-in); you enable it yourself in settings and can disable it again there at any time using the same toggle, with effect for the future.
- Recipients
- Google LLC (Firebase Crashlytics, USA).
- Storage
- A crash report is first created only on your device and is only transmitted the next time the app starts. On the server, crash reports are kept for a maximum of 90 days; we store a maximum of 5,000 reports in total, with older ones automatically overwritten.
Statutory reporting duty
If there is reasonable suspicion of a serious crime - in particular depictions of the sexual abuse of children - we are required under Art. 18 of Regulation (EU) 2022/2065 (Digital Services Act) to inform the competent law enforcement authority. The central reporting body in Germany is the Bundeskriminalamt as the central office under § 13 DDG in conjunction with § 2 BKAG. Only the content concerned is, in this case, excluded from end-to-end encryption and secured with a separate key that only the automated, official reporting channel can open. No one at Senorit sees this content in plain text.
Cancellation and withdrawal function
- Purpose
- Receiving and automatically carrying out statutory declarations under § 312k BGB (cancellation) and § 356a BGB (withdrawal).
- Data
- Name, email address, contract details, and the time of the declaration.
- Legal basis
- Art. 6 Abs. 1 lit. b and lit. c DSGVO.
- Recipients
- Payment processing (Stripe), email delivery (Resend), database (Supabase).
- Storage
- For evidentiary purposes, for the duration of the statutory retention periods.
Legal bases
- Art. 6 Abs. 1 lit. b DSGVO - provision of the app, its features, and the paid contracts.
- Art. 6 Abs. 1 lit. a DSGVO - consent for push notifications and for optional crash reports; revocable at any time.
- Art. 9 Abs. 2 lit. a DSGVO - express consent for the meet-people feature, to the extent it may involve special categories of personal data.
- Art. 6 Abs. 1 lit. f DSGVO - operation, security, and abuse prevention.
- Art. 6 Abs. 1 lit. c DSGVO - statutory reporting and cooperation duties.
Retention period
Content and account data are stored for as long as your account exists; upon deletion they are removed (see account and data deletion). If a statutory report under Art. 18 DSA has been triggered for a piece of content, that content remains excluded from deletion for the duration of the official proceedings; the legal basis for this is Art. 17 Abs. 3 lit. b DSGVO.
Your rights
You have the right to access (Art. 15 DSGVO, first copy free of charge), rectification, erasure (Art. 17 DSGVO), restriction of processing, data portability, and objection (Art. 15-21 DSGVO), as well as the right to withdraw any consent given at any time with effect for the future. The app offers an export and a deletion function directly in the settings; see account and data deletion. Requests at any time to privacy@glenby.de.
Right to lodge a complaint
You can lodge a complaint with a data protection supervisory authority, generally the authority of the German federal state (Bundesland) where you reside.
Technical error reports on this website
- Purpose
- Detecting and fixing technical errors on glenby.de, maintaining safe and stable operation.
- Data
- Automatically captured JavaScript error messages and violations of our Content Security Policy (CSP reports). No cookies, no user identifier; IP addresses are not stored.
- Legal basis
- Art. 6 Abs. 1 lit. f DSGVO (legitimate interest in a secure and error-free operation of the website). Since no cookies are set and no recognition takes place, no consent under § 25 TDDDG is required for this.
- Recipients
- Internal operations system, database (Supabase, Frankfurt region).
- Storage
- For abuse-prevention reasons we accept a maximum of 500 reports within 24 hours. The retention period is 90 days, after which reports are automatically deleted.