Privacy Policy

1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on data protection, please refer to our privacy policy set out below this text.

Data collection on this website

2. Hosting

We host the content of our website with the following provider:

External hosting

This website is hosted by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (registration court Ansbach, HRB 6089) (hereinafter the “host”). The personal data collected on this website is stored on the host's servers. This may primarily include IP addresses, contact enquiries, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.

The external hosting is carried out for the purpose of performing our contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). We have concluded a data processing agreement (DPA) with the host in accordance with Art. 28 GDPR; processing takes place in data centres within the European Union.

3. General information and mandatory disclosures

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various items of personal data are collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the internet (e.g. when communicating by email) can have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information on the controller

The controller responsible for data processing on this website is:

Boomerent GmbH
represented by the managing directors Stephan Thiel and Dr. Ron van de Sand
c/o Reaktor Wildau
Schmiedestraße 2A
15745 Wildau
Germany

Commercial register: HRB 19766, Cottbus Local Court
Phone: +49 174 4411117
Email: [email protected]

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.). A statutory obligation to appoint a data protection officer under Art. 37 GDPR, § 38 BDSG does not currently exist given Boomerent's current company size, according to our assessment; we review this regularly and adjust this statement if necessary.

Storage duration

Unless a more specific storage period is stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for deletion or revoke consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion takes place once these reasons no longer apply. Specifically, the following storage periods apply in particular: user accounts and the personal data contained therein are deleted upon deletion of the account by you or at the latest 30 days after a corresponding request; uploaded lease agreements, service-charge statements and receipts are deleted as soon as they are no longer required for the use of the respective function, but at the latest upon deletion of the associated user account; backups are deleted or overwritten as part of our backup rotation; where invoices are created, the retention periods under commercial and tax law pursuant to § 257 HGB and § 147 AO (generally six or ten years) apply. Anonymised data, for which re-identification is excluded according to the state of the art and which therefore no longer allows any conclusions to be drawn about you, is not subject to the deletion periods stated above; we may use such data for internal analysis and benchmarking purposes for an unlimited period, even beyond the end of the respective contractual relationship, as this no longer constitutes personal data within the meaning of Art. 4(1) GDPR.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases (Art. 21 GDPR)

If data processing is carried out on the basis of Art. 6(1)(e) or (f) GDPR, you have the right at any time to object, on grounds relating to your particular situation, to the processing of your personal data. The respective legal basis on which processing is based can be found in this privacy policy. If you lodge an objection, we will no longer process your affected personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims (objection pursuant to Art. 21(1) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or the place of the alleged breach. This right to complain exists without prejudice to any other administrative or judicial remedy.

The competent supervisory authority is:
Die Landesbeauftragte für den Datenschutz und für das Recht auf Akteneinsicht Brandenburg
Stahnsdorfer Damm 77
14532 Kleinmachnow
www.lda.brandenburg.de

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, correction and deletion

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, where applicable, a right to correction or deletion of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. To do so, you can contact us at any time. The right to restriction of processing exists in the following cases: if you dispute the accuracy of your personal data stored with us; if the processing of your personal data was or is unlawful; if we no longer need your personal data but you require it to exercise, defend or assert legal claims; or if you have lodged an objection pursuant to Art. 21(1) GDPR.

SSL/TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries you send to us as the site operator, this site uses SSL/TLS encryption. You can recognise an encrypted connection by the fact that the browser's address line changes from “http://” to “https://” and by the lock symbol in your browser line. In addition to transport encryption, we implement the following technical and organisational measures (Art. 32 GDPR): encryption of stored data at our hosting partners, a role-based access authorisation concept that limits access to personal data to the necessary extent, as well as a regular review of the processors used.

4. Data collection on this website

Enquiry by email

If you contact us by email, your enquiry including all personal data resulting from it (name, enquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR insofar as your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this was requested.

Registration on this website

You can register on this website to use additional functions on the site. We use the data entered for this purpose only for the use of the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject the registration.

For important changes, such as to the scope of the offer or in the case of technically necessary changes, we use the email address provided during registration to inform you in this way.

The data entered during registration is processed for the purpose of carrying out the usage relationship established by the registration and, where applicable, for initiating further contracts (Art. 6(1)(b) GDPR).

The data collected during registration is stored by us for as long as you are registered on this website and is subsequently deleted. Statutory retention periods remain unaffected.

Processing of uploaded documents (commissioned processing)

Insofar as you, as a customer, upload documents (e.g. lease agreements, service-charge statements) that contain personal data of third parties, we process this exclusively on your behalf and according to your instructions. You remain responsible under data protection law for this content; Boomerent acts as a processor within the meaning of Art. 28 GDPR in this respect. On request, we will conclude a data processing agreement (DPA) with you.

Checklist request (lead magnet)

When you request our free service-charge checklist, we process your email address in order to send you the checklist. In addition, we as the provider receive an internal copy of your request (via BCC to the founders) so that we can see who is interested in our offering. No automatic newsletter is sent.

The checklist is sent on the basis of Art. 6(1)(b) or (f) GDPR. The internal record of who requested the checklist is based on our legitimate interest in approaching and evaluating prospective customers (Art. 6(1)(f) GDPR). You can object to this processing at any time and request deletion of your data (Art. 21 GDPR) — informally to [email protected]. Delivery is handled via the service provider Resend (see section 6 d).

5. Cookies and local storage

Without your consent, this website does not use any tracking cookies or cookies for advertising purposes; the consent-based website tracking described below (Google Analytics) remains unaffected by this. We use exclusively technically necessary storage mechanisms (localStorage) to store your language settings and cookie consent preferences. This data is stored exclusively locally in your browser and is not transmitted to third parties.

The following data is stored locally:

• Language preference (German/English)
• Your cookie consent (cookie “br_consent”)
• Authentication token (after login, for the duration of the session)

The legal basis for the processing is Art. 6(1)(f) GDPR (legitimate interest in the technically error-free provision of the website).

Website tracking (only with consent)

If you select “Accept all” in our cookie banner, Google Analytics 4 is loaded, a web analytics service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google Analytics 4 uses cookies (including “_ga”) to analyse your use of this website. The analytics script is only loaded after you have given your consent in the cookie banner; without your consent, no data is transmitted to Google (Google Consent Mode v2). In particular, the pages visited, the time spent, an approximate location based on the truncated IP address, the device and browser used, as well as referrer information are recorded. The IP address is truncated by Google and not merged with other data held by Google; the analysis is carried out pseudonymously and serves exclusively for statistical analysis and the improvement of our online offering.

The legal basis for the use of Google Analytics is your consent pursuant to Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG. You can revoke your consent at any time by selecting “Decline” in the cookie banner or by deleting the consent cookie “br_consent”. In the course of using Google Analytics, personal data may be transferred to Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework; we base the transfer to the USA primarily on the European Commission's adequacy decision (Art. 45 GDPR), supplemented by standard contractual clauses (Art. 46(2)(c) GDPR). For more information, please see Google's privacy policy at policies.google.com/privacy.

6. Hosting and technical infrastructure

To operate this platform, we work with several specialised service providers. Below, we transparently inform you about all the companies involved, their role and the location of the data processing.

a) Domain registrar: INWX

The domain boomerent.de is registered and managed through INWX (InterNetworX Ltd., Berlin, Germany). INWX is a German domain registrar. No personal data beyond what is required for DNS resolution is transmitted to INWX.

b) Frontend (in-house development), hosting via Hetzner

The frontend (the user interface) of this application is an in-house development and is hosted and delivered via Hetzner Online GmbH (cf. Section 2) in data centres within the European Union. When the website is accessed, the usual connection data (IP address, browser type, timestamp) is processed. In individual areas, we additionally use services from Lovable (Lovable Technologies Ltd., lovable.dev); the AI processing via the Lovable AI Gateway is described separately in Section 8.

c) Backend, database & file storage: Supabase

The database (PostgreSQL), user authentication, file storage (uploaded lease agreements, service-charge statements, receipts) and serverless backend functions (Edge Functions) are operated via Supabase (Supabase Inc., supabase.com). The data is stored and processed in EU data centres (AWS Frankfurt, eu-central-1). Data transmission is exclusively encrypted (TLS). For this purpose, Supabase uses Amazon Web Services (AWS EMEA SARL or Amazon Web Services, Inc.) as a sub-processor for the physical server infrastructure; the data processing agreement in place with Supabase also covers the use of AWS as a sub-processor.

d) Email dispatch: Resend

For sending transactional emails (e.g. objection letters to landlords, reminders to service providers) we use Resend (Resend Inc., resend.com). In doing so, the recipient's email address, the subject and the message content are transmitted. Processing is based on Art. 6(1)(b) GDPR (performance of a contract). Resend Inc. is based in the USA; we base the transfer primarily on the European Commission's adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR), as Resend is certified under the procedure provided for this, supplemented by standard contractual clauses (Art. 46(2)(c) GDPR).

e) Payment processing & invoicing: Lexware

Payment processing is carried out via our own system, without engaging an external payment service provider. For invoicing, we use the software Lexware (Haufe-Lexware GmbH & Co. KG, Freiburg, Germany). In Lexware, the personal data required for invoicing (including name, address, invoice data) is processed and stored. Processing is based on Art. 6(1)(b) GDPR (performance of a contract) and Art. 6(1)(c) GDPR (retention obligations under commercial and tax law). A data processing agreement pursuant to Art. 28 GDPR exists with Haufe-Lexware.

f) Customer management (CRM): HubSpot

To manage customer and user data, we use HubSpot (HubSpot Inc., USA, or HubSpot Ireland Ltd.) as a CRM system. In HubSpot, personal data of our users and customers (including name, contact details, communication history) is managed. Processing is based on Art. 6(1)(b) GDPR (performance of a contract) or Art. 6(1)(f) GDPR (legitimate interest in efficient customer management). HubSpot is certified under the EU-US Data Privacy Framework; we base the transfer to the USA primarily on the European Commission's adequacy decision (Art. 45 GDPR), supplemented by standard contractual clauses (Art. 46(2)(c) GDPR). A data processing agreement pursuant to Art. 28 GDPR exists with HubSpot.

g) Business email: Google Workspace

For our business email communication ([email protected]) we use Google Workspace (Google Ireland Limited). A data processing agreement pursuant to Art. 28 GDPR exists with Google. Insofar as personal data is transferred to the USA in this context, this is done on the basis of the EU-U.S. Data Privacy Framework (Art. 45 GDPR) or the EU standard contractual clauses (Art. 46(2)(c) GDPR). More information: policies.google.com/privacy.

We have concluded data processing agreements (DPAs) with our hosting and cloud service providers. This ensures that they process the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

7. Authentication via third-party providers

We offer the option of logging in to our platform via Google OAuth (Google LLC, USA). When you use this function, the following data is transmitted from Google to us:

• Email address
• Name (if stored in the Google profile)
• Profile picture URL (if available)

Processing is based on Art. 6(1)(b) GDPR (performance of a contract) or Art. 6(1)(a) GDPR (consent). Google LLC is certified under the EU-US Data Privacy Framework; we therefore base the transfer to the USA primarily on the European Commission's adequacy decision (Art. 45 GDPR), supplemented by standard contractual clauses (Art. 46(2)(c) GDPR). For more information on data protection at Google, please see policies.google.com/privacy.

Registration and login (Supabase, Clerk in future)

For registration and login in our application, we currently use authentication from Supabase (see Section 6 c)). In doing so, we process in particular your email address, your name (if provided) and an encrypted password or login token. This data is processed in EU data centres (Frankfurt).

We plan to handle authentication via the service Clerk (Clerk, Inc., USA) in the future. Once this service is in production, we will update this privacy policy; a data transfer to the USA will then take place on the basis of the EU-U.S. Data Privacy Framework (Art. 45 GDPR) or the EU standard contractual clauses (Art. 46(2)(c) GDPR). More information: clerk.com/legal/privacy.

8. Use of AI-supported functions

Our platform uses AI-supported services to analyse and process your documents. The AI processing is carried out via the Lovable AI Gateway, which forwards requests to the AI provider Google (Google LLC, USA). The models used are Google Gemini 2.5 Flash and – for certain functions – Anthropic Claude (Anthropic Ireland Ltd. or Anthropic PBC, USA). OpenAI (OpenAI Ireland Ltd. or OpenAI L.L.C., USA) is not currently used in production; however, the Lovable AI Gateway is technically designed so that requests could also be forwarded to OpenAI. If and as soon as another or additional model provider is used in production, we will update this section accordingly.

In addition, we are gradually migrating the AI processing to Microsoft Azure (Microsoft Ireland Operations Limited); the processing takes place in data centres within the EU. The services used are Azure AI Document Intelligence (text recognition/OCR), Azure AI Content Understanding and AI models from Anthropic (Claude) provided via Microsoft Azure. With this processing too, your content is not used to train AI models and is not stored permanently.

The following functions use AI processing:

• Extraction of lease-agreement data from uploaded PDFs (OCR)
• Analysis of service-charge statements
• Calculation and review of CPI-based rent adjustments
• Review of rent invoices and rent-increase letters
• Detection of tenant obligations from contracts
• Generation of tenant letters (objections, reminders)

When using these functions, the documents you upload are transmitted via the Lovable AI Gateway to Google Gemini or Anthropic Claude, processed there and the results returned to you. The data is not used by Google or Anthropic to train AI models and is not stored permanently. Lovable itself may retain AI request and response content for a period of up to 90 days for debugging and monitoring purposes, provided the corresponding activity logging function is enabled.

The language models used constitute AI systems within the meaning of Art. 3(1) of Regulation (EU) 2024/1689 (AI Act). Boomerent uses these systems as a deployer within the meaning of Art. 3(4) of the AI Act. Based on our assessment, the functions used do not fall under the prohibited practices of Art. 5 of the AI Act. Classification as a high-risk AI system under Art. 6 in conjunction with Annex III of the AI Act is not applicable at present, as the systems do not make any creditworthiness assessments or access decisions regarding essential private services, but rather serve to support tenants in reviewing their own contractual documents; we review this assessment regularly. Pursuant to Art. 50 of the AI Act, we label automatically generated text drafts (e.g. objection letters) as such before they are sent by you. Within the framework of Art. 4 of the AI Act, we ensure that staff involved in the operation of these systems have the necessary AI literacy.

The AI-supported analyses (e.g. review of rent increases, CPI calculations) serve to support your own decision. Letters generated by the platform (e.g. objections) are shown to you as a draft for your own review and are not sent without your active confirmation. Therefore, no solely automated decision-making within the meaning of Art. 22 GDPR takes place that produces legal effects concerning you or similarly significantly affects you.

Processing is based on Art. 6(1)(b) GDPR (performance of a contract). Insofar as processing is carried out by Google, we base the transfer to the USA primarily on the European Commission's adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR), as Google LLC is certified under the procedure provided for this; in addition, we have agreed standard contractual clauses (Art. 46(2)(c) GDPR). For processing by Anthropic, we base the transfer to the USA on standard contractual clauses (Art. 46(2)(c) GDPR), as Anthropic is, to our knowledge, not continuously certified under the Data Privacy Framework. If requests are forwarded to OpenAI in the future, we will likewise base the transfer to the USA on standard contractual clauses (Art. 46(2)(c) GDPR). Processing via Microsoft Azure takes place within the EU (Microsoft Ireland Operations Limited); no third-country transfer takes place in this respect.

9. Email communication

For sending emails (e.g. objection letters, service-provider reminders) we use the service Resend (Resend Inc., USA). In doing so, the recipient's email address and the message content are transmitted to Resend. Processing is based on Art. 6(1)(b) GDPR. More information: resend.com/legal/privacy-policy.

Details on the legal basis for the transfer to the USA can be found in Section 6 d) of this privacy policy.

10. External content and media

Map display (OpenStreetMap)

To display our location, we embed map tiles from OpenStreetMap (OpenStreetMap Foundation, St John's Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom). When the map is loaded, your IP address is transmitted to the OpenStreetMap servers; this is technically necessary so that the tiles can be delivered to your browser. No cookies are set. The legal basis is our legitimate interest in an appealing presentation of our location (Art. 6(1)(f) GDPR). More information: openstreetmap.org/copyright.

Images (Unsplash)

Individual images are delivered via the content delivery network of Unsplash (Unsplash Inc., Canada). In doing so, your IP address is transmitted to Unsplash. The legal basis is our legitimate interest in fast and reliable image delivery (Art. 6(1)(f) GDPR). More information: unsplash.com/privacy.

11. Overview of data locations

The following table provides an overview of where your data is stored:

12. Your rights at a glance

You have the following rights regarding your personal data:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to withdraw consent given (Art. 7(3) GDPR)
• Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)