Privacy Policy

1. Controller

The controller within the meaning of the GDPR is the provider of this app. The full contact details (name, address, email) can be found in the Legal Notice (shown there as an image to make data misuse more difficult).

2. What Data Is Processed?

a) Server logs (Netlify)

When this web app is accessed, the hosting provider Netlify, Inc. (512 2nd Street, Suite 200, San Francisco, CA 94107, USA) automatically stores information in so-called server log files. This includes:

• IP address of the requesting device
• Date and time of access
• Name and URL of the file accessed
• Browser type and version
• User's operating system
• Referrer URL (previously visited page)

This data is technically necessary to deliver the app and is not combined with other data sources. Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in operating a secure and functional website).

Netlify processes this data in the USA. Netlify is certified under the EU-US Data Privacy Framework and provides a Data Processing Agreement (DPA). Further information: netlify.com/gdpr-ccpa

b) Umami Analytics (audience measurement)

FireLotse uses Umami Cloud, a privacy-friendly open-source analytics tool provided by Umami Software, Inc. The data is stored in the EU region. Umami does not process any personal data.

For page views and anonymous usage events (e.g. which features are used), the following technical information is collected:

• Page accessed (URL)
• Referrer (previously visited page, if any)
• Browser name and version (derived from the user agent)
• Operating system (derived from the user agent)
• Device type (desktop / mobile / tablet)
• Screen resolution
• Browser language
• Country of origin (derived from the IP address – the IP address itself is not stored)

Umami sets no cookies, does not store IP addresses, does not create user profiles and does not enable cross-device tracking. Your financial data from LocalStorage is never transmitted – Umami has no technical access to it.

Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in anonymous audience measurement to justify operating the app). A cookie consent banner is not required pursuant to § 25 (2) No. 2 TDDDG, as no cookies are set.

c) LocalStorage (your financial data)

FireLotse stores all data you enter (assets, cash flow, debts, personal settings) exclusively in your browser's LocalStorage. This means:

• The data does not leave your device
• We have no access to your financial data
• No transmission to servers takes place
• The data remains stored until you delete it manually

You can remove your data at any time via Settings → Delete data or clear the LocalStorage via your browser settings.

As no personal data is processed or transmitted, no legal basis under the GDPR is required for LocalStorage.

d) Parqet import (optional)

FireLotse offers an optional connection to Parqet (Parqet GmbH, Germany) to automatically transfer portfolio data into the asset building blocks. Use of this feature is voluntary – it must be actively started by the user via the "Parqet Import" module.

The connection uses an OAuth2 authorisation flow (PKCE). You are redirected to the Parqet website, where you authorise the connection. FireLotse then receives a time-limited access token with the scope portfolio:read (read-only access to portfolio data).

The following data is processed during use:

• OAuth2 token (access token, expiry time) – stored locally in the browser (LocalStorage)
• Portfolio data (position names, ISIN, current market values) – retrieved from the Parqet API and stored locally
• Assignments (mapping to asset building blocks) – stored exclusively locally

API communication with Parqet takes place via a server-side proxy (Netlify Function), as the Parqet API does not allow direct browser requests (CORS). The proxy forwards requests and stores no data. Your access token is transmitted from the browser to the proxy with each request and is used there only for forwarding to Parqet.

You can revoke the connection at any time via Parqet Import → Disconnect. This deletes the token and all imported data from LocalStorage.

Legal basis: Art. 6 (1) (a) GDPR (consent through voluntary activation and authorisation of the Parqet connection).

e) Cloud Sync via Dropbox or OneDrive (optional)

FireLotse offers an optional Cloud Sync feature that allows you to use your local data set across devices (e.g. desktop and tablet). The feature is part of the optional Cloud Sync module and must be actively enabled by the user. Supported cloud storage providers are Dropbox (Dropbox International Unlimited Company, One Park Place, Floor 5, Upper Hatch Street, Dublin 2, Ireland) or Microsoft OneDrive (Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland). You choose which provider to use when connecting. FireLotse operates no server of its own for synchronisation – your data is stored exclusively in your own cloud account.

The connection uses an OAuth2 authorisation flow (PKCE). You are redirected to the website of the selected provider (Dropbox or Microsoft) and authorise the connection. In both cases, FireLotse uses an app folder scope (Dropbox: App folder scope, OneDrive: Files.ReadWrite.AppFolder) – the app therefore has access only to the folder created specifically for it (/Apps/FireLotse/ or Apps/FireLotse). FireLotse has no access to any other content in your cloud account.

The following data is processed while Cloud Sync is active:

• OAuth2 tokens (access token, refresh token, expiry time) – stored locally in the browser (LocalStorage). They are not written to the cloud file and not to JSON exports, so that shared backups contain no credentials.
• Account information (email address, display name, country) – retrieved once after connecting and used exclusively locally for display in the UI (e.g. "Connected to Dropbox (you@mail.com)"). It is not processed further, not written to the cloud file and not passed on to third parties.
• Synchronised user data – on manual upload, a JSON snapshot of your local data set (assets, cash flow, debts, milestones, retirement configuration etc.) is written to the file firelotse.json in the app folder of your cloud account (Dropbox: /Apps/FireLotse/firelotse.json, OneDrive: Apps/FireLotse/firelotse.json). The OAuth tokens are removed from the snapshot before upload.
• Sync metadata (time of the last sync, revision identifier of the cloud file) – stored locally to detect conflicts between devices.

Note on the permission dialog: During the OAuth process, Dropbox indicates that FireLotse can additionally view "basic information about your Dropbox account" (user name, email, country). This permission (account_info.read) is automatically and inseparably enabled by Dropbox when file scopes are granted and cannot be removed in the Dropbox app setup. FireLotse uses it exclusively to display the account email in the UI; no further processing takes place. With OneDrive, Microsoft additionally requests the permissions "Sign you in and read your profile" (User.Read) and "Maintain access to data you have given it access to" (offline_access). FireLotse uses the profile exclusively to display the email address and display name in the UI; offline_access allows the connection to be maintained without signing in again.

API communication with Dropbox or Microsoft takes place directly from the browser – unlike the Parqet import, no server-side proxy is used. As a result, no data is ever transmitted to a server operated by FireLotse.

Cloud Sync is fully manual: uploading and downloading are only triggered by an explicit user action (buttons "Upload now" and "Load from cloud"). No automatic background sync takes place.

You can revoke the connection at any time via Cloud Sync → Disconnect. This deletes all tokens from LocalStorage. The file firelotse.json stored in your cloud account is kept and can be deleted manually by you in Dropbox or OneDrive.

Dropbox processes data in the USA, among other places. Dropbox is certified under the EU-US Data Privacy Framework and provides a Data Processing Agreement (DPA). Further information: dropbox.com/privacy .

When OneDrive is used, Microsoft processes data in the USA, among other places. Microsoft is certified under the EU-US Data Privacy Framework and provides a Data Processing Agreement (DPA). Further information: privacy.microsoft.com .

Legal basis: Art. 6 (1) (a) GDPR (consent through voluntary activation of the Cloud Sync module and authorisation of the connection to the selected cloud provider).

f) Fonts

This app uses the typefaces DM Sans and DM Serif Display, which are embedded locally (self-hosted). No connection is made to Google Fonts or any other external font servers.

3. Cookies

FireLotse sets no tracking cookies of its own. The hosting provider Netlify may set technically necessary cookies (e.g. for DDoS protection and load balancing). These are essential for operation and fall under the legitimate interest pursuant to § 25 (2) No. 2 TDDDG – a cookie consent banner is therefore not required.

4. Your Rights

You have the following rights towards us:

• Access (Art. 15 GDPR): What data do we process about you?
• Rectification (Art. 16 GDPR): Correction of inaccurate data
• Erasure (Art. 17 GDPR): Deletion of your data
• Restriction (Art. 18 GDPR): Restriction of processing
• Objection (Art. 21 GDPR): Objection to processing
• Right to lodge a complaint with the competent supervisory authority (LDI NRW)

As we process practically no personal data (apart from technically necessary server logs via Netlify), these rights must largely be asserted against Netlify. Contact: Netlify Privacy

For all other enquiries, please contact the provider using the contact details given in the Legal Notice.

5. External Links & Services

This app contains no embedded social media and no payment services. All calculations take place entirely locally in the browser. Optional external API connections (Parqet import and Cloud Sync via Dropbox or OneDrive) are described in sections 2d and 2e and are only used after explicit activation by the user.

Feedback form (Netlify Forms)

FireLotse offers an integrated feedback form that is processed via Netlify Forms (Netlify, Inc., 512 2nd Street, Suite 200, San Francisco, CA 94107, USA). Use is voluntary.

When you submit the form, the data you enter (feedback type, title, message and optionally your email address and an attached screenshot) is transmitted to Netlify and stored there. No cookies are set and no tracking takes place. Your financial data from FireLotse is not transmitted automatically – you decide yourself what you enter in the form.

You only add a screenshot actively yourself (by pasting or choosing a file). The image is shrunk in your browser before sending and transmitted to Netlify together with the form. Please make sure it does not show unnecessary sensitive data (e.g. account balances).

Submissions, including attached screenshots, are deleted as soon as your request has been dealt with.

Netlify processes this data in the USA and is certified under the EU-US Data Privacy Framework. Further information: netlify.com/gdpr-ccpa

Legal basis: Art. 6 (1) (a) GDPR (consent through voluntary use of the form).

6. Changes to This Privacy Policy

We reserve the right to update this privacy policy to adapt it to changes in the law or to changes to the app. The current version is always available in the app.

7. Competent Supervisory Authority

State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, LDI NRW)
Postfach 20 04 44, 40102 Düsseldorf, Germany
www.ldi.nrw.de