1. Controller
The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) is:
Threeples UG (haftungsbeschränkt)
represented by the managing director Stefan Schmid
Straubinger Straße 34, 80687 München
Email: info@threeples.com
2. Personal data collected
Important: Data that you or your employer record in CloudyBird (tasks, times, absences, personnel files, files, messages, customers, invoices) is processed by us as a processor on the instructions of the respective customer (Art. 28 GDPR, see section 2.3). The customer is the controller for this data; please address any requests to the customer. We forward requests we receive. This privacy policy describes which data we process under our own responsibility.
2.1 Account data
When you register for and use CloudyBird, we collect and process the following personal data:
- Email address (for login and communication)
- Password (stored encrypted, not in plain text)
- First and last name
- Profile picture (optional)
- User settings and preferences
2.2 Usage data
When you access the platform, we process technically necessary data:
- IP address and times of access (protection against misuse, e.g. limiting login attempts)
- Device information (browser, operating system)
- Error reports without content, on our own server
We do not use any analytics or statistics tools.
2.3 Content data (on behalf of our customers)
Content recorded in CloudyBird – e.g. tasks, comments, messages, working hours, absences, personnel files, documents and files (including text recognition), customers, quotes and invoices – is processed by us exclusively on behalf of and on the instructions of the respective customer. The customer determines the purpose, scope and storage period; the basis is the data processing agreement with the customer.
2.4 Calls and meetings
In calls in the chat and in meeting rooms, audio, camera image and screen sharing are transmitted directly between the participants' devices (WebRTC, peer-to-peer) and are end-to-end encrypted (DTLS-SRTP). Microphone and camera access is only requested in the preview or when joining. Calls and meetings are neither recorded nor transcribed; the in-meeting chat, reactions and the waiting room are not stored.
Our server brokers the connection set-up. In doing so, it stores which members took part in a call and when (for chat calls as an entry in the chat history), as well as your organisation's meeting rooms. If no direct connection can be established, e.g. behind corporate firewalls, our self-operated relay server (TURN, at Scaleway in the EU) forwards the encrypted data packets. For this purpose it processes IP addresses and connection data, but cannot decrypt the content and does not store it. The direct connection makes your IP address visible to the other participants.
Guests in meetings take part via a link without an account. For this we process the name entered (visible to the other participants) and the IP address (connection set-up, protection against misuse) and set a technically necessary cookie for the guest session (12 hours at most, readable only by our server). Guest names are not stored – the history shows only the number of guests. The form is protected against automated requests.
Noise suppression and backgrounds (blur, background image) are computed exclusively by your device in the browser; audio and camera image are not transmitted to us or to third parties for this purpose. Your own background images remain in your browser's storage and are not uploaded.
2.5 Payment data
For paid subscriptions, payment data is processed by the payment service provider Mollie. We do not store complete credit card details or other sensitive payment information on our servers. To match payments, we process technical payment references (e.g. payment and subscription IDs) as well as billing-related metadata.
2.6 Contact and support requests
If you write to us using the contact form on the website, via "Help & feedback" in the app or by email to our support address, we store your email address, your name and your company (where provided), the topic you chose, your message and our replies in order to handle and answer your request. For requests from the app, this also includes your organisation, its plan and your roles and, if you choose, the page you had open and the app version (option "Include technical details"). Of email attachments, we only store the file names.
The legal basis is Art. 6(1)(b) GDPR where the request concerns an existing or prospective contract, and otherwise Art. 6(1)(f) GDPR (our legitimate interest in answering requests). There is no double opt-in and no confirmation email; we do not use the details for advertising.
3. Purposes of processing
We process your personal data for the following purposes:
- Performance of the contract: provision and operation of the CloudyBird platform in accordance with the terms of use
- Authentication: ensuring access to your account and protection against unauthorised access
- Communication: sending emails (e.g. password reset, notifications)
- Functionality: provision of the platform features (time tracking, tasks, files, etc.)
- Legal compliance: compliance with statutory retention obligations
- Data security: protecting the platform against misuse and ensuring system stability
4. Legal bases
Your personal data is processed on the following legal bases:
- Art. 6(1)(b) GDPR: performance of the contract of use and pre-contractual measures
- Art. 6(1)(f) GDPR: legitimate interests (e.g. platform security, fraud prevention)
- Art. 6(1)(c) GDPR: compliance with legal obligations (e.g. retention obligations)
5. Recipients and processors
5.1 Hosting provider
The platform is operated by Scaleway in data centres in Amsterdam (the Netherlands); encrypted backups are kept in Paris (France). Scaleway is a European provider without a parent company outside the EU and acts as a processor pursuant to Art. 28 GDPR. A data processing agreement (DPA) is in place. The database, files, search index and application run exclusively there.
Scaleway SAS
8 rue de la Ville l'Evêque
75008 Paris, France (EU)
5.2 Payment service provider
We use Mollie to process payments. Mollie processes payment data as an independent controller. We only transmit the information required for payment processing (e.g. email address, subscription details). To verify payment status, we also process notifications from the Mollie webhook.
Mollie B.V.
Keizersgracht 126
1015 CW Amsterdam, the Netherlands
Further information on data processing by Mollie can be found in Mollie's privacy policy.
5.3 Sending emails
We send system emails (e.g. sign-in codes, password resets, notifications) via Lettermint (the Netherlands, EU) as a processor pursuant to Art. 28 GDPR. The recipient address, subject and content of the respective email are processed.
If an organisation sets up incoming invoices by email, Lettermint receives emails sent to the organisation's inbound address, checks them for spam and passes them on to us. The sender, recipient, subject, content and attachments of these emails are processed. We only import attached e-invoices (XRechnung, ZUGFeRD) into the organisation's incoming invoices; we do not store the rest of the email.
We also send replies to contact and support requests (section 2.6) via Lettermint; Lettermint receives emails sent to our support address and replies to our support emails, checks them for spam and passes them on to us.
5.4 Signing in with Google or Microsoft (optional)
If you choose “Continue with Google”, your browser transmits the sign-in to Google (Google Ireland Limited, Dublin, Ireland). We receive your name, email address and an identifier of your Google account. A transfer to the USA by Google is possible (see section 6). Only when you click “Continue with Google” does your browser load a script from Google and display the Google sign-in; in doing so, Google receives your IP address and technical browser data (Art. 6(1)(a) GDPR, § 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act) – your consent through the click). Without this click, no connection to Google takes place.
If you choose “Sign in with Microsoft” or “Continue with Microsoft”, your browser redirects you to the Microsoft sign-in page (Microsoft Ireland Operations Limited, Dublin, Ireland), where you sign in with your work, school or personal Microsoft account. Microsoft receives your IP address, technical browser data and your login details in accordance with Microsoft's own privacy terms. From Microsoft we receive your name, your email address, the information whether Microsoft has verified the address, and the identifiers of your account and of your directory (organisation); only the account identifier is stored, to link it to your access (Art. 6(1)(b) GDPR – sign-in at your request). A transfer to the USA by Microsoft is possible (see section 6). Without your click on the button, no connection to Microsoft takes place.
5.5 Push notifications (optional)
If you activate push notifications, they are delivered via the push service of your browser or operating system manufacturer. The content is end-to-end encrypted; the service only sees a device identifier, your IP address and the time.
5.6 Embedded videos (optional)
In onboarding content and texts, customers can link videos from YouTube (in privacy-enhanced mode, youtube-nocookie.com) or Vimeo. The player is only loaded when you click “Load video”; only then does your browser load content from the respective provider, which receives your IP address in the process. CloudyBird does not load images from external addresses – they are only displayed as a link.
5.7 AI assistants (optional)
Users can connect their own AI assistants (e.g. Claude or ChatGPT) to CloudyBird. The assistant then accesses the shared areas with the user's permissions; the data goes to the provider of the assistant chosen by the user. Administrators can restrict this in the settings. For each access we log the connection, user, function and result – without content – and delete the log after 90 days.
6. Transfer of data to third countries
The platform itself is operated exclusively in the EU. A transfer to third countries can only occur with the optional functions in sections 5.4 to 5.7 (Google, Microsoft, push services, embedded videos and external images, self-connected AI assistants). It takes place on the basis of the EU-US Data Privacy Framework or the standard contractual clauses (Art. 46(2)(c) GDPR).
Mollie is a Dutch company and processes payment data predominantly within the European Union or the European Economic Area. Should a transfer of data to third countries be necessary in individual cases, it takes place on the basis of appropriate safeguards, in particular the standard contractual clauses (SCCs) pursuant to Art. 46(2)(c) GDPR.
You have the right to request a copy of the standard contractual clauses.
7. Storage period
We store your personal data only for as long as is necessary for the respective purposes:
- Account data: for as long as your account exists; invoices and accounting records relating to subscriptions for the duration of the statutory retention obligations
- Content data (section 2.3): according to the customer's instructions; upon a deletion request from an administrator, we delete all of the organisation's data after 30 days, and backups expire no later than 35 days thereafter
- Abandoned registrations: after 14 days
- Contact and support requests (section 2.6): 24 months after the request has been closed, or earlier on request
- Server logs: rotated by size and usually overwritten after a few days; error reports contain no content
Once the storage periods have expired, the data is deleted unless further storage is required by law or otherwise justified.
8. Your rights as a data subject
You have the following rights with regard to your personal data:
8.1 Right of access (Art. 15 GDPR)
You have the right to obtain information about the personal data we store about you.
8.2 Right to rectification (Art. 16 GDPR)
You have the right to request the rectification of inaccurate data or the completion of incomplete data.
8.3 Right to erasure (Art. 17 GDPR)
You have the right to request the erasure of your personal data, provided there are no statutory retention obligations or legitimate interests to the contrary.
8.4 Restriction of processing (Art. 18 GDPR)
You have the right to request the restriction of the processing of your personal data.
8.5 Data portability (Art. 20 GDPR)
You have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit it to another controller.
8.6 Right to object (Art. 21 GDPR)
You have the right to object to the processing of your personal data if the processing is based on legitimate interests.
8.7 Withdrawal of consent
Where processing is based on consent, you have the right to withdraw it at any time. This does not affect the lawfulness of processing carried out before the withdrawal.
8.8 Right to lodge a complaint
You have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement.
To exercise your rights, please contact us at the email address given above.
9. Cookies and local storage
9.1 Sign-in
For signing in, we set two technically necessary cookies (session and session renewal) that only our server can read (HttpOnly), a short-lived security cookie during the Google Drive import, and, for guests in meetings, a cookie for the guest session (12 hours at most, see 2.4). Legal basis: § 25(2) no. 2 TDDDG, Art. 6(1)(b) GDPR.
9.2 User settings
In your browser's local storage (LocalStorage/SessionStorage) we store: profile and organisation data for display, the session expiry time, a short-lived selection token when choosing an organisation after signing in, language, theme, settings for the sidebar, columns and calendar, open chat windows and, during registration, your email address. This data does not leave your device and is necessary for the function you have requested (§ 25(2) no. 2 TDDDG).
9.3 No tracking cookies
We currently do not use cookies for tracking or analytics purposes. No third-party cookies (e.g. Google Analytics) are set.
10. Data security
We use technical and organisational measures to protect your personal data:
- Encryption: all data transmissions take place over encrypted HTTPS connections (TLS/SSL)
- Password security: passwords are stored using modern hashing methods (not in plain text)
- Access control: access to personal data is only possible for authorised persons
- Regular updates: systems are updated regularly to close security vulnerabilities
- Backups: regular backups ensure the availability of the data
Despite all security measures, complete security cannot be guaranteed. We recommend that you keep your login details safe and do not pass them on to third parties.
11. Obligation to provide data
Providing your personal data is necessary in order to use CloudyBird. Without this data, we cannot grant you access to the platform or provide the contractual services.
12. Automated decision-making
We do not use automated decision-making, including profiling, within the meaning of Art. 22 GDPR.
13. Changes to this privacy policy
We reserve the right to amend this privacy policy in order to adapt it to changes in the legal situation or to changes in our services. The current version can always be found on this page. We will inform you of material changes by email or via the platform.
14. Contact
If you have any questions about data processing or about exercising your rights, you can contact us at any time:
Email: info@threeples.com