Privacy Policy

Draft, needs lawyer review before launch. Version 2026-10-30.

Dankeroo is a place where people chip in for each other's bills. You trust us with personal things, so we keep only what we need and explain every step here.

1. Who is responsible

Neurotech AI Solutions GmbH, Lückstraße 24, 10317 Berlin, Germany. Managing Director: Ashraf Al-Eryani. Email: hello@dankeroo.com. We are the controller under the GDPR. We have not appointed a data protection officer because we are not legally required to; write to the address above with any privacy question.

2. What we process, why, and on which legal basis

• Account (email, name, password hash managed by Amazon Cognito, sign-in provider, language, country, city): to run your account. Art. 6(1)(b) GDPR (contract).
• Sign in with Google or Apple: if you choose it, we receive your name, email and, if shared, profile picture from that provider. Art. 6(1)(b) GDPR.
• Mobile number: you add it after sign-up and confirm it with a one-time code sent by SMS (Amazon Cognito and Amazon SNS, Frankfurt). We keep the number and whether it is verified, use it to protect people chipping in (a verified number is needed before you post a bill) and never show it publicly or use it for marketing. Art. 6(1)(b) and (f) GDPR. You can skip it until you post a bill.
• Profile extras (photo, social handles): optional, shown on bills you post so people can see you are real. Art. 6(1)(a) GDPR (consent), which you can withdraw by deleting them.
• Bills you post (invoice photo or PDF, biller name, IBAN, BIC, amount, due date, reference, your story, photos or videos): to review the bill and pay the biller directly. Art. 6(1)(b) GDPR. Other people only ever see the masked IBAN (last four digits), never the full number.
• Invoice reading: the invoice image is sent to Amazon Bedrock (AI model, run in the EU) to suggest the fields. QR payment codes (GiroCode, Swiss QR-bill) are read on our servers. You always check and correct the result. No automated decision is made about you (Art. 22 GDPR does not apply). Art. 6(1)(b) GDPR.
• Safety checks: images are checked by Amazon Rekognition for harmful content, and moderators review every bill before it goes live. Art. 6(1)(f) GDPR (our legitimate interest in a safe, fraud-free platform).
• Chip-ins and pledges (amount, bill, time, payment status): to process payments and to show you your history. Payment card or wallet details are entered only at Stripe; we never see your full card number. Art. 6(1)(b) and (c) GDPR (bookkeeping duties).
• Push notifications (Expo push token, your per-type preferences): only if you allow them. Art. 6(1)(a) GDPR.
• Weekly Sunday email: only if you switch it on. Art. 6(1)(a) GDPR, § 7(2) UWG. Every email has an unsubscribe link and an unsubscribe header. Service emails (welcome email after sign-up, receipts, security emails) are sent on Art. 6(1)(b) GDPR.
• Reports you send about a bill: to keep the community safe. Art. 6(1)(f) GDPR.
• Server logs (IP address, time, request): kept for 30 days for security and troubleshooting. Art. 6(1)(f) GDPR.

We do not sell your data, we do not show ads, and we do not use tracking or advertising SDKs.

3. Who processes data for us

All processors work under a data processing agreement (Art. 28 GDPR).

• Amazon Web Services EMEA SARL, Luxembourg: hosting in Frankfurt (eu-central-1): Cognito (sign-in), Aurora database, S3 and CloudFront (media), Lambda, SES (email), SNS (verification texts), Bedrock (invoice reading), Rekognition (image safety), Location Service (map tiles).
• Stripe Payments Europe, Ltd., Dublin, Ireland: payment processing. Stripe is also its own controller for fraud prevention and legal duties; see stripe.com/privacy.
• 650 Industries, Inc. (Expo), USA: delivers push notifications to Apple and Google. Only the push token and the message text are passed on. Transfer based on the EU-US Data Privacy Framework and/or standard contractual clauses.
• Apple (APNs) and Google (Firebase Cloud Messaging): deliver push notifications to your device.
• Google, Apple, Meta Platforms Ireland: only if you choose to sign in with them.

Some of these companies have parent companies in the USA. Where data may leave the EU, we rely on adequacy decisions (EU-US Data Privacy Framework) or standard contractual clauses (Art. 46 GDPR).

4. How long we keep data

• Account data: until you delete your account.
• Bills: while open, then 90 days after they close; invoice images are deleted after payout.
• Payment and payout records: 10 years (§ 147 AO, § 257 HGB). After account deletion they are kept without your name.
• Push tokens: until you sign out, switch off pushes, or the token expires.
• Email preferences and unsubscribe records: as long as needed to respect your choice.
• Server logs: 30 days.

5. Deleting your account

You can delete your account at any time in Me → Delete account. We delete your profile, photo, social handles, push tokens and email preferences, close your open bills and refund held chip-ins. Records we must keep by law are anonymised.

6. Your rights

You have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20) and to object (Art. 21) to processing based on legitimate interest. You can withdraw consent at any time with effect for the future (Art. 7(3)). Request a copy of your data in Me → Request a copy of my data or by email.

You may complain to a supervisory authority, for example ours: Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin.

7. Example stories

Until the first real bills are verified, Dankeroo shows clearly labelled example stories. They are invented to show how the app works, do not describe real people, and cannot receive payments.

8. Children

Dankeroo is for people aged 18 and over.

9. Changes

We will tell you in the app before important changes to this policy take effect.