Contrato de encargo de tratamiento

Last updated: 4 October 2026

This is an English translation for your convenience. Only the German version (Vertrag zur Auftragsverarbeitung) is legally binding.

This agreement applies between the customer as controller (“client”) and Marlon Güttler, Saldiqo, c/o BFG Mediagroup, Bändelstockweg 20, 88326 Aulendorf as processor (“Saldiqo”). It forms part of the terms and conditions and is concluded on registration. It meets the requirements of Art. 28 GDPR.

This agreement does not cover processing for which Saldiqo itself is the controller, for example the user account, consents and proof of consent, partner requests with the contact details of the requesting person, the template market and the measurement of advertising on the public pages of the app. The privacy policy applies to these.

1. Subject matter and duration

Saldiqo processes personal data on behalf of the client in order to provide the Saldiqo service. The agreement runs for as long as the user agreement exists and beyond that until all client data has been deleted or returned.

2. Nature, purpose and scope

Purpose	Storing and processing the data that the client manages in the service: creating and sending documents and e-invoices and reading received e-invoices, importing bank statements and matching payments, recording expenses, creating reports, answering support requests through the help centre, working together in a team, exporting and backing up data; also the savings check and, if the client switches it on, the AI assistant (section 3).
Types of data	Names, addresses and contact details; customer and supplier numbers; contents of quotes, invoices and reminders; bank details and account transactions; receipts and files; messages and attachments from support requests; tax identifiers of business partners.
Data subjects	Customers, prospects, suppliers and their contact persons; employees and team members of the client; people who send requests through the client’s help centre.

The service does not specifically process special categories of personal data (Art. 9 GDPR). However, they may be contained in receipts, files, support requests and account transactions, for example if a payee or payment reference points to a health insurer, a trade union or a religious community. The client only stores such data if there is a legal basis for it. The savings check hint on health insurance is only given if an authorised person switched on the savings check with their consent, not with the savings check from registration. Only a consent in version 2026-10-07.5 or later, whose text names health insurance, is sufficient for this. Social security contributions for the client’s employees (recognisable, for example, by the payment reference “Beitragsnachweis”) do not count.

3. Instructions

Saldiqo processes the data only on documented instructions from the client, including with regard to transfers to third countries, unless required to do so by law; in that case Saldiqo informs the client beforehand, unless the law prohibits this. The instructions result from this agreement and from the client’s use of the service (for example creating, sending, exporting, deleting). The client gives further instructions in text form. If Saldiqo considers an instruction to be unlawful, it will point this out without delay.

Savings check. For the company created at registration, the savings check is switched on under § 5(1) of the terms of service; this counts as an instruction within the meaning of this section. For further companies, the client instructs Saldiqo by an owner or admin switching it on. Switching it off is a counter-instruction. With this instruction, Saldiqo automatically analyses, every week and according to fixed rules, the expenses and outgoing bank transactions of the last 12 months and the invoiced revenue of the current year and stores the hints in the client’s database. Saldiqo does not use the analysis for its own purposes: Saldiqo does not build profiles from it for itself, and does not pass client data on to partners or advertising providers. If a partner is entered for the topic of a hint, Saldiqo only shows its name and an offer marked as advertising once a person chooses “View offers (ad)”; which hints appear does not depend on this.

AI assistant. If an owner or admin of the client switches on the AI assistant, they instruct Saldiqo to transmit messages to the assistant and the data needed to answer them to the provider listed in Annex 2; the assistant only carries out changes after confirmation. Even then, Saldiqo does not use client data for its own purposes and does not pass client data on to partners or advertising providers. The savings check and the AI assistant can be switched off again at any time.

4. Confidentiality

Saldiqo only engages persons who are committed to confidentiality. Client data is only accessed insofar as this is necessary for operations, for support at the client’s request or to fix faults.

5. Security of processing

Saldiqo takes the technical and organisational measures under Art. 32 GDPR described in Annex 1. Saldiqo may develop them further as long as the level of protection does not decrease.

6. Sub-processors

(1) The client approves the sub-processors listed in Annex 2.

(2) Saldiqo may engage further sub-processors or replace existing ones. Saldiqo informs the client at least four weeks in advance in text form. The client may object for an important reason relating to data protection. If the parties cannot agree, the client may terminate the agreement with effect from the date of the change.

(3) Saldiqo contractually binds sub-processors to the same data protection obligations and remains responsible to the client for their compliance.

(4) Processing outside the EU/EEA only takes place if the requirements of Art. 44 et seq. GDPR are met.

7. Assisting the client

(1) Saldiqo assists the client with appropriate measures in responding to requests from data subjects (Art. 12 to 22 GDPR). The service offers functions for changing, exporting and deleting data for this purpose. If a data subject contacts Saldiqo directly, Saldiqo forwards the request without delay.

(2) Saldiqo assists the client with the security of processing, with notifications of personal data breaches, with data protection impact assessments and with consultations of the supervisory authority (Art. 32 to 36 GDPR).

8. Notification of breaches

Saldiqo notifies the client of a breach of the protection of client data without undue delay after becoming aware of it, if possible within 24 hours. As far as known, the notification contains the information under Art. 33(3) GDPR. Saldiqo immediately takes measures to contain the breach and mitigate its consequences.

9. Deletion and return

The client can export their data at any time. If the client deletes a company or their account themselves, Saldiqo deletes the client data concerned from the live system immediately. If the agreement ends in another way (for example by termination in text form), the client’s account remains in place for at least 30 days after the end of the agreement so that they can retrieve and export their data (§ 9a and § 10(5) of the terms of service); after that Saldiqo deletes the client data from the live system. The data disappears from the encrypted backups when the backup concerned is deleted: Saldiqo backs up daily and keeps the backups of the last 14 days and one backup per month for the last 12 months; no backup is older than 400 days. The backups are currently kept only on the server at the hosting provider named in Annex 2. Longer storage only takes place if required by law.

10. Evidence and audits

On request, Saldiqo provides the client with all information necessary to demonstrate compliance with the obligations under Art. 28 GDPR. The client, or an auditor commissioned by the client and bound to confidentiality, may carry out audits during business hours after giving reasonable notice, without disrupting operations. Saldiqo may request reasonable compensation for the effort if an audit goes beyond one per year and there is no specific reason for it.

11. Liability and final provisions

Liability is governed by Art. 82 GDPR; otherwise the provisions of the terms and conditions apply. In the event of contradictions, this agreement takes precedence on matters of data protection. German law applies.

Annex 1: Technical and organisational measures

Confidentiality

• Physical access: servers in a data centre of Hostinger International Ltd., 61 Lordou Vironos Street, 6023 Larnaca, Cyprus with access control, video surveillance and security staff according to the provider.
• System access: server access only with SSH keys, no password login. For users: passwords with a minimum length, stored only as scrypt hashes; two-factor sign-in for every account (passkey or authenticator app, backup codes stored only as hashes); limits on sign-in attempts; sessions expire after 12 hours of inactivity.
• Data access: roles and permissions per company (for example owner, admin, accounting, support, tax adviser with read-only access). Every request is checked against the role on the server. Access to platform administration is only available for expressly approved addresses with two-factor sign-in.
• Platform administration and support: operators cannot add themselves to companies, cannot add accounts to other people’s companies and can neither appoint nor change the owner. Access to client data for support is only available for a limited time (at most 72 hours), with a role without admin rights and only after approval by the owner. If an operator changes the role of an existing member, the app notifies the owner. Write actions in platform administration and the request, approval and end of support access are recorded in the security log and kept for 90 days. Individual read accesses are not recorded.
• Separation: every company has its own database with its own key. Data of different companies is never stored together.
• Encryption: databases encrypted with AES-256 (SQLCipher); transmission exclusively via HTTPS (TLS) with HSTS. Deleted records are overwritten in the database.
• No third-party scripts in the signed-in area: advertising pixels are only possible on public pages without sign-in; for signed-in users the Content Security Policy only allows our own scripts. The service worker only stores program files, no client data.

Integrity

• Protection against browser-based attacks through a Content Security Policy, protection against cross-site request forgery and validation of all input on the server; uploaded files are checked by their content; usage limits for features prone to misuse.
• Finalised documents are locked against changes; document actions are logged.
• Security-relevant events, including actions in platform administration, are logged and deleted after 90 days.

Availability and resilience

• Daily encrypted backups of all databases; the backups of the last 14 days and one backup per month for the last 12 months are kept, none for longer than 400 days. The backups are currently kept on the same server; there is no copy at a second location yet. The master key is stored separately from the backups.
• Containers with a read-only file system and minimal permissions; automatic restart on errors.
• Security updates for the operating system and dependencies are applied promptly.

Regular review

• Automated tests before every new version, checking dependencies for known vulnerabilities.
• Review of these measures at least once a year.

Annex 2: Sub-processors

Backups and operating and security logs are kept on the hosting provider’s server; Saldiqo does not use any other provider for them. If one is added, section 6(2) applies.