Privacy – WerkFlow

2. General Information on Data Processing

WerkFlow is an app for trade businesses for creating quotes and invoices (including e-invoices) as well as cost estimates, managing customers and managing material lists. Personal data is processed when the app is used. Personal data is any data that can be related to you personally, e.g. name, address, e-mail address or user behaviour.

We only process your data insofar as this is necessary to provide a functional app and our content and services, or insofar as you have given your consent.

3. What Data We Process

3.1 Account and Authentication Data

When you register, we collect:

• E-mail address
• Password (stored in encrypted form, not visible to us)
• Time of registration, login history, session token

We only send account e-mails to your e-mail address: the confirmation upon registration and the link to reset your password (sent via Resend, see section 4.5).

Legal basis: Art. 6(1)(b) GDPR (performance of a contract – provision of the user account)

3.2 Company Profile Data

To create quotes, cost estimates, invoices and PDFs, we collect and store the information you enter about your business:

• Company name, legal form
• Address (street, postcode, city)
• Tax number / VAT ID
• Phone number, company e-mail, website
• Contact person, managing director
• Registered office, registry court, commercial register number
• Company logo (image file)
• Name and position of the authorised signatory
• Digital signature (as an image file)
• If you use the DATEV export: chart of accounts, adviser and client number at your tax advisor, debtor and revenue accounts

Legal basis: Art. 6(1)(b) GDPR (performance of a contract) and Art. 6(1)(c) GDPR (legal obligation, insofar as mandatory information for invoices/quotes is required under § 14 of the German VAT Act (UStG))

3.3 Bank Details (Particularly Sensitive Financial Data)

You can store the following data for display on your quotes and invoices:

• Bank name
• IBAN
• BIC

This data is stored exclusively for the purpose of display on your own quotes and invoices. On invoices, it also appears as payment information in the embedded e-invoice (ZUGFeRD or XRechnung, the German e-invoice formats). It is not used for payment processing within the app.

Legal basis: Art. 6(1)(b) GDPR (performance of a contract)

3.4 Customer Data

When you create customers in the app, we process the data you enter about your end customers:

• First and last name, company if applicable
• Address (street, house number, postcode, city, country)
• Phone number (optional)
• E-mail address (optional)
• Customer number
• VAT identification number (optional; required if the reverse-charge procedure under § 13b UStG applies)
• Classification as a private or business customer (controls the legally required notices on the invoice)
• Leitweg-ID (optional; only for public-sector clients. The authority provides this routing ID so that the invoice is assigned to the correct office on its receiving platform.)

Note: As a user, you are yourself the controller under data protection law with regard to your customers' data (Art. 4(7) GDPR). We process this data on your behalf as a processor within the meaning of Art. 28 GDPR. A corresponding data processing agreement (DPA) can be provided on request.

Legal basis (from your perspective as a user): Art. 6(1)(b) or (f) GDPR, depending on the customer relationship

3.5 Quote, Cost Estimate, Invoice and Material Data

A cost estimate is a non-binding estimate of costs. It is created like a quote and kept in the same archive. It can be turned into a quote or, after the order confirmation, directly into an invoice. Invoices can be created in the app from an accepted quote, from a commissioned cost estimate or without a prior quote. The following is processed:

• Quote number or cost estimate number (KV-year-number, with an appended revision number for a new revision, e.g. KV-2026-0001-2), date, subject, for quotes the validity period
• Line items, quantities, unit prices, totals, VAT
• Payment terms, delivery/performance period
• Status (draft, sent, accepted, rejected, replaced by a new version or revision)
• For a quote created from a cost estimate: the reference to that cost estimate, so that the chain of documents from the cost estimate to the invoice remains complete
• For sent quotes and cost estimates: time of sending, the sent PDF as your customer received it, and its checksum (SHA-256)
• For accepted quotes and commissioned cost estimates, the order confirmation: sequential number, date and type of acceptance (verbal, e-mail, letter or signature), expected start, your note; for private customers additionally where the order was concluded, whether a right of withdrawal exists and whether the customer requested work to begin before the withdrawal period expires; for acceptance by signature, the customer's name and signature as an image file; the PDF of the order confirmation with its checksum (SHA-256)
• Material list with descriptions, prices, units
• For invoices, additionally the information required under § 14 UStG: sequential invoice number, invoice type (invoice, partial, final or cancellation invoice) and invoice date
• Date or period of performance, due date and payment term
• Split into labour and material costs (§ 35a of the German Income Tax Act (EStG)) and the indicators for § 13b, § 14b and § 19 UStG
• A frozen copy of the customer data at the time of the invoice. If the customer moves later, the archived invoice must still show the address valid at the time.
• The generated PDF with its checksum (SHA-256) and the e-invoice embedded in it in the ZUGFeRD 2.3 / Factur-X format (profile EN 16931). This XML file contains the same invoice information again in machine-readable form so that your customer's accounting can import it automatically.
• For invoices to public-sector clients, the same file is instead created in the XRechnung 3.0 format. It additionally contains the Leitweg-ID and a contact person at your business with phone number and e-mail address, because the authority's invoice receiving platform requires this information.

Legal basis: Art. 6(1)(b) GDPR (performance of a contract), for the mandatory information additionally Art. 6(1)(c) GDPR (legal obligation under § 14 UStG).

Immutability: A sent invoice can neither be changed in the app nor deleted before the end of the retention period (German principles for the proper keeping and storage of books, records and documents in electronic form, GoBD). A correction is only possible via a cancellation invoice that refers to the original invoice. The same applies to sent quotes: a change creates a new version with a new quote number, and the old version is retained. For a cost estimate, the changed revision carries the number of the original with an appended revision number (KV-2026-0001-2); the older revision is retained unchanged and counts as replaced. If it has already been commissioned, it remains accepted.

Retention Obligations

The statutory retention obligations for your business records apply to you as a business owner. In particular:

• Invoices, partial, final and cancellation invoices including the embedded e-invoice (XML), as well as quotes and cost estimates that led to an order: 8 years (§ 147(1) no. 4, (3) of the German Fiscal Code (AO), § 257(1) no. 4, (4) of the German Commercial Code (HGB), § 14b UStG)
• Quotes and cost estimates without a subsequent order: 6 years (§ 147(1) nos. 2, 3, (3) AO, § 257(1) nos. 2, 3, (4) HGB)
• For context, not kept in WerkFlow: incoming invoices and other accounting vouchers 8 years (§ 147(1) no. 4, (3) AO, § 14b(1) UStG); books, inventories and annual financial statements 10 years (§ 147(1) no. 1, (3) AO, § 257(1) no. 1, (4) HGB)

The period does not begin on the day of creation but at the end of the calendar year in which the document was created (§ 147(4) AO, § 257(5) HGB). Example: an invoice dated 15 May 2026 must be retained until 31 December 2034, a quote without an order dated the same day until 31 December 2032. The period is extended as long as the documents are relevant for a tax assessment that has not yet been completed (§ 147(3) sentence 5 AO).

The 8 years apply regardless of whether an invoice exists on paper, as a PDF, as ZUGFeRD or as XRechnung (§ 14b(1) UStG). For e-invoices, the structured XML part is authoritative and must be preserved unchanged in its original form: for ZUGFeRD the XML file embedded in the PDF, for XRechnung the XML file itself. A PDF generated from it is only a visual representation. WerkFlow therefore stores the PDF and the e-invoice together and unchanged.

Storage and Deletion by Us

We store your sent quotes, cost estimates and invoices, including PDF and e-invoice, until the end of the retention period. Before then, they cannot be deleted, not even by you, so that your retention obligation remains fulfilled. You can delete drafts at any time.

After the period has expired, we delete the documents automatically, because we may not store personal data for longer than necessary (Art. 5(1)(e), Art. 17(1)(a) GDPR):

• From 1 October of the last retention year, we show you in the app which documents are affected and offer them for download (section 7). We do not send an e-mail about this.
• On 31 March of the following year, we delete the record, PDF and e-invoice of these documents, even if you have not opened the app in the meantime.
• If you need documents for longer, for example because a tax audit, an objection or other proceedings are ongoing (§ 147(3) sentence 5 AO), you can extend retention in the app by one year at a time.
• Between the end of the period and the deletion date, you can also delete documents yourself in the app.

Example: an invoice dated 15 May 2026 must be retained until 31 December 2034. From 1 October 2034, the app points out the upcoming deletion; it is deleted on 31 March 2035.

If you delete your account, all data including quotes and invoices is deleted immediately and permanently, even if the retention period is still running. The app therefore offers you the option of downloading the archive for all years beforehand (section 7).

3.6 Photos and Voice Recordings (AI Analysis)

To enable the automatic creation of quotes and cost estimates using AI, you can:

• take photos of construction sites using the device camera or choose them from the gallery
• record voice notes using the microphone
• upload photos of handwritten or printed material lists

This content is only transmitted to our servers (Supabase, see section 4.1) via a secure connection after your express consent (consent dialog in the app) and forwarded from there to an AI service for automated analysis.

Primary AI service: Google Gemini (paid plan with billing enabled) processes photos, voice recordings and text descriptions for creating quotes and cost estimates, photos of material lists and job descriptions from which items and a service text are generated for an invoice without a quote by default.

So that the AI can use your own descriptions and prices, the entries of your material list (description, unit, price) are also transmitted.

Fallback service: If Google Gemini is temporarily unavailable (e.g. due to a technical fault), the request is automatically forwarded to OpenAI (GPT-4o, including Whisper transcription for voice recordings where applicable) so that your request can still be processed. The fallback is only used in exceptional cases.

The raw data (photos, audio files) is not stored permanently on our servers after the AI analysis has been completed, but is only transmitted for the duration of processing. This does not apply to photos that you add to a quote, a cost estimate or an invoice (see below).

As we use a paid plan with billing enabled for Google Gemini, the Gemini API terms of use expressly provide that Google does not use your input (prompts, images, audio files) or the generated responses to improve Google products. Input is only logged there for a limited time for abuse detection and for security reasons (source: Gemini API – terms of use for paid services).

Legal basis: Art. 6(1)(a) GDPR (consent). Consent can be withdrawn at any time with effect for the future in the app settings (toggle “Use AI Analysis”).

Important note: When photographing construction sites/customers' homes, make sure that no people or sensitive private documents are recognisable in the picture, as you as the user are responsible for this.

Dictation (speech to text): In quotes, cost estimates, invoices and notes, you can dictate text instead of typing. Unlike the quote analysis, the spoken content is not analysed but only converted into text. For this purpose, the recording is transmitted to our server – only with your consent under this section and only with an internet connection – and converted into text there by Google Gemini or, as a substitute, OpenAI Whisper; the audio file is not stored permanently after conversion and is deleted from your device immediately. Without consent or without an internet connection, dictation is not available; the app does not use on-device speech recognition. Dictation does not use up any of your analysis quotas. Without a subscription, dictation is available in quotes and cost estimates only as long as free AI quotes remain, in invoices only as long as free AI invoices remain, and in notes until both quotas are used up. With a subscription, it remains available everywhere, even after the monthly quota has been reached.

Photos for quotes and invoices: Photos that you add to a quote or invoice in the app – including the photo for the AI analysis as soon as you save the quote – are stored in a storage area on our servers that only your account can access (Supabase, see section 4.1), so that you can view them again later with the document. They do not appear on the document and are not transmitted to your customers. You can delete them individually at any time; they are also deleted together with the deleted draft or document and with your account. Legal basis: Art. 6(1)(b) GDPR (provision of the feature you use).

3.7 Free-Form Notes

In the app, you can create free-form notes (typed or dictated). Their content is stored on our servers (Supabase, see section 4.1) and is assigned exclusively to your account. You alone decide what information a note contains; it can be deleted in the app at any time.

Legal basis: Art. 6(1)(b) GDPR (performance of a contract)

3.8 Subscription and Payment Data

For the use of paid features (subscription plans “Solo”, “Small Business”, “Pro”), we process:

• your user ID (to assign the subscription to your account)
• subscription status, plan booked, expiry date
• purchase history (managed via RevenueCat, see section 4.3)
• number of AI quotes and AI invoices used in the current month (to calculate your quota; an AI cost estimate counts like an AI quote)

The actual payment processing takes place entirely via Google Play Billing. At no time do we collect, store or view credit card or other payment data.

Legal basis: Art. 6(1)(b) GDPR (performance of a contract)

3.9 Technical Data / Usage Data

When the app is used, the following is processed automatically for technical reasons:

• Device information (operating system, app version)
• Error logs (for troubleshooting)
• Usage of AI calls: time, function, AI model and number of tokens processed, no content (for cost control)
• Local settings (theme, language setting – stored only locally on the device)

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the functionality and security of the app)

3.10 Change Log of Documents

So that it remains traceable when a quote, a cost estimate or an invoice was created, sent or changed, the app keeps a log for each document. The following is stored:

• time and type of the operation (created, changed, issued, status change, PDF archived, shared, exported, retention extended, deleted)
• document type and document number
• the names of the changed fields, and for documents already sent, additionally the old and new values of the changed fields (e.g. payment status and payment date); for a deletion, the document number, date and amount
• whether the operation was triggered by you or automatically by the system
• checksums (SHA-256) that chain each entry to the previous one so that subsequent changes to the log are detectable

Complete documents or customer data are not included in the log. The log cannot be edited in the app; you receive it with the export for your tax advisor and with the data export (section 7).

Purpose: proof that bookings and records have not been changed unnoticed (§ 146(4) AO, GoBD).

Legal basis: Art. 6(1)(b) GDPR (performance of a contract – GoBD-compliant record keeping) and Art. 6(1)(c) GDPR (your recording obligation under § 146(4) AO)

Storage period: the same as the associated document. If a document is deleted after the period has expired, we remove the document reference, document number, field names and values from its log entries. Only the time, type of operation and checksums remain, so that the chain remains verifiable. These remnants are deleted together with the account.

3.11 Feedback and Ratings

Under Settings → “Send feedback”, you can voluntarily send us a rating of 1 to 5 stars and optionally a text (up to 2,000 characters). The following is stored:

• your user ID
• star rating and text
• app version
• time of submission

Purpose: improving the app. Only we as the provider read your feedback; it is not published or passed on to third parties. It is stored on our servers (Supabase, see section 4.1). Please do not include any personal data of your customers in the text.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in improving the app). Submitting feedback is voluntary. You can object to the processing at any time (Art. 21 GDPR), e.g. by e-mail to info@simplynext.de; we will then delete your feedback.

Storage period: until your account is deleted; your feedback is deleted together with the account.

Rating on Google Play: After the second quote sent, the app shows the Google Play rating dialog once (Google Play In-App Review API); whether it actually appears is decided by Google. Under Settings → “Rate the app” you can also open the app's listing in the Google Play Store. A rating you submit there goes directly to Google and is published in accordance with Google's terms. We receive neither stars nor text; the app does not learn whether you have rated it. Google is responsible for this processing (see section 4.4).

4. Recipients of Data / Processors

We use carefully selected service providers who process your data exclusively on our instructions. Where necessary, data processing agreements (Art. 28 GDPR) are in place with all providers.

4.1 Supabase (Backend, Database, Authentication, File Storage)

Supabase Inc., USA. The data is stored on servers in the EU (data centre in Ireland).

Data transmitted: all data listed in sections 3.1–3.10 (account, profile, customer, quote, cost estimate, invoice and material data, free-form notes, generated PDF and ZUGFeRD files, change log, company logo, signature image file, photos for quotes, cost estimates and invoices, order confirmations with your customers' signatures).

Transfer to third countries: As Supabase is a company based in the USA, access from the USA (e.g. in the context of maintenance and support) cannot be ruled out. This is safeguarded by the data processing agreement with EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).

Privacy policy: supabase.com/privacy

4.2 AI Analysis Services (Google Gemini Primary, OpenAI GPT-4o as Fallback)

For the automated evaluation of photos, voice recordings and text descriptions and for converting dictation into text (see section 3.6), we use:

• Google Gemini (Google Ireland Limited / Google LLC, USA) – primary and regularly used AI service, paid plan without your data being used for training. Privacy policy: policies.google.com/privacy · Terms of use: ai.google.dev/gemini-api/terms#paid-services
• OpenAI GPT-4o (contracting party for customers in the EEA: OpenAI Ireland Ltd., Dublin, Ireland; affiliated with OpenAI, L.L.C., USA) – exclusively as a technical fallback if Google Gemini is temporarily unavailable. This is based on OpenAI's Data Processing Addendum. Privacy policy: openai.com/policies/eu-privacy-policy

Transfer to third countries: As these providers also operate servers in the USA, personal data may be transferred to a country outside the EU/EEA. We ensure an adequate level of data protection by concluding EU Standard Contractual Clauses (Art. 46(2)(c) GDPR) with the respective providers.

The transfer takes place only after your active consent (section 3.6) and is limited in time to the duration of the analysis.

4.3 RevenueCat (Subscription Management)

RevenueCat, Inc., San Francisco, USA

Data transmitted: user ID, purchase and subscription status, device-side purchase confirmations.

Privacy policy: www.revenuecat.com/privacy

Transfer to third countries: USA, safeguarded by EU Standard Contractual Clauses.

4.4 Google Play Billing / Google Play Services

Google Ireland Limited / Google LLC

Payment for subscriptions is processed entirely via Google Play. Google's privacy policy also applies: policies.google.com/privacy

Google Play also provides the rating dialog and the app's store listing (section 3.11). Google processes ratings you submit there under its own responsibility.

4.5 Resend (Sending Account E-Mails)

Plus Five Five, Inc. (Resend), 2261 Market Street #5039, San Francisco, CA 94114, USA

Purpose: sending the confirmation e-mail upon registration and the password reset e-mail (section 3.1).

Data transmitted: your e-mail address, the content of the respective account e-mail, time of sending and delivery status.

Privacy policy: resend.com/legal/privacy-policy

Transfer to third countries: USA, safeguarded by Resend's data processing agreement with EU Standard Contractual Clauses; Resend is also certified under the EU-U.S. Data Privacy Framework.

Legal basis: Art. 6(1)(b) GDPR (performance of a contract – provision of the user account)

4.6 Google Analytics for Firebase (Usage Statistics, Only with Consent)

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland / Google LLC, USA

Purpose: We measure anonymously which features of the app are used and whether it runs stably, in order to improve it.

On first launch the app asks whether you agree. Without your consent nothing is collected and nothing is sent to Google. You can withdraw your consent at any time under Settings → “Usage statistics”; collection then stops immediately.

Data transmitted (only after consent): events such as app start, registration, login, opening the plans page, purchase or cancellation of a subscription (with plan name and price), sending a quote, cost estimate or invoice, and deletion of the account – in each case only the fact, never the content. In addition your current plan (e.g. trial or subscription) as a user property, device and app information (device model, Android version, app version, language), a random app instance ID and approximate region. No customer data, amounts, document texts or photos are transmitted; the advertising ID is not collected, and advertising features and personalized advertising are switched off.

Storage period: Event and user data are deleted in Google Analytics after 2 months. Google Analytics itself detects that the app has been uninstalled; this too is only evaluated with your consent.

Transfer to third countries: USA, safeguarded by EU Standard Contractual Clauses and the EU-U.S. Data Privacy Framework; the basis is Google's data processing terms.

Legal basis: Art. 6(1)(a) GDPR and Section 25(1) TDDDG (consent).

5. App Permissions

The app requests the following system permissions:

The app does not request access to location, contacts, SMS, call log or other apps.

Permissions are requested at runtime and can be revoked at any time in the Android system settings. Without camera/microphone access, the affected individual functions (photo analysis, voice recording) cannot be used; the rest of the app remains fully functional.

6. Storage Period

7. Your Rights as a Data Subject

You have the right at any time to:

• access to the personal data processed by us (Art. 15 GDPR)
• rectification of inaccurate data (Art. 16 GDPR)
• erasure of your data (Art. 17 GDPR)
• restriction of processing (Art. 18 GDPR)
• data portability (Art. 20 GDPR)
• object to processing (Art. 21 GDPR)
• withdraw consent given, with effect for the future (Art. 7(3) GDPR)
• lodge a complaint with a supervisory authority (Art. 77 GDPR)

Functions Available Directly in the App

• Data export: Under Settings → “Export My Data”, you can download all stored data as a JSON file, including your invoices with the e-invoice data and the change log.
• Export for tax advisor: Under Settings → “Export for tax advisor”, you receive your quotes, cost estimates and invoices for a period as a ZIP archive (PDF, e-invoice, tables, change log) and, if desired, a DATEV posting batch. The file is created on your device; you decide where to store it and to whom to pass it on.
• Account deletion: Under Settings → “Delete Account”, you can have your account and all associated data irrevocably deleted. This also deletes your quotes and invoices; the app offers you the option of downloading the archive for all years beforehand (section 3.5).
• Withdrawal of AI consent: You can deactivate the AI-supported analysis in the settings at any time.

For all other requests, please contact: info@simplynext.de

8. Data Security

We use technical and organisational measures to protect your data against loss, misuse and unauthorised access:

• Encrypted transmission of all data via TLS/HTTPS
• Access control at database level (Row Level Security) – each user can only access their own data
• Secure, PKCE-based authentication with automatic token expiry and renewal
• Third-party API keys (e.g. RevenueCat) are not stored in the app code but provided securely server-side
• Passwords are stored exclusively in encrypted (hashed) form
• Sent documents and their archived PDFs are locked against modification and premature deletion at database and storage level; checksums and a chained change log make changes detectable

9. No Automated Decision-Making

No automated decision-making within the meaning of Art. 22 GDPR that produces legal effects concerning you takes place. The AI-supported recognition of materials and working hours serves only as a suggestion; you check all AI-generated information before saving or sending a document (for quotes and cost estimates additionally via the confirmation in the app: “I have reviewed the AI-generated data and confirm its accuracy”).

10. Changes to This Privacy Policy

We reserve the right to amend this privacy policy to adapt it to changes in the legal situation or in the event of changes to the app or to data processing. The new privacy policy will then apply to your next visit or next use of the app. We will inform you separately in the app of any significant changes.

11. Contact

If you have any questions about data protection, please contact:

• SimplyNext
• E-Mail: info@simplynext.de
• Phone: +49 1743389049