Privacy Policy

1. Controller

The controller responsible for processing under Article 4(7) GDPR is:

Marcel Traser (sole proprietor, "Traymo")
Rhönring 127
64289 Darmstadt, Germany
Email: datenschutz@traymo.de

We have not appointed a data protection officer, as we are not obliged to do so (Article 37 GDPR, Section 38 of the German Federal Data Protection Act, BDSG).

Exception: For personal data that landlords record in Traymo about their tenants and other persons (e.g. tenant data, contracts, payments), the respective landlord is the controller. We process this data on their behalf (Article 28 GDPR). Please address enquiries about it to your landlord; we will forward them on request. When deleting your account, you can ask your landlord directly in the app to delete it.

2. Which data we process

Account data: name, email address, phone number, date of birth, home address, profile picture (optional), role. When signing in with Google, additionally the information Google transmits for this purpose (name, email address, profile picture).

Property and tenancy data: address and features of properties (optionally with information on the plot such as area, cadastral parcel, land register and heritable building right), tenancy agreements, payments, service charges, meter readings, handover reports, notices of termination.

Damage reports: description, category, photos, releases by the reporting person.

Communication: chat messages, appointment arrangements, forum posts (under a self-chosen pseudonym), reports of content, requests via the help form (message, category, email address, role, language, app version and platform).

Service provider data: company profile (including logo, description, service area, qualifications, business contact details), services, offers, jobs (including manually recorded ones), the business's customer contacts, reviews; optionally the live location during an assignment.

Reviews: stars, criteria and comment on a completed job, your first name with the initial of your last name, type of service and location of the job, and the business's reply.

Household book: income and expenses you record; visible only to you.

Your own service provider contacts: name, address, phone, email, website, trades and note of businesses you create yourself in the Contact Book (e.g. your regular tradesperson); visible only to you. We only use them to show you the business in the Contact Book and in Smart Acquisition – only you yourself contact the business.

Documents: files you upload or store in Traymo (e.g. contracts, statements, receipts, records), with checksum, deliveries, time of first opening by recipients and approvals (name, time, checksum of the approved version, whether you signed in again beforehand).

Signatures on tenancy agreements: entered name, time, time of re-authentication, checksum of the signed version and – if you sign – the image of your drawn signature. They become part of the signed copy filed with the landlord and the tenants.

Usage and device data: sign-in times, the device's push token, technical logs; in addition, usage statistics without personal reference and cleaned-up error reports from the app (section 10).

Subscription data: plan, status, purchase channel and term (payment itself is handled by Apple or Google).

3. Purposes and legal bases

• Provision of Traymo and performance of the user agreement, including chat, marketplace and management (Article 6(1)(b) GDPR)
• Processing on behalf of tenant data recorded by landlords (Article 28 GDPR; legal basis with the landlord, usually Article 6(1)(b) or (f) GDPR)
• Document storage: storing, delivering to the parties to a tenancy agreement or job and recording approvals and signatures in text form (Article 6(1)(b) GDPR; for landlords' data on their behalf under Article 28 GDPR). Documents are not analysed automatically; an AI analysis only takes place if you start it yourself.
• Sharing released damage photos, descriptions and contact details with service providers (consent, Article 6(1)(a) GDPR)
• Reviews of service providers: publication to signed-in users so that clients can assess businesses before awarding a job. Only the client side of a completed job can submit a review (up to 90 days after acceptance, editable for 30 days, deletable at any time); the first name and initial are shown, never the address or contact details (Article 6(1)(b) and (f) GDPR – legitimate interest in reliable reviews). Reviews can be reported.
• Customer contacts and manually created jobs of service providers: the business is the controller; Traymo processes the data on its behalf (Article 28 GDPR). Visible only to the owner and admins of the business.
• Push notifications about your matters (consent via the device settings, Article 6(1)(a) GDPR); you choose which notifications you receive under "Notifications". We do not send advertising notifications.
• Answering requests via the help form and by email (Article 6(1)(b) GDPR or legitimate interest in answering them, point (f))
• Security, prevention of misuse, moderation and improvement of the service, including usage statistics and error reports (legitimate interest, Article 6(1)(f) GDPR; section 10)
• Compliance with legal obligations, e.g. retention of business records and business emails (Article 6(1)(c) GDPR)

4. Who can see your profile and contact data

Only your name, profile picture, role and, where applicable, your company are public within Traymo (for signed-in users).

Email address, phone number, date of birth and home address are protected. They can only be seen by:
• you,
• people you have a relationship with in Traymo: your landlord or your tenants and the co-managers of the property, the parties to a tenancy agreement, the client and the commissioned service provider of a job,
• colleagues at your company in Traymo.

Co-residents or neighbours only see each other's name and profile picture.

5. Damage reports and marketplace

Damage reports initially only go to the landlord and their co-managers.

Tender: If the landlord puts a job out to tender, service providers only see the category, postcode and town as well as the photos and description released by the reporting person before the job is awarded. Release is given separately for each photo and for the text and can be withdrawn at any time in the damage view. Without release, neither image nor text is transmitted. Only the commissioned service provider receives the exact address and contact details; tenants' contact details only under the following conditions.

Direct contact with the tradesperson: The commissioned business only receives a tenant's name, phone number and email address if the tenant has consented (Article 6(1)(a) GDPR) and the landlord as client has agreed. Neither can decide for the other. The tenant is then added to the job chat and can arrange appointments. Consent can be given as a default for damage in one's own flat or per damage report and can be withdrawn at any time; we store the time and type of consent as evidence. When either side withdraws or the job is completed, the business's access to the contact details ends. Under "Marketplace Settings", the tenant can see which businesses have received their contact details and for which period.

Requests to service providers: Businesses registered with Traymo receive the landlord's requests for matching tenders as a message in the Traymo chat; they can switch off receiving them in the company settings. We do not contact unregistered businesses; landlords can send them a request with a personal request link themselves (from their own email program, by text message or via the share function of their device). To enable landlords to reach the business, at their request we determine the business's phone number and website via the Google Maps Platform and read the business email address from the legal notice of the website. For each request, we store the name of the business, the identifier from the map search, the chosen channel (email, text message, share) and – only when sent by email – the email address used, so that an offer submitted in response can be assigned and duplicate requests avoided (legitimate interest, Article 6(1)(f) GDPR). These businesses only receive emails from Traymo about the status of an offer with their consent (section 6). We do not store phone numbers. The data is deleted together with the listing. The request only contains the released contents of the tender and the landlord's contact details, no contact details of tenants.

Photos: For damage and listing photos, we remove the metadata (e.g. GPS coordinates, device information) before uploading. Please do not upload photos showing identifiable persons, other people's property or licence plates.

Retention: Releases and listings are stored with the damage report and deleted with it.

6. Service providers without a Traymo account

Unregistered service providers can submit an offer, arrange appointments and write in a job chat via a personal link without an account. In doing so, we process the information from the form (company name, contact person, email, phone, offer, messages) to carry out the request or job (Article 6(1)(b) GDPR).

We only send email notifications (acceptance or rejection of the offer, appointment proposals and confirmations, new messages in the job chat) if the business has expressly agreed in the form – the checkbox is not pre-ticked (consent, Article 6(1)(a) GDPR). We store whether and when consent was given. Consent is voluntary and can be withdrawn at any time with effect for the future: via the unsubscribe link in every email or in the form. Without consent we do not write to the business; it sees the current status via its personal link, and the client informs it directly. The data is deleted when the listing is deleted, unless there is a retention obligation.

7. AI features (Google Vertex AI, EU region)

For the automatic assessment of damage reports (including photos), offer analyses, contract analyses and the chat assistant, we transmit the necessary content to Google Vertex AI (Google Cloud, processing in the EU). Under Google Cloud's contractual terms, the data is not used to train models. We store the results in Traymo.

Document storage: In response to your question, the assistant can retrieve the list of your documents (title, category, date, sender, delivery and approval status). The assistant does not read the content of the files.

The automatic damage analysis is enabled by default and can be switched off by the landlord in the Marketplace Settings. The legal basis is the performance of the contract or our legitimate interest in fast processing (Article 6(1)(b) and (f) GDPR). No solely automated decision within the meaning of Article 22 GDPR takes place.

8. Community, neighbourhood and reports

In the forum, you only appear under a self-chosen pseudonym; only Traymo knows which account is behind it. For the "Neighbourhood" category, we store the location of your rented property with your posts, rounded to about 1 km, and compare it with the location of other tenants (radius of about 1 km); it is not displayed.

Content and chats can be reported. We evaluate reports together with the reported content for moderation and delete them after the review is completed, at the latest after 12 months.

9. Live location of tradespeople

During an ongoing job, tradespeople can voluntarily share their location so that the client can see their journey. It is only visible to the client side (the client, for landlords their co-managers and involved tenants) and the tradesperson themselves – not to colleagues or company management; it is not used to monitor performance or behaviour.

The location is only transmitted while the job page is open, updated about every minute and for a maximum of three hours at a time. Only the last position is stored (no history). It is deleted as soon as sharing ends, the page is left, or the job is completed or handed over, at the latest 15 minutes after the last update.

For the estimated time of arrival, our servers transmit the tradesperson's position and the coordinates of the property to the Google Maps Platform (Routes API), at most every two minutes or after a distance of 300 metres. Only the result (arrival time, distance) is stored; it is deleted together with the location. The map itself comes from the German Federal Agency for Cartography and Geodesy (see section 11).

The legal basis is consent (Article 6(1)(a) GDPR); it can be withdrawn at any time by switching sharing off.

10. Usage statistics and error reports

To see which features are used and to fix errors quickly, we use our own solution – no Google Analytics, no Crashlytics, no cookies.

Usage statistics: While in use, the app counts in memory which areas and features are accessed (e.g. "damage reported") and transmits these figures in bundled form to our servers. Only daily totals per feature, user role (landlord, tenant, service provider) and platform (web, Android, iOS) are stored – without user ID, IP address or device ID. It is not possible to draw conclusions about individual persons.

Error reports: If an error occurs in the app, it transmits the error message, technical trace data (stack trace), app version, platform and your role. Before storing, we remove email addresses, phone numbers, identifiers and access keys; errors of the same kind are grouped and counted. We do not store any link to your account.

The legal basis is our legitimate interest in a stable and user-friendly service (Article 6(1)(f) GDPR). Nothing is stored on your device for this. You can switch both off at any time in the app under "Privacy & statistics" (objection, Article 21 GDPR). The data is stored in Google Firebase (storage location EU, server functions in Frankfurt); only administrators authorised by us have access.

11. Services used and recipients

Google Firebase (Google Ireland Ltd.): provision of the web app (hosting), sign-in, database (storage location EU), file storage, server functions (Frankfurt), push notifications, misuse protection (App Check in the apps). The web app loads the Firebase program libraries from Google servers (part of the Firebase service). We serve fonts and all other program files ourselves; Google Fonts and Google's sign-in script are not loaded.

Sign in with Google: If you choose "Sign in with Google", a Google window opens; Google then transmits your name, email address and profile picture to us. Google's privacy policy also applies.

Google Maps Platform (Google Ireland Ltd.; Google is an independent controller for this):
• Address entry and radius search for service providers: our servers transmit search terms or coordinates to Google, not your IP address.
• Map in the service provider search: it is only loaded once you agree ("Load map"). Your device then retrieves the map directly from Google; Google receives, among other things, your IP address and device information. The legal basis is your consent (Article 6(1)(a) GDPR, Section 25(1) of the German Telecommunications Digital Services Data Protection Act, TDDDG). If you have chosen "Always load the Google map", you can withdraw this at any time with "Hide Google map" on the map.
• Arrival time for the live location (see section 9).

Maps in the location profile and for the live location: your device loads the map images directly from the German Federal Agency for Cartography and Geodesy (sgx.geodatenzentrum.de); your IP address is transmitted in the process. The map position comes from OpenStreetMap, not from Google.

Email: We send system emails relating to an ongoing matter (invitations, status of a submitted offer, messages in the job chat – to businesses without a Traymo account only with consent, see section 6) and replies to enquiries via our email provider STRATO GmbH (Otto-Ostrowski-Straße 7, 10249 Berlin, Germany) as processor. We forward messages from the help form to our mailbox at STRATO. We archive business emails using STRATO's email archiving service, which is operated by Dropsuite Ltd. (Singapore) as a further processor.

Geodata: For location information on a property, we query public services using coordinates or the address (including the German Federal Agency for Cartography and Geodesy, the Federal Institute of Hydrology, the German Environment Agency, the federal states' geoportals and land value portals) as well as Nominatim of the OpenStreetMap Foundation (United Kingdom; adequacy decision of the European Commission).

Index rent: For the calculation, we retrieve consumer price indices from the German Federal Statistical Office (without personal data).

Apple Push Notification service (Apple Inc.): delivery of push notifications on iPhone and iPad; a device token and the notification text are transmitted to Apple. Notifications only contain the occasion (e.g. sender and message preview, "contract change for approval"), no amounts or contract contents.

RevenueCat, Inc. (USA): management of subscriptions (subscription status, purchase history, device ID); no payment data.

Apple and Google: processing of in-app purchases in accordance with their own privacy policies.

Other users: within the visibility described in sections 4 and 5.

12. Transfers to third countries

Google LLC, Apple Inc. and RevenueCat, Inc. are certified under the EU-US Data Privacy Framework; transfers to the USA take place on the basis of the European Commission's adequacy decision or standard contractual clauses.

Dropsuite Ltd. (Singapore) processes archived emails on the basis of EU standard contractual clauses (Article 46(2)(c) GDPR).

13. Retention periods

• Account: until deletion (Edit Profile → Delete account). We then immediately remove your profile, contact details, login, contacts, personal expenses, appointments, invitations, open tenders and offers as well as the subscription record at RevenueCat. Beforehand, you can export your data. Please cancel an active subscription yourself where you purchased it (App Store or Google Play); the "Subscription" page takes you there via "Manage or cancel subscription".
• What other parties lawfully need is retained without a link to your account: tenancy documents with the landlord (who is responsible for them), completed jobs and invoices with the other contracting party (at most 10 years after completion) and chat messages under "Deleted user" (direct chats at most 3 years after the last message, job chats 6 months after the end of the warranty period). Forum posts and reviews remain anonymised unless you choose to delete them when deleting your account.
• If a landlord deletes their account, their tenants with a Traymo account receive copies of their tenancy documents; the landlord's other data is deleted.
• Documents: until you delete them or until your account or the property is deleted (a download of all documents as a ZIP file is possible beforehand). Copies you have delivered to others remain with the recipients. For receipts and tenancy documents, Traymo shows retention recommendations; nothing is deleted automatically.
• Deletion record (without content) and proof of your consent to the Terms and Privacy Policy: 3 years, pseudonymised.
• Support requests in Traymo and reports: at most 12 months. Email correspondence in the archive: until the end of the statutory retention period (6 or 10 years), where one applies. Server logs: 30 days.
• Usage statistics (daily totals without personal reference): 24 months. Error reports: 90 days after the last occurrence.
• Cached AI evaluations (contract, property and offer analyses): 180 days after creation. Daily counters to prevent abuse (e.g. number of address searches): 2 days.
• Consent of external businesses to email notifications: together with the listing or job.
• Push: device token and app language until signing out on the device, deletion of the account or 90 days after the device was last used.
• Documents relevant under tax and commercial law: 6, 8 or 10 years.

14. Storage on your device

We only store on your device what is technically necessary for the service (sign-in status, push token, cache for search results and settings such as theme, language, selected map type and your decision on the Google map; Section 25(2) TDDDG). We do not use tracking or advertising cookies; usage statistics and error reports (section 10) do not store anything on your device either. A cookie banner is therefore not necessary.

15. Your rights

You have the right of access (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20) and to object to processing based on legitimate interests (Article 21 GDPR). You can withdraw consent at any time with effect for the future, e.g. photo and contact releases in the damage view. You switch off usage statistics and error reports under "Privacy & statistics".

To do so, please contact: datenschutz@traymo.de. We respond within one month.

16. Right to lodge a complaint

You can lodge a complaint with a data protection supervisory authority, in particular in the federal state of your residence or of our place of business. The authority responsible for us is the Hessian Commissioner for Data Protection and Freedom of Information (Der Hessische Beauftragte für Datenschutz und Informationsfreiheit), Postfach 31 63, 65021 Wiesbaden, Germany, https://datenschutz.hessen.de. An overview of all supervisory authorities can be found at https://www.bfdi.bund.de.

17. Data security

All connections are encrypted (TLS). Access to data is technically restricted to the persons who may see it under sections 4 and 5. Files in the document storage cannot be accessed via links, only via server functions that check authorisation on every access; each file receives a checksum with which changes can be detected. The Google Cloud infrastructure is certified, among other things, to ISO 27001.

18. Changes

We adapt this Privacy Policy when our service or the legal situation changes. The current version is available in the app at any time; we will inform you of significant changes. The German version is legally binding; translations are provided for information.