Legal
Data processing
This is a translation for information purposes. The German version is the legally binding one.
For all personal data that a customer and the persons it has invited process in Feldkontor, the customer is the controller. ALR Consulting UG (haftungsbeschränkt) is the processor. The basis is the following agreement, which is concluded together with the usage contract. The details of the controller that have to be filled in are added when the contract is concluded.
§ 1 Subject matter and duration
The Processor operates the web application “Feldkontor” for the Controller on the basis of the usage contract. This agreement applies for the term of the usage contract and beyond, as long as the Processor processes data of the Controller.
§ 2 Nature, purpose, data and data subjects
| Item | Content |
|---|---|
| Nature of the processing | Collecting, storing, making available, displaying, evaluating, backing up, restoring and deleting data in the application; sending invitation and notification e-mails |
| Purpose | Site diary, construction progress, logistics, daywork, defects, serial numbers, variation orders, test, measurement and earthing test records as well as construction controlling for projects of the Controller |
| Types of personal data | Name, e-mail address, company, role and rights in the project; login times, IP addresses and device details of the sessions; personnel details in daily site reports such as headcount, working hours and crew designations; names and signatures on daywork sheets, records and attendance lists; core workers reported by subcontractors; photos from the site in which persons may be identifiable |
| Categories of data subjects | Employees of the Controller, employees of its subcontractors, representatives of its client or the owner, other invited users |
| Special categories under Art. 9 GDPR | are not processed; the Controller ensures that such data is not entered |
| Place of processing | exclusively within the European Union |
§ 3 Instructions
The Processor processes the data only on documented instructions from the Controller, unless it is required to process it under Union law or the law of a Member State; in that case it notifies the legal requirement before the processing, unless the law prohibits this.
Instructions are given in writing. The Controller confirms oral instructions in writing without delay. If the Processor considers an instruction unlawful, it says so without delay and may suspend its execution until the matter is clarified.
§ 4 Duties of the Processor
It obliges all persons who have access to the data to maintain confidentiality.
It takes the technical and organisational measures under Art. 32 GDPR in accordance with Annex 1 and adapts them to the state of the art without lowering the level of protection.
It supports the Controller with reasonable measures in meeting the rights of data subjects under Art. 12 to 23 GDPR. If a data subject approaches the Processor directly, it forwards the request to the Controller without delay and does not answer it itself.
It supports the Controller with the duties under Art. 32 to 36 GDPR, to the extent that the required information is not otherwise available to the Controller.
It reports personal data breaches without delay, as a rule within 48 hours of becoming aware of them, with the details under Art. 33(3) GDPR as far as these are known.
It keeps a record of processing activities under Art. 30(2) GDPR.
Support services that go beyond the statutory scope or that are prompted by circumstances within the Controller's sphere of responsibility are paid for by the Controller on a time basis at the agreed hourly rate ⟨hourly rate⟩; the Processor gives notice of this beforehand.
§ 5 Sub-processors
The Controller gives general authorisation for sub-processors to be engaged and approves the following:
| Sub-processor | Service | Place |
|---|---|---|
| STRATO GmbH, Otto-Ostrowski-Str. 7, 10249 Berlin | Server operation, storage, data backup | Germany |
| A.S. Burgos Assistenz Dienstleistungen, owner Ana Silvia Burgos Gonzales, Am Mühlenbach 1, 49536 Lienen | Maintenance, fault rectification and further development of the application, setting up projects | Germany |
| No separate dispatch service, e-mails are sent through the operator's mailbox at STRATO GmbH | Sending invitation and notification e-mails | Germany |
The Processor informs the Controller of intended changes at least four weeks in advance in writing. The Controller may object for important data protection reasons. If it objects, the Processor may terminate the agreement in respect of the service concerned with one month's notice.
The Processor contractually obliges sub-processors to the same data protection duties and is liable to the Controller for their compliance.
Telecommunications, postal, transport and cleaning services as well as other ancillary services with no connection to the processing of the data do not count as sub-processing.
Weather display. The server retrieves the weather details for the daily site report from Open-Meteo and transmits only the coordinates of the site, no personal data; the result is cached for one hour. In server operation the user's browser does not call the service directly, so the service receives no IP addresses of the users.
§ 6 Audit rights
The Controller may satisfy itself that this agreement is being complied with. It announces audits at least two weeks in advance and carries them out during normal business hours without disrupting operations, as a rule once per calendar year and whenever there is specific cause.
The Processor provides the required information and evidence, in particular on the measures under Annex 1 as well as evidence from its sub-processors, to the extent that it holds this.
For the effort of an audit that goes beyond information given in writing, the Processor may charge remuneration on a time basis.
§ 7 Deletion and return
After the services end the Processor either hands over the data as a data export or deletes it, at the Controller's choice, at the latest 30 days after the end of the contract, unless a statutory retention obligation applies.
Data backups are deleted when their retention period of 120 days expires. Until then they are blocked against restoration and are stored further only in order to meet this deletion duty.
Entries deleted in the application stay in the archive for up to 120 days and are then deleted for good.
§ 8 Liability and final provisions
Art. 82 GDPR applies to liability. Between the parties each party is liable for the part of the damage that it caused; Art. 82(5) GDPR remains unaffected.
Otherwise the provisions of the usage contract apply, in particular its liability provisions. In the event of conflict this agreement takes precedence over the data protection provisions of the usage contract.
Amendments must be in writing. German law applies. Should a provision be invalid, the validity of the remaining provisions is not affected.
Annex 1: technical and organisational measures under Art. 32 GDPR
The measures describe the state of version 1.6.3 of the application of 21 October 2026. The detailed version of this annex exists as a separate document; in the event of discrepancies the detailed document applies.
| Protection objective | Measure |
|---|---|
| Physical access control | Operation on a virtual server of STRATO GmbH; their data centres in Berlin and Karlsruhe are certified to DIN ISO/IEC 27001, the processing takes place exclusively in Germany |
| System access control | Login only with a personal user account; passwords of at least 10 characters from 3 of 4 character types or 16 characters; stored exclusively as a bcrypt hash; first login via a randomly generated one-time code valid for 72 hours, stored only as an SHA-256 hash; lockout for 15 minutes after 8 failed attempts per IP address or 10 per account; server access exclusively via SSH for administrators |
| Data access control | Roles and individual rights per project; rights checked by the server on every read and write access; tenant separation, users see only the projects assigned to them; internal content is not delivered to client and reader roles |
| Transfer control | Transmission exclusively encrypted over HTTPS with a valid certificate; configuration files with access credentials readable only by the system service |
| Input control | Editor and time stamp stored for daily site reports, approvals and test records; unchangeable audit log of all changes to users, rights and projects; login history of the last 20 logins per user; checksum for every PDF produced |
| Availability control | daily full backup with 120 days of retention; additional backup before updates, restores and changes to the project master data; restoration of individual projects or of the whole data set; archive of deleted entries for 120 days; a backup copy held outside the server |
| Separation control | separate tenants and project areas in the database; rights checked per project; separation of the production, demonstration and development environments |
| Processing control | Processing only on instruction; the persons involved are obliged to maintain confidentiality; data processing agreements with all sub-processors |
| Review | The measures are reviewed with every new version of the application, at least once a year; state of the review: version 1.6.3 of 21 October 2026 |