Privacy Policy for Use of the Betreuung24 PartnerApp

As of: March 2026 · Art. 13, 14 GDPR

1. Controller

2. Purposes of Data Processing

We process personal data of users (Referral Partners) in order to:

• enable registration and use of the app,
• carry out participation in the referral and brokerage programme,
• settle commissions and bonuses,
• manage user accounts,
• detect and prevent misuse and fake leads,
• fulfil statutory retention obligations.

3. Categories of Personal Data

3.1 Data of the Referral Partner

• name
• contact details
• bank details / payout data
• referral history
• app usage data
• device / access logs (IP address, time stamp)

3.2 Data of Referred Prospects (Lead Data)

The Referral Partner submits exclusively:

• name
• telephone number
• e-mail address

4. Legal Bases of Processing

4.1 For data of the Referral Partner:

• Art. 6(1)(b) GDPR (user contract / remuneration settlement)
• Art. 6(1)(f) GDPR (prevention of misuse / system stability)
• Art. 6(1)(c) GDPR (statutory obligations)

4.2 For data of prospects

The disclosure is made by the Referral Partner on the basis of a freely given, informed and explicit consent obtained by them from the data subject → Art. 6(1)(a) GDPR

From the moment the data is transmitted, BEX GmbH is the independent controller.

5. Recipients of the Data

• Betreuung24 Sp. z o.o. (brokerage partner)
• IT service providers (hosting, app operations)
• payment service providers
• tax advisors / accounting within the scope of statutory obligations
• authorities in the case of legal obligations

Transfers to third countries take place only where an adequate level of data protection exists or where standard contractual clauses are used.

6. Obligations of the Referral Partner (GDPR Compliance)

Until the prospect data is transmitted, the Referral Partner is the independent controller. They are obliged to

• obtain valid, documented consent,
• provide evidence of such consent on request,
• not transmit any special categories of personal data,
• transmit only true and necessary contact details.

In the event of data protection breaches, the following apply:

• no commission entitlement,
• possible suspension of the account,
• obligation to indemnify BEX GmbH.

7. Storage Period

We store personal data

• for as long as is necessary to carry out the programme,
• for 6–10 years for tax evidence obligations under HGB / German Fiscal Code,
• usage data generally for a maximum of 24 months.

Prospect data are deleted as soon as

• no business relationship arises, or
• statutory retention periods have expired.

8. Rights of Data Subjects

Data subjects have the right to:

• access (Art. 15 GDPR)
• rectification (Art. 16 GDPR)
• erasure (Art. 17 GDPR)
• restriction (Art. 18 GDPR)
• data portability (Art. 20 GDPR)
• withdrawal of consent (Art. 7 GDPR)
• lodging a complaint with a supervisory authority (Art. 77 GDPR)

9. Withdrawal of Consent (Prospects)

The prospect may withdraw their consent at any time vis-à-vis BEX GmbH. A withdrawal does not affect the lawfulness of processing carried out up to that point.

10. Automated Decision-Making

No automated decision-making or profiling takes place.

11. Security

We take technical and organisational measures to ensure a level of protection appropriate to the risk.

12. Cookies and Tracking

The Betreuung24 app uses no cookies and no tracking.

We do not collect any analytics data about your usage behaviour.

13. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy. The current version is always available in the app and on our website.

14. Contact for Data Protection Enquiries