Privacy Policy – E-Rechnung Deutschland
Last updated: 21 October 2026
E-Rechnung Deutschland · aoex · https://aoex.be/ · Deutsch
1. Who we are
E-Rechnung Deutschland (the “App”) is published by aoex (https://aoex.be/). Contact for any privacy question: contact@aoex.be.
2. Roles
For the data of the merchant who installs the App (the “Merchant”), aoex is the controller. For the data of the Merchant’s customers that the App processes to issue invoices, the Merchant is the controller and aoex acts as processor on the Merchant’s behalf (Art. 28 GDPR), under the data processing terms in section 8 of our Terms of Service.
3. Data we process
| Category | Data | Source |
|---|---|---|
| Merchant account | Shop domain, Shopify access token (session), e-mail and name of the staff member who opens the App | Shopify, at installation and login |
| Merchant settings | Company name, address, VAT ID (USt-IdNr.), tax number (Steuernummer), contact details, IBAN, invoice number prefixes, chosen format, e-mail subject and text | Entered by the Merchant in the App |
| Customer and order data | Order number and lines, prices, taxes, discounts, shipping, refunds and cancellations; buyer name, e-mail, billing and shipping address, company name, VAT ID, Leitweg-ID (public-sector buyers) | Shopify Admin API (scopes read_orders, read_customers) and order webhooks |
| Invoices | Issued invoices and correction invoices (PDF/A-3 and XML), validation reports, SHA-256 checksums, audit log of actions | Generated by the App |
| Technical data | Webhook identifiers, server logs (IP address, time, request path) kept for security and troubleshooting | Hosting provider |
The App does not use advertising, tracking or analytics cookies. Inside the Shopify admin it uses Shopify session tokens only. It does not sell or rent any data and does not use it to train models.
4. Purposes and legal bases
- Creating, validating, numbering, storing and sending invoices and correction invoices for the Merchant’s orders: performance of the contract with the Merchant (Art. 6(1)(b) GDPR) and, for the Merchant, its legal invoicing duties (§ 14 UStG; Art. 6(1)(c) GDPR).
- Keeping issued invoices unchanged for the legal retention period: legal obligation (§ 147 AO, § 14b UStG; Art. 6(1)(c) and Art. 17(3)(b) GDPR).
- Security, backups, prevention of abuse and support: legitimate interest (Art. 6(1)(f) GDPR).
5. Service providers (sub-processors)
| Provider | Purpose | Location / safeguards |
|---|---|---|
| Shopify | Platform on which the App runs; source of order data | Per Shopify’s own terms |
| Fly.io, Inc. | Hosting of the App, its database (PostgreSQL) and the KoSIT validator | Region Frankfurt (fra), Germany; US company: EU Standard Contractual Clauses / Data Privacy Framework |
| Tigris Data, Inc. | Object storage of invoice files (PDF/XML) and encrypted daily database backups | EU storage requested; US company: EU Standard Contractual Clauses |
| Resend (Plus Five Five, Inc.) | Sending invoice e-mails to buyers when the Merchant enables it | US company: EU Standard Contractual Clauses / Data Privacy Framework |
We tell Merchants about any change of sub-processor at least 30 days in advance by e-mail or in the App.
6. Retention
- Issued invoices and correction invoices, the seller details they contain and their audit log: 10 years from the end of the calendar year of issue (German retention rules, § 147 AO, § 14b UStG). They cannot be modified or deleted during that time, even after the App is uninstalled; after uninstallation they are no longer reachable through the App but can be requested by the Merchant at contact@aoex.be.
- Drafts and documents that were never issued: deleted on a customers/redact or shop/redact request.
- Sessions and access tokens: deleted when the App is uninstalled.
- Encrypted database backups: 35 days.
- Server logs: kept by the hosting provider for a short period (typically up to 30 days).
7. Shopify privacy webhooks
The App implements Shopify’s mandatory privacy webhooks:
- customers/data_request: the data held about the customer is compiled and made available to the Merchant in the App.
- customers/redact: personal data in drafts and unissued documents is erased; issued invoices are kept because the law requires it (Art. 17(3)(b) GDPR).
- shop/redact (48 hours after uninstallation): sessions, drafts and e-mail texts are erased; issued invoices are kept for the legal retention period.
8. Security
- HTTPS for all traffic; signed (HMAC) webhooks are verified.
- Data separated by shop; issued invoices are write-once (database triggers and conditional storage writes).
- Daily encrypted backups to a separate bucket; restore tests.
- Access limited to the aoex team members who need it, with two-factor authentication.
How security incidents are handled: https://aoex.be/en/e-rechnung/security-incidents. How data loss is limited: https://aoex.be/en/e-rechnung/data-loss.
9. Your rights
You may request access, rectification, erasure, restriction, portability or object to processing, within the limits of the legal retention duties above. Buyers of a shop should contact the Merchant first, who is the controller of their data; we assist the Merchant. Write to contact@aoex.be. You may also lodge a complaint with a data protection supervisory authority.
10. Changes
We will publish any change on this page and update the date above. Material changes are announced to Merchants in advance.
aoex · contact@aoex.be · https://aoex.be/
