General Terms and Conditions

The rules for using SchlüsselBot — fair and transparent.

As of 16 August 2026

§ 1 Scope and definitions

(1) These General Terms and Conditions (hereinafter “Terms”) apply to the use of the service “SchlüsselBot” (hereinafter “Service”), provided via https://schluesselbot.de (hereinafter “Website”), by the respective user (hereinafter “Users”) in the version valid at the time of use or contract conclusion.

(2) The service is intended for both consumers (§ 13 BGB) and entrepreneurs (§ 14 BGB). Certain provisions of these Terms and Conditions apply expressly only to consumers or only to entrepreneurs; this is clearly indicated at the relevant point.

(3) Consumer means any natural person who uses the service for purposes that are predominantly neither commercial nor self-employed professional activities. Entrepreneur means any natural person, legal entity, or legally competent partnership that acts in the course of their commercial or self-employed professional activities when using the service.

(4) Any divergent, conflicting or supplementary general terms and conditions of the user shall not form part of the contract unless the provider explicitly agrees in writing. This also applies if the provider provides the service without reservation despite being aware of conflicting terms.

(5) The following terms are commonly used:

§ 2 Provider, contractual partner, contact

(1) The provider and contracting party is:

MessingerDesign, Philipp Messinger & Werner Messinger GbR

Gesellschaft bürgerlichen Rechts

Individually authorised partners: Philipp Messinger, Werner Messinger (each individually authorised)

Dahmestraße 10, 12526 Berlin, Germany

(hereinafter “Provider”)

(2) Contact:

(3) VAT identification number: DE332090964.

(4) For paid services, payment processing may be handled by an external payment service provider, who only processes the payment; the provider remains the seller in a legal sense (see § 8). The provider remains the contractual partner in relation to the Service provision in all cases.

§ 3 Description of services

(1) SchlüsselBot is a service for the browser-encrypted, one-time accessible transmission of text messages and files. The user creates a message, which is encrypted client-side in the browser; the recipient is notified by email and can retrieve and decrypt the message once using a one-time code and a retrieval link. Whether the key reaches the provider technically in full depends on the chosen delivery method or secure inbox level; § 4 is decisive. After retrieval or upon expiry of the respective deadline, the message is permanently deleted (see § 5).

(2) The service is offered in a free Basic Version (Free) as well as in paid versions (Pro, Business). The features and performance levels of the individual versions, including permitted file sizes, expiry rules, available management functions, and any applicable limits, are determined by the respective current service description on the website. The performance level as displayed at the time of contract conclusion or service use shall be decisive.

(3) Free Basic Version (Free): Use is available without registration or user account. There are limitations, particularly regarding file size, number of simultaneous active messages, and management capabilities. Sent links may include a reference to the service.

(4) Paid versions (Pro, Business): These require a user account (see § 6) and offer an expanded feature set (e.g. larger file attachments, configurable expiry rules, send status and delivery confirmation, persistent receiving secure inboxes, and in the Business plan, API access and team features). The exact scope depends on the selected version and the respective service description.

(5) The service is no permanent storage or archiving service and no guaranteed delivery service. The transmission is designed for short-term, self-erasing availability. The user is responsible for backing up any content they transmit.

(6) The provider is entitled to further develop, adapt, and modify individual features, provided this is reasonable for the user and does not substantially reduce the core service scope of a paid version. For consumers, additional provisions apply under §§ 327 et seq. BGB, in particular § 327r BGB (changes to digital products).

§ 4 Browser-side encryption and key management — Provider’s access to content (important notice)

(1) Content encryption (message text and attachments) takes place client-side in the user's browser when using the website; on the separate vault server, content exists exclusively as ciphertext. A technically complete lack of knowledge on the provider’s part is guaranteed in security mode and in the E2E passphrase secure inbox; other key pathways are described in Paragraph 2. An exception applies to the business plan’s API: if the user submits plaintext, the provider encrypts on their behalf; the content reaches the provider in readable form and is overwritten in storage after encryption. Users wishing to exclude this must encrypt themselves and submit pre-encrypted ciphertext. In direct delivery, the key required for decryption is carried in the address fragment of the retrieval link (the part after the # character) and is not stored. For the direct open button in the logged-in inbox, the edge server holds an additional, separately encrypted copy of this fragment for the duration of retrieval, expiry, or hiding, for secure inboxes without their own key pair. A secure inbox using its own E2E passphrase instead uses a key pair generated in the browser; only the public key and the passphrase-encrypted private key are stored.

(2) Delivery methods. When sending via the service's sending form, the user decides independently for each transaction through which channel the access link is delivered to the recipient; this choice is crucial for the security properties of the transaction and thus for expectation management. Specifically:

(3) The user is solely responsible for securely safeguarding the access link, key fragment and one-time code, and for making them available only to authorised persons. Additionally, for a receiving secure inbox, the user must protect their Passkey devices, their Authenticator app or their own E2E passphrase, depending on the selected security level. Forgetting an E2E passphrase results in irreversible loss of unopened submissions. In the "Secure" sending mode, the access link must be communicated to the recipient via a other channel from the notification email. In "Convenience" mode ("Simple") and for receiving secure inboxes, the provider arranges the dispatch of the access link to the specified recipient address as instructed; the user remains responsible for selecting and verifying the accuracy of this address.

(4) Technically enforced provider blindness applies in security mode and for E2E passphrase secure inboxes. In all other cases, content is not automatically decrypted, checked or scanned for malware (see § 10 and § 11); ciphertext and key fragments are stored separately, and while access is not technically ruled out, it is not guaranteed. The user alone is responsible for the legality and acceptability of transmitted content.

(5) Metadata (in particular recipient email address, timestamp, file size, technical processing data) are made available to the provider to the extent required; their processing is governed by the privacy policy (see § 16).

§ 5 Message storage and deletion (lifecycle)

(1) Sent messages are stored exclusively in encrypted form and deleted according to the following rules (the retention periods below are part of the contract; the values specified in the sending form refer to the selected option for the specific transaction):

(2) In paid versions, customisable expiry rules may be set within the specified limits.

(3) Deletion occurs on a time-based schedule and independently of access. The Ciphertext of a previously deleted message may still reside in encrypted backups until the backup retention period expires (daily 7, weekly 4, monthly 12 generations). The server key for direct secure inbox opening is deliberately not included in these application backups; therefore, removed fragment copies cannot be restored together with the ciphertext. In security mode and for E2E passphrase secure inboxes, the provider never had the decryption key. This differs for the Accompanying notes under § 10 para. 8 (in particular sender and recipient address): These are also encrypted in the backup, but the necessary key material is part of the same backup set. Anyone who has access to a backup and the corresponding passphrase can read them. The backups themselves are encrypted using GPG and stored on a separate, non-publicly accessible system.

(4) The user acknowledges that the service not suitable for long-term data storage and does not offer any recovery of deleted or expired content.

§ 6 Registration and user account (paid versions)

(1) For paid versions, user account setup is required. By registering, the user submits an offer to enter into a usage contract. The provider may decline registration without stating reasons.

(2) The user must provide complete and accurate information during registration and update it promptly if any changes occur. Registration may be performed using email and password, or via a third-party login (e.g. Apple, Google, Microsoft). When using a third-party login, the user must also comply with the terms and privacy notices of the respective provider; the resulting data transfer is noted in the privacy policy.

(3) The user must keep their access credentials and any two-factor authentication methods (e.g. passkey, TOTP, recovery codes) confidential and protect them from unauthorised access. The provider recommends enabling two-factor authentication. In case of suspected abuse, the provider must be notified immediately.

(4) The user account is not transferable. Sharing access credentials with third parties is not permitted — except where separate, explicitly agreed team or multi-user functions (Business) apply.

(5) A user account provides no access to the encrypted content of sent messages. Signing in does not alter the architecture or delivery methods under section 4: an account gives the provider no additional access to keys or content and is used solely for administration, status information and enabling additional features and limits.

§ 7 Contract formation

(1) The presentation of the service and paid versions on the website does not constitute a binding offer, but an invitation to submit an offer.

(2) Free Basic Version: Using the free service establishes a free-of-charge usage relationship governed by these GTCs, without requiring registration. No right to availability or continued provision of the free service exists.

(3) Paid versions: By clicking the order/payment button during the checkout process, the user submits a binding offer to enter into a paid contract. The contract is formed upon confirmation of the order or upon activation of the paid features by the provider or the appointed payment service provider. The payment service provider (§ 8) handles only the payment transaction; the provider is always the user’s contractual partner.

(4) The contract text will be stored by the provider in accordance with legal requirements or made available via the payment service provider. Order details will be confirmed to the user by email.

(5) The contract is concluded in German.

§ 8 Prices, payment, payment service providers, default

(1) The prices displayed at the time of order in the checkout process apply. For billing addresses in Germany and EU private customers, SchlüsselBot displays the applicable gross price including VAT. For businesses in the EU with confirmed, valid VAT ID matching the billing country, the net price without German VAT is charged; tax liability is transferred to the recipient under the reverse charge mechanism. For customers outside the EU, an individual request and technical review of the respective country is currently required; online self-booking is blocked by default. The total price explicitly shown in an individual offer or prior to a later released payment step is binding; no further fees from SchlüsselBot will apply.

(2) Payment service provider: Payment for paid versions is processed through the payment service provider PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg. The provider remains the seller in a legal sense and the contracting party in all cases; PayPal only handles the payment transaction. Invoices and VAT invoices are issued by the provider. Additional terms of the respective payment service provider apply to the payment process. Payment method and card details are processed exclusively by the payment service provider and are not stored by the provider.

(3) The paid versions are offered as monthly subscription services. The fee is due monthly in advance. Payment is made via the payment methods available during the ordering process.

(4) Change of business places: The group administrator may adjust the number of seats in an active Business subscription via the account. The change only becomes binding after reconfirmation via the payment service provider. Additional seats are activated immediately after confirmation; the new recurring price applies from the next regular billing period, with no pro-rata adjustment for the current period. A reduction in seats and recurring price takes effect at the start of the next billing period and is displayed in the account with the effective date and new price until then. Reducing the number of seats below the number already assigned to users or pending invitations is not permitted.

(5) To the extent a free trial period is offered, it will either convert into a paid subscription or revert to the free basic version upon expiry — provided this was clearly displayed during the ordering process. The specific conditions of the trial period are clearly displayed during the ordering process.

(6) Payment overdue: If the user falls behind on payments, the provider (or payment service provider) is entitled to charge default interest in accordance with statutory provisions (§§ 288, 247 BGB). The right to claim further damages remains unaffected. In case of payment default, the provider is entitled to block paid features or downgrade the account to the free basic version; previously sent messages remain unaffected within their lifecycle (§ 5).

(7) The user may only set off claims against the provider using undisputed or legally established counterclaims. The user may only exercise a right of retention if it arises from the same contractual relationship. Legal rights for consumers remain unaffected.

§ 9 Term and termination

(1) Paid subscriptions are concluded with a minimum term of one month and automatically renew for an additional month unless terminated.

(2) Consumer: The subscription may be cancelled cancellable at any time, at the end of the current, already paid billing period; no notice period applies. Already paid time remains usable until its end. For contractual agreements concluded via the website that are for a fee and ongoing, consumers additionally have the right to cancel via the legally required cancellation button ("cancellation button", § 312k BGB).

(3) Entrepreneur: The same rule applies: termination at any time, effective at the end of the current, already paid billing period, without notice.

(4) The right to terminate the contract for important cause remains unaffected for both parties. An important cause for the provider exists in particular in cases of serious or repeated breaches by the user of § 10 (obligations and prohibitions).

(5) Cancellations require written form (e.g. email) or may be carried out via the functions provided in the account or the cancellation button.

(6) The provider may terminate the free usage arrangement and free accounts at any time with reasonable notice. Immediate suspension or termination is permitted for important reasons (in particular misuse under § 10).

(7) Upon effective termination of a paid subscription, the account will be downgraded to the extent of the free basic version, provided it has not been fully deleted and such a version still exists. Any deletion of account data shall be governed by the privacy policy and applicable legal retention requirements.

§ 10 User obligations and prohibitions; permitted use

(1) The user is solely responsible for all content transmitted via the service (messages, attachments, entered notes, recipient details) and warrants that they are authorised to transmit such content and do not infringe third-party rights or legal provisions.

(2) It is particularly prohibited to use the service to:

a) to send Spam, bulk or unsolicited messages or use the service to harass third parties, for example by repeatedly sending unwanted messages to the same recipient address;

b) Phishing, identity fraud, or spreading content that is fraudulent, misleading, or intended to obtain access, payment, or authentication data;

c) to transmit Malware (viruses, trojans, ransomware, worms, etc.) or harmful code;

d) to transmit illegal content, particularly content that infringes on third-party rights (copyright, trademark, personality, data protection), criminal laws, or other legal provisions, as well as content that incites hatred, glorifies violence, endangers minors, is insulting, or threatening;

e) automated mass access, circumventing security, captcha, or rate-limiting mechanisms, denial-of-service (DoS/DDoS) attacks, or any other actions that impair the service's availability, integrity, or security;

f) to use the service in a way that could damage the reputation of the shipping infrastructure (particularly email delivery) used by the provider.

(3) The user must comply with applicable technical restrictions (e.g. file sizes, limits, rate limits, blocked file types) and must not circumvent protection mechanisms (CAPTCHA, abuse protection).

(4) By entering recipient addresses, the user confirms that transmission to the respective recipient is desired, necessary and lawful. Any optional note line entered by the user in the notification email must not contain unlawful, misleading or offensive content; the provider does not review such content.

(5) The provider is entitled to suspend or delete affected processes, temporarily or permanently suspend accounts, and — to the extent permitted by law — take appropriate measures if there is a justified suspicion of a breach of these GTCs or statutory provisions. The provider's rights under § 9 (Termination) remain unaffected. Due to the encryption architecture, content review is limited to what is technically feasible and the reporting/remediation procedure under § 11.

(6) The user ensures that they — where they transmit personal data of third parties via the service — hold the necessary legal basis and comply with data protection obligations. If a business user uses the service for processing personal data within their own responsibility, a data processing agreement under Art. 28 GDPR must be concluded. The provider offers this in the Business plan; it can be generated directly within the account. No data processing agreement is concluded in the Free and Pro plans — these are therefore not suitable for personal data of third parties.

(7) Special categories of personal data and professional secrecy. If special categories of personal data under Article 9(1) GDPR — particularly health data — or information subject to professional secrecy under § 203(1) StGB are to be transmitted via the service, the Business plan must be selected. The provider issues, alongside the data processing agreement, a separate Obligation declaration under § 203 para. 4 StGB; both are accessible in the account. Whether processing under Article 9(2) GDPR or § 22 BDSG is permitted is solely the user’s responsibility as the data controller; the provider does not assess this and cannot verify it due to encryption.

(8) Accompanying data are readable by the provider. Message and attachment are available to the provider only as ciphertext. In contrast, accompanying data — the sender and recipient email addresses, a subject line assigned by the user, a sender name, and the name of a recipient secure inbox that forms part of a publicly distributed address — are stored partially unencrypted and partially encrypted. The provider holds the necessary key to access these data and thus they are not protected in the same way as the message content. The user is obligated not to enter information about diagnosis, treatment, procedure subject, or consultation purpose in these fields; subject line, sender name, and secure inbox name may remain blank. The recipient address is required for delivery. The provider draws attention to this again in section 6.4 of the privacy policy.

§ 11 Notice-and-Action procedures (reporting and remediation); abuse prevention

(1) The provider makes available at abuse (at) schluesselbot dot de an easily accessible contact point through which unlawful content or misuse can be reported (reporting and remedy procedure as defined in Article 16 of Regulation (EU) 2022/2065 — Digital Services Act). The same address also serves as the central contact point for authorities (Article 11 DSA) and for users (Article 12 DSA); communication languages are German and English.

(2) Upon receiving a sufficiently justified report, the provider will, to the extent technically and legally feasible, review the reported transaction and immediately delete or block any unlawful content. Messages are not automatically decrypted or reviewed during normal operation; access to content is technically impossible in security mode and in E2E passphrase secure inboxes. Deletion of the affected transaction remains possible at any time by reference to its identifier.

(3) To prevent abuse, the provider implements technical and organisational measures (e.g. rate limits, CAPTCHA, recipient protection limits, block and blacklist systems, automatic analysis of delivery and complaint data). Recipients may object to further notifications from the service (opt-out); such addresses will be excluded from future sending.

(4) The provider reserves the right to inform the competent authorities in case of unlawful use and to comply with statutory obligations to provide information and cooperate.

(5) If the provider suspends or deletes a case or account, they must immediately inform the affected individual and clearly and specifically justify the decision (Art. 17 of Regulation (EU) 2022/2065). The notification must include the reason, factual basis, whether automated evaluation was involved, and the available legal remedies. Clarification regarding the only automatically generated measure: If a recipient's mail server permanently rejects an address, it is added to the delivery blocklist. A separate notification to that address is then technically impossible — it is not reachable. The provider will supply the reason and date of entry upon request via the contact point specified in § 11. Note: The blocklist primarily includes recipients without their own account — a reference to data access within the account would be meaningless for them. Removal from the blocklist is possible at any time via the contact point specified in paragraph 1. The provider also informs the reporting party about the outcome of the report and the remedies available to them (Art. 16 para. 5 of the Regulation).

§ 12 Right of withdrawal for consumers

(1) Consumers have a statutory right of withdrawal under paid contracts, subject to the withdrawal information set out below. No right of withdrawal exists in the case of free use, as there is no consideration for the service provided.

(1a) Electronic revocation function. The provider offers a right of withdrawal under § 356a BGB at schluesselbot.de/widerrufen. This function is prominently displayed via the highlighted link “Withdraw contract” in the footer of all information and customer pages, and additionally highlighted in the account during the withdrawal period. Upon submission, the consumer receives an immediate written confirmation including the content of the declaration, as well as the date and time of receipt.

(2) Early expiry of the right of withdrawal: SchlüsselBot Pro and Business are digital Services within the meaning of § 327 para. 2 sentence 2 BGB. The right of withdrawal therefore only expires once the provider has fully fulfilled the service and has begun execution, after the consumer

a) explicitly agreed that the provider may begin performance of the contract before the withdrawal period expires, and

b) has confirmed awareness that their right of revocation lapses upon full performance of the contract by the provider (§ 356 para. 5 no. 2 letters a and c BGB).

For active subscriptions, the right of withdrawal remains valid until full performance of the respective billing period; if the consumer withdraws during the term, they are liable for compensation under § 357a para. 2 BGB for services already provided. The provider obtains consent and confirmation of knowledge during the ordering process and confirms them in the contract confirmation under § 312f BGB

Withdrawal information

Right of withdrawal

You have the right to cancel this contract within fourteen days without giving any reason. The cancellation period is fourteen days from the date the contract was concluded.

To exercise your right of withdrawal, you must contact us

MessingerDesign, Philipp Messinger & Werner Messinger GbR, Dahmestraße 10, 12526 Berlin, Email: pmessinger@messingerdesign.de, Phone: +49 174 967 61 56

by means of a clear statement (e.g. a letter sent by post or an email) inform us of your decision to withdraw from this contract. You may use the attached model withdrawal form, although it is not mandatory.

You can also exercise your right of withdrawal online at https://schluesselbot.de/widerrufen. If you use this online function, we will immediately send you a confirmation of receipt on a durable medium (e.g. via email), including details about the content of your withdrawal declaration, as well as the date and time of receipt.

To preserve the withdrawal period, it is sufficient that you send your notice of withdrawal before the withdrawal period expires.

Consequences of withdrawal

If you withdraw this contract, we will refund you all payments we have received from you immediately and no later than fourteen days from the day on which your notice of withdrawal of this contract reached us. We will use the same means of payment you used for the original transaction, unless you and we have expressly agreed otherwise; in no case will you be charged fees for this refund.

If you requested the service to begin during the withdrawal period, you must pay us a reasonable amount corresponding to the proportion of services already provided up to the point when you inform us of your withdrawal from this contract, compared to the total scope of services agreed in the contract.

Model withdrawal form

(If you wish to withdraw from the contract, please complete this form and send it back.)

To MessingerDesign, Philipp Messinger & Werner Messinger GbR, Dahmestraße 10, 12526 Berlin, Email: pmessinger@messingerdesign.de:

– Hereby I/we (*) revoke the contract concluded by me/us (*) for the provision of the following service (*)

– Ordered on (*) / Received on (*)

– Consumer's name

– Consumer's address

– Consumer's signature (only if sending by paper)

– Date

(*) Delete incorrect text.

§ 13 Availability, maintenance, no SLA

(1) The provider endeavours to maintain the highest possible service availability but, unless a separate availability commitment (service-level agreement) has expressly been agreed, guarantees no specific availability. Such a commitment exists only where it has been agreed in writing for a particular plan.

(2) The provider may temporarily restrict or suspend the service to carry out maintenance, security, or update activities. Planned maintenance work will, where reasonably possible, be announced in advance and scheduled during periods of low usage.

(3) Temporary disruptions or outages caused by circumstances beyond the provider’s control (including force majeure, telecommunications network failures, third-party service outages, regulatory actions, or delivery issues with the recipient’s email provider) do not give rise to any claim by the user; rights under § 14 remain unaffected.

(4) The provider does not guarantee that notification or code emails reach the recipient; delivery depends on factors outside the provider’s control (e.g. spam filters, incorrect addresses, recipient’s provider).

§ 14 Liability

(1) The provider is liable unlimited

a) in cases of intent and gross negligence,

b) for damages resulting from the violation of life, body, or health, based on an intentional or negligent breach of duty by the provider or one of its legal representatives or agents,

c) within the scope of an explicitly assumed guarantee, to the extent agreed, and

d) in accordance with the mandatory provisions of the Product Liability Act (ProdHaftG).

(2) In the case of slightly negligent in the breach of a essential contractual obligation (cardinal obligation) — i.e. a duty whose fulfilment is essential to the proper performance of the contract and on which the user may reasonably rely — the provider’s liability is limited to the contractual, foreseeable damage arising from the contract.

(3) Otherwise, the provider's liability for damage caused by slight negligence is excluded.

(4) To the extent the provider’s liability is excluded or limited under the preceding paragraphs, this also applies to the personal liability of the provider’s legal representatives, shareholders, employees and agents.

(5) The shift in burden of proof to the detriment of the user is not linked to the provisions set out above.

(6) Special feature of the free basic version: In the case of free use (Free), the provider is not liable — beyond the cases specified in para. 1 (intentional conduct, gross negligence, life, body, health, warranty, Product Liability Act) — for any other claims. In particular, the provider is not liable for minor negligence in the free tier; statutory liability limitations for free services remain unaffected.

(7) The liability provisions set out above apply equally to consumers and business users, unless explicitly differentiated. Mandatory statutory liability provisions, in particular the consumer-protective regulations under §§ 327 et seq. BGB for paid digital services, remain unaffected.

§ 15 Liability for data loss; responsibility for keys and one-time codes

(1) The user acknowledges that, due to its architecture (Section 4, Section 5), the service is designed for short-term, self-erasing transmission and does not offer the user no data backup or recovery service for transmitted content. The provider maintains operational safeguards solely for restoring the Service's after a failure (Section 5, Paragraph 3); no user claim to recover individual content arises from this, and due to encryption, such recovery is not technically possible for the provider either.

(2) The provider is not for loss of content resulting from:

a) the retrieval link, key fragment, or one-time code is lost, incorrectly shared, made accessible to third parties, or the user fails to adequately protect their passkey devices, authenticator app, or E2E passphrase,

b) a message was deleted according to the rules of § 5 (retrieval, expiry, deletion),

c) the user failed to make their own backup of the transmitted content.

(3) The user is responsible for backing up any content they send or require prior to sending. Responsibility for securely storing access and decryption means (link, one-time code, password) lies entirely with the user or recipient.

(4) To the extent not otherwise specified, liability for data loss is governed by § 14 accordingly; in particular, liability for data loss caused by the provider’s negligence is limited to the typical recovery cost that would have occurred had the user maintained proper and regular data backups — provided such limitation is permitted under § 14.

(5) Optional add-on features (e.g. inactivity or inheritance functions): To the extent the service offers functions that provide time- or event-triggered release, these are provided as a "best effort" service without any guarantee of a specific outcome. The provider does not warrant that such release will occur at a specific time, in full, or at all. Any further liability is governed by § 14.

§ 16 Data protection

(1) The provider processes personal data in accordance with applicable data protection regulations (in particular GDPR and BDSG). Details regarding processing, legal bases, storage periods, appointed processors, transfers to third countries, and the rights of data subjects are provided in the Privacy policy, accessible at https://schluesselbot.de/datenschutz.

(2) The user acknowledges that the provider cannot technically access or view stored encrypted content in security mode or in E2E passphrase secure inboxes, and therefore cannot provide any content-related information or corrections (Art. 11 GDPR). For all other secure inbox levels, separate, time-limited processing and data subject rights apply as described in the privacy policy. Deletion of a specific transaction remains possible at any time by reference to its identifier; otherwise, deletion occurs automatically in accordance with § 5.

(3) Where a business user uses the service such that the provider processes personal data on their behalf, the parties shall conclude a data processing agreement in accordance with Article 28 GDPR; see § 10 para 6.

§ 17 Changes to these Terms and Conditions

(1) The provider reserves the right to amend these terms and conditions with effect for the future, provided this is necessary for a valid reason, particularly due to changes in legal regulations, supreme court rulings, technical developments, changes in service offerings, or to close regulatory gaps, and the user is not unfairly disadvantaged thereby in good faith.

(2) In the case of ongoing recurring contractual relationships, the user will be notified of the revised GTCs at least Six weeks prior to their intended effective date, in written form (e.g. by email). The changes shall be deemed accepted unless the user objects in writing within six weeks of receiving the notice. The provider will specifically draw the user’s attention in the notice to the significance of the deadline, the right to object, and the consequences of silence.

(3) If the user objects in due time, the contract will continue under the previous terms; in this case, the provider is entitled to terminate the contract with effect from the earliest possible date.

(4) Changes to paid services for consumers are additionally governed by §§ 327r, 327m BGB. Substantial, not merely minor, impairments to accessibility or usability entitle the consumer to terminate the contract in accordance with applicable legal provisions.

(5) The above consent procedure does not apply to changes in the main performance obligations or fees; such changes require a separate agreement or are governed by the applicable legal provisions.

§ 18 Final provisions

(1) Applicable law: German federal law applies, excluding the United Nations Convention on Contracts for the International Sale of Goods (CISG). This choice of law is valid for consumers only to the extent that it does not deprive the consumer of the protection conferred by mandatory provisions of the law of the country of their habitual residence (Art. 6 para. 2 Rome I Regulation).

(2) Jurisdiction: If the user is a merchant, a legal entity under public law, a public-law special fund, or does not have a general place of jurisdiction in Germany, the exclusive place of jurisdiction for all disputes arising from or in connection with the contractual relationship is the registered office of the provider in Berlin. Mandatory statutory jurisdictions, in particular for consumers, remain unaffected.

(3) Consumer dispute resolution (§ 36 VSBG): The provider is neither willing nor obliged to participate in a dispute resolution procedure before a consumer mediation body neither ready nor obliged.

(4) Online dispute resolution: A reference to the former EU Online Dispute Resolution (OS) platform is no longer applicable; the platform was discontinued as of 20 July 2025. Therefore, no link is provided.

(5) Written form/Text form: Amendments and additions to this contract require text form. This also applies to the revocation of this text form requirement. Individual agreements in specific cases (§ 305b BGB) take precedence.

(6) Savings clause: If individual provisions of these terms and conditions are wholly or partially invalid or unenforceable, this does not affect the validity of the remaining provisions. In place of any invalid or unenforceable provision, the applicable legal provisions shall apply. For consumers, § 306 BGB applies; no reduction of validity to the detriment of the consumer shall occur.

*These GTC are available for retrieval and storage at https://schluesselbot.de/agb.*