Privacy notice for the FinWell calculator
This notice applies to the FinWell calculator at finwell-score.de, finwell-award.com and finwell-score.netlify.app. All other HoFT services are covered by our general privacy policy.
Controller
House of Finance and Tech Berlin GmbH, Saarbrücker Straße 36, 10405 Berlin, Germany. Phone: +49 (0)30 43974287-0, email: info@hoft.berlin
Hosting and server logs
The calculator is hosted by Netlify, Inc., 101 2nd Street, San Francisco, CA 94105, USA. Netlify processes data on our behalf under a data processing agreement (Art. 28 GDPR) and uses sub-processors for this, including Amazon Web Services.
When you visit the pages, Netlify processes technically necessary data, in particular your IP address, date and time, the page requested, and browser and device information. The purpose is to deliver the pages and keep them secure. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR). According to Netlify, these logs are kept online for 90 days and archived for up to one year.
Taking part in the FinWell calculator
When you complete the questionnaire, we store:
- your answers to the 5 or 10 questions, and the calculated score and its range
- your age group (not your exact age), your gender and your industry
- the language, the questionnaire version and the date you took part (no time of day)
We do not store your name, email address or IP address with this data. The data is stored with Netlify in Frankfurt am Main (EU). When you submit, it is transmitted via Netlify servers in the USA.
We use this data to show you your score and how it compares with your peer group, and we analyse it for research. We publish results only in aggregated form and never for groups small enough to allow conclusions about individuals. The legal basis is our legitimate interest in research on financial health (Art. 6(1)(f) GDPR).
We delete the survey data as soon as it is no longer needed for this research purpose.
Taking part is voluntary. Because we cannot link stored records to a person, we cannot find, correct or delete an individual record on request (Art. 11 GDPR). If you give us details that let us identify your record unambiguously, we will act on your request.
Transfer to the USA
Netlify, Inc. is certified under the EU-U.S. Data Privacy Framework. Transfers are based on the European Commission's adequacy decision (Art. 45 GDPR). Should the Data Privacy Framework cease to apply, EU standard contractual clauses apply instead (Art. 46(2)(c) GDPR).
No cookies, no tracking
The calculator sets no cookies and stores nothing on your device. It loads no third-party content; fonts are served from our own server. We use no analytics or tracking services.
Only the password-protected admin area, used exclusively by authorised HoFT staff, sets a technically necessary session cookie after login (Section 25(2) TDDDG).
Recipients
The only recipient is Netlify as our processor, together with its sub-processors. We do not sell the data or pass it on to third parties.
Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20). You can object at any time to processing based on legitimate interests (Art. 21 GDPR). To do so, contact info@hoft.berlin.
You can also lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59–61, 10555 Berlin, Germany.