Data privacy

Effective as of: September 8, 2026

1. General

This privacy policy informs you about the type, scope, and purpose of the processing of personal data (hereinafter referred to as 'data') within our website and its associated web pages, features, and content. Regarding the terminology used, such as 'processing' or 'controller,' we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

2. Controller

minimum energy GmbH
Siebengebirgsallee 60
50939 Köln, Germany
Represented by: Dr. Leander Kotzur, Stanley Risch, Dr. Felix Kullmann
Contact: support@minimum.energy

3. Types of Processed Data
  • Inventory data (e.g., name, company, role).
  • Contact data (e.g., email address).
  • Communication data (e.g., messages to the AI assistant and to our support team).
  • Content data (e.g., building and energy data, project data, optimization results).
  • Usage data (e.g., features used, access times).
  • Payment data (e.g., billing address, payment status, invoice references).
  • Technical data (e.g., IP address, browser, device information).
  • Authorization data (e.g., registration data of connected third-party applications, token checksums, granted permissions).
4. Purpose of Processing
  • Provision of the online offer, its functions, and content.
  • Responding to contact requests and communicating with users.
  • Security measures.
  • Product analysis and improvement.
  • Provision of interfaces for third-party applications you authorize (e.g., AI assistants).
  • Provision of the AI assistant inside the application.
5. Used Technologies
  • SSL Encryption (HTTPS): To protect the data transmitted via our website, we use SSL encryption.
  • Cookies: Our website uses 'cookies' to improve the usage of our offerings.
6. Consent Management (CookieScript)

To obtain and document your consent for non-essential storage access on your device (cookies as well as local/session storage), we use the service CookieScript by CookieScript UAB, Lithuania. CookieScript presents a banner with the available consent categories and stores your decision locally in the cookie "CookieScriptConsent" (lifetime: approx. 1 month). Only consent-requiring third-party components are loaded after you have granted the relevant consent — specifically Sentry Session Replay (category "Performance") and Featurebase (category "Functionality"); see the respective sections. Third-party services operating on a different legal basis (performance of contract or legitimate interest) are not affected. You may change your decision at any time — directly via the button below or (inside the signed-in application) via the "Cookie settings" menu in the sidebar.

Legal bases: For storing the consent cookie on your device, § 25(2)(2) TTDSG (strictly necessary for the explicitly requested consent-management service). For processing the consent record contained therein, Art. 6(1)(c) GDPR (legal obligation to document consent pursuant to Art. 7(1) GDPR).

7. Server-side Consent Audit Log

To fulfill our obligation of proof under Art. 7(1) GDPR, we additionally record your consent decisions on the server side in an immutable log. The following are recorded: user ID, email address (at the time of the decision), action (accept/reject), selected categories, timestamp, and an identifier of the banner installation shown to you. Anonymous decisions are not logged.

Legal basis: Art. 6(1)(c) GDPR (statutory obligation of proof under Art. 7(1) GDPR).

Retention: Each entry is deleted three years after its validity ends — that is, three years after contract termination or, if you revoke or change your consent earlier, three years after that point (aligned with § 195 BGB and § 31 OWiG). In case of an ongoing dispute, the period is extended accordingly. We review individual deletion requests under Art. 17 GDPR on a case-by-case basis.

8. Mixpanel

To analyze and improve the user experience on our platform, we use the analytics service Mixpanel, operated by Mixpanel Inc., 1 Front Street, 28th Floor, San Francisco, CA 94111, USA. Mixpanel allows us to understand how our application is used, e.g., which features are utilized. Analysis is performed exclusively server-side — no data is stored on or read from your device. Pseudonymized usage data such as feature interactions are collected. Data is processed in the EU (Netherlands). Processing is based on our legitimate interest pursuant to Art. 6(1)(f) GDPR to make our services more user-friendly and efficient. You may object to processing at any time by contacting us at support@minimum.energy.

9. Intercom

For customer support and communication with authenticated users, we use the service Intercom by Intercom Inc., 55 2nd Street, 4th Floor, San Francisco, CA 94105, USA. Intercom is part of the contractually owed support service and is loaded exclusively for authenticated users. For the chat to function, technically required information is stored in your browser's local storage (e.g., "intercom.intercom-state", and the realtime transport preference "ably-transport-preference"). Intercom is certified under the EU-U.S. Data Privacy Framework; data is stored on servers in the USA.

Legal basis: Art. 6(1)(b) GDPR (performance of the contract with you for the provision of the platform, including support); the storage on your device required for this purpose is permitted without consent pursuant to § 25(2)(2) TTDSG. Because Intercom is part of the contractually owed service, objection to processing is only possible by terminating the contract.

Storage period: we delete conversations in Intercom (support chat as well as handovers and feedback from the AI assistant) 365 days after the last activity in the conversation, including replies from you or our support team; deletion runs daily. We keep a conversation longer only where statutory retention obligations apply (e.g., for business letters under § 257 HGB, such as a cancellation). Which data from the AI assistant is sent to Intercom is described in section 19 "In-app AI Assistant".

10. Sentry (Error Tracking)

To monitor and improve the technical stability of our website, we use Sentry, a service by Functional Software, Inc., 45 Fremont Street, San Francisco, CA 94105, USA. When an error occurs, Sentry collects technical data (e.g., device type, browser, stack trace, error message, timestamp, and IP address) to enable us to analyze and resolve the cause.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the stability and security of our services).

11. Sentry Session Replay

Additionally — only if you have explicitly consented — Sentry may transmit a recording of the browser session immediately preceding an error ("Session Replay"). DOM snapshots and click, scroll, and input events are captured to facilitate reproducing the error. Text and media content is automatically masked before transmission (configuration: "maskAllText", "blockAllMedia"). Without your consent no Session Replay recording takes place; the error tracking described above is not affected.

Legal basis: Art. 6(1)(a) GDPR (consent) in conjunction with § 25(1) TTDSG (consent to storage on the device). You may revoke your consent at any time via "Cookie settings"; revocation takes effect for the future.

12. Mailgun

For sending transactional emails (e.g., registration confirmations, password resets, notifications) we use the service Mailgun by Sinch Email (Pathwire GmbH). Email address, name, and email content are transmitted to Mailgun. Processing takes place on servers in the EU (Frankfurt). The legal basis is Art. 6(1)(b) GDPR (performance of contract). A data processing agreement pursuant to Art. 28 GDPR is in place.

13. Featurebase

For collecting user feedback and presenting our product roadmap, we use the service Featurebase by CORDNET OÜ (Estonia). The Featurebase widget is loaded as an embedded iframe when you open the "Roadmap" feature in the application. Your name and email address are transmitted; additionally, functional usage data (e.g., completed tours, viewed content) are stored in your browser's local storage (keys with prefix "uf_", "tours", "checklistsDismiss"). Processing takes place in the EU.

The Featurebase widget is loaded only after your explicit consent to functional cookies (category "Functionality" in the cookie banner). Without consent the roadmap/feedback feature is unavailable; you will be informed about this in the application. Legal basis: Art. 6(1)(a) GDPR (consent) in conjunction with § 25(1) TTDSG. You may revoke your consent at any time via "Cookie settings".

14. External Links

This website contains links to external websites of third parties, over whose content we have no influence. Therefore, we cannot assume any liability for these external contents.

15. Hosting

Our platform is hosted by Hetzner Online GmbH (ISO 27001 certified) in Germany. We process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers and users based on our legitimate interests in an efficient and secure provision of this online offer according to Art. 6(1)(f) GDPR in conjunction with Art. 28 GDPR. Database backups are stored with Amazon Web Services (AWS EMEA SARL) in the EU region Frankfurt.

16. Your Rights

You have the right to receive information about the personal data processed by us, as well as the right to correction or deletion, restriction of processing, objection to processing, and the right to data portability. You also have the right to file a complaint with a supervisory authority.

17. Single Sign-On

To simplify your access to our services, we offer the option of Single Sign-On. You can log in to our website using existing login data of a third-party provider (e.g., Google or Facebook). When using this function, certain information from your third-party provider account is transferred to us.

18. Connecting AI Assistants and Other Third-Party Applications (MCP / OAuth)

If your company has subscribed to this feature, you can connect third-party applications, in particular AI assistants (e.g., Claude or ChatGPT), to your account via the Model Context Protocol (MCP). The connection is established through an OAuth 2.1 authorization: the application registers with us, you sign in and grant it access of a defined scope (read and/or write) on an authorization page. The application then receives an access token with which it accesses your company's projects, calculations, and results on your behalf.

In doing so we process: the application's registration data (application name, client identifier, redirect addresses), cryptographic checksums of the issued access and refresh tokens (we do not store the tokens themselves), the granted scope, your user account and company, and the time of last use. Access tokens are valid for one hour, refresh tokens for 30 days from their last use. Expired or revoked tokens, as well as registrations unused for 30 days, are deleted automatically every day.

In addition, we keep a log of granted and revoked authorizations (user ID, company, application, scope, timestamp, reason for a revocation). It serves as evidence of which application had access to your data and when, supports responding to access requests, and serves security purposes, for example to notify affected users if an application is compromised. Likewise, we log who switches the feature on or off for your company (user ID, company, timestamp, whether the required contract documents had been accepted). Your email address is not stored in these logs; if your account is deleted, the entry is retained without reference to you. Log entries are deleted three years after they were created.

Data that a connected application retrieves via the interface is transferred to its operator and processed there under the operator's privacy policy, possibly outside the EU. The choice of application and the transfer to its operator take place at your or your company's instruction; the operator is not a processor acting on behalf of minimum energy, and we have no control over the processing there. You can revoke access at any time by disconnecting the application or by contacting us at support@minimum.energy. Your company's administrators can switch the feature off for all of its users in the security settings; on request we do this for you.

Legal bases: Art. 6(1)(b) GDPR (provision of the connection you requested) for the authorization data; Art. 6(1)(f) GDPR (legitimate interest in the verifiability and security of the interface) in conjunction with our obligations under Art. 5(2) and Art. 28(3) GDPR for the logs of authorizations and of switching the feature on and off.

19. In-app AI Assistant

If your company has subscribed to and activated the AI assistant, you can chat with an AI assistant inside the application. On your behalf it creates projects, imports load profiles, edits components and tariffs, starts calculations and explains results. In doing so we process your messages and attached files (e.g., load profiles), the assistant's answers, the project and result data of your company that the assistant reads or changes, the view of the application you have open, and usage data (timestamps, number of requests, computing resources used and costs per user and month). Your company's administrators can switch the assistant off for all of its users in the settings at any time. We log who switches it on or off (user ID, company, timestamp, whether the required contract documents had been accepted); if the account is deleted, the entry is retained without reference to the person, and it is deleted after three years.

To generate the answers, we send the conversation with this content to the "Generative APIs" service of Scaleway SAS, 8 rue de la Ville-l'Évêque, 75008 Paris, France. Scaleway processes the data on our behalf (Art. 28 GDPR) in data centers in Paris. According to Scaleway, inputs and outputs are not stored and not used to train AI models. Only when requests disrupt the operation of the service or appear abusive may Scaleway keep their content for up to two weeks for error and security analysis. Scaleway stores anonymized, aggregated usage data (e.g., number of requests, status codes) for up to six months. Where the assistant processes your company's project data, we do so as your company's processor under the data processing agreement; for this processing Scaleway is a sub-processor.

We store your chats so that you can continue and review them. You can delete any chat yourself at any time ("Delete this chat"). Otherwise we automatically delete a chat with all its messages and attached files 365 days after the last activity in the chat (messages, answers and actions of the assistant), and in any case when your user account or your company is deleted. Deletion runs daily; if the assistant is working in the chat at that moment, we check it again on the next run. We delete the monthly usage data (without conversation content) three years after the end of the respective month. Deleted data disappears from our backups with the regular rotation after at most 30 days.

Handover to our support team and feedback: with the buttons "Contact support" (headset icon) and "Give feedback" (megaphone icon) in the chat window you can send us the conversation. Nothing is sent until you click "Send" in the respective dialog, which informs you beforehand. We send your message (optional for a support request, required for feedback), your name, your email address, your company, your user and company IDs, the chat's ID and language, the ID and title of the project and calculation concerned, and the conversation including the project data it contains: for a support request the part since the last handover, for feedback the whole chat, in each case at most the most recent 20,000 characters. We make access keys to our platform, e.g., in share links, unrecognizable before sending. The recipient is our support system Intercom (see section 9 "Intercom"): your message appears as a conversation in your support chat, the conversation history is attached as an internal note, and feedback is labeled "KI-Assistent Feedback". If the handover cannot be delivered, your support chat opens instead with your message as a draft; what you send there yourself is an ordinary support conversation without the conversation history.

The resulting conversations in Intercom follow the storage period in section 9 "Intercom". Deleting a chat in the application does not delete copies already sent; this storage period applies to them. On request we delete them earlier (support@minimum.energy).

Legal bases: Art. 6(1)(b) GDPR (performance of the contract for the use of the platform) for operating the assistant and handling support requests; Art. 6(1)(f) GDPR (legitimate interest in improving our offering) for feedback; Art. 6(1)(f) GDPR (legitimate interest in being able to prove who enabled the feature for a company) for the log of switching it on and off.

20. Use of Google Geocoder

Our website uses the Google Geocoder service to convert addresses into geographic coordinates and vice versa. Your entered address data is transmitted to Google for geographic localization. We use this information exclusively for location determination and improving our offer.

21. Use of Amazon S3

Our website uses Amazon Simple Storage Service (Amazon S3) by Amazon Web Services EMEA SARL (AWS) for storing and providing media files. Storage is performed in EU data centers (Frankfurt region). AWS processes data on our behalf. More information: https://aws.amazon.com/privacy/

22. Changes to the Privacy Policy

We reserve the right to change this privacy policy to adapt it to changed legal situations, or in the event of changes to the service and data processing.