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Security & Data Protection

Security you can verify.

A naturalization or residence procedure is one of the most sensitive administrative matters there is. That is why we host in Germany, additionally encrypt application data at the application layer, and disclose every service provider we use — all documented on this page.

Hosting in GermanyAES-256-GCM at the application layerData subject rights via self-service
Category 01

Hosting & Architecture.

The civitas. platform — application, database, and document uploads — runs on servers operated by Hetzner Online GmbH in Germany. Individual, clearly delimited functions use specialized service providers in the EU and the USA — fully disclosed in Category 03.

Server location
Hetzner Online GmbH, Nuremberg — an ISO/IEC 27001-certified German data center operator. Application, database, and uploads reside on servers in Germany.
Data location
Application and account data are stored in Germany. Where individual service providers process data in the USA (email delivery, error telemetry, AI document analysis, usage analytics), this takes place on the basis of the safeguards under Art. 44 ff. DSGVO — transparently shown in the service-provider register.
Encrypted storage
Sensitive application data are encrypted at the application layer with AES-256-GCM before storage — access to the database alone reveals no readable personal data. Details in Category 02.
Account & deletion
You can delete your account and its data yourself (Art. 17 DSGVO) — directly in your account, without a separate request. Statutory retention obligations (e.g. accounting) remain unaffected.
Backups
The database is backed up automatically every day.
Category 02

Encryption.

Encryption takes place in transit and at rest. Sensitive application data are additionally encrypted at the application layer, so that even direct access to the database without the application key shows only ciphertext.

Transport (in transit)
All data traffic runs exclusively over HTTPS/TLS. HSTS is active with max-age=31536000; includeSubDomains; preload — browsers permanently enforce the encrypted connection.
Application layer (at rest)
Sensitive application data are stored encrypted with AES-256-GCM at the application layer. Anyone who sees only the database sees ciphertext — not your data.
Key management
The application key (256-bit) is managed separately from the database and code in the server configuration. Without an explicitly set production key, the application refuses to start — operating with a placeholder key is technically impossible.
Authentication
Passwordless sign-in via magic link: the login link is valid for 30 minutes; only a SHA-256 hash of the token is stored — the link itself cannot be reconstructed from the database. No password that could be stolen.
Category 03

Service Providers & Data Processors.

civitas. uses a small number of clearly delimited service providers — each with a defined purpose. If a provider processes data in the USA, we disclose this openly; such transfers are safeguarded by the guarantees under Art. 44 ff. DSGVO (EU Standard Contractual Clauses or the EU-US Data Privacy Framework).

Hetzner Online GmbH
Hosting · Database · Uploads
Purpose: Server infrastructure
Location: Nuremberg (DE)
Germany
Stripe Payments Europe Ltd.
Payment processing
Purpose: Card payments
Location: Dublin (IE)
EU
Plausible Insights OÜ
Web statistics
Purpose: Cookieless, aggregated statistics
Location: Tallinn (EE)
EU
Postmark (AC PM LLC)
Transactional emails
Purpose: Magic link · Service emails
Location: USA
USA
Anthropic, PBC
AI document analysis (Claude API)
Purpose: Analysis of uploaded letters & documents
Location: USA
USA
Sentry (Functional Software, Inc.)
Error telemetry
Purpose: Application error logs
Location: USA
USA
Microsoft Corporation
Microsoft Clarity
Purpose: Website usage analytics
Location: USA
USA

This register is updated whenever a change occurs. Details on the purposes, legal bases, and storage periods for each service provider are set out in the Privacy Policy.

Category 04

Data Processing.

Two roles, clearly separated: toward private customers, civitas. is the controller under Art. 4 Nr. 7 DSGVO — with our service providers we have agreements under Art. 28 DSGVO insofar as they act as processors. For institutional partners (law firms, advisory centers), civitas. acts as a processor under Art. 28 DSGVO on the basis of a data processing agreement.

Role clarity
For private customers, civitas. is the controller — the Privacy Policy applies, and a data processing agreement is not required. civitas. acts as a processor only toward institutional partners.
Bound by instructions
In the processing relationship, civitas. processes personal data exclusively in accordance with the documented instructions of the controller (Art. 28 Abs. 3 lit. a DSGVO).
Deletion & return
After the end of the processing, personal data are deleted or returned at the controller's choice (Art. 28 Abs. 3 lit. g DSGVO).
Subprocessor transparency
The service-provider register in Category 03 is publicly accessible. Contractual partners are informed of intended changes and may object (Art. 28 Abs. 2 DSGVO).
Data processing agreement on request
Data processing agreement under Art. 28 DSGVO.
Law firms and advisory centers receive our data processing agreement on request — for preliminary review by data protection officers and legal departments, tailored to your requirements where needed.
Basis: Art. 28 DSGVOProvision: On request by emailAudience: Law firms & advisory centers

For private customers who use civitas. themselves, civitas. is the controller under Art. 4 Nr. 7 DSGVO — here the Privacy Policy applies, not a data processing agreement.

Category 05

Data Subject Rights.

You can exercise your rights under the DSGVO toward civitas. at any time — informally, free of charge, and without giving reasons. We process requests within the statutory period of one month (Art. 12 Abs. 3 DSGVO).

01
Right of access
Art. 15 DSGVO
Which personal data we process, for which purposes, and to which recipients they are passed on — on request you receive a complete overview.
02
Right to rectification
Art. 16 DSGVO
Correction of incorrect or incomplete data — can be done directly in your account yourself or by email to kontakt@einbuergerungsservice.de.
03
Right to erasure
Art. 17 DSGVO
Complete deletion of your data, provided no statutory retention periods stand against it (e.g. accounting). Can be triggered directly in your account under “Settings → Delete account”.
04
Right to restriction
Art. 18 DSGVO
Have the processing of your data restricted in certain cases — for example, while the accuracy of the data is being verified.
05
Data portability
Art. 20 DSGVO
Export of your application and account data in a structured, machine-readable format (JSON) — on request by email, after identity verification, within one month.
06
Right to object
Art. 21 DSGVO
Objection to processing based on legitimate interests — against direct marketing, the objection applies without exception.
How to reach us: by email to kontakt@einbuergerungsservice.de. Independently of this, you can lodge a complaint with the competent supervisory authority at any time (Art. 77 DSGVO): Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW), Kavalleriestr. 2-4, 40213 Düsseldorf.
Category 06

Incident Response.

In the event of a personal data breach, the following applies: notification of the competent supervisory authority (LDI NRW) without undue delay and, where feasible, within 72 hours under Art. 33 DSGVO — and, where a high risk is likely, notification of the affected individuals without undue delay under Art. 34 DSGVO.

Procedure for security incidents.

Detect, contain, report, review — in that order. Affected individuals and the supervisory authority are informed as early and as transparently as the state of the investigation allows.

Immediately
Detect & contain. Affected systems are isolated, access is secured, and further spread is prevented.
≤ 72 hrs
Notification of the supervisory authority (LDI NRW) for reportable incidents — without undue delay, where feasible within 72 hours (Art. 33 DSGVO).
Without undue delay
Notification of the affected individuals where a high risk to their rights and freedoms is likely (Art. 34 DSGVO).
Afterward
Root cause analysis & consequences. The incident is fully reviewed, and measures are implemented and documented.
Category 07

Compliance.

An honest status instead of compliance theater: what applies today and what comes next — clearly separated into Met and Planned.

Met
DSGVO / BDSG
Processing of personal data in accordance with the DSGVO and BDSG — with data subject rights via self-service, a transparent service-provider register, and encryption at the application layer.
Met
§ 19 TDDDG
Technical measures for digital services under § 19 Abs. 4 TDDDG: protection against unauthorized access and the use of encryption methods recognized as secure.
Met
RDG boundary
We provide software-assisted application and form-filling support.
Met
Third-country transfers
US service providers only with guarantees under Art. 44 ff. DSGVO (EU Standard Contractual Clauses or the EU-US Data Privacy Framework) — openly disclosed in Category 03.
Planned
ISO/IEC 27001
Certification of information security management — planned as the next development step for the platform.
Planned
BSI C5
The BSI's Cloud Computing Compliance Criteria Catalogue — relevant for cooperation with public administration.
Responsible

A direct line for security and data protection.

For data protection inquiries, security reports, and questions about our architecture. If you suspect a security vulnerability, we ask for a confidential report by email — also available in machine-readable form at /.well-known/security.txt.

Data protection & security

Civitas UG (haftungsbeschränkt)

Data protection inquiries
Address
Breite Straße 22, 40213 Düsseldorf
Supervisory authority
LDI NRW, Kavalleriestr. 2-4, 40213 Düsseldorf