Privacy Policy
The protection of your personal data is important to us. We therefore process your data exclusively on the basis of the statutory provisions (GDPR, TDDDG).
In this privacy policy, we inform you about the most important aspects of data processing in connection with our website and our services.
Last updated: 4 November 2026
1. Controller responsible for data processing
Hofmann & Stein GbR (“Trailer Swarm”)
Kornmarkt 10
65795 Hattersheim am Main, Germany
Email: datenschutz@trailer-swarm.de
Telephone: +49 89 244 182 67
No data protection officer has been appointed, as there is no legal obligation to do so under Art. 37 GDPR. For data protection questions, please use the contact details above.
2. Collection and storage of personal data
2.1 When visiting the website (server logs)
When you access our website, the browser used on your device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file.
The following information is collected without any action on your part:
- IP address of the requesting computer (shortened/anonymised)
- Date and time of access
- Name and URL of the file accessed
- Website from which access is made (referrer URL)
- Browser used and, where applicable, the operating system of your computer
- Name of your access provider
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure, stable provision)
Storage period: 7–30 days (automatic deletion)
Availability queries (demand analysis): If, during the booking process, you check a period for a location and no trailer is available for that period, we store a record without any personal reference for demand analysis and capacity planning: the location concerned, the period requested and the time of the query. We store no IP address, no device identifier and no other information that would allow conclusions to be drawn about you. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in planning our trailer availability according to demand).
2.2 Content delivery network & web application firewall (Cloudflare)
Our website is provided via Cloudflare Pages. Cloudflare acts as a content delivery network (CDN) and web application firewall (WAF) to speed up, secure and ensure the availability of our website.
Provider: Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA
Purpose:
- Fast and secure delivery of the website worldwide
- Protection against DDoS attacks, bot traffic and misuse
- Load balancing and performance optimisation
- Caching of static content
- Error analysis and stability monitoring
Data processed:
- IP address (shortened/anonymised)
- Timestamp of access
- Requested URL and HTTP referrer
- User agent (browser/operating system information)
- Security/firewall events (e.g. blocked attacks)
Legal basis: Art. 6(1)(f) GDPR (legitimate interest)
Storage period: server logs max. 30 days
Transfer to third countries: Data may be processed on edge servers worldwide (including the USA). Cloudflare is certified under the EU-US Data Privacy Framework (DPF) and offers the European Commission’s standard contractual clauses (SCCs). In addition, Cloudflare participates in the EU Code of Conduct.
Privacy: cloudflare.com/privacypolicy
DPA: cloudflare.com/cloudflare-customer-dpa
2.3 Backend infrastructure & database (Supabase)
For booking management, user data and all database operations, we use Supabase as a backend-as-a-service in the EU region.
Provider: Supabase, Inc., USA (operated in the EU region Frankfurt)
Purpose:
- Storage of booking and customer data
- Authentication and user management
- Database operations and API access
- Encrypted backups
Data processed:
- Master data (name, email, telephone)
- Booking information (rental period, location, trailer type)
- Payment references (no card data)
- Communication history
Legal basis: Art. 6(1)(b) GDPR (performance of a contract)
EU region: All data are stored exclusively in the EU region (eu-central-1, Frankfurt/Germany) and processed there in regular operation. For exceptions (support access from the USA), see the following note.
Note on transfers to third countries: The data are stored in the EU and are not moved to third countries in regular operation. Supabase, Inc. has its registered office in the USA; access from the USA (e.g. in technical support) is possible. As an appropriate safeguard under Art. 46(2)(c) GDPR, the European Commission’s standard contractual clauses (SCCs) (Implementing Decision (EU) 2021/914, Module 2: controller to processor) are in place, supplemented by technical and organisational measures (TOMs) under Art. 32 GDPR.
Data protection measures:
- Row Level Security (RLS): database access is protected at row level
- Encryption: TLS 1.3 in transit, AES-256 at rest
- Access control: role-based access with 2FA
- Backups: encrypted daily backups with 30-day retention
- Monitoring: logging of all admin access
Storage period: see section 7 (retention periods)
Privacy: supabase.com/privacy
DPA: Supabase DPA
2.4 When booking a trailer
When you book a trailer via our website, we collect the following personal data:
- First name and surname
- Full address (street, house number, postcode, town)
- Email address
- Telephone number
- Number of your official identity document (German identity card (Personalausweis), another country’s national identity card, or passport) and the issuing country
- Booking data (rental period, location, trailer type)
- Payment information (see section 2.6)
📋 Identity document details: prevention of misuse and theft
Our trailers are handed over contact-free around the clock — there is no handover in person. The identity document number and issuing country therefore serve the prevention of misuse and theft: they raise the threshold for renting under a false name and can support us in pursuing legal claims in the event of damage or a dispute. We need the issuing country because the number cannot even be checked for plausibility without the issuing state.
What we expressly do not do: We do not check your details against an official database when you book, and we do not carry out an identification in the legal sense. We make no copy, no photo and no scan of your identity document. Only the document number as text and the issuing country are recorded. The number is not used as a search key for the automated retrieval or linking of personal data. No automated biometric processing takes place.
The issuing country refers exclusively to the state that issued the document. We neither collect your nationality nor derive it from this information; it has no influence on your booking.
Legal basis:
- Art. 6(1)(b) GDPR (performance of a contract) — for name, address, contact details, booking and payment data
- Art. 6(1)(f) GDPR (legitimate interest) — for the identity document number and issuing country. Our legitimate interest is the prevention of misuse and theft in the contact-free handover of valuable rental items without personal contact.
Storage period:
- Contract data (incl. address): 10 years after the end of the contract (§ 147 AO, § 257 HGB)
- Identity document number and issuing country: 3 years from the return of the trailer. The period is based on the regular limitation period for contractual and tortious claims (§§ 195, 199 BGB) — for example in the event of non-return, misappropriation or fraud. After expiry, the number and issuing country are deleted; the remaining contract data are stored until the end of the statutory retention period.
2.5 Trailer telemetry and GPS tracking
Our trailers are equipped with GPS tracking devices to enable theft prevention, contract processing and the investigation of damage.
Technology provider: Giesecke & Devrient GmbH (G+D Mobile Security), Germany
Purpose:
- Prevention of theft and misuse
- Contract processing (start/end location, distance travelled)
- Investigation of damage in the event of accidents or violations
- Technical error analysis and maintenance
- Safety alert where the maximum permissible speed is considerably exceeded (see below)
Data recorded:
- GPS position data (longitude/latitude)
- Timestamps of the positions
- Speed of movement
- Trailer ID and booking assignment
Recording interval: At most once per minute while driving. When stationary, there is no continuous recording of the position (only when movement is detected or on request).
Legal basis:
- Art. 6(1)(b) GDPR (performance of a contract)
- Art. 6(1)(f) GDPR (legitimate interest in theft prevention and the investigation of damage)
Storage period:
- Regular journey data: 30 days after the end of the rental (under GTC § 17)
- Event-related data: until damage cases/disputes have been resolved (max. 3 years)
- Suspected theft: until clarified by the police
Access: only authorised staff where there is a legitimate reason (customer request, suspicion, damage case). Access is logged.
Customer rights: GPS data can be inspected on request (right of access, Art. 15 GDPR)
Automatic safety alert for excessive speed
The telematics system automatically reports if a trailer is moved at more than 120 km/h during an ongoing rental. This threshold is well above the maximum speed permitted for vehicle-and-trailer combinations (usually 80 km/h; 100 km/h on motorways if the combination has a German “Tempo 100” approval). Below this threshold, speed is not evaluated.
Processing: An alert is assigned to the ongoing booking. We store the time of the alert, the number of alerts and – where transmitted by the telematics system – the speed measured. With the first alert of a rental, you receive a one-off notification email; further alerts during the same rental do not trigger any further email.
Alert log: Each alert received is also recorded in a technical log (the telematics provider’s alert ID, the trailer’s registration number, timestamp, raw text of the report). It prevents the same alert from being processed twice and ensures traceability. When the associated booking is deleted, the reference to the booking is removed there; the remaining entry can then no longer be attributed to any person.
Purpose: road safety, protection of the rented trailer against damage and informing you that the contractual limitation of liability (damage protection) does not apply if the maximum permissible speed is exceeded (GTC § 13).
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in road safety, in the protection of the rental item and in the avoidance of damage). A documented balancing of interests is in place.
No legal consequence: The notification is purely informative. It does not in itself trigger any fee, contractual penalty or report to authorities or third parties (see also section 10).
Storage period: The alert metadata are stored with the associated booking data and deleted at the latest together with them. For the underlying position data, the period of 30 days after the end of the rental stated above applies.
Right to object: You may object to this processing under Art. 21 GDPR. We will then examine whether our legitimate grounds override your interests.
ℹ️ Transparency & data protection:
The GPS data serve exclusively the purposes stated above. We create no movement profiles, evaluate no driving behaviour and carry out no ongoing live tracking. Position data are only accessed by our staff where there is a specific reason; every access is logged. The only ongoing automatic evaluation is the safety alert from 120 km/h described above — it evaluates neither route nor location nor a driving profile, but exclusively whether this one threshold is exceeded.
2.6 Payment processing (Stripe)
We use the payment service provider Stripe for the secure processing of online payments.
Provider: Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland
Data processed:
- Credit card data (stored only by Stripe, not by us)
- PayPal data (if selected; PayPal is integrated via Stripe)
- Billing address
- Transaction ID and payment status
Note on PayPal: PayPal payments are processed via the Stripe platform. Stripe acts as a technical intermediary; the payment data are forwarded to PayPal (PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg).
Purpose: secure payment processing, fraud prevention
Legal basis: Art. 6(1)(b) GDPR (performance of a contract)
Role: Stripe processes payment data on its own responsibility as an independent controller (not as a processor)
Merchant-initiated transactions (MIT): By booking, you agree that additional costs (e.g. damages, late return, cleaning) may be collected after the end of the rental via the stored payment method. The authorisation ends 90 days after the end of the rental (under GTC § 6 paras. 2–3).
Transfer to third countries: Data may be transferred to the USA. Stripe is certified under the EU-US Data Privacy Framework and uses standard contractual clauses (SCCs).
Privacy: stripe.com/de/privacy
Cancellation of the PayPal billing agreement: If you cancel the PayPal billing agreement given when booking, our payment service provider Stripe informs us. Our backend server (see sections 2.12 and 4.1) assigns this notice to your booking via the payment method stored with your booking. The notice also contains the IP address and browser identifier that Stripe recorded when you gave your consent during payment; we neither evaluate nor store this information. Depending on the case, we send you an email (sent via Postmark) with a link to Stripe, through which you can store PayPal as a payment method again, or a member of staff reviews the case. The notification that PayPal also sends us by email is not evaluated automatically.
Purpose: assigning the cancellation to your booking and storing a payment method again so that any additional costs under GTC § 6 can continue to be settled.
Legal basis:
- Art. 6(1)(b) GDPR (performance of a contract) — processing of the rental agreement including the payment authorisation for additional costs
- Art. 6(1)(f) GDPR (legitimate interest) — securing possible claims under the rental agreement
2.6a Reminder of uncompleted booking processes
If you start a booking process (selection of trailer, period and location) and are forwarded to payment, we reserve the trailer for you for 30 minutes. If you do not complete the payment within this period, we send you a one-off reminder email shortly before the reservation expires to the address given in the booking process, so that you can continue the booking you started.
Data processed:
- Email address
- First name
- Key booking details (location, period, price)
- Reservation number
Purpose: completion of the booking process initiated by you
Legal basis: Art. 6(1)(b) GDPR (taking steps prior to entering into a contract at your request); alternatively Art. 6(1)(f) GDPR (legitimate interest in the resumption of processes started by you)
Sending: The email is sent via our processor Postmark (see section 5). The time of sending is stored with the booking to avoid multiple sending.
Objection: You may object to this processing at any time using the contact details given above.
2.7 When using the contact form / email communication
For questions of any kind, we offer you the opportunity to contact us via a form provided on the website or directly by email.
Required information:
- Name
- Email address
- Message text
Email provider: Strato AG, Germany (Strato Webmail)
Legal basis: Art. 6(1)(a) GDPR (consent) or Art. 6(1)(f) GDPR (legitimate interest)
Storage period: 24 months after the communication has been completed (support purposes)
Encryption: TLS-encrypted email transport
2.8 Newsletter
On our website, you have the option of subscribing to our newsletter. With the newsletter, we inform you about exclusive offers, tips about motorcycles and news about our services.
Data processed:
- Email address
- IP address and user agent (for the audit trail)
- Time and version of the consent
- Source of the sign-up (footer, exit modal, etc.)
Voluntary nature: Providing your email address is voluntary; without it, we cannot send you the newsletter.
Recipients & places of processing: Supabase (storage in the EU region Frankfurt) and Postmark (email sending, USA – see section 5: transfer to third countries).
Sign-up procedure: Double opt-in – after entering your email address, you receive a confirmation email. Your subscription only becomes active after you click the confirmation link. This link is valid for 24 hours.
Email sending: Postmark (processor under Art. 28 GDPR, USA) – for sending confirmation and newsletter emails. EU standard contractual clauses (SCCs) and a data processing agreement (DPA) apply. Postmark EU privacy
No tracking: We do not use open or click tracking in our newsletter emails.
Legal basis: Art. 6(1)(a) GDPR (consent)
Withdrawal: You can withdraw your consent at any time by clicking the unsubscribe link in any newsletter email or by contacting us directly. The withdrawal takes effect for the future; the lawfulness of the processing carried out until the withdrawal remains unaffected.
Storage period: Your data are stored for as long as you are subscribed to the newsletter. After you unsubscribe, your data are anonymised after 6 months (email address replaced by a placeholder, IP and user agent deleted).
Consent log: To fulfil our accountability obligations under Art. 7(1) GDPR, we keep a log of your consent (time, version, action). IP address and user agent are removed from the log no later than 6 months after you unsubscribe; a log limited to what is strictly necessary (without IP/user agent) is kept for up to 3 years to fulfil statutory accountability obligations.
Promotional emails in connection with a booking
You may optionally consent to being informed by us by email about offers and news relating to motorcycle trailers – either in the booking process, on the confirmation page after completing a booking or in the customer portal. This consent is independent of the booking – booking is also possible without it; the corresponding box or switch is not preselected or not activated by default at any of these places.
Data processed:
- Email address (already collected in connection with the booking)
- Time and version of the consent
- for consent given on the confirmation page: the internal identifier of the booking through which you gave the consent (for evidence purposes only)
- in the event of a withdrawal: its time
Voluntary nature: Consent is voluntary and has no effect on the conclusion or the terms of your booking.
Sign-up procedure: Simple consent with logging. As consent is given in connection with a verified, paid booking with a confirmed email address, we do not use an additional double opt-in procedure here – unlike for the newsletter alone.
Recipients & places of processing: Supabase (storage in the EU region Frankfurt) and Postmark (processor under Art. 28 GDPR, email sending, USA). For the transfer to the USA, a data processing agreement and EU standard contractual clauses (SCCs) or – where applicable – the EU-US Data Privacy Framework are in place; details in section 5 (transfer to third countries).
Legal basis: Art. 6(1)(a) GDPR (consent). Under unfair competition law, emails are sent exclusively on the basis of your express consent (§ 7 para. 2 no. 2 UWG).
Withdrawal: You can withdraw your consent at any time with effect for the future by clicking the unsubscribe link in any promotional email, deactivating the switch in the customer portal or contacting us directly. After a withdrawal, we stop sending promotional emails. We record the withdrawal with its time so that you are not contacted again afterwards without a new consent given by you yourself. The lawfulness of the processing carried out until the withdrawal remains unaffected.
Storage period: We store your marketing consent (opt-in status, time and version) for as long as it exists. After a withdrawal, we deactivate the marketing flag. If both your consent and your last booking with us are more than 36 months in the past, we no longer send you advertising unless you book with us again. We keep a log limited to the information stated above (time, version, where applicable booking identifier and time of withdrawal) for up to 3 years after the end of the consent (withdrawal or expiry of the 36 months) to fulfil statutory accountability obligations, and delete it automatically afterwards. After this deletion, consent that has ended in this way does not revive through a new booking either, but requires new consent.
Consent log: To fulfil our accountability obligations under Art. 7(1) GDPR, we store the time and version of the consent together with your customer record; the stored version also identifies at which of the places mentioned above the consent was given. For consent given on the confirmation page, we additionally store the internal identifier of the booking through which you gave the consent. Name, IP address or device data are not stored for this purpose.
2.9 Feedback surveys to optimise our service
+Optional micro-surveys to improve our booking processes
2.10 WhatsApp customer communication (chatbot “Sam”)
We offer an automated customer service via WhatsApp. Incoming messages are processed and answered by an AI-supported chatbot (“Sam”). The chatbot can retrieve booking information and answer frequently asked questions.
Data processed:
- Telephone number (stored as a SHA-256 hash with a secret server-side salt — never in plain text on the server; it cannot be traced back to the original number with reasonable effort)
- Chat messages (text of the conversation)
- Media you send us (photos, videos, voice messages) — see the following paragraph “Media”
- Booking data (name, period — looked up by telephone number, not stored permanently in the chatbot system)
Media (photos, videos, voice messages): Media are not persisted on our server. Photos are transmitted to Anthropic so that the chatbot can understand the request. Voice messages are transmitted to ElevenLabs for automatic transcription; the transcript is deleted from the service provider immediately after retrieval, after which only the transcription text is processed further. All media are additionally forwarded to a Slack channel for internal quality assurance (see section 4.1, Slack).
Photos for pick-up or return: By way of derogation, we store photos and videos that you send us after our automatic request for photos of the pick-up or return (see section 2.15) as handover documentation for your booking: they are filed in the booking folder in Google Drive, together with the photos from the pick-up or return form (Google Workspace, see sections 4.1 and 5). This applies to photos and videos that arrive up to 24 hours after the form has been submitted; we do not file voice messages there. The legal basis is Art. 6(1)(b) GDPR (performance of the rental agreement) and Art. 6(1)(f) GDPR (legitimate interest in evidencing the condition of the trailer at handover and in asserting or defending claims). We store them for 3 years from the return of the trailer (see section 2.15).
AI processing: Your messages and photos are transmitted to Anthropic (Claude API) in order to generate automated replies. Anthropic processes the data as a processor; use of the data for model training purposes is contractually excluded.
Internal mirroring: Messages are mirrored in an internal Slack channel to ensure service quality and to allow a human to take over where necessary. Access is restricted to authorised staff.
Legal basis:
- Art. 6(1)(b) GDPR (performance of a contract) — for booking-related enquiries
- Art. 6(1)(f) GDPR (legitimate interest) — for general enquiries without reference to a contract (e.g. pre-sales questions)
Storage period: Chat histories are deleted automatically 72 hours after the last message. If there is a booking relating to the enquiry, storage is extended until 7 days after the end of the rental so that queries about the rental can be answered. Telephone number hashes are deleted together with the chat session.
Transfer to third countries: Meta WhatsApp Cloud API (USA/EU), Anthropic Claude API (USA), ElevenLabs (USA), Slack (Salesforce) (USA), Google Workspace (EU/USA, only for photos and videos of the pick-up or return) — see section 5.
Alternative ways of contacting us: You can also contact us at any time by email or telephone if you do not wish to use the WhatsApp channel (see contact details in section 1).
ℹ️ Transparency on AI processing:
The chatbot “Sam” uses an AI language model (Anthropic Claude) to answer your enquiries. There is no automated decision-making with legal effect (Art. 22 GDPR) and no profiling within the meaning of Art. 4(4) GDPR — the chatbot answers questions and passes on information. Booking changes or cancellations require manual confirmation by our staff.
2.11 Google Ads offline conversion upload
To measure the effectiveness of our Google Ads campaigns, we transmit conversion data to Google Ads server-side. The transmission depends on the user’s consent status (Consent Mode v2).
Data transmitted:
- Google Click ID (gclid) — a pseudonymous click identifier from the Google ad
- Booking value and timestamp
- Consent status (ad_user_data, ad_personalization)
Not transmitted: Names, email addresses, telephone numbers or other directly personal customer data are not transmitted to Google.
Consent check: Conversion data that can be related to a person are uploaded only if the customer gave consent to advertising tracking when visiting the website (Consent Mode v2: ad_user_data: granted).
Frequency: regularly and automatically via our backend server.
Legal basis: Art. 6(1)(a) GDPR (consent via the cookie banner, “Marketing” category)
Storage period: The storage period of the transmitted data at Google is Google’s responsibility (see Google privacy policy).
Transfer to third countries: Google Ads API (USA) — Google is certified under the EU-US Data Privacy Framework. See section 5.
2.12 Automated operational monitoring (backend server)
For the automated monitoring of our trailer fleet and operational control, we operate a dedicated server at Hetzner Online GmbH in Germany. We use technical and organisational measures (TLS encryption, role-based access controls, automatic redaction of sensitive data in logs) to ensure the security of processing in accordance with Art. 32 GDPR.
For resilience, we additionally operate an identical failover standby server at netcup GmbH (server location Vienna, Austria – EU/EEA). Customer and booking data are actively processed on this standby server only if the primary server fails. There is no transfer to third countries (processing within the EU/EEA). A data processing agreement under Art. 28 GDPR is in place with netcup (see section 4.1).
GPS location monitoring (theft protection)
It is checked automatically at regular intervals whether our trailers are at their assigned home location. This check concerns exclusively vehicle telemetry (GPS coordinates of the trailers) — a link to booking or customer data is not technically implemented. GPS data are only processed in memory and are not persisted on the server.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest: theft prevention)
Parking duration monitoring (legal obligation)
It is checked daily whether trailers exceed the statutory 14-day parking limit for vehicles without a towing vehicle. This processing concerns only vehicle data (registration number, location, parking duration).
Legal basis: Art. 6(1)(f) GDPR (legitimate interest: avoidance of regulatory offences)
Server logs (nginx)
The backend server logs incoming requests in nginx access logs. Personal data (IP addresses), URLs accessed, timestamps and user agents are recorded.
Storage period: 90 days (automatic deletion via logrotate). The storage period of 90 days is necessary in order to be able to analyse security incidents and attempted attacks afterwards (incident response).
Legal basis: Art. 6(1)(f) GDPR (legitimate interest: IT security, detection and defence against attacks)
Application logs
The application software on the server creates log files for error analysis and operational monitoring. Sensitive data (passwords, API keys, tokens) are redacted automatically. Telephone numbers are only logged as a shortened hash that cannot be traced back without disproportionate effort.
Storage period: max. 30 days or until automatically overwritten by rotating log files. Operational reports are deleted automatically after 30 days.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest: technical error analysis)
Error and crash monitoring of the backend server (Sentry)
For operational security and stability, our backend server (Hetzner, Germany) monitors software errors and crashes that occur using the Sentry service (Functional Software, Inc. d/b/a Sentry). The processing serves exclusively to detect, diagnose and fix technical errors. This is purely server-side monitoring — there is no user-related tracking and no cookie is set.
Data transmitted (with active data minimisation): exclusively technical error data — stack traces, error messages and timestamps, runtime and environment metadata (e.g. Node version, operating system, environment/server identifier) and the HTTP method and path of a failed request.
Not transmitted, or removed server-side before the data reach Sentry: request bodies, HTTP headers and cookies, query strings (which may contain access tokens or magic links), user IP addresses and user identifiers. Email addresses and telephone numbers are automatically redacted from any free-text error content. We therefore deliberately transmit no personal data; should personal data nevertheless appear incidentally in an error message, the above redaction and the principle of data minimisation (Art. 5(1)(c) GDPR) apply.
Storage period: approx. 90 days (Sentry’s standard retention for error events), followed by automatic deletion.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure, trouble-free operation).
Data location: Sentry EU data region (storage in the EU). Any access from the USA (the provider’s registered office) is covered by the data processing agreement concluded (Art. 28 GDPR) including EU standard contractual clauses (SCCs).
Recipients and transfers outside the EU/EEA: Functional Software, Inc. d/b/a Sentry — see section 4.1 (processors) and section 5 (transfers to third countries).
Encrypted off-site backup
For resilience and protection against data loss, our backend server (Hetzner, Germany) creates a daily backup of the database and the server configuration and additionally uploads it to a physically separate storage location (off-site backup) at the provider Backblaze, Inc. (Backblaze B2 Cloud Storage). The data are held in a data centre in the EU (Amsterdam, Netherlands).
Encryption (decisive): The backup is encrypted client-side on our own server before transmission (gpg, AES-256). Backblaze receives and stores only this encrypted data set (ciphertext) and is technically unable to view the contents. The key required for decryption never leaves our server.
Categories of data concerned: all booking and customer data stored in the database (e.g. name, contact details, booking data) — but without exception in client-side encrypted form.
Storage period: 30 days on a rolling basis; older backups are deleted automatically.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest: resilience and data security) in conjunction with Art. 32 GDPR (data security through backups).
Recipients and transfers outside the EU/EEA: Backblaze, Inc. (see section 4.1 – processors, and section 5 – transfers to third countries).
Central aggregation of server logs (Axiom)
For operational security, error diagnosis and forensics, our backend server (Hetzner, Germany) consolidates the technical server logs centrally at the Axiom service (Axiom, Inc.). The processing serves exclusively to detect, diagnose and trace technical operations and errors. This is purely server-side log management — there is no user-related tracking and no cookie is set.
Data transmitted (with active data minimisation): exclusively technical server logs — timestamps, log level, service and cron names and operational messages. In addition, pseudonymous identifiers, namely internal booking IDs/UUIDs and registration numbers of our own trailer fleet. The pseudonymous booking ID can only be attributed to a person internally via our database.
Not transmitted, or removed server-side before the data reach Axiom: Email addresses and telephone numbers are automatically redacted from all log content before the logs leave our server; secrets and tokens are removed even before that. We therefore deliberately transmit no directly identifying customer data; should personal data nevertheless appear incidentally in an operational message, the above redaction and the principle of data minimisation (Art. 5(1)(c) GDPR) apply.
Storage period: approx. 30 days (Axiom’s standard retention), followed by automatic deletion.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure, traceable operation).
Data location: Axiom EU region (storage in the EU). Any access from the USA (the provider’s registered office) is covered by the data processing agreement concluded (Art. 28 GDPR) including EU standard contractual clauses (SCCs).
Recipients and transfers outside the EU/EEA: Axiom, Inc. — see section 4.1 (processors) and section 5 (transfers to third countries).
2.13 Incoming enquiries via eBay Kleinanzeigen (auto-reply)
We receive rental enquiries from prospective customers via the eBay Kleinanzeigen platform. These enquiries are processed on our backend server at Hetzner in Germany for the purpose of initiating a contract (answering the enquiry). Draft replies are prepared by an AI language model, manually approved by our team in Slack and then sent back to the prospective customer via the Kleinanzeigen platform.
Data flow:
- The prospective customer writes to us via the Kleinanzeigen platform. eBay Kleinanzeigen sends a notification email to our address hello@trailer-swarm.de.
- Our email provider Strato forwards this notification email via filtered forwarding to an inbound webhook of Postmark.
- Our backend server (Hetzner, Germany) processes the message, stores it in the database (Supabase, EU region Frankfurt) and mirrors it into a private internal Slack channel for team approval.
- An AI language model (Anthropic Claude, USA) creates a draft reply.
- An authorised team member approves the draft in Slack by reaction.
- The approved reply is sent via Postmark (USA) to the Kleinanzeigen forwarding address; eBay Kleinanzeigen forwards the reply to the prospective customer.
Data processed:
- Email address: exclusively the anonymised forwarding address assigned by eBay Kleinanzeigen (e.g.
abc123-…-ek-ek@mail.kleinanzeigen.de). We do not know the prospective customer’s actual email address. - Name: if supplied by Kleinanzeigen in the email header or message text (best-effort extraction, usually first name only). The platform only transmits what the prospective customer has stored in their Kleinanzeigen profile.
- Content of the message: plain text of the prospective customer’s enquiry and our reply.
- Context information: ad ID and ad title of the Kleinanzeigen listing concerned.
- Timestamps.
Not collected: In this processing operation we collect no real-name email address and no telephone number. The Kleinanzeigen terms of use prohibit off-platform contact before a contract is concluded; communication therefore remains in the email conversation brokered by Kleinanzeigen.
Purpose:
- Answering rental enquiries (pre-contractual measure at the prospective customer’s request)
- Internal team approval and quality assurance of the reply (private Slack channel with a restricted group of people)
Legal basis: Art. 6(1)(b) GDPR (taking steps prior to entering into a contract at the request of the data subject)
Storage location: backend server at Hetzner Online GmbH (Germany) and Supabase database in the EU region Frankfurt (eu-central-1). The conversation is stored in separate tables, kept apart from the booking database (Row Level Security, service-role access only).
Pseudonymised lookup: In addition to the forwarding address, we store a SHA-256 hash with a secret server-side salt as a secondary search index so that the forwarding address does not appear in plain text in search or error logs. The plain text of the forwarding address must remain in the table because we have to send the reply to this address.
Recipients:
- Postmark (Wildbit LLC / ActiveCampaign, USA) – inbound and outbound email processing (see sections 4.1 and 5)
- Supabase (EU region Frankfurt) – storage of the conversation (see section 2.3)
- Hetzner Online GmbH (Germany) – server hosting (see section 2.12)
- Anthropic PBC (USA) – AI language model Claude for creating the draft reply (see sections 4.1 and 5; no use of the data for AI training)
- Slack (Salesforce) (USA) – internal mirroring for team approval (see sections 4.1 and 5)
Storage period: The entire conversation (thread and all associated messages) is stored for 90 days after the last activity (“sliding window” on last_activity_at). A nightly clean-up job deletes expired conversations completely (cascade delete). If a booking results, the necessary customer data are transferred to the regular booking flow; from that point the applicable storage period from section 7 applies to the booking data.
ℹ️ Transparency on AI-supported drafting of replies:
The draft reply is generated by an AI language model (Anthropic Claude, USA). There is no automated decision-making with legal effect (Art. 22 GDPR) and no profiling within the meaning of Art. 4(4) GDPR. Every reply is checked and expressly approved by a human team member before it is sent.
2.14 Technical performance measurement and error recording in the browser
When you access our pages, your browser measures how quickly the page is displayed and reports these measurements to our own server. We use them exclusively to monitor loading times and to detect technical errors. The data are stored in our own database at Supabase in the EU region (see section 2.3) and are not passed on to any third party.
Legal basis: We need this measurement for the secure and error-free operation of the website and the booking (§ 25 para. 2 no. 2 TDDDG, Art. 6(1)(f) GDPR). We do not use cookies or other entries in your browser’s storage for this.
Loading time measurements
The following are recorded: the page path accessed (without parameters), measurements of display speed, the type of page view, a rough classification of connection quality and the graded window size and screen resolution of your device.
Without an identifier: These records contain neither an IP address nor a session or user identifier; the information is graded (four connection classes, four window sizes).
Storage period: unlimited, in order to detect long-term deterioration in loading times.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest: technical monitoring of page performance)
Technical operating and error events
If a technical error occurs in the browser, we transmit the error message to our server for evaluation. In addition, a measurement script transmits a sample of roughly every tenth loading time measurement and error. The following are recorded: error message and technical context, the page path accessed (without parameters, and in the customer portal without the booking number), browser family with major version and operating system (not the full browser identifier) and, for the sample, a random session identifier that exists only in memory for the duration of the page visit and is not stored on your device.
Error and operating events also carry the random session identifier of the page visit, the same one as for the process events in the booking form, which exists only in memory for the duration of the page visit and is not stored on your device, and an indication of whether the request comes from an automated browser.
Not recorded: your IP address. It is neither stored nor kept in converted form. Personal information in error texts (email addresses, telephone numbers, payment data, access keys, IP addresses) is automatically redacted before storage.
Storage period: 30 days. Older entries are deleted automatically every day. From the loading time measurements in the sample, we form hourly values per page path, without a session identifier and without browser information; we keep these indefinitely.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest: detection and remedying of technical faults)
Process events in the booking form
In the booking form, we report process events to our own server in order to identify the points at which a booking fails or is abandoned and to improve the form. The following are recorded: which step of the form was reached or completed (with location, rental duration and number of extras selected), the technical result when the payment is started (success or error, status code, duration, location), whether a payment already started was resumed and via which notice, for which input field which kind of error occurred (for example “email address invalid” or “required field missing”), whether a notice about a possible typo in the domain of the email address was shown or accepted, how many attempts to leave the step were rejected because of incorrect information and how many fields were flagged in the process, whether the error occurred when leaving the field, when clicking “next”, during a paste or drag attempt or when clicking the suggestion, the page path accessed, the time, a rough device class (smartphone, tablet or computer, derived from the window width), whether the request comes from an automated browser, and the random session identifier that exists only in memory for the duration of the page visit.
Not recorded: your entries. Neither email address nor name, telephone number, address or ID number, nor the domain of your email address or any part of it are transmitted; only the name of the field and the type of error are reported. Your IP address is not recorded either.
Automated requests: We recognise whether a request comes from an automated browser, such as a test tool, a search engine, a link preview or an availability checker, from a feature that automatically controlled browsers set themselves and from your browser identifier. For this purpose, the browser identifier is compared with a list of such programs in the browser and on arrival at our server. Only the result and whether it was established in the browser or on the server are stored, not the browser identifier itself. Internal test requests by our team are also marked as automated requests. This is done with an addition at the end of the page address that only our team uses; nothing is stored on your device for this.
We do not use cookies or other entries in your browser’s storage for these process events.
Storage period: 30 days. Older entries are deleted automatically every day.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest: detection of obstacles and faults in the booking process and improvement of the form)
2.15 Pick-up and return form (handover documentation)
Our trailers are handed over contact-free. At pick-up and at return, you therefore fill in a form each time, the link to which we send you. We use it to document the condition of the trailer at handover.
Data processed:
- Your information on the condition of the trailer (including cleanliness, lighting, tyres, jockey wheel, coupling lock, plug, wheel chocks), reported damage and your comments
- Photos of the trailer that you take in the form with your device’s camera
- Time of pick-up or return and the location and odometer reading of the trailer at that time (from the telematics, see section 2.5)
- Photos and videos that you send afterwards via WhatsApp at our request (see below)
Handover report: From your information, we create a handover report as a PDF with name, address, booking number, rental period, registration number, condition and location of the trailer and your comments. You receive the report by email, where applicable together with the photos (sent via Postmark, see section 4.1); a copy goes to our booking mailbox.
Access code by SMS: After the pick-up form has been submitted, we additionally send you the code for the lock by SMS to the telephone number given when booking. The SMS is sent via Twilio (see sections 4.1 and 5); your telephone number and the text of the SMS with the access code are transmitted. We delete the log of the SMS at Twilio after 30 days (see section 2.16).
Storage location: We file photos, videos and handover reports in your booking’s folder in Google Drive (Google Workspace, see sections 4.1 and 5). Until they are processed, the form photos are briefly held in non-public storage at our database provider (Supabase) and are deleted there afterwards. We store your condition information with your booking; our team additionally receives your comments in an internal Slack channel (see section 4.1).
Sending photos later via WhatsApp: If you submit the form without all the photos or report damage in it, we automatically ask you for photos via WhatsApp. We also file in the booking folder photos and videos that you send to our WhatsApp service number up to 24 hours after submitting the form (see also section 2.10).
Purpose: evidence of the condition of the trailer at pick-up and return (e.g. in the event of damage, missing accessories or soiling) and the cleanliness check (see section 10).
Legal basis:
- Art. 6(1)(b) GDPR (performance of a contract) — performance of the rental agreement including the contact-free handover
- Art. 6(1)(f) GDPR (legitimate interest) — evidence of the condition of the trailer at handover and the assertion or defence of claims
Storage period: 3 years from the return of the trailer. The period is based on the regular limitation period (§§ 195, 199 BGB), for example in the event of a dispute about damage or subsequent charges. After that, the photos, videos and handover reports in the booking folder are deleted; your contract data remain stored until the end of the statutory retention period (see section 7).
2.16 Telephone customer service
Our telephone provider forwards calls to our service number to a number at Twilio. There a voice menu answers the call and connects you to our team. If you do not reach anyone, you can leave a message on our voicemail.
Data processed:
- Your telephone number (if transmitted), time and duration of the call and the path through the voice menu
- Your voice message, if you leave a voicemail message
Notification to our team: Our team receives information about the call, including your telephone number, in an internal Slack channel. If your telephone number belongs to a booking, we add first name, booking number, status, rental period, location and registration number to the notification. If you leave a voicemail message, the recording is also transferred there as an audio file so that we can call you back. The transfer runs via our backend server (see section 2.12).
WhatsApp after the call: If you request a WhatsApp message in the voice menu by pressing a key, we send it to the number from which you called, for example with the link to online booking. Without this request, we do not send any WhatsApp message. It is sent by our backend server via the WhatsApp Business API; if you reply to the message, section 2.10 applies.
Damage report by SMS: If you select the damage option in the voice menu, we send you a link by SMS (via Twilio) through which you can send us photos via WhatsApp.
Purpose: handling your request and calling you back.
Legal basis:
- Art. 6(1)(b) GDPR (performance of a contract or pre-contractual measures) — for enquiries about a booking or a planned rental and for the WhatsApp message you requested
- Art. 6(1)(f) GDPR (legitimate interest) — efficient handling of telephone enquiries, including those without reference to a contract
Storage period: We delete voicemail recordings at Twilio as soon as they have been transferred to our team. At Twilio, we delete call and SMS logs, and recordings whose transfer fails, 30 days after creation. Twilio itself removes deleted message texts from its backups within up to 30 days and keeps information on deleted recordings (without audio) for a further 40 days. Twilio no longer provides logs from the period up to September 2025 via its interface; we are clarifying their deletion with Twilio. Call information and recordings in Slack are deleted automatically after 90 days.
Transfer to third countries: Twilio (EU/USA), Slack (Salesforce) (USA), Meta WhatsApp Cloud API (USA/EU) — see section 5.
4. Disclosure of data to third parties & recipients
We only pass on your personal data to third parties if one of the following applies:
- you have given your express consent to this under Art. 6(1) sentence 1(a) GDPR;
- the disclosure is necessary under Art. 6(1) sentence 1(f) GDPR for the establishment, exercise or defence of legal claims;
- there is a legal obligation for the disclosure under Art. 6(1) sentence 1(c) GDPR; or
- this is legally permissible and necessary under Art. 6(1) sentence 1(b) GDPR for the performance of contractual relationships with you.
4.1 Processors (Art. 28 GDPR)
We work with the following processors. Data processing agreements (DPAs) are in place with all service providers:
Cloudflare (CDN/WAF/hosting)
Provider: Cloudflare, Inc., USA
Purpose: website provision, security, performance
DPA: in place under Art. 28 GDPR
Region: worldwide (edge servers), including the USA
Supabase (database & backend)
Provider: Supabase Inc., USA
Purpose: storage of booking data, user management
DPA: in place under Art. 28 GDPR
Region: EU (Frankfurt, eu-central-1); support access from the USA only in exceptional cases (see section 5)
Google Workspace (Google Drive)
Provider: Google Cloud EMEA Limited, Velasco, Clanwilliam Place, Dublin 2, Ireland
Purpose: filing of the handover documentation in the booking folder (photos and videos from the pick-up and return form or sent afterwards via WhatsApp, handover reports as PDF, see section 2.15); retrieval of the loading area photo for the cleanliness check (see section 10)
DPA: Cloud Data Processing Addendum under Art. 28 GDPR
Region: EU/USA (processing also by Google LLC, USA, see section 5)
Giesecke & Devrient (GPS telemetry)
Provider: Giesecke & Devrient GmbH, Germany
Purpose: GPS tracking of the trailers
DPA: in place under Art. 28 GDPR
Region: Germany/EU
Strato AG (email)
Provider: Strato AG, Germany
Purpose: email hosting and sending
DPA: in place under Art. 28 GDPR
Region: Germany
Postmark (transactional emails & inbound)
Provider: Wildbit LLC (ActiveCampaign), USA
Purpose: sending of booking confirmations, handover reports (see section 2.15), double opt-in and newsletter emails (without open/click tracking), emails for storing PayPal again (see section 2.6) and receipt of rental enquiries via eBay Kleinanzeigen (see section 2.13) via inbound webhook
DPA: Postmark standard DPA (postmarkapp.com/dpa); safeguards: SCCs (Module 2, controller to processor)
Region: USA
Hetzner Online GmbH (backend server)
Provider: Hetzner Online GmbH, Germany
Purpose: backend server for automated operational monitoring, WhatsApp chatbot, conversion upload, processes in telephone customer service (see section 2.16) and assignment of cancelled PayPal billing agreements (see section 2.6)
DPA: in place under Art. 28 GDPR
Region: Germany (Nuremberg)
netcup GmbH (backend server, failover standby)
Provider: netcup GmbH, Daimlerstraße 25, 76185 Karlsruhe, Germany
Purpose: server hosting as failover standby for the backend server (resilience). Processes customer/booking data only if the primary server fails (see section 2.12)
DPA: in place under Art. 28 GDPR (concluded on 8 July 2026)
Region: Vienna, Austria (EU/EEA)
Anthropic PBC (AI language model)
Provider: Anthropic PBC, USA
Purpose: AI language model (Claude) for automated WhatsApp customer communication and for the automated preliminary assessment of the loading area photo from the pick-up form (cleanliness check, see section 10)
DPA: data processing agreement; standard contractual clauses (SCCs)
Region: USA
Eleven Labs Inc. (“ElevenLabs”) — voice transcription
Provider: Eleven Labs Inc., 169 Madison Ave #2484, New York, NY 10016, USA
Purpose: automatic transcription of voice messages from customer service
DPA: data processing agreement that automatically forms part of the terms of use. The transfer is based primarily on certification under the EU-US Data Privacy Framework (expressly named in the DPA, § 11.1(i)); in addition, the European Commission’s standard contractual clauses (SCCs) form part of the DPA (§ 11).
Special feature: use of the data for the provider’s own purposes — including model training — is contractually excluded (instruction clause § 3.1, purpose limitation § 12.1.1). The transcript is deleted immediately after retrieval.
Note: the US company is the contracting party for customers from the EEA too; there is no EU subsidiary. For the standard contractual clauses, Clause 17 Option 1 has been agreed; Irish law applies (DPA § 11.2).
Region: USA
Meta Platforms (WhatsApp Business API)
Provider: Meta Platforms Ireland Limited, Ireland
Purpose: WhatsApp Business API for customer communication
DPA: Meta Business Tools Terms; EU-US Data Privacy Framework (DPF); standard contractual clauses (SCCs)
Region: USA/EU
Twilio (SMS and telephony)
Provider: Twilio Ireland Limited, 70 Sir John Rogerson's Quay, Dublin 2, D02 R296, Ireland
Purpose: sending of the access code SMS (see section 2.15) and telephony for our service number with voice menu, voicemail and SMS with a link to the damage report (see section 2.16)
Storage period: call and SMS logs as well as recordings are deleted after 30 days (see section 2.16)
DPA: Twilio Data Protection Addendum under Art. 28 GDPR (part of the contract)
Region: EU/USA (processing also possible by Twilio Inc., USA, see section 5)
Slack (Salesforce) — internal communication
Provider: Salesforce, Inc., USA
Purpose: internal mirroring of customer communication for quality assurance (legitimate interest under Art. 6(1)(f) GDPR), forwarding of your comments from the pick-up and return form to our team (see section 2.15) and notifications of calls and voicemail messages (see section 2.16)
DPA: Salesforce DPA under Art. 28 GDPR; standard contractual clauses (SCCs)
Storage period: messages and files are deleted automatically after 90 days
Region: USA
Make (formerly Integromat), operated by Celonis SE
Provider: Celonis SE, Germany
Purpose: publication of posts in our Google Business Profile. Make does not process any customer data in doing so.
DPA: in place under Art. 28 GDPR
Region: EU
Backblaze (encrypted off-site backup)
Provider: Backblaze, Inc., USA
Purpose: encrypted off-site backup of the database and server configuration. Backblaze receives only data encrypted client-side (gpg, AES-256) (ciphertext) and is technically unable to view the contents (see section 2.12).
DPA: Data Processing Addendum under Art. 28 GDPR (backblaze.com/dpa); safeguards: SCCs (Module 2, controller to processor); list of sub-processors: backblaze.com/subprocessors
Region: data held in the EU (Amsterdam, Netherlands); provider based in the USA
Sentry (backend server error monitoring)
Provider: Functional Software, Inc. d/b/a Sentry, 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA
Purpose: detection, diagnosis and fixing of software errors and crashes of the backend server (operational security, stability). Purely server-side monitoring without user tracking; with active data minimisation, no personal data are transmitted (see section 2.12).
DPA: Data Processing Amendment (DPA, version 5.1.0) under Art. 28 GDPR (concluded on 23 July 2026); safeguards: SCCs (Module 2, controller to processor)
Region: EU data region (storage in the EU); provider based in the USA
Axiom (server log aggregation)
Provider: Axiom, Inc. (Delaware corporation), 1390 Market Street, Suite 200, San Francisco, CA 94102, USA
Purpose: central aggregation of the server logs for error diagnosis, forensics and ensuring secure operation (operational security). Purely server-side log management without user tracking; with active data minimisation, no directly identifying customer data are transmitted (see section 2.12).
DPA: Data Processing Addendum under Art. 28 GDPR (axiom.co/docs/legal/data-processing); safeguards: SCCs (Module 2, controller to processor); list of sub-processors: trust.axiom.co/subprocessors
Region: EU region (storage in the EU); provider based in the USA
4.2 Third parties acting on their own responsibility
The following service providers process data on their own responsibility (not as processors):
Stripe (payment processing)
Provider: Stripe Payments Europe Ltd., Ireland
Purpose: payment processing
Role: independent controller
Privacy: stripe.com/de/privacy
Google Analytics 4 (only with consent)
Provider: Google Ireland Limited, Ireland
Purpose: web analytics
Legal basis: consent (Art. 6(1)(a) GDPR)
4.3 Recipients in specific cases
In certain cases, data may be passed on to the following recipients:
- DEVK insurance: in damage cases, for claims settlement
- Debt collection service providers: in the event of payment default (planned for the future, currently handled internally)
- Authorities/law enforcement: where there is a legal obligation or a suspicion of criminal offences
- Legal advisers: in legal disputes
- Police: in the event of theft or misuse (GPS data)
4.4 Disclosure of data in the event of claims arising from the use of the trailer
Purpose: If enquiries, requests to comment (Anhörung), notices or claims concerning your use of a rented trailer are asserted against us (e.g. fines, tolls, parking or usage fees), we process your data in order to handle these matters and forward them to the competent or claiming body.
Recipients or categories of recipients: authorities, toll operators, parking management companies and creditors and their authorised representatives (in particular lawyers; where engaged in an individual case, also debt collection service providers – cf. section 4.3).
Legal bases: Depending on the occasion, the respective disclosure is based on one or more of the following grounds:
- Art. 6(1)(b) GDPR (performance of the rental agreement and the obligations arising from it) – insofar as the processing serves the performance of your rental relationship, for example the internal attribution of the hirer responsible for the use.
- Art. 6(1)(c) GDPR (compliance with a legal obligation) – insofar as we are legally obliged to provide information, for example, when an authority asks us, as the registered keeper of the trailer, to name the person who was using it in proceedings for an administrative fine or other regulatory offence.
- Art. 6(1)(f) GDPR (protection of legitimate interests) – our legitimate interest lies in handling, forwarding and defending against or reducing such claims and in asserting our own claims (e.g. recourse) against you. The disclosure to private claiming bodies (e.g. toll operators, parking management companies, creditors and debt collection service providers) is based in particular on this ground. You may object to this processing in accordance with Art. 21 GDPR (see section “Your rights”).
Scope (data minimisation): We only pass on the data necessary for handling the respective matter (in particular name, address, rental period, vehicle/trailer concerned), Art. 5(1)(c) GDPR.
Storage period: We store these data for as long as is necessary to handle the matter and to fulfil statutory retention obligations.
This processing specifies § 18 para. 3 of our rental terms (GTC). As a rule, no third country is involved in this context; claiming bodies (e.g. authorities, toll and parking operators, creditors and their authorised representatives) are typically based in the EEA. For Switzerland, there is an adequacy decision of the European Commission; Liechtenstein is part of the EEA. Should a disclosure to a recipient in a country without an adequacy decision become necessary in an individual case (e.g. Andorra, Monaco, San Marino, Vatican City), it will only take place on the basis of appropriate safeguards (Art. 46 GDPR, for example standard contractual clauses) or a derogation under Art. 49 GDPR – in particular Art. 49(1)(e) for the establishment or defence of legal claims.
5. Transfers to third countries
Some of our service providers process data outside the European Economic Area (EEA). We ensure that an adequate level of data protection is guaranteed in this respect. You can request a copy of the appropriate safeguards agreed in each case (e.g. standard contractual clauses) using the contact details given in section 1; confidential business information may be redacted in them.
USA: Cloudflare
Processing of traffic metadata on edge servers (worldwide, including the USA).
Safeguards:
- EU-US Data Privacy Framework (DPF) certification
- Standard contractual clauses (SCCs) of the European Commission
- Participation in the EU Code of Conduct
- Technical/organisational measures (TOMs)
USA: Stripe
Payment data may be transferred to the USA.
Safeguards:
- EU-US Data Privacy Framework (DPF) certification
- Standard contractual clauses (SCCs)
- PCI DSS Level 1 certification (highest security standard)
USA: Google Analytics / GTM (only with consent)
Usage data may be transferred to the USA, only after consent.
Safeguards:
- EU-US Data Privacy Framework (DPF) certification
- Standard contractual clauses (SCCs)
- Consent Mode v2 (no loading without consent)
USA: Sentry (website error monitoring)
Anonymised error data from the website are transferred to the USA to ensure stability (stage 1: legitimate interest). Additional session replays only after analytics consent (stage 2). See section 3.5.
Safeguards:
- Standard contractual clauses (SCCs)
- Technical/organisational measures (TOMs)
- IP anonymisation, no user identifiers in stage 1
US provider / EU storage: Sentry (backend server error monitoring)
For error and crash monitoring of our backend server (see section 2.12), we use Sentry (Functional Software, Inc. d/b/a Sentry) in the EU data region; the technical error data are stored in the EU. The provider has its registered office in the USA; access from the USA is possible and is safeguarded by the following measures.
Safeguards:
- Standard contractual clauses (SCCs) of the European Commission, Module 2 (controller to processor)
- Data processing agreement under Art. 28 GDPR (Data Processing Amendment, version 5.1.0, concluded on 23 July 2026)
- Active data minimisation before transmission — only technical error data are transmitted; request bodies, headers, cookies, query strings, IP addresses and user identifiers are removed, and email addresses and telephone numbers in free-text error content are redacted automatically
- Data held in the EU (Sentry EU data region)
USA: Postmark (email inbound & outbound: transactional, newsletter, Kleinanzeigen)
Email data for booking confirmations, handover reports, double opt-in confirmations, newsletter sending, emails for storing PayPal again (see section 2.6) and the receipt and sending of enquiries via eBay Kleinanzeigen (see section 2.13) are transferred to the USA.
Safeguards:
- Standard contractual clauses (SCCs) of the European Commission, Module 2 (controller to processor)
- Data processing agreement under Art. 28 GDPR via postmarkapp.com/dpa
- Encryption in transit and at rest
- No open/click tracking in the newsletter
- Overview of sub-processors: postmarkapp.com/eu-privacy
USA: Google (Google Workspace / Google Drive)
The handover documentation (photos, videos and handover reports, see section 2.15) is held in Google Drive. Our contractual partner is Google Cloud EMEA Limited (Ireland); processing outside the EU, in particular in the USA by Google LLC as a sub-processor, is possible.
Safeguards:
- EU-US Data Privacy Framework (DPF) certification of Google LLC
- Standard contractual clauses (SCCs) under the Cloud Data Processing Addendum, insofar as no other transfer mechanism applies
- Data processing agreement under Art. 28 GDPR
USA: Anthropic (AI language model)
Chat messages, photos you send and the loading area photo from the pick-up form are transferred to Anthropic (Claude API) in the USA for AI processing.
Safeguards:
- Data processing agreement; standard contractual clauses (SCCs)
- Use of the data for AI training is contractually excluded
- Telephone numbers are only transmitted as a hash that cannot be traced back without disproportionate effort
USA: Twilio (SMS and telephony)
Access code SMS, calls to our service number and voicemail messages run via Twilio (see sections 2.15 and 2.16). Our contractual partner is Twilio Ireland Limited (Ireland); processing in the USA, in particular by Twilio Inc., is possible.
Safeguards:
- EU-US Data Privacy Framework (DPF) certification of Twilio Inc.
- Binding corporate rules (BCRs)
- Standard contractual clauses (SCCs) of the European Commission
- Data processing agreement under Art. 28 GDPR
USA: ElevenLabs (voice transcription)
Voice messages from the WhatsApp customer service are transferred to Eleven Labs Inc. in the USA for automatic transcription (see section 2.10).
Safeguards:
- EU-US Data Privacy Framework (DPF) certification — including the UK and Swiss extensions; the certification expressly covers processing on behalf of others and is named in the DPA as the transfer mechanism (§ 11.1(i))
- In addition, standard contractual clauses (SCCs) of the European Commission as part of the DPA (§ 11; Clause 17 Option 1, Irish law)
- Data processing agreement under Art. 28 GDPR
- No contractually permitted use of the data for the provider’s own purposes, including AI training (§ 3.1, § 12.1.1)
- Deletion of the transcript immediately after retrieval
USA/EU: Meta (WhatsApp Business API)
WhatsApp messages are processed via the Meta WhatsApp Cloud API.
Safeguards:
- EU-US Data Privacy Framework (DPF) certification
- Standard contractual clauses (SCCs)
- Meta Business Tools Terms
- Encrypted transmission
USA: Slack (Salesforce) — internal communication
Customer messages from WhatsApp — including media sent (photos, videos, voice messages) — are mirrored in Slack for internal quality assurance. Our team also receives your comments from the pick-up and return form there, as well as information about calls and voicemail messages (see section 2.16). Messages and files are deleted automatically after 90 days.
Safeguards:
- Salesforce DPA under Art. 28 GDPR
- Standard contractual clauses (SCCs)
- Encryption in transit and at rest
US provider / EU storage: Backblaze (encrypted backup)
Our off-site backup (see section 2.12) is stored at the provider Backblaze, Inc. The data are held in a data centre in the EU (Amsterdam, Netherlands). Backblaze has its registered office in the USA; access from the USA is possible and is safeguarded by the following measures.
Safeguards:
- Standard contractual clauses (SCCs) of the European Commission, Module 2 (controller to processor)
- Data processing agreement under Art. 28 GDPR via backblaze.com/dpa
- Additional technical safeguard (Schrems II): client-side encryption (gpg, AES-256) before transmission — Backblaze only sees encrypted data (ciphertext), no plain text; the key never leaves our server
- Data held in the EU (Amsterdam, Netherlands)
- Overview of sub-processors: backblaze.com/subprocessors
US provider / EU storage: Supabase (database & backend)
We operate our database at Supabase (Supabase, Inc., USA) in the EU region Frankfurt (see section 2.3); the data are stored in the EU and are not moved to third countries in regular operation. The provider has its registered office in the USA; access from the USA (e.g. in technical support) is possible. The following safeguards apply to this.
Safeguards:
- Standard contractual clauses (SCCs) of the European Commission as an appropriate safeguard under Art. 46(2)(c) GDPR (Implementing Decision (EU) 2021/914, Module 2: controller to processor), supplemented by technical and organisational measures (TOMs) under Art. 32 GDPR
- Data processing agreement under Art. 28 GDPR via Supabase DPA
- Data held in the EU (eu-central-1, Frankfurt/Germany)
US provider / EU storage: Axiom (server log aggregation)
For the central aggregation of our server logs (see section 2.12), we use Axiom (Axiom, Inc.) in the EU region; the technical log data are stored in the EU. The provider has its registered office in the USA; access from the USA is possible and is safeguarded by the following measures.
Safeguards:
- Standard contractual clauses (SCCs) of the European Commission, Module 2 (controller to processor)
- Data processing agreement under Art. 28 GDPR via axiom.co/docs/legal/data-processing
- Active data minimisation before transmission — only technical server logs are transmitted; email addresses and telephone numbers are redacted server-side and secrets/tokens removed before the logs leave our server
- Data held in the EU (Axiom EU region)
- Overview of sub-processors: trust.axiom.co/subprocessors
✅ No transfer to third countries:
- Giesecke & Devrient: Germany/EU
- Strato: Germany
- Hetzner: Germany (Nuremberg)
- netcup (failover standby): Austria (Vienna) — EU/EEA
- Make (Celonis SE): EU
6. Your rights as a data subject
You have the following rights vis-à-vis us with regard to the personal data concerning you:
Right of access (Art. 15 GDPR)
You have the right to request information about your personal data processed by us. In particular, you can request information about the purposes of processing, the categories of personal data, the categories of recipients, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the source of your data and the existence of automated decision-making including profiling.
Right to rectification (Art. 16 GDPR)
You have the right to request the rectification of inaccurate personal data or the completion of your personal data stored by us.
Right to erasure (Art. 17 GDPR)
You have the right to request the erasure of your personal data stored by us, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation (e.g. retention obligations under HGB/AO), for reasons of public interest or for the establishment, exercise or defence of legal claims.
Right to restriction of processing (Art. 18 GDPR)
You have the right to request the restriction of the processing of your personal data if you contest the accuracy of the data, the processing is unlawful but you oppose its erasure, or if we no longer need the data but you require them for the establishment, exercise or defence of legal claims.
Right to data portability (Art. 20 GDPR)
You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format or to request their transmission to another controller.
Right to object (Art. 21 GDPR)
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is carried out on the basis of Art. 6(1)(f) GDPR (data processing on the basis of a balancing of interests).
Special note: You can object to the processing of your data for direct marketing purposes at any time without giving reasons.
Right to withdraw consent (Art. 7(3) GDPR)
You have the right to withdraw any consent you have given (e.g. for cookies, analytics) at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent before its withdrawal.
Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)
You have the right to lodge a complaint with a data protection supervisory authority about our processing of your personal data.
Competent supervisory authority in Germany (Hesse):
The Hessian Commissioner for Data Protection and Freedom of Information (Der Hessische Beauftragte für Datenschutz und Informationsfreiheit)
Postfach 3163, 65021 Wiesbaden
Telephone: +49 611 1408-0
Email: poststelle@datenschutz.hessen.de
Website: datenschutz.hessen.de
7. Retention periods (in detail)
We only store personal data for as long as is necessary for the respective purposes or as statutory retention obligations exist. After the periods have expired, the data are routinely deleted.
| Data category | Retention period | Legal basis |
|---|---|---|
| Contract & invoice data (incl. address) | 10 years after the end of the contract | § 147 AO, § 257 HGB |
| Identity document number, issuing country | 3 years from the return of the trailer | §§ 195, 199 BGB (limitation) |
| GPS telemetry (regular) | 30 days after the end of the rental | GTC § 17, GDPR (data minimisation) |
| GPS telemetry (damage case) | Until resolved (max. 3 years) | Art. 6(1)(f) GDPR |
| Speed alerts (time, number, speed) | With the associated booking data | Art. 6(1)(f) GDPR |
| Technical alert log (alert ID, trailer registration number, timestamp, raw text) | Reference to the booking is removed when the booking is deleted; the entry without personal reference is kept as deduplication/audit evidence | Art. 6(1)(f) GDPR |
| Support/communication matters | 24 months after completion | Art. 6(1)(f) GDPR |
| Cookie consent logs | 2 years or until withdrawal | GDPR (accountability) |
| Server/security logs (Cloudflare) | Max. 30 days | Art. 6(1)(f) GDPR |
| Server logs (own) | 7 days | Art. 6(1)(f) GDPR |
| Payment data (references) | 10 years | § 147 AO (accounting) |
| Supabase backups | 30 days | Technical security |
| Handover documentation in the booking folder (photos and videos from the pick-up and return form or sent afterwards via WhatsApp, handover reports) | 3 years from the return of the trailer | Art. 6(1)(b)/(f) GDPR; §§ 195, 199 BGB (limitation) |
| Call information and voicemail recordings (internal Slack) | 90 days | Art. 6(1)(b)/(f) GDPR |
| Twilio: call and SMS logs, voicemail recordings | 30 days (logs up to September 2025: deletion being clarified with Twilio) | Art. 6(1)(b)/(f) GDPR |
| WhatsApp chat histories | 72 hours after the last message; with an assigned booking, until 7 days after the end of the rental | Art. 6(1)(b)/(f) GDPR |
| Kleinanzeigen conversations (thread & messages) | 90 days sliding window after the last activity (cascade delete) | Art. 6(1)(b) GDPR |
| Backend server logs (nginx, IP addresses) | 90 days | Art. 6(1)(f) GDPR (IT security) |
| Backend application logs | Max. 30 days (rotating log files) | Art. 6(1)(f) GDPR |
Exception: In the event of ongoing legal disputes, official investigations or criminal offences, data may be retained until finally resolved, even beyond the periods stated (purposes of evidence and defence).
8. Data security & technical/organisational measures
During your visit to the website, we use the widespread SSL/TLS method in conjunction with the highest level of encryption supported by your browser (at least TLS 1.2).
Our staff and all persons involved in data processing are obliged to comply with data protection provisions and to treat personal data confidentially.
Overview of security measures:
🔒 Transport encryption
- TLS 1.3 (latest standard)
- HSTS (HTTP Strict Transport Security)
- Encrypted email communication
🛡️ Data storage
- AES-256 encryption (Supabase)
- Row Level Security (RLS)
- Encrypted backups
🔐 Access control
- Role-based access (RBAC)
- 2FA/MFA for admin access
- Principle of least privilege
- Access logging
🚨 Attack detection
- Cloudflare WAF (web application firewall)
- DDoS protection
- Rate limiting
- Bot detection
🔄 Maintenance & updates
- Regular security updates
- Automated backups (daily)
- Monitoring & alerting
📋 Organisational
- Confidentiality undertakings
- Data protection training
- Incident response plan
9. Obligation to provide data
To book a trailer, name, address, contact details and payment information are required (performance of a contract). Without these data, a contract cannot be concluded.
In addition, we ask for the identity document number and issuing country. We do not process this information for the performance of the contract, but on the basis of our legitimate interest in preventing misuse and theft in the contact-free handover (section 2.4). We only offer contact-free rental with this information; without it, we therefore cannot accept a booking. Your right to object under Art. 21 GDPR (section 2.4) remains unaffected.
For voluntary information (e.g. newsletter sign-up), we point this out separately.
10. Automated decisions & profiling
There is no automated profiling within the meaning of Art. 4(4) GDPR and no automated decision-making with legal effect (Art. 22 GDPR).
All booking decisions and damage cases are handled by human staff.
Automatic speed safety alert:
During an ongoing rental, our telematics system automatically checks whether a fixed speed threshold is exceeded (see section 2.5). This is a pure threshold comparison without any assessment of driving behaviour and without any forecast. It only results in an informative notification email and makes no decision about your booking. Any consequences — for example in the event of damage — are always examined by staff on a case-by-case basis.
AI-supported preliminary assessment of the loading area photo (cleanliness check):
At pick-up, you photograph the loading area of the trailer in the pick-up form. An AI language model (Anthropic Claude, see section 4.1) assesses from this photo whether the loading area is dirty. The assessment decides exclusively whether a member of staff additionally checks the photo: if the loading area appears dirty or the photo cannot be assessed clearly, a member of staff checks it and decides whether we offer you a refund for the cleaning. If the loading area appears clearly clean, the photo is filed in the booking folder without further checking (see section 2.15); we spot-check some of these photos. The assessment has no influence on your booking, does not lead to any charge and is not a damage assessment — damage cases continue to be handled by staff. Only the photo is transmitted to Anthropic, no names, contact or booking data. We store the result (clean, light traces, dirty or cannot be assessed), a short descriptive sentence about the loading area, a confidence value of the assessment and information on the course of the check (AI model used, whether and when the photo was filed without checking).
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in an efficient check of the vehicle’s condition in the contact-free handover).
Storage period: The AI assessment and the information on the course of the check are deleted automatically 30 days after the pick-up.
AI-supported communication (WhatsApp chatbot):
Our WhatsApp chatbot “Sam” uses an AI language model (Anthropic Claude) to answer customer enquiries automatically (see section 2.10). The chatbot provides information only and makes no binding decisions. Booking changes, cancellations or damage reports always require manual confirmation by our staff. You can request to be put through to a human contact at any time.
11. Validity and changes to this privacy policy
This privacy policy is currently valid and was last updated on: 4 November 2026 (Version 3.30).
As a result of the further development of our website and offers, or due to changes in legal or official requirements, it may become necessary to amend this privacy policy. You can access and print out the current privacy policy at any time on the website at https://trailer-swarm.de/datenschutz/.
Questions about data protection?
For questions about the collection, processing or use of your personal data, for information, rectification, restriction of processing or erasure of data and for withdrawing consent given or objecting to a particular use of data, please contact us directly:
Email: datenschutz@trailer-swarm.de
Telephone: +49 89 244 182 67
We endeavour to answer your enquiries within 30 days (statutory period under Art. 12 GDPR).