Privacy policy

Last updated: Sep 30, 2026

This policy covers personal data for which ZeroCrumb is the controller. For data a bakery processes through ZeroCrumb, the bakery is the controller — see the data processing agreement.

1. Controller

[Company name, address, email — same as in the legal notice]

2. Two roles — please distinguish

ZeroCrumb acts in two distinct roles. This is not a formality — it determines who is accountable for which data:

3. Data processed and legal bases

3.1 Account data

Email address, business name, role and language preference. Authentication runs on Amazon Cognito, which additionally processes sign-in times and security events. If you customise your dashboard, we store which cards it shows, in which order and width, and with which settings. If you set your own order of the products for a table (Products, Logbook, Forecasting), we store that order. These settings contain no free text. They are deleted with the account. Legal basis: Art. 6(1)(b) GDPR (performance of a contract).

3.2 Business and sales data

Sales figures, product catalogue, opening days, and the business country and city. Also the production figures you enter in the Logbook or import from your production workbook (baked, left over, sold out at), the workbook column names you match to a product, and — only if you explicitly choose it during the import — its day comments as day notes. The workbook itself is read in your browser only and is not uploaded; only product, date, figures and any chosen comments are sent. Cell notes (they carry author names) are never read. Please do not write names or contact details of people into notes. Largely non-personal, but linked to an account. Used to produce demand forecasts — the purpose of the service. Legal basis: Art. 6(1)(b) GDPR.

3.3 Server logs

Technically necessary data is processed on each request (IP address, timestamp, requested resource, status code). Legal basis: Art. 6(1)(f) GDPR (operational security).

3.4 Security event log

Security-relevant account events are logged: sign-in, password change, enabling or disabling two-factor authentication, signing out all devices, data export and account deletion. Only the account identifier, the event type, the timestamp and whether the event was observed server-side or reported by the browser are stored. No IP addresses, email addresses or user-agent strings are logged. The table has no column capable of holding such data. Legal basis: Art. 6(1)(f) GDPR (security of processing, Art. 32 GDPR) and Art. 33 GDPR. Deleted after 365 days.

4. No tracking, no cookie banner

ZeroCrumb uses no analytics, advertising or tracking services. Only strictly necessary cookies/storage entries are set, for sign-in and language preference. These require no consent under §25(2) TTDSG — which is why there is deliberately no cookie banner. This statement must be revisited the moment any analytics tool is added.

5. Recipients and sub-processors

Server provider: netcup GmbH, Emmy-Noether-Straße 10, 76131 Karlsruhe, Germany (HRB 705547, Amtsgericht Mannheim). The server is located in the Vienna, Austria datacentre, so processing takes place exclusively within the EU.

For providers with a possible third-country element, appropriate safeguards (standard contractual clauses) must be verified and documented. Status of the Art. 28 GDPR processing agreements: [conclude and file the DPA with netcup GmbH — still outstanding]

6. Retention

• Account data: until the account is deleted.
• Forecast history: automatically deleted after 180 days.
• Production figures and workbook imports: until the account is deleted. An import can be undone in the Logbook: its figures are removed (values entered before come back), and so are the day notes it brought in, unless they were changed since.
• Security event log (section 3.4): automatically deleted after 365 days. Entries deliberately outlive account deletion so that the deletion itself remains evidenced; they contain no content data.
• Register receipts: while the account exists, imported receipts are not deleted individually. If an import is rolled back the receipt is kept and marked as voided with a timestamp and reason, so the import history stays auditable.
• On account deletion ALL of the business’s data is removed, including imported receipts. The statutory retention duty (RKSV, roughly seven years) rests with the bakery and is met by its own cash register — ZeroCrumb holds only a working copy as processor and returns or deletes it at the end of the contract (Art. 28(3)(g) GDPR).

Deletion can be triggered in the application itself (Account → Data) and requires typing the business name to confirm. It removes the data from the database and the user account from the authentication service.

7. Automated forecasting

ZeroCrumb produces demand forecasts from each business’s own sales data. Models are trained per business only — one bakery’s data never informs another’s forecast. A forecast is decision support for production planning and has no legal effect on any individual, so Art. 22 GDPR is not expected to apply.

8. Your rights

You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and objection (Art. 21), and the right to lodge a complaint with a supervisory authority (Art. 77). Requests to: [datenschutz@…]

Where a request concerns data a bakery processes through ZeroCrumb (for example customer details on a receipt), the bakery is the controller. We forward such requests to them without delay.