Privacy Policy – Customer Portal and App

1. Controller

The controller responsible for data processing in the customer portal and the app is:

Future Machine Labs GmbH
Zimmerstraße 79-80
10117 Berlin

Phone: +49 30 7566 8290
Email: info@fm-labs.de

Managing director: Nick Nidens
Commercial register: HRB 260051, Charlottenburg Local Court

For privacy inquiries, you can reach us at: datenschutz@fm-labs.de

2. At a glance

• We process your account data (name, email address, organisation) so that you can see your organisation’s machines and contact our support.
• Machine data belongs to your organisation. It is personal data where it is linked to a person – for example who wrote a support request or started a cleaning. Other users in your organisation see this too.
• We never store your password in readable form. Sign-in keys are kept in cookies only our server can read (web portal) or in the iOS Keychain (app).
• For usage analytics we use PostHog (EU cloud) and link usage to your account. Your screen is not recorded, neither in the portal nor in the app (section 3.9).
• No advertising, no sale of data, no tracking across other companies’ apps or websites.
• Our servers run on Vercel (server functions in Frankfurt am Main) and Microsoft Azure (West Europe region).

3. What data we process, why, and on what legal basis

3.1 Your account

We create your account for your organisation. We store your name, your email address, the organisation the account belongs to, your scope of access (the whole organisation or specific sites), the account status and the time of your last sign-in. You choose your password yourself; we store it only as a cryptographic hash (scrypt).

Your invitation contains a link that can be used once and is valid for 72 hours. If you forget your password, we record your request and our team sends you a new link, valid for one hour.

The purpose is to give you the access to your organisation’s data that your organisation has agreed with us. The legal basis is Art. 6(1)(b) GDPR where you yourself are our contracting party, and otherwise Art. 6(1)(f) GDPR: our legitimate interest, and that of your organisation, in providing the agreed access to the people it names.

3.2 Sign-in and session

After you sign in you receive two keys: an access key, currently valid for 15 minutes, and a renewal key, currently valid for 30 days and replaced by a new one every time it is used. On our servers we store the renewal key only as a hash, together with a device label (“Kundenportal Web” or your device’s model, e.g. “iPhone 15 Pro”), its expiry time and, where applicable, the time of sign-out.

In the web portal this information is kept in cookies that only our server can read (httpOnly) – neither scripts on the page nor third parties can access them:

In the app the keys are kept only in the iOS Keychain – on this device only, readable only while the device is unlocked, and not included in backups.

When you sign out, we invalidate the session on our server and remove the keys from your device. If you reset your password, we end all other sessions of your account.

The legal basis is Art. 6(1)(b) or (f) GDPR (secure access). Storing the keys on your device is strictly necessary for the service you use (Section 25(2) No. 2 of the German TDDDG).

3.3 Your machines’ data

The portal and the app show the data of your organisation’s machines: status, cleaning runs and areas cleaned, maps and floor plans, faults and cleaning schedules. We receive this data from the machines and their manufacturers’ cloud services. It relates to machines and sites, not to people. It becomes personal data where it is linked to a person:

• Starting a cleaning: If this function is enabled for your organisation and you start a cleaning, we store which account started it, when, and on which machine. Other users in your organisation see your name or email address on that cleaning run. The command sent to the machine contains no information about you.
• Settings: If an account with access to the whole organisation changes an organisation setting (e.g. the boundary between early and late shift), we log who changed it and when.

The legal basis is Art. 6(1)(b) or (f) GDPR (performance of the contract with your organisation; traceability of commands sent to machines).

3.4 Support requests (“Meldungen”)

In the web portal you send a new request directly: topic, your text, site and machine, whether you would like a call back, up to four photos and – added automatically and visible to you before sending – the machine’s state at the time of the request. As the sender we add your name, your email address and your organisation. Photos are transmitted as you select them, including metadata stored in them such as the time or place they were taken, if your device embeds it.

In the app a new request is prepared as a message that you send to us yourself via WhatsApp or email (section 3.12). The app does not transmit a new request itself.

In both you can reply to existing requests (text and up to four photos) and mark a request as solved or reopen it, each with a comment. The app scales photos down before sending and re-saves them as JPEG.

We store requests, replies and photos on our servers at Microsoft Azure (West Europe region). From them we create or update a ticket in our helpdesk system (Odoo). Our support team is notified in our internal chat service Slack – with topic, organisation, site, machine, your name (or, failing that, your email address) and an excerpt of your text, without photos. You see our support team’s replies in the portal and the app.

Who sees your requests: our support team and all users in your organisation who have access to the site concerned – including your name as the author.

The legal basis is Art. 6(1)(b) or (f) GDPR (handling service requests under the contract with your organisation).

3.5 Feedback

Under “Feedback” you tell us what you think of the portal. We store your answers (e.g. category, rating, your text and whether we may contact you about it), your name, your email address, your organisation, the page you gave feedback from, and the technical identifier of your browser or app (user agent). We read feedback on our platform; it is not forwarded to any other system. Giving feedback is voluntary. The legal basis is Art. 6(1)(f) GDPR (our interest in improving the portal).

3.6 News

We store which news items you have read and when, so that the portal and the app can mark unread items. The legal basis is Art. 6(1)(f) GDPR.

3.7 Data on your device

If the portal appears in your organisation’s branding, it remembers your organisation’s colour, name and logo version so the page displays correctly straight away – in the web portal in the kp_brand cookie, in the app in app storage. The app also caches images it has displayed (photos from requests, images from news, logos). When you sign out, the app removes this data and the cache; the web portal deletes its cookies. For PostHog’s identifier, see section 3.9.

3.8 Logs

We log every request to our interface with time, account, function called, result, duration, IP address and user agent. For requests from the web portal this is the IP address of our portal server – your own IP address is processed there by our hosting provider Vercel (section 3.11); for the app it is your device’s IP address. Sign-ins and failed sign-in attempts, refused requests and the starting of a cleaning are additionally recorded in an audit log, also with the IP address.

The purpose is secure operation, troubleshooting and protection against misuse. The legal basis is Art. 6(1)(f) GDPR.

3.9 Usage analytics with PostHog

To understand how the portal and the app are used, and to find errors, we use PostHog, an analytics service of PostHog, Inc., 2261 Market Street #4008, San Francisco, CA 94114, USA. We exclusively use PostHog’s EU cloud: analytics data is processed and stored on servers in the European Union (Frankfurt am Main, AWS eu-central-1); analytics data is not transferred to the USA.

After you sign in, we link usage to your account: PostHog receives your email address (as the identifier), your name and your organisation. PostHog also stores a random identifier on your device – in the web portal in a cookie or the browser’s local storage, in the app in app storage. After you sign out, the link is reset. PostHog also processes your device’s IP address, for example for an approximate location.

In the app, PostHog records:

• which screens you open – with their address, which may contain a machine’s serial number or a site’s identifier,
• app events such as installation, update, opening and moving to the background,
• which controls you tap – not what you type,
• technical details such as device model, operating system and app version.

In the web portal, PostHog records:

• which pages you open, with the full address – including machine serial numbers and site identifiers – and when you leave a page,
• clicks and other interactions with page elements, including their visible labels,
• technical details such as browser, operating system and screen size.

Neither the portal nor the app records your screen or your session.

The legal basis is our legitimate interest in improving the portal and the app based on how they are actually used, finding errors and supporting our customers effectively (Art. 6(1)(f) GDPR). You can object to this processing at any time (Art. 21 GDPR); a message to datenschutz@fm-labs.de is sufficient.

3.10 App updates

We deliver small app updates through EAS Update, the update service of our development tool Expo (650 Industries, Inc., USA). On launch the app asks it for an update; this transmits your IP address, a random identifier of this app installation, the platform and the app version. Expo does not learn who you are. The legal basis is Art. 6(1)(f) GDPR (our interest in fixing errors quickly).

3.11 Hosting

We run the portal and the interface (app.daedalus.fm, daedalus.future-machines.com) on Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA; the server functions run in the Frankfurt am Main region. With every request, Vercel processes technical data such as IP address, time, requested address, browser and operating system and stores it in server log files. Vercel is certified under the EU-US Data Privacy Framework; in addition, we base data transfers to the USA on the EU Standard Contractual Clauses.

We run the database, photo storage and the service that receives support requests on Microsoft Azure (Microsoft Ireland Operations Ltd.) in the West Europe region (Netherlands).

The legal basis is Art. 6(1)(f) GDPR (reliable and secure operation). Both providers process the data on our behalf (Art. 28 GDPR).

3.12 Contact by email or WhatsApp

You can reach our support by email at support@fm-labs.de and via WhatsApp at +49 158 8865 7196 (WhatsApp only, not a phone line). In the app, you send a new request by one of these routes. We process your message and your contact details – for WhatsApp also your phone number and WhatsApp profile name – to handle your request (Art. 6(1)(b) or (f) GDPR).

Our email mailbox is run by Google (Google Workspace, Google Ireland Limited) on our behalf. WhatsApp is a service of WhatsApp Ireland Limited (Meta). If you use WhatsApp, its privacy terms also apply; Meta may transfer data to the USA. Email is always available as an alternative.

3.13 Invitation emails

We send invitations from noreply@future-machines.com via Azure Communication Services (Microsoft, data location Europe). The email contains your name, the name and, where available, the logo of your organisation, your personal invitation link and, where available, images of an evaluation of your organisation’s machines. We log every send with recipient, time and result. The legal basis is Art. 6(1)(b) or (f) GDPR.

3.14 App Store

You download the app from Apple’s App Store; we distribute test versions through Apple’s TestFlight. Downloading and updating via the App Store are governed by Apple’s own privacy terms; Apple is responsible for them itself. If you have agreed in your iPhone’s settings to share analytics with app developers, Apple provides us with crash reports and usage statistics that do not identify you.

4. Recipients and processors

These service providers process data on our behalf (Art. 28 GDPR):

At Future Machines, staff in support, customer care and engineering have access to the extent they need it for their work. In your organisation, other users see who wrote a request or started a cleaning (sections 3.3 and 3.4). Apple (App Store) and, if you use it, WhatsApp are independently responsible. Data is not passed on for advertising purposes.

5. Transfers outside the EU

The database, photos and analytics data are stored in the EU. Data may reach the USA via Vercel (hosting), Expo (app updates), Slack (notifying our support), Google (email mailbox) and Apple and WhatsApp, insofar as you use their services. The basis is the European Commission’s adequacy decision on the EU-US Data Privacy Framework where the provider is certified under it, otherwise the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).

6. Retention period

Where automatic deletion is not yet set up, we delete data as soon as it is no longer needed for its purpose and no statutory retention obligations prevent this, and on your request (section 8).

7. Automated decisions

We do not make any decisions based solely on automated processing within the meaning of Art. 22 GDPR.

8. Your rights

You have the right at any time to:

• obtain information about the data we hold about you (Art. 15 GDPR)
• request the correction of inaccurate data (Art. 16 GDPR)
• request the deletion of your data (Art. 17 GDPR)
• request the restriction of processing (Art. 18 GDPR)
• request data portability (Art. 20 GDPR)
• object to processing based on our legitimate interest, such as usage analytics (Art. 21 GDPR)
• withdraw consent you have given at any time with effect for the future (Art. 7(3) GDPR), for example the app’s access to camera and photos in your iPhone’s settings
• lodge a complaint with a supervisory authority (Art. 77 GDPR)

To do so, write to datenschutz@fm-labs.de.

Deleting your account: We create and manage your account for your organisation; the app itself creates no accounts. To have it deleted, write to datenschutz@fm-labs.de or contact your organisation. We end your access immediately and process the deletion within 30 days, including at the processors we use. Data we have to keep for legal reasons is blocked instead of deleted.

Competent supervisory authority:
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59-61, 10555 Berlin
www.datenschutz-berlin.de

9. Changes

If what the portal or the app processes changes, we update this privacy policy. The current version applies; you can find it in the app under “Mehr” → “Datenschutz”.