WENDY

Privacy Policy

for the WENDY platform

Last updated: 6 October 2026

This is a translation of the German original version.

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Stern Technic GmbH
Represented by: Nicolai Stern
Hafenstraße 25
68159 Mannheim, Germany
Email: info@sterntechnic.com

2. Purpose and legal basis of data processing

The WENDY platform is a cloud-based software-as-a-service application (SaaS) for digital planning, analysis and simulation in trenchless pipeline construction.

Personal data is processed only to the extent necessary in order to:

  • provide and operate the platform (Art. 6(1)(b) GDPR),
  • ensure technical stability and security (Art. 6(1)(f) GDPR),
  • answer support and communication enquiries (Art. 6(1)(b) GDPR),
  • fulfil legal obligations (Art. 6(1)(c) GDPR),
  • provide optional services (map, error monitoring, statistics) subject to consent, which you can give for each service individually (Art. 6(1)(a) GDPR).

3. Types of data processed

Depending on use, the following categories of data are processed:

  • Usage data: IP address, browser type, time stamp, system logs
  • Account data: Name, email address, company name, login data
  • Project data: Map coordinates, route alignments, cost parameters, file uploads
  • Communication data: Email, chat histories, support enquiries
  • Request data: Name, company, e-mail address, telephone number, message and details of the desired licence from the quotation request form, also without an account (see Section 7)
  • Simulation and AI data: Text, image, document and audio analyses, project data (partly pseudonymised, see Section 5 b and e)

4. Hosting and technical infrastructure

Google Cloud Platform (main system)

The platform is operated primarily on the Google Cloud Platform (GCP). Data is stored in data centres of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Under the data processing terms for Google Cloud, Google acts as a processor pursuant to Art. 28 GDPR; whether these terms have been agreed for our account has not yet been conclusively reviewed. Data processing may take place via Google LLC (USA); for the basis of such a transfer, see Section 12.

5. External services used

a) Google Maps Platform

Used for map display, geocoding, elevation profiles and site planning.

  • Data: IP address, browser information, location data (if enabled).
  • Legal basis: Art. 6(1)(f) GDPR (legitimate interest in visual presentation).
  • Consent: In the web application, Google Maps is only loaded after you have consented to the “Map” category in the consent banner.

b) Google Gemini API (AI functions)

For analysing project data, risk assessment and cost estimation, and for evaluating photos, documents (e.g. soil reports, utility plans), voice recordings and imported tables.

  • Data: Depending on the function, text inputs and project data. Uploaded files – photos, PDF documents and images (e.g. soil reports, utility plans with stamps or names) as well as voice recordings – are transmitted unchanged and may therefore contain names, voices and other personal data. When tables are imported, the column headings, column statistics and numeric and time values from sample rows, including coordinates in full precision, are transmitted; other text values are replaced by placeholders. How long Google stores the transmitted data has not yet been conclusively reviewed.
  • Processing: Transmission takes place exclusively via our server (Firebase Cloud Functions), so that the API key is not held on the device.
  • Pseudonymisation: In text requests, the app replaces the project name with a pseudonym before transmission and omits addresses, company and team names that are labelled as such; locations are only transmitted roughly (coordinates rounded to about 100 m, or the municipality), except for the sample values in table imports. This processing takes place on the device, not on our server. Names or other details that appear in running text without a label, and the content of uploaded files, are not removed.
  • Legal basis: Presumably Art. 6(1)(b) GDPR (performance of the contract) or Art. 6(1)(f) GDPR (legitimate interest in AI-supported evaluation) insofar as employees of our customers or third parties are concerned; the allocation, including whether we act as controller or as processor of our customers in this respect, has not yet been conclusively reviewed.
  • Terms and third country: The Gemini API is governed by Google's Gemini API Additional Terms of Service, not by the data processing terms for Google Cloud referred to in Section 4. According to these terms, for paid use – in the EEA also for the free quota – Google processes prompts and responses in accordance with the "Data Processing Addendum for Products Where Google is a Data Processor" and does not use them to improve its products; the data may be stored transiently in any country in which Google or its agents maintain facilities. Whether these terms apply to our account, which Google entity is the recipient and on what basis data are transferred to third countries has not yet been conclusively reviewed. You can obtain information via the contact details in Section 1.

c) Sentry (error monitoring)

To detect and remedy technical errors we use the service Sentry (Functional Software, Inc., San Francisco, USA).

  • Data: Error reports with technical information (browser, operating system, error message), pseudonymised user ID.
  • Session Replay: In the event of errors, a simplified recording of the most recent user actions is captured (without text entries or sensitive data) in order to enable troubleshooting.
  • Legal basis: Art. 6(1)(f) GDPR (legitimate interest in error-free software).
  • Processing on behalf of the controller: Sentry acts as a processor pursuant to Art. 28 GDPR. The data transfer to the USA is safeguarded by EU standard contractual clauses.
  • Opt-out: Error monitoring can be deactivated in the cookie settings.
  • Consent: In the web application, error monitoring only starts after you have consented to the “Error analysis” category in the consent banner. Sentry does not set cookies; for the recording in case of errors, a session state is stored in the session storage of your browser (see cookie policy).

d) WENDY-Control machine control (HiveMQ Cloud)

The control unit of a drilling machine (BOB/BUDDEL) is connected via the internet to an MQTT message broker of the HiveMQ Cloud service. The machine sends its telemetry and event messages to the broker and receives commands from it. The app connects directly to this broker in the browser in order to display the telemetry live and to send commands. While a test run is active, our server (Firebase Cloud Functions) additionally connects to the broker and records the telemetry of the machines.

  • Provider: HiveMQ Cloud. According to HiveMQ’s current contractual terms, HiveMQ GmbH (Berlin) is the contractual partner for customers domiciled in the EEA; whether this version applies to our account and whether HiveMQ, Inc. (USA) receives data has not yet been conclusively reviewed. According to the region identifier in its host name, the broker cluster used is set up in the EU region of HiveMQ Cloud.
  • Data: Machine telemetry (including operating state, motor currents, rotational speed, temperatures, attitude angles, distance travelled, vibration, magnetic field values), event messages of the machine, device identifier and firmware version, as well as commands to the machine (e.g. start, stop, release). For technical reasons, the broker processes the IP addresses of the connected devices.
  • Legal basis: Presumably Art. 6(1)(b) GDPR (performance of a contract) or Art. 6(1)(f) GDPR (legitimate interest in the remote monitoring and control of the machines) insofar as employees of our customers are affected; the allocation, including whether we act in this respect as controller or as processor on behalf of our customers, has not yet been conclusively reviewed.
  • Storage location: The current telemetry status and the event messages are stored via our server in the Firebase database (Google Cloud, see Section 4), together with the identifier of the user whose app transmitted them. The current telemetry status of a machine is deleted 90 days after its last update; no deletion period has been set up for the event messages. A thinned-out history of measured values is also stored there and transferred daily by our server to a long-term archive in Firebase storage (Google Cloud Storage); only entries that are older than 30 days and already in the archive are deleted from the database. The app stores commands sent, with their content, time and the identifier of the sending user, in the command log of the respective customer company in WENDY; no deletion period has been set up for this log. Recordings of active test runs are stored by our server as files in Firebase storage, and for each recording it stores a directory entry (including machine identifier, time period, number of measured values) in the database; no deletion period has been set up for these entries. WENDY does not delete the long-term archive or the recording files; whether a deletion period applies to them at storage level has not yet been conclusively reviewed. How long HiveMQ stores messages and connection data (including IP addresses) has not yet been conclusively reviewed.
  • Third country: Whether data is transferred to HiveMQ, Inc. in the USA and on what basis (adequacy decision or appropriate safeguards pursuant to Art. 46 GDPR) has not yet been conclusively reviewed; information is available via the contact details in Section 1.

e) Anthropic Claude (AI assistant and analyses)

The WENDY AI assistant, the AI analysis of machine-control test runs and an automatic AI diagnosis in the event of critical anomalies in the machine telemetry use the Claude language model. According to Anthropic’s commercial terms of service, Anthropic Ireland, Limited is the contractual partner and thus the recipient for customers domiciled in the EEA; whether these terms apply to our account has not yet been conclusively reviewed. Whether processing also takes place in the USA has not yet been conclusively reviewed. Requests are made exclusively by our server (Firebase Cloud Functions, region europe-west3, Frankfurt) to the Anthropic API; the app itself does not establish a connection to Anthropic.

  • Data: Depending on the function, in particular: chat messages in text form with the previous conversation history (at most the last 20 messages); project context, including the project only under a pseudonym, the distance of the device to the recognised project or, if no project was recognised, a device location rounded to approximately 100 m, identifiers and names of planning objects, and notes remembered by the assistant; in the chat of the desktop application, additionally the project status, pipeline data (type, length, depth, method, number of route points), cost factors (laying method, soil class, pipe material) and information from the company profile (pipeline types, methods, own machines by manufacturer and model); results of the assistant’s project data queries; for test run analyses, aggregated machine measurements with the operator’s label and notes; for the automatic diagnosis, the current measured values of the machine and the detected anomalies. Whatever a user writes into a chat message or note is transmitted unchanged.
  • Not transmitted: The user identifier and the company name are not sent. Email addresses and information marked as an address or company are removed from the context before transmission.
  • Storage: According to Anthropic, inputs and outputs of the API are deleted within 30 days unless they are retained for longer to enforce the usage policies (in that case for up to 2 years; the resulting classification scores for up to 7 years) or for legal reasons; whether different arrangements apply to our contract has not yet been conclusively reviewed.
  • Legal basis: Presumably Art. 6(1)(b) GDPR (performance of a contract) or Art. 6(1)(f) GDPR (legitimate interest in AI-assisted analysis) insofar as employees of our customers are affected; the allocation, including whether we act in this respect as controller or as processor on behalf of our customers, has not yet been conclusively reviewed.
  • Third country: Whether and on what basis data is transferred to the USA (adequacy decision or appropriate safeguards pursuant to Art. 46 GDPR) has not yet been conclusively reviewed. Anthropic’s Data Processing Addendum provides for EU standard contractual clauses for this purpose; whether it applies to our contract has not yet been conclusively reviewed. Information is available via the contact details in Section 1.

f) Autodesk Platform Services (CAD view)

When a user uploads a CAD or 3D model file (e.g. DWG, DXF, IFC, RVT, NWD, STEP, STL or SKP) to the project documents, our server automatically transmits the file to Autodesk Platform Services (APS), a service of Autodesk, so that it can be converted there into a format that can be displayed in the browser. Which Autodesk company is the recipient and our contractual partner has not yet been conclusively reviewed. For display, the browser loads the viewer and the converted model data directly from Autodesk servers.

  • Data: The uploaded file with its complete content and file name, as well as an internal project identifier in the object name; when viewing, for technical reasons, the IP address and browser information of the viewing device.
  • Storage: If the storage area at Autodesk does not yet exist, our integration creates it with the setting for permanent retention. If the file is deleted in WENDY, neither the copy transmitted to Autodesk nor the display data generated from it are deleted there; no deletion period has been set up.
  • Legal basis: Presumably Art. 6(1)(b) GDPR (performance of a contract) or Art. 6(1)(f) GDPR (legitimate interest in displaying CAD and 3D models in the browser) insofar as employees of our customers are affected; the allocation, including whether we act in this respect as controller or as processor on behalf of our customers, has not yet been conclusively reviewed.
  • Third country: Our integration does not specify a region at Autodesk; according to Autodesk, the default region is then the USA. The display data generated from the file is therefore generated and stored in the USA; the same is to be assumed for the uploaded file itself. On what basis a transfer takes place (adequacy decision or appropriate safeguards pursuant to Art. 46 GDPR) has not yet been conclusively reviewed; information is available via the contact details in Section 1.

g) n8n automation (Hostinger)

To connect to Autodesk Platform Services (among other things for the 3D view of the machine, digital twin), WENDY uses a technical auxiliary service based on n8n (automation service), which is operated on a server of the hosting provider Hostinger. According to Hostinger’s terms of service, the contractual partner for customers in the EU is Hostinger International Limited (Larnaca, Cyprus); under whose account the server runs, who operates the n8n instance and whether these terms therefore apply to us have not yet been conclusively reviewed.

  • Data: No project or user data is transmitted to the service. For technical reasons, the server receives the IP address and browser information of the requesting device.
  • Storage: Whether and for how long access logs containing IP addresses are stored on the server has not yet been conclusively reviewed.
  • Legal basis: Presumably Art. 6(1)(b) GDPR (performance of a contract) or Art. 6(1)(f) GDPR (legitimate interest in connecting to Autodesk Platform Services, among other things for the 3D view of the machine) insofar as employees of our customers are affected; the allocation, including whether we act in this respect as controller or as processor on behalf of our customers, has not yet been conclusively reviewed.
  • Third country: The server location of the instance has not yet been verified; a transfer to a third country therefore cannot currently be ruled out.

h) Open-Meteo (weather data)

In the app – not on the public pages – some functions retrieve current weather data or a precipitation forecast from the Open-Meteo service: the weather for an operation, the assistant’s rain warning, the site context at the start of a bore in the mobile app, and the obstruction notice. The request is sent directly from your device to Open-Meteo.

  • Data: Coordinates of the project or of your current location (mostly rounded to four decimal places, i.e. about 10 m; not rounded in the obstruction notice) and, for technical reasons, your IP address. According to the provider, server logs that may contain coordinates are deleted after 90 days, and no cookies are set.
  • Provider: OpenMeteo GmbH, Hintere Schilligmatte 6, 6463 Bürglen (UR), Switzerland. Switzerland is not an EU member state; on what basis the transfer takes place and whether a contract with the provider exists has not yet been conclusively reviewed.
  • Legal basis: The retrieval currently does not depend on consent in the consent banner. Which legal basis applies and whether consent is required has not yet been conclusively reviewed.

i) OpenStreetMap map tiles (offline map)

For a project selected on the device, the mobile app pre-loads map tiles around the site (radius of about 300 m) – at most once per project and day – so that the map is available without a network connection. The tiles are retrieved directly from your device from the OpenStreetMap tile server (tile.openstreetmap.org) of the OpenStreetMap Foundation and are cached only on your device.

  • Data: For technical reasons your IP address, information about your browser or device, and the retrieved map sections, from which the location of the site can be derived. According to the privacy policy of the OpenStreetMap Foundation, the use of its services records, among other things, IP address, browser and device type, operating system, referring page and date and time.
  • Legal basis: The retrieval does not depend on consent in the consent banner. Which legal basis applies, how long the provider stores the data and whether data are transferred to a third country in the process has not yet been conclusively reviewed.

5a. Sensor data of the WENDY app

The WENDY app (iOS) records sensor data of the device in order to improve the locating of drill heads and the site documentation: acceleration and rate of rotation, magnetic field, air pressure as well as the accuracy of satellite positioning. The microphone is not used for this. Recording does not take place permanently, but only in event windows: while a route is being walked, while a bore record is running, while a machine is paired with the app and for ten seconds after a photo or a voice note. Every recording is assigned to the project, the route, the machine and the trigger.

The legal basis is Art. 6(1)(b) GDPR (performance of the contract vis-à-vis the client) as well as Art. 6(1)(f) GDPR (legitimate interest in improving the locating procedures). The company's administrator can switch the recording off for all devices at any time in the settings under „Unternehmen“ (Company). Raw data is deleted automatically after 180 days; recordings belonging to a bore record are retained together with it.

5b. Local caching on the device

So that the app continues to work without a network, it first stores recordings and changes on the device: photos, voice notes, videos, GPS tracks, sensor and telemetry recordings as well as changes to projects and construction diary entries that have not yet been transmitted. This data is held exclusively locally (IndexedDB and local browser storage) and is transmitted as soon as a connection exists again.

When logging out, this data cached locally on the device and not yet transmitted is deleted. If recordings or captures are still outstanding, the app points this out beforehand, states — as far as it can be read — their number and asks for confirmation; if the query is cancelled, the login remains in place and nothing is deleted. A logout by expiry of time (session timeout) deletes no content, only session characteristics — the data is then retained and continues to be transmitted at the next login of the same account; if instead a different account logs in on this device, the data is deleted before that login and the logging-in user is informed of this.

Deleted in the process are: the recordings and captures named, the queue of changes not yet transmitted, session characteristics, the locally cached company profile, the intermediate values of an Autodesk login in progress as well as locally held histories of the AI strategy chat. Upon an intentional logout, locally stored data for which there is no copy on our servers and which would otherwise be irretrievably lost is expressly not deleted: saved locations, projects created without login and team invitations recorded offline. These are removed only upon deletion of the account and upon the login of a different account on this device.

Likewise not deleted are pure device settings (e.g. language, map options, window positions), the documented cookie consent and the pairing with a WENDY control unit. Upon deletion of the account, the access data of paired WENDY control units is additionally removed and the cookie consent is reset; device settings and the pairing state per company are retained. If one of these stores cannot technically be emptied, this is stated and not reported as a deletion.

6. Storage and deletion

Data is deleted as soon as it is no longer necessary for the purpose of processing or the user requests its deletion, provided that no statutory retention obligations exist.

  • Project data: after the end of the contract or on request
  • System logs: max. 90 days
  • Account data: after deactivation of the user account
  • Quote and drilling-service enquiries: no deletion period set up (see Section 7)
  • Protection of the enquiry form: shortened hash value of the IP address with a counter, deleted automatically at the latest about two days after the last enquiry (see Section 7)

7. Disclosure of data

Disclosure takes place exclusively:

  • to technical service providers (e.g. Google) for the performance of the contract,
  • in the event of a legal obligation (e.g. official requests),
  • with the express consent of the user.

There is no disclosure to third parties for marketing or advertising purposes.

Quotation and invoicing: A quotation can be requested via the request form on our website or in the app, also without an account. We store the request with the details from the form (name, company, e-mail address, desired term, number of users, information on a WENDY machine and, if provided, telephone number and message) and the time of receipt in our database (Google Cloud, see Section 4) and receive a notification with the form details by e-mail, in order to answer the request and prepare a quotation. Name, company, e-mail address and number of users (pre-filled: 5) are mandatory; without them the request cannot be sent. If the requester is signed in, we additionally store the identifier of the account and the login e-mail address and, where applicable, the identifier of the company account and include them in the notification, so that a licence can be assigned to the correct account; without signing in, the form does not send an account identifier. An e-mail delivery service is used to send the notification; for this purpose the notification is also stored in our database as a delivery job. Which delivery service this is, with which provider the mailbox info@sterntechnic.com that receives the notifications is hosted, on what basis and whether data are transferred to a third country in the process has not yet been conclusively reviewed. If the request cannot be transmitted, the form offers to send it to info@sterntechnic.com using your own e-mail program instead. No deletion period has been set up for stored requests and the stored delivery jobs. We prepare quotations and invoices outside WENDY using the accounting software Lexware of Haufe-Lexware GmbH & Co. KG, Munzinger Straße 9, 79111 Freiburg, Germany; in doing so, company and contact person data of the customer are processed. We retain invoices for the duration of the retention periods under commercial and tax law; the specific period has not yet been conclusively reviewed. No payment processing takes place via WENDY itself. The legal basis is presumably Art. 6(1)(b) GDPR (pre-contractual measures and performance of the contract) or Art. 6(1)(f) GDPR (legitimate interest in handling contracts with business customers) insofar as contact persons of requesting companies or of our customers are concerned, and, for the retention of invoices, Art. 6(1)(c) GDPR in conjunction with the retention obligations under commercial and tax law; this allocation has not yet been conclusively reviewed. Whether a data processing agreement exists with Haufe-Lexware has not yet been conclusively reviewed.

Drilling-service enquiry: Using the form on the drilling-service (Robotics as a Service) page you can enquire without obligation and without an account. We store name and e-mail address (mandatory), if provided telephone number, company and message, the details chosen in the calculator (machine, section lengths, total length, soil class, depth, crossing, number of pits) and, if you previously drew a route on our home page, its length, sections and the coordinate of the starting point, as well as the time of receipt in our database, and receive a notification with these details by e-mail in order to answer the enquiry. Regarding the mail delivery service, mailbox, mailto fallback and deletion period, what is said above about the quote request applies. The legal basis is presumably Art. 6(1)(b) GDPR (pre-contractual steps) or Art. 6(1)(f) GDPR insofar as contact persons of enquiring companies are concerned; the assignment has not yet been conclusively reviewed.

Protection against misuse of the enquiry forms: We accept at most five enquiries per sender within ten minutes. For this purpose we do not store the IP address itself but a shortened hash value of the IP address formed with an additional value, together with a counter and time information, in our database. A daily clean-up run deletes the entry once the last enquiry is more than one day old, i.e. at the latest about two days afterwards. Enquiries that our form recognises as automated are discarded and not stored. The legal basis is presumably Art. 6(1)(f) GDPR (legitimate interest in protection against misuse); the assignment has not yet been conclusively reviewed.

8. Data security

Stern Technic GmbH employs technical and organisational measures in order to protect personal data:

  • TLS encryption
  • Access restriction via authentication tokens
  • Role-based user permissions
  • Regular backups and security updates

9. Rights of data subjects

Data subjects have the following rights under the GDPR:

  • Access (Art. 15 GDPR)
  • Rectification (Art. 16 GDPR)
  • Erasure (Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Objection (Art. 21 GDPR)

Requests are to be addressed to: info@sterntechnic.com

10. Cookies and local storage

In the web application, without your consent WENDY stores information in your browser, in particular the sign-in (IndexedDB or Local Storage), your choice in the consent banner (Local Storage), settings such as the selected language, and data captured offline that have not yet been transmitted (IndexedDB). Whether each of these storage operations is strictly necessary within the meaning of Section 25(2) no. 2 TDDDG has not yet been conclusively reviewed. If you are signed in, we additionally store your choice in the consent banner with the time, the version of the privacy policy and the browser identifier in your user account as proof of consent (Art. 7(1) GDPR). With your consent, which you can give for each service individually, optional services are additionally loaded – Google Maps (map), error monitoring (Sentry) and analytics (Google Analytics); they are subject to the data protection provisions of the respective provider. Google Analytics sets the cookies `_ga` and `_ga_<ID>`, with a default expiration of 2 years according to Google; Sentry does not set cookies; which cookies Google Maps sets has not yet been conclusively reviewed (details in the cookie policy). Analytics is set up in production. Which Google company is the contracting party, how long the analytics data are stored and whether and on what basis data are transferred to the USA has not yet been conclusively reviewed. You can withdraw consent you have given at any time with effect for the future (Art. 7(3) GDPR), also without an account: “Cookie settings” in the footer of the public pages (as well as in this privacy policy and in the cookie policy) reopens the consent banner; “Necessary only” withdraws your consent entirely, and under “Settings” it can be withdrawn for individual services. After that, analytics that has already been loaded no longer sends any data, its cookies on this website are deleted and error monitoring is stopped; if Google Maps had already been loaded, the page is reloaded. When signed in, you can also withdraw consent in the settings under “Privacy & Consent”. If you delete the data stored for this website in your browser, the consent banner likewise appears again.

Tracking or analytics cookies are not used unless the user expressly consents to this.

11. AI-supported processing

Which data are transmitted to the AI services Google Gemini and Anthropic Claude, which details are omitted or replaced by a pseudonym in the process, and what is known about storage by the providers is described in Section 5 under b) and e). Anything a user writes into a chat message or note, and the content of uploaded files, are transmitted unchanged. The AI functions provide suggestions and evaluations for the users; WENDY does not make any decision based solely on automated processing within the meaning of Art. 22 GDPR.

12. International data transfer

Insofar as data are transferred to Google LLC (USA): for this purpose, the data processing terms for Google Cloud provide for an alternative transfer solution adopted by Google (e.g. a recognised data protection framework) or, if none has been adopted, EU standard contractual clauses. Whether and in which version these terms apply to our account, and which basis applies in the individual case, has not yet been conclusively reviewed. You can obtain information via the contact details in Section 1.

Whether and on what basis data are transferred to third countries in connection with Google Gemini, HiveMQ, Anthropic, Autodesk, the n8n instance at Hostinger, Open-Meteo and the OpenStreetMap map tiles is described in Section 5 under b) and d) to i); insofar as it is described there as not yet conclusively reviewed, this also applies here.

13. Amendments to this privacy policy

This privacy policy may be adapted on account of technical changes or new legal requirements. The version applicable at any given time is available at: https://www.sterntechnic.com/datenschutz

14. Competent supervisory authority

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg
Königstraße 10a
70173 Stuttgart
Email: poststelle@lfdi.bwl.de

© 2026 Stern Technic GmbH – All rights reserved.