Privacy policy

The controller for data processing on this website, for orders and in the Phonestar customer portal is:

Phonestar LLC
30 N Gould St Ste N
Sheridan, WY 82801
United States of America
Phone: +49 151 16347800
Email: [email protected]

Please send data protection enquiries and requests to exercise your rights to [email protected].

Contact for data protection matters: Phonestar LLC, 30 N Gould St Ste N, Sheridan, WY 82801, United States of America, email: [email protected].

Phonestar is a cloud-based phone system with phone numbers, an app, a customer portal and voice assistants (voice agents). We process personal data only to the extent necessary to operate this website, for your order, to provide the telecommunications service, for billing and to meet legal obligations.

On this website we use no cookies for recognition and no analytics or advertising services. Your browser stores only what you choose yourself or put in the cart: country and customer type for the price display and the cart (section 3.4). We serve fonts from our own server; no third party is contacted for them. Third-party services are only integrated in the consultation form, at checkout and on the payment page: Cloudflare Turnstile (section 3.3), at checkout for addresses outside Germany, Austria and Switzerland and only with your consent, address suggestions from Google (section 4.2), and on the payment page the payment form of Stripe (section 5.3). During a payment the website sets a technically necessary cookie (section 5.3). What the website stores and what you can consent to is explained in plain words on the privacy settings page. The customer portal uses only technically necessary cookies for sign-in (section 7).

This privacy policy informs you as a visitor to the website, as a prospective customer, as a customer and as a user of a customer. Where we process data of people calling our customers, we do so on behalf of the respective customer (sections 8 and 9); the customer is then the controller.

3.1 Accessing the pages

When you access the website, your browser technically transmits data to our server, in particular the IP address, date and time, the requested address, the previously visited page (referrer) and information about the browser and operating system. We process this data to deliver the pages and to ensure secure operation (Art. 6 (1) (f) GDPR). The website is delivered via the network of Cloudflare, Inc. (protection against attacks and overload); Cloudflare processes connection data such as your IP address on our behalf (sections 12 and 13). We store server logs containing this information only as long as necessary for secure operation and for investigating faults or attacks, and evaluate them only for this purpose. For hosting, see section 12.

3.2 Consultation form

When you submit the form “Arrange a consultation”, we process the information you enter: name and email address (mandatory) and — voluntarily — company name and address, phone number, number of employees, your message, preferred contact method and preferred time. The information is sent as an email via our own mail server to our mailbox; it is not stored in a database of the website.

The purpose is to handle your enquiry and to prepare a contract (Art. 6 (1) (b) GDPR), and otherwise our interest in answering enquiries (Art. 6 (1) (f) GDPR). We delete consultation enquiries once your request has been dealt with and no contract is concluded.

3.3 Protection against automated requests (Cloudflare Turnstile)

To protect the consultation form and checkout against automated input we use the “Turnstile” service of Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. For this, a script is loaded from challenges.cloudflare.com; Cloudflare receives your IP address and technical information about your browser and device and checks whether the input comes from a human. Our server then has the result confirmed by Cloudflare and transmits the verification token and your IP address for this. If Cloudflare is unavailable, a consultation enquiry is still accepted. Cloudflare does not set recognition cookies for Turnstile.

In addition, we use a form field that is invisible to humans and measure the time between displaying and submitting the form. These two checks run exclusively on our server.

The legal basis is our interest in protection against abuse and spam (Art. 6 (1) (f) GDPR). Cloudflare is our processor; Cloudflare is certified under the EU-U.S. Data Privacy Framework (section 13).

3.4 Price display and cart in the browser

If you choose your country and whether you order as a private individual or as a company in the header, the cart or at checkout, your browser stores this choice in two cookies (ps-land and ps-kundenart, one year each) and in the browser's local storage. Our server reads the cookies only to display prices appropriately (gross including VAT or net). Without a choice, the website shows prices for private customers in the country derived from your IP address; Cloudflare provides this information when delivering the website (section 3.1), and we do not store it.

Your browser keeps the contents of your cart (plan, number of users, eSIM data packages) in local storage until you empty it or order; it is only sent to our server at checkout.

These storage operations are strictly necessary for the functions you request (Section 25 (2) No. 2 TDDDG); the processing is based on Art. 6 (1) (b) GDPR. You can delete them at any time in your browser settings.

Consent to further services: On your first visit in a session, a notice asks for whom prices should be displayed (private or company, country) and whether you allow further services (“Allow all”) or only want to use the necessary functions (“Necessary only”). If you close the notice without a choice, “Necessary only” applies. The purpose of the consent is to use services only if you want them; which services these are is explained on the privacy settings page and in section 4.2. Your browser stores your decision only in session storage (ps-consent: your choice and the time), not in a cookie and not permanently; it is deleted when the session ends (closing the browser or tab), and we ask again on your next visit. It is not sent to our server. The legal basis for storing the decision is Section 25 (2) No. 2 TDDDG, and for the services consented to, your consent (Section 25 (1) TDDDG, Art. 6 (1) (a) GDPR). You can withdraw your consent at any time with effect for the future: via “Privacy settings” or “Withdraw consent” in the footer of every page or on the privacy settings page.

4.1 Ordering via the website (cart and checkout)

When you order via the website checkout, we process:

• whether you order as a private individual or as a company, for companies the company name and, where applicable, the VAT identification number,
• first name, last name, email address and phone number,
• the address (street and house number, address supplement where applicable, postcode, town, country),
• for private individuals, the date of birth,
• the contents of your cart (plan, number of users, eSIM data packages) with prices and VAT,
• a referral code, where applicable,
• your confirmation that you have read the terms and the withdrawal information and, where applicable, your request to receive the activation code of an eSIM before the withdrawal period ends, each with a timestamp,
• technical information: your IP address to limit abuse, the country derived from it and the language of the page.

Verification code: Before you can order, we send a six-digit code to the email address you entered; with it you confirm that the address belongs to you. The code is valid for ten minutes; after three failed attempts you request a new one. It is sent via our own mail server. We do not store the code in a database: the check runs via a token signed by our server, which your browser keeps until the order, and a counter of failed attempts in our server's memory, which expires with the code.

Transfer to our billing system: When you submit, the website transfers your order to the billing system of Phonestar LLC, which we operate ourselves (section 12). The order is stored and processed there; from there you receive the confirmation of receipt by email. The website itself does not store your order in a database. If a payment is due at checkout, the website redirects you to the payment page (section 5.1); until you reach the confirmation page, your browser keeps the order number, whether a payment is open and, where applicable, the payment link in local storage, for at most 14 days. On the confirmation page, the cart in your browser is emptied.

Protection against abuse: Before submission we use Cloudflare Turnstile, a form field invisible to humans, a time measurement and a limit on orders and code requests per IP address as well as on code requests per email address (section 3.3).

Purpose and legal basis: We process the information to conclude and perform the contract with you (Art. 6 (1) (b) GDPR) and to collect the subscriber data we are obliged to collect as a provider of telecommunications services, in particular name, address and, for natural persons, date of birth (Art. 6 (1) (c) GDPR in conjunction with Section 172 TKG). Protection against abuse is based on our legitimate interest (Art. 6 (1) (f) GDPR).

Retention: If a contract is concluded, the order becomes part of your contract records; the periods in section 14 apply, and for subscriber data under Section 172 TKG until the end of the calendar year following the end of the contract. If we decline the order or you cancel it, we delete it as soon as it is no longer needed for processing and possible queries and no statutory retention obligations apply.

4.2 Address suggestions (OpenPLZ, Google Places)

So that your address is correct and complete, checkout suggests matching towns and streets as you type. You can always enter your address without suggestions.

Germany, Austria and Switzerland: The suggestions come from the OpenPLZ API (openplzapi.org), a free directory of postcodes, towns and streets. Your browser only queries our server; our server queries OpenPLZ and transmits only the country, the postcode, the town and the beginning of the street name you typed, without house number, without your IP address and without any further personal information. We keep the responses in our server's memory for up to 24 hours so that identical queries are not repeated. The legal basis is our legitimate interest in a correct and complete address, which we must collect as subscriber data (Art. 6 (1) (f) GDPR).

Other countries (Google Places): For addresses outside Germany, Austria and Switzerland we use the “Places Autocomplete” service of the Google Maps Platform (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). These suggestions are only available if you have chosen “Allow all” (section 3.4); without consent you enter the address freely. Even then, checkout loads Google's script only once you have chosen such a country and click into the street field, not before and on no other page.

While you type, your browser transmits your input in the street field, your IP address and technical information about your browser and device to Google; if you choose a suggestion, checkout retrieves the components of that address from Google. Google does not receive your other checkout details (such as name, email address or date of birth). The legal basis is your consent (Section 25 (1) TDDDG, Art. 6 (1) (a) GDPR), which you can withdraw at any time (section 3.4). Google processes the data as an independent controller under the terms of the Google Maps Platform and is certified under the EU-U.S. Data Privacy Framework (section 13); further information can be found in Google's privacy policy.

4.3 Subscriber data and other ways of ordering

To set up your connection and for the contract we process, from checkout, the customer portal or the information you provide in text form:

• email address, first name, last name, phone number,
• address (street and house number, postcode, town, country), for natural persons the date of birth,
• whether you order as a private or business customer, and the chosen plan,
• for business customers: company, where applicable register number, register court and authorised representative, where applicable VAT identification number,
• a referral code, where applicable.

The purpose is concluding and performing the contract (Art. 6 (1) (b) GDPR) and meeting telecommunications law obligations to collect subscriber data (Section 172 TKG, Art. 6 (1) (c) GDPR). We need the phone number to reach you with queries, in particular about number porting.

If you provide an EU VAT identification number, we check it via the European Commission's VIES system; the number is transmitted to the Commission for this. The legal basis is the correct tax treatment of the invoice (Art. 6 (1) (c) GDPR).

5.1 Payment

You pay invoices via the secure payment page of a licensed payment service provider, which you reach from the customer portal. If a payment is due at checkout when ordering via the website, checkout redirects you after submission to our payment page (address phonestar.io/link/…), in which the payment form of the payment service provider is embedded (section 5.3); you also receive the link by email. For this we pass the amount, the order number and the address to which the provider redirects you after payment to the payment service provider. The payment service provider is a supervised payment institution. You enter your payment details (such as card number or bank details) directly on its payment page; it processes them for payment processing, to meet its legal obligations and for fraud prevention under its own responsibility. If you store a payment method there for future invoices, the payment service provider stores it.

We receive from the payment service provider only the payment status and the information needed for accounting and billing: amount, time, payment method, an identifier of the payment transaction or the stored payment method and, where applicable, the last digits of the card or account. We do not store full card details.

The payment service provider is based in the EU or the USA. If it is based in the USA, the transfer takes place on the basis of the EU-U.S. Data Privacy Framework (Art. 45 GDPR) or the European Commission's standard contractual clauses (Art. 46 (2) (c) GDPR); see section 13. You can see the specific payment service provider on the payment page; in the customer portal we name it before you switch to the payment page, and on request. On our payment page phonestar.io/link/… it is Stripe (section 5.3).

The legal basis is the performance of the contract (Art. 6 (1) (b) GDPR).

5.2 Invoices

We create invoices, credit notes and payment reminders with our billing platform, which we operate ourselves (section 12). Your master data (name or company, address, country, email address, VAT identification number where applicable), the invoice items, the credit balance and the payment status are stored there.

The legal basis is the performance of the contract (Art. 6 (1) (b) GDPR) and compliance with commercial and tax law obligations (Art. 6 (1) (c) GDPR). We retain invoices and accounting records for the statutory retention periods, generally ten years from the end of the calendar year in which the invoice was issued.

Via the link in the invoice email you can view the invoice on our website (address phonestar.io/link/…) and download it as a PDF. For this, our server retrieves the invoice from the billing platform and transmits your IP address to it so that abusive requests can be limited (Art. 6 (1) (f) GDPR). The link contains an unguessable token; anyone who knows it can see the invoice. Therefore do not pass it on.

5.3 Payment processing on our payment page (Stripe)

On our payment page (address phonestar.io/link/…) you pay via an embedded payment form of Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland (“Stripe”). The purpose is processing your payment and preventing fraud. We load Stripe's script (from js.stripe.com) only on the payment page and only once the payment has been prepared, not on the other pages of the website. Stripe receives your payment details (such as card number, expiry date and security code or bank details, name, email address where applicable), your IP address and information about your browser and device as well as the amount and purpose of the payment. You enter your payment details directly into Stripe's form; they do not reach our server. Stripe uses its own cookies and similar technologies to detect fraud and to process the payment securely. Stripe processes the data for payment processing, to meet its legal obligations and for fraud prevention under its own responsibility; further information can be found in Stripe's privacy policy. Stripe may transfer data to Stripe, Inc. in the USA; Stripe, Inc. is certified under the EU-U.S. Data Privacy Framework (section 13).

The legal basis is the performance of the contract (Art. 6 (1) (b) GDPR); Stripe's cookies are necessary for the payment you request (Section 25 (2) No. 2 TDDDG). We do not ask for consent for this; if you do not want to pay via the payment page, you can write to us.

Cookie during payment: When a payment process starts on the payment page, our server sets a technically necessary cookie ps-claim-… (a random proof that the process belongs to your browser, not readable by scripts, at most 24 hours). It only serves to query the status of your payment without transmitting the proof in the address. It is not set when the page is merely opened. The legal basis is Section 25 (2) No. 2 TDDDG and our legitimate interest in secure payment processing (Art. 6 (1) (f) GDPR). When loading the payment page and during payment, our server transmits your IP address to our billing platform so that abusive requests can be limited (Art. 6 (1) (f) GDPR).

6.1 Plausibility check and identity verification in individual cases

Plausibility check: Before activating your connection, we check the subscriber data from your order for plausibility, in particular whether the address given exists (Art. 6 (1) (c) GDPR in conjunction with Section 172 TKG). For this we use the information you gave us and the directories behind the address suggestions at checkout (section 4.2). We do not require an ID document when you order.

Identity verification only in individual cases: If there are indications that information is incorrect or that phone numbers are to be misused, or if proof is required for other reasons (such as for companies or for local landline numbers), we may verify your identity or that of your authorised representative in individual cases. We will then tell you which proof is needed. If we use the secure online procedure of a commissioned verification service for this, you photograph a valid official photo ID; the verification service reads the details and checks the authenticity of the document. Where applicable, you also take a selfie, which the verification service compares with the photo in the ID (selfie match).

Categories of data in individual cases: details from the ID (in particular name, date of birth, address where stated, nationality, type of ID, ID number, validity), the image of the ID, for a selfie match the selfie and the biometric features derived from it, as well as technical information about the verification process (time, device and browser, IP address).

Legal bases: The collection of subscriber data is based on our legal obligation under Section 172 TKG (Art. 6 (1) (c) GDPR), a check in an individual case on the performance of the contract (Art. 6 (1) (b) GDPR) and on our legitimate interest in protection against abuse (Art. 6 (1) (f) GDPR). For a selfie match the verification service processes biometric data; this only happens on the basis of your explicit consent (Art. 9 (2) (a) GDPR), which we obtain before the check starts. You can withdraw your consent at any time with effect for the future, for example by email to [email protected]; the lawfulness of the processing carried out until then remains unaffected.

What we receive: From the verification service we receive the result of the check and the verified master data (name, date of birth, address, type of ID and validity). We do not receive or store the image of your ID, your selfie or biometric features.

Recipients and retention period: The verification service is our processor and processes the data in the EU. It deletes the ID image, selfie and biometric features after the check is completed. We retain the result of the check and the verified master data for the duration of the contract and beyond until the end of the calendar year following the end of the contract (Section 172 TKG). We name the verification service before the check begins, and on request.

6.2 Proof of location

For local landline numbers we need proof of your location in the respective local area. You upload the proof as a PDF file in the customer portal. The file is kept in a non-public storage area; an employee checks it and approves the location. The legal basis is Art. 6 (1) (c) GDPR. We store proofs of location as long as you use numbers of the local area concerned, and beyond that until the end of the calendar year following the end of use.

In the customer portal you manage your phone system, users, phone numbers, announcements, voice agents and orders. You sign in via a link we send to your email address. For the duration of the sign-in, the portal sets technically necessary cookies; we do not use any other cookies, analytics or advertising services in the portal.

We store account data, tenant and user data, orders and settings in a self-operated database (Supabase, self-hosted; section 12). Interventions by our employees in your customer account are logged.

The legal basis is the performance of the contract (Art. 6 (1) (b) GDPR); for storing the sign-in cookies, Section 25 (2) No. 2 TDDDG.

Retention period: We delete the customer account, phone system, users, announcements, call lists, voice agents and call reports after the end of the contract as soon as no statutory retention periods or telecommunications law information obligations stand in the way. Master data needed for invoices is retained in accordance with section 5; subscriber data under Section 172 TKG until the end of the calendar year following the end of the contract.

Support requests

Orders of local landline numbers and international numbers as well as number porting reach us as support requests and are handled by employees. We keep requests you send us by email in our mailbox until they are resolved and no further queries are expected; after the end of the contract we delete them as soon as no statutory retention obligations stand in the way.

8.1 Phone system and switching

Your phone system runs on a system we operate from the manufacturer PortSIP. Calls are handed over via a switching point we operate to our network operator Enreach (Enreach Germany GmbH, Robert-Bosch-Straße 1, 44803 Bochum, Germany), which also provides the phone numbers. Your users (name, email address, extension), phone numbers, call destinations, office hours, announcements, voice messages and the call list are stored in the phone system.

For every connection we process traffic data: calling and called number, start and end of the connection, the line used and the information needed for billing. We do not record call content; exceptions are voice messages that callers leave on your mailbox and calls with voice agents (section 9). The legal basis is Art. 6 (1) (b) GDPR and the provisions of Sections 9 to 12 TDDDG on traffic data.

Retention period: We store traffic data needed for billing for up to six months after the invoice is sent (Section 10 TDDDG); if you have raised objections to the invoice, until they are resolved. You and your users can delete the call list in your phone system yourselves; at the latest we delete it together with the phone system after the end of the contract. You delete voice messages yourself in the app or the customer portal.

8.2 Ordering numbers and number porting

To order local landline numbers and to port existing numbers, we transmit the necessary information to Enreach: name or company, address, the numbers concerned, for landline numbers a proof of address as a PDF file and, for private customers, also the date of birth. Enreach transmits the information on number porting to your previous provider. The legal basis is Art. 6 (1) (b) and (c) GDPR.

8.3 Calling in the app

To make calls on your mobile phone you use the app “Phonestar Connect”, which you set up via the QR code from our welcome email or from the customer portal. The app signs in via the infrastructure of an app telephony provider which, on our behalf, handles the registration of the app, the delivery of calls and messages to the app and the notifications. In doing so, it processes the access details of your extension, device identifiers, call signalling as well as messages and files exchanged via the app; calls are routed via our switching point. So that the app can notify you of incoming calls, it uses the push services of Apple (Apple Push Notification Service) or Google (Firebase Cloud Messaging); Apple or Google receive a device identifier and the information that a notification is to be delivered, but not the content of the call. The legal basis is Art. 6 (1) (b) GDPR.

Microphone and camera: The customer portal only accesses the microphone, after your permission, when you record your own announcement there. The customer portal does not access the camera.

8.4 Texts (SMS)

We receive texts to your mobile number via our network operator Enreach and — for numbers provided via a SIM card in our own gateways — via these gateways. We process the sender number, time and content of the text in order to deliver it to you. The legal basis is Art. 6 (1) (b) GDPR. We store texts in our delivery systems only as long as necessary for delivery and troubleshooting.

If a sender number is assigned to your extension, you can send texts from the app. In doing so, we process the recipient number, the sender number, the time and the content of the text in order to deliver it via our network operator. The legal basis is Art. 6 (1) (b) GDPR. We store sent texts in our delivery systems only as long as necessary for delivery and troubleshooting.

8.5 Mobile data (eSIM)

When you order a data pack for an eSIM, we process your order details (section 4.1), the chosen pack and destination, the eSIM activation code with the QR code generated from it, and the usage and validity data of the pack (data used, start and end of validity, top-ups), which we show you in your account. The purpose is to provide the data pack: issuing the eSIM, showing usage and validity, top-ups and billing. The legal basis is Art. 6 (1) (b) GDPR.

Recipients: The eSIM profiles are provided by upstream mobile network providers which, depending on the destination, are based in the European Union or outside it. They receive the details needed to issue and operate the profile (eSIM identifier and chosen pack) and report usage and validity back to us. On transfers to third countries see section 13.

Retention period: for the term of the contract; after that we keep order and billing data for the statutory periods (section 14).

Customers can have calls answered by an AI voice assistant. Anyone calling such a line speaks with an automated system. The portal informs our customers that the assistant's greeting must make the use of AI recognisable (Art. 50 AI Act).

During the call, the caller's speech is converted into text, processed by a language model and the answer is output as speech. The following services are used:

• LiveKit — call handling; we operate the software ourselves (section 12).
• Deepgram (Deepgram, Inc., San Francisco, USA) — speech recognition (converting speech into text). The audio data is transmitted solely for recognition and processed on our behalf.
• cortecs (Cortecs GmbH, Althanstraße 4, 1090 Vienna, Austria) — access to the language model via a provider with processing in the EU; the summary of the call also runs through it.
• ElevenLabs (ElevenLabs, Inc., New York, USA) — speech output (converting the answer text into speech).
• OpenAI (for customers in the EEA: OpenAI Ireland Ltd., Dublin, Ireland; processing by OpenAI, L.L.C., USA) — only as a fallback if one of the aforementioned services for the language model or speech recognition is unavailable. Data transmitted via the interface is not used by OpenAI for training.

All the services mentioned process the data on our behalf on the basis of data processing agreements. For transfers to the USA, see section 13.

After the call we store a call report: transcript of the call, the caller's number, a callback number mentioned where applicable, messages left and an automatically generated summary. The customer can have the content delivered by email or to their own interface (webhook). Call reports are kept for 90 days and then deleted automatically. We do not store call recordings as audio files. Phone numbers are masked in technical logs.

Our customer is responsible for the content of the calls with the callers; we process this data on the customer's behalf as a processor (Art. 28 GDPR). We provide our customers with a data processing agreement on request (Section 14 of the terms). Callers contact the customer whose line they called to exercise their rights; we support our customers in this.

Creating announcements

When you create an announcement from a text in the customer portal, we transmit the text and the chosen voice to ElevenLabs and store the generated audio file in your phone system. We automatically delete preview versions after a short time; saved announcements remain until you delete them or the phone system is deleted after the end of the contract.

We send you emails that are necessary for the order and the contract: the verification code for your email address at checkout, the confirmation of receipt of your order, the welcome email with the access details to the customer portal and the QR code for the app, reminders of open payments, invoices and payment reminders, announcements of changes and notifications you have set up yourself (such as about calls to your voice agents). They are sent via our own mail server (section 12). We do not send promotional newsletters. The legal basis is Art. 6 (1) (b) GDPR.

If you come to the website via a link with a referral code, your browser keeps the code in session storage only until the tab is closed and inserts it at checkout; you can change or delete it there. If you provide a referral code when ordering, we store the assignment to the referring partner. We calculate the partner's commission from your paid invoices. In their customer portal the partner only sees the number of customers referred via their code and the commission amounts per billing period; they do not receive your name, your company or your contact details. The legal basis is Art. 6 (1) (b) and (f) GDPR (settlement of the referral with the partner).

Self-operated systems

We operate the website, customer portal, database (Supabase), phone system (PortSIP) and switching point, voice agent service (LiveKit), our billing platform and mail servers ourselves on servers we rent. The servers are located in data centres within the European Union. The hosting providers process data exclusively on our behalf on the basis of data processing agreements and have no access to the content of your data. The website and customer portal are delivered via the network of Cloudflare, Inc. (protection against attacks and overload); Cloudflare processes connection data such as your IP address on our behalf (see sections 3.3 and 13).

External service providers

Beyond this, we only pass on data if we are legally obliged to do so, for example to law enforcement authorities and courts within the scope of telecommunications law information obligations (Sections 173 et seq. TKG), to the Federal Network Agency or to tax authorities.

The controller, Phonestar LLC, is based in the USA. Your data is stored on servers in the European Union (section 12). Phonestar employees access customer data to the extent necessary to provide the service, for support and for billing; such access may also take place from the USA. Insofar as this constitutes a transfer to a third country, it is necessary for the performance of the contract with you (Art. 49 (1) (b) GDPR); in addition, Phonestar as controller is directly subject to the GDPR (Art. 3 (2) GDPR) and applies its requirements to all processing. Phonestar is seeking certification under the EU-U.S. Data Privacy Framework; once certified, Phonestar will update this policy accordingly.

For transfers to service providers in the USA: Cloudflare, Stripe, ElevenLabs, OpenAI, Apple and Google are certified under the EU-U.S. Data Privacy Framework; an adequacy decision of the European Commission exists for them (Art. 45 GDPR). With Deepgram we have agreed the European Commission's standard contractual clauses (Art. 46 (2) (c) GDPR). If the payment service provider (section 5.1) is based in the USA, it is certified under the EU-U.S. Data Privacy Framework or the transfer takes place on the basis of the standard contractual clauses. If the app infrastructure provider (section 8.3) transfers data to a third country, this only happens on the basis of an adequacy decision or the standard contractual clauses. You can obtain a copy of the respective safeguards on request to [email protected]; you can view the certifications at www.dataprivacyframework.gov.

We store personal data only as long as necessary for the purposes mentioned or as long as statutory retention obligations exist. At a glance:

• website server logs: only as long as necessary for secure operation and for investigating faults or attacks,
• consultation enquiries: until your request has been dealt with,
• orders without a contract: until they are no longer needed for processing and queries, unless statutory retention obligations stand in the way,
• checkout verification codes: not stored; the counter of failed attempts expires with the code after ten minutes,
• in the browser: country and customer type one year, cart until you order or empty it, referral code until the tab is closed, cookie ps-claim-… during a payment at most 24 hours,
• ID image, selfie and biometric features at the verification service: deleted after the check is completed,
• traffic data for billing: up to six months after the invoice is sent (Section 10 TDDDG),
• texts in the delivery systems: only as long as necessary for delivery and troubleshooting,
• voice agent call reports (transcript, summary, phone numbers): 90 days,
• phone system, users, announcements, call lists, voice agents: after the end of the contract, as soon as no statutory retention periods or telecommunications law information obligations stand in the way,
• result of an identity verification, proofs of location and subscriber data under Section 172 TKG: until the end of the calendar year following the end of the contract,
• invoices and accounting records: generally ten years after the end of the calendar year in which the invoice was issued (commercial and tax law retention obligations).

Backups of our databases are overwritten on a rotating basis; deleted data may remain in them until the next overwrite and is no longer actively processed.

The order details marked as mandatory (in particular name, address, email address, phone number and, for private individuals, date of birth) are required by law or contract for concluding the contract and assigning phone numbers; without them we cannot conclude the contract. If we require an identity verification in an individual case (section 6.1), we cannot activate phone numbers without it.

No decision based solely on automated processing with legal effect within the meaning of Art. 22 GDPR takes place. Our systems restrict services and report anomalies; a human decides on any refusal or blocking.

Under the GDPR you have the right to

• access the data stored about you (Art. 15),
• rectification of incorrect data (Art. 16),
• erasure (Art. 17),
• restriction of processing (Art. 18),
• data portability (Art. 20),
• withdraw consent given, with effect for the future (Art. 7 (3)).

Right to object: Insofar as we process data on the basis of Art. 6 (1) (f) GDPR, you can object to the processing at any time on grounds relating to your particular situation (Art. 21 GDPR).

To exercise your rights, a message to [email protected] or to us (section 1) is sufficient.

Right to lodge a complaint: You have the right to lodge a complaint with a data protection supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement (Art. 77 GDPR). For telecommunications services in Germany, the Federal Commissioner for Data Protection and Freedom of Information is also responsible (Graurheindorfer Straße 153, 53117 Bonn, Germany).