We have revised our data processing agreement (in German: AV-Vertrag or AVV). The reasons were feedback from customers and their data protection officers as well as changes at our service providers. Here we show you what changes and why.
You don't need to do anything. Nothing to print, sign or send back. The new version applies from 1 December 2026. If you don't agree with the changes, you can cancel your account until 30 November 2026. Otherwise the new version also applies to you from 1 December. You can already find it (in German) at centralplanner.de/avv.
Sub-processors (Annex 3)
Telekom Deutschland GmbH is no longer one of our sub-processors. We no longer store any data there.
New is Schwarz Digits Cloud GmbH & Co. KG from Bad Friedrichshall with its cloud STACKIT. We plan to use STACKIT for storing files and backups, among other things. STACKIT's data centres are in Germany, so your data stays here.
Also new is Scoria Labs GmbH from Hallbergmoos with its service CaptchaFox, which protects web forms from spam. We plan to use it to protect our online reservation forms from spam in the future.
Data export before cancellation (clause 10.2)
You have always been able to export your contacts and reservations yourself at any time. So far, however, the agreement only said that we delete your data when the contract ends. Now it also describes the export. Nothing changes in practice.
You start the export in the account settings: there you can export all reservations and all contacts to Excel. You need admin rights for this. Please export your data before you cancel: when you cancel, we deactivate your account immediately and delete it after three days. If you haven't exported anything by then, we delete your data.
Costs of audits (clause 9.5)
You can check whether we comply with the agreement. That you bear the costs of such an audit was already in the agreement. What's new is that the amount follows our price list, so you know in advance what to expect. We're happy to send you the price list on request.
Backups (clause 10.3)
Our backups are there for emergencies, for example after a system failure or a cyberattack. In that case we restore the complete system. We don't restore individual data or individual accounts from backups. The agreement now says so explicitly.
We removed the promise to delete everything you had deleted before again after restoring a backup, based on a separate deletion history. In an emergency, all changes since the last backup are missing anyway, and we can't reliably track deletions from exactly that period. If an entry you deleted shortly before reappears afterwards, you can simply delete it again.
New data protection officer from 1 January 2027
From 1 January 2027, lawyer Jan Rübsteck will be our data protection officer. Until the end of 2026, KINAST Rechtsanwaltsgesellschaft remains responsible. Nothing changes for you. We will update the contact details in Annex 4 at the turn of the year.
Other changes
- Annex 1 now explicitly names the CentralPlanner app for iOS and Android as a way to access the service.
- Support with your information obligations towards data subjects is now in clause 5.6 instead of 11.1.3. The content stays the same.
- We corrected two wrong references (clauses 9.4 and 9.6), fixed the GDPR citation in clause 1.1 ("Art. 28" instead of "§ 28") and removed a few typos.
If you have questions about the data processing agreement, just contact our support.
