Skip to content

Data processing agreement

Zur Information, maßgeblich ist die deutsche Fassung. For information only; the German version is binding. Deutsche Fassung

As of 30 October 2026 · Download the German version as PDF

Data processing agreement under Art. 28 GDPR between the customer as controller (the “client”) and the provider as processor (the “contractor”):

Feldmelder is offered by a sole proprietorship, Albert-Altwicker-Straße 31, 47445 Moers, Germany (the “provider”; owner and full details in the imprint).

1. Subject matter and duration

The contractor processes personal data on behalf of the client in order to provide the Feldmelder services agreed in the main contract (portal, data reception from the Feldmelder Boxes, alarms, evaluations, export). This agreement applies for the term of the main contract.

2. Nature and purpose of the processing

Receiving, storing, evaluating and displaying plant data; sending alarm messages to the contacts stored by the client; managing the client’s user accounts; logging security-relevant actions; creating exports and reports; backups.

3. Types of data

  • user data: e-mail address, role, language setting, sign-in logs (time, IP address), audit log entries, Telegram chat ID;
  • contact data for alarms: name, e-mail address, phone number, Telegram chat ID;
  • plant and operating data (angles, mode, weather values, alarms, commands and acknowledgements), to the extent they can be attributed to a person;
  • content of exports and reports.

4. Data subjects

Employees and agents of the client who use the portal or are stored as alarm contacts, and persons to whom the client grants access (e.g. maintenance service providers).

5. Instructions

The contractor processes the data only on documented instructions of the client; the main contract and the settings the client makes in the portal count as instructions. The client gives further instructions in text form. If the contractor considers an instruction unlawful, it informs the client without delay. Where processing is required by law, the contractor informs the client beforehand unless the law prohibits this.

6. Confidentiality

The contractor only uses persons who are bound to confidentiality or are subject to a statutory duty of secrecy.

7. Technical and organisational measures

The contractor takes the measures described in the annex under Art. 32 GDPR. It may replace them with equivalent or better measures and documents changes.

8. Sub-processors

The client approves the following sub-processors:

  • Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA – DNS, reverse proxy and TLS termination for website and portal; transfer based on the EU-US Data Privacy Framework and the standard contractual clauses;
  • Sendinblue SAS (Brevo), 106 boulevard Haussmann, 75008 Paris, France – sending e-mails (alarm messages, invitations, password resets);
  • planned for production: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany – server operation in a data centre in Germany. The contractor announces the change in advance.

The contractor informs the client of new or changed sub-processors at least four weeks in advance in text form; the client may object for an important data protection reason. Telegram is not a sub-processor: the contractor sends messages via Telegram only if the client sets up this channel for a contact.

9. Assistance to the client

The contractor assists the client to a reasonable extent in responding to requests from data subjects, in notifying personal data breaches and in data protection impact assessments. It notifies the client of personal data breaches without undue delay after becoming aware of them.

10. Deletion and return

After the end of the main contract the contractor provides the client with the data as an export on request and then deletes it, at the latest three months after the end of the contract, unless there is a legal obligation to retain it. Backups are overwritten in the course of the regular rotation.

11. Evidence and audits

The contractor provides the client with the information necessary to demonstrate compliance and allows audits after timely notice in text form, during normal business hours and without disrupting operations. As a first step, written information is usually sufficient.

12. Liability

Liability is governed by Art. 82 GDPR. Otherwise the liability provisions of the main contract apply.

Annex: technical and organisational measures

  • Encryption in transit: website and portal only via HTTPS (TLS); the Feldmelder Boxes transmit via MQTT with TLS.
  • Device identity: each box identifies itself with its own client certificate (mTLS); revoked certificates are rejected via a revocation list.
  • Commands: remote commands to plants are digitally signed and valid for a short time only; the box checks signature and validity before executing them.
  • Access: passwords only as Argon2id hashes; two-factor sign-in for administrators and everyone allowed to send commands; limits on sign-in attempts.
  • Permissions: role-based rights; strict separation of the data of different customers (tenants).
  • Traceability: audit log of security-relevant actions, logging of sign-ins and commands.
  • Availability: daily backups with tested restore; the box keeps controlling the plant without a connection to the portal and buffers data until reconnection.
  • Location: servers in Germany.
  • Operation: logging of server and application operation; bill of materials of the software components with automatic checks for known vulnerabilities.