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Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as the "online offering").

The terms used are not gender-specific.

Last updated: September 3, 2026

Table of Contents

  • Preamble
  • Controller
  • Hosting and Content Delivery Networks (CDN)
  • Overview of processing operations
  • Relevant legal bases
  • Security measures
  • Transmission of personal data
  • General information on data storage and deletion
  • Rights of data subjects
  • Use of Cookies
  • Blogs and publication media
  • Contact and inquiry management
  • Web analysis, monitoring, and optimization
  • Online marketing
  • Data Usage Within the Software ("Solar Miner App")
  • Data Sharing / Network Telemetry (optional)
  • Lightning Node & Payment Transactions
  • Modification and updating
  • Definitions of terms

Controller

Lukas Jonsson c/o flexdienst - #12037 Kurt-Schumacher-Straße 74 67663 Germany

E-mail: [email protected]

Hosting and Content Delivery Networks (CDN)

We are hosting the content of our website at the following provider:

Hetzner

The provider is the Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (hereinafter referred to as Hetzner). For details, please view the data privacy policy of Hetzner: https://www.hetzner.com/de/legal/privacy-policy/. We use Hetzner on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable depiction of our website possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Data processing agreement We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Cloudflare

We use the "Cloudflare" service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as "Cloudflare"). Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose. The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible (Art. 6(1)(f) GDPR). Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details and further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/.

The company is certified in accordance with the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5666.

Overview of processing operations

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g., names, addresses).
  • Employee data.
  • Contact data (e.g., email, phone numbers).
  • Content data (e.g., text inputs, photographs, videos).
  • Contract data (e.g., subject matter of the contract, term, customer category).
  • Usage data (e.g., websites visited, interest in content, access times).
  • Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, persons involved).
  • Log data.

Categories of data subjects

  • Service recipients and clients.
  • Employees.
  • Communication partners.
  • Users.
  • Business and contractual partners.
  • Third parties.
  • Whistleblowers.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Reach measurement (e.g., access statistics).
  • Tracking.
  • Conversion measurement.
  • Target group formation.
  • Affiliate tracking.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Whistleblower protection.

Relevant legal bases

Relevant legal bases under the GDPR: The following provides an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Art. 6 (1) (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 (1) (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) (f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the Federal Data Protection Act (BDSG). The BDSG contains special provisions regarding the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated decision-making in individual cases including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Security measures

In accordance with legal requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transmission, securing of availability, and its separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data endangerment. We also take the protection of personal data into account during the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL.

Transmission of personal data

In the context of our processing of personal data, it may happen that this data is transferred or disclosed to other entities, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

General information on data storage and deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consents are revoked or there are no further legal bases for processing. This concerns cases in which the original purpose of processing ceases to apply or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or the protection of the rights of other natural or legal persons, must be archived accordingly.

Where several details regarding the retention period or deletion periods of a data item are provided, the longest period is always authoritative.

Retention and deletion of data: The following general periods apply to retention and archiving under German law:

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balances, as well as the working instructions and other organizational documents required to understand them.
  • 8 years - Accounting vouchers, such as invoices and cost receipts.
  • 6 years - Other business documents: received commercial or business letters, reproductions of dispatched commercial or business letters, other documents insofar as they are of importance for taxation.
  • 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims.

Commencement of period at the end of the year: If a period does not explicitly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right, in accordance with legal requirements, to request the completion of data concerning you or the rectification of incorrect data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to demand that data concerning you be deleted immediately, or alternatively, in accordance with legal requirements, to demand a restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format in accordance with legal requirements or to request its transmission to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Use of Cookies

The term "cookies" refers to functions that store information on users' end devices and read it from them. Cookies can also be used for various purposes, for instance for the functionality, security, and convenience of online offerings, as well as the creation of analyses of visitor flows. We use cookies in accordance with legal regulations. If necessary, we obtain the users' consent in advance. If consent is not necessary, we rely on our legitimate interests.

Information on data protection legal bases: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their end device.
  • Permanent cookies: Permanent cookies remain stored even after closing the end device. If we do not provide users with explicit information on the type and storage duration of cookies, they should assume that these are permanent and the storage duration can be up to two years.

General information on withdrawal and objection (opt-out): Users can revoke their consent at any time and also declare an objection to processing in accordance with legal requirements.

  • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time specifications, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR). Consent (Art. 6 (1) (a) GDPR).

Further information on processing operations, procedures, and services:

  • Processing of cookie data based on consent: We use a consent management solution to obtain the consent of users for the use of cookies. This procedure serves to obtain, log, manage, and revoke consent. The duration of storage of consent is up to two years; Legal bases: Consent (Art. 6 (1) (a) GDPR).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only insofar as it is necessary for its presentation and communication between authors and readers or for security reasons.

  • Types of data processed: Inventory data; Contact data; Content data; Usage data; Meta, communication, and procedural data.
  • Data subjects: Users.
  • Purposes of processing and legitimate interests: Feedback; Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion".
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Contact and inquiry management

When contacting us (e.g., via contact form, e-mail, telephone, or via social media) as well as within the framework of existing user and business relationships, the information provided by the inquiring persons is processed insofar as this is necessary to respond to contact requests and any requested measures.

  • Types of data processed: Contact data; Content data; Meta, communication, and procedural data.
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; Organizational and administrative procedures; Feedback; Provision of our online offering and user-friendliness.
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR). Performance of a contract and prior requests (Art. 6 (1) (b) GDPR).

Web analysis, monitoring, and optimization

Web analysis (also referred to as "reach measurement") serves the evaluation of visitor flows of our online offering and can include behavior, interests, or demographic information about visitors.

Furthermore, we can also use test procedures, for instance, to test and optimize different versions of our online offering. The IP addresses of the users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users.

  • Types of data processed: Usage data; Meta, communication, and procedural data.
  • Data subjects: Users.
  • Purposes of processing and legitimate interests: Reach measurement; Profiles with user-related information; Provision of our online offering and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing operations, procedures, and services:

  • Google Tag Manager: We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States. The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time. The company is certified in accordance with the "EU-US Data Privacy Framework" (DPF). For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any clear data, such as names or e-mail addresses. Analytics provides coarse geographical location data by deriving metadata from IP addresses. When handling EU traffic, the IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Security measures: IP masking; Privacy Policy: https://business.safety.google/privacy/; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en.

Online marketing

We process personal data for the purpose of online marketing, which can include, in particular, the marketing of advertising space or the presentation of advertising and other content based on the potential interests of users, as well as measuring their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used. Moreover, the IP addresses of users are stored. We use IP masking procedures for user protection.

Information on revocation and objection: We refer to the privacy policies of the respective providers and the opt-out options specified there. a) Europe: https://youronlinechoices.eu/ b) Canada: https://youradchoices.ca/ c) USA: https://optout.aboutads.info/ d) Cross-territory: https://optout.aboutads.info

  • Types of data processed: Usage data; Meta, communication, and procedural data.
  • Data subjects: Users.
  • Purposes of processing and legitimate interests: Reach measurement; Tracking; Target group formation; Marketing; Profiles with user-related information; Conversion measurement.
  • Security measures: IP masking.
  • Legal bases: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing operations, procedures, and services:

  • Google Ads and Conversion Measurement: Online marketing procedure for the purpose of placing content and advertisements within the advertising network of the service provider. We also measure conversion, i.e. whether users took the ads as an opportunity to interact with them; Service provider: Google Ireland Limited, Dublin 4, Ireland; Legal bases: Consent (Art. 6 (1) (a) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://marketingplatform.google.com.
  • Google Adsense with personalized ads: We integrate the Google Adsense service, which enables personalized ads to be placed within our online offering. Google Adsense analyzes user behavior to display targeted advertising; Service provider: Google Ireland Limited, Dublin 4, Ireland; Legal bases: Consent (Art. 6 (1) (a) GDPR); Website: https://marketingplatform.google.com.

Data Usage Within the Software ("Solar Miner App")

Our software is designed according to the "Local-First" principle.

  • No User Accounts: We do not create, manage, or store any accounts or profiles of you on our servers. The software is used without registration.
  • Local Data Sovereignty: All configurations (e.g., IP addresses of your ASIC miners, API keys of inverters, or logins for smart home systems) are stored exclusively locally on your own device or within your local network. None of this configuration data is transmitted to our servers. You are responsible for backing up and protecting this local data. The only data the software may send to our servers is the optional, privacy-minimized network telemetry described in the next section — and only while that option is enabled.
  • Third-Party Services: To use the software, you connect it at your own discretion to external interfaces (e.g., crypto mining pools like Braiins Pool, inverter interfaces). Data processing by these third-party providers is subject solely to their respective privacy policies. We have no access to these data streams and assume no responsibility for them.

Data Sharing / Network Telemetry (optional)

To maintain public, anonymized statistics about the SolarMiner network (for example, the number of active nodes, the combined hashrate, and the amount of solar energy generated, as shown on our website), the software can send a small, privacy-minimized telemetry sample to our servers. This option is enabled by default and can be turned off at any time in the software's settings.

  • What is sent (only while enabled): a random, stable device identifier (a UUID generated locally on your device — not your name, e-mail address, or any account); the software version; the referral code bound to your node (not a name); your installed PV capacity (kWp); the number of miners; your combined hashrate (TH/s); the solar energy generated today and in total (kWh); a coarse location (at most your country or a grid cell of roughly 200–500 km — your exact GPS coordinates are never transmitted); and, if a Lightning wallet is configured, its public key (a public identifier, not a private key).
  • What is NOT sent: names, addresses, exact GPS coordinates, e-mail addresses, IP addresses, private keys, wallet balances, funds, or any raw device or inverter data.
  • Purpose: anonymized network statistics only. The data is aggregated across many nodes; we do not use it to identify you individually or for marketing purposes.
  • Legal basis: no consent is required. We rely on our legitimate interest in operating and improving our service and in providing aggregate network statistics (Art. 6(1)(f) GDPR). Because the data is pseudonymous and aggregated, we do not build individual user profiles.
  • How to disable: turn off the data-sharing option in the software's settings ("Data sharing / Send anonymous usage & energy data"). Once disabled, no telemetry is sent. You can change this setting at any time.
  • Storage and deletion: we store each sample together with the node's stable identifier so that repeated samples from the same node are not double-counted. When you disable the option or request deletion, we stop using the data for statistics and delete it within a reasonable period.

Lightning Node & Payment Transactions

  • Integration of phoenixd: The software integrates phoenixd (ACINQ) as a local Lightning node. As the operator of this node, you are solely responsible for managing your channels and funds.
  • Socket Connection: To enable Lightning payments (LNURL), the software establishes a temporary connection to our backend server. This connection is used exclusively for processing payment requests. The user has the option to manually deactivate the socket connection after the program starts, in which case the backend will no longer be contacted (only BOLT12 will remain available).
  • Non-Custodial Service: This is a non-custodial service. We never have access to your private keys or your Lightning funds.
  • Third-Party Liability: The fee structure for Lightning transactions is determined by phoenixd. We have no influence over these fees and assume no liability for transaction costs or errors during processing by the third-party provider.

Modification and updating

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Insofar as terms are defined by law, their legal definitions apply. The following explanations are primarily intended to aid comprehension.

  • Affiliate tracking: In the context of affiliate tracking, links that direct users to websites with products or other offers are logged.
  • Employees: Refers to persons who are in an employment relationship.
  • Inventory data: Includes essential information necessary for the identification and administration of contractual partners, user accounts, profiles, etc.
  • Content data: Includes information generated in the course of creating, editing, and publishing content of all kinds (texts, images, videos).
  • Contact data: Essential information enabling communication (phone numbers, postal addresses, email).
  • Conversion measurement: A procedure used to determine the effectiveness of marketing measures.
  • Meta, communication, and procedural data: Categories containing information about how data is processed, transmitted, and managed.
  • Usage data: Information that captures how users interact with digital products, services, or platforms.
  • Personal data: Any information relating to an identified or identifiable natural person ("data subject").
  • Profiles with user-related information: Automated processing of personal data to evaluate, analyze, or predict certain personal aspects (profiling).
  • Log data: Information about events or activities logged in a system or network (e.g., timestamps, IP addresses).
  • Reach measurement: Web analytics serving the evaluation of visitor flows.
  • Tracking: When the behavior of users can be traced across several online offerings.
  • Controller: The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: Any operation performed on personal data, whether or not by automated means.
  • Contract data: Specific information relating to the formalization of an agreement between parties.
  • Target group formation: (Custom Audiences) Determining target groups for advertising purposes.

Created with free privacy policy generator Datenschutz-Generator.de by Dr. Thomas Schwenke