Privacy Policy

Last updated: March 2026

1. Controller

The data controller for Upwarden is Felix Wortmann. You can reach us at:

2. Data We Collect

We collect the following personal data:

3. Legal Basis for Processing

We process your data on the following legal grounds:

4. How We Use Your Data

Your data is used to:

5. Sub-processors

We share your data with the following third-party service providers. All have data processing agreements in place:

ProviderPurposeLocationPrivacy/DPA
CloudflareDDoS protection, CDN, DNSEU/US (EU DPA)GDPR Hub
HetznerHosting, database, object storageGermanyDPA
ResendTransactional email deliveryUS (EU DPA, SCCs)DPA
Polar.shSubscription billingNorway (EEA)DPA

For transfers outside the EEA, we rely on Standard Contractual Clauses (SCCs) and EU-approved data processing agreements.

6. Data Retention

Data TypeRetention Period
Account dataUntil account deletion + 30 days
Monitor results365 days
Audit logs90 days
Billing records7 years (legal requirement)

When you delete your account, all personal data is permanently removed within 30 days, except where retention is required by law.

7. Your Rights

Under GDPR, you have the right to:

To exercise these rights, contact us at [email protected]. We respond within 30 days.

You also have the right to lodge a complaint with a supervisory authority in your jurisdiction or in Germany (Bayerisches Landesamt für Datenschutzaufsicht).

8. Data Processing Agreement

Business customers requiring a signed Data Processing Agreement (DPA) can request one at [email protected]. Our standard DPA is available at /dpa.

9. Analytics

We use PostHog EU Cloud for product and website analytics. PostHog is configured without analytics cookies and is used to understand signup and checkout funnel performance.

Because analytics cookies are not used, no analytics cookie consent banner is required under GDPR.

10. Cookies

We use a single essential session cookie for authentication. No tracking or analytics cookies are used. See our Cookie Policy for details.

11. Security

We implement appropriate technical and organizational measures to protect your data, including encryption at rest and in transit, access controls, and regular security updates.

12. Changes to This Policy

We may update this policy occasionally. Significant changes will be communicated via email. Continued use of Upwarden after changes constitutes acceptance.

13. Contact

For privacy questions or to exercise your rights, contact us at [email protected].