Privacy Policy
1. Controller
BrightComb, owner Gor Gevorkjan, Teichmummelring 65, 12527 Berlin, Germany, email hello@brightcomb.com.
2. Principle
We process as little data as possible. There are no ad trackers, no analytics cookies and no sale of data. The calculators work without an account; calculator inputs are not stored, except that Pro calculations are sent to our server and discarded immediately after the response.
3. Hosting and server logs
The site is hosted by Vercel Inc. (USA). On access Vercel processes technically necessary data (IP address, time, requested URL, user agent) in server logs that are deleted after a short period. Legal basis: Art. 6 (1) (f) GDPR (operation and security). Vercel is certified under the EU-US Data Privacy Framework; standard contractual clauses are in place in addition.
4. Cookies
We only set technically necessary cookies that require no consent (§ 25 (2) German TDDDG): language and currency (12 months), sign-in session (30 days, only when signed in) and a “counted today” marker (24 hours, no content, see 5). There is no cookie banner because there is nothing to consent to.
5. Anonymous country statistics
To see which regions show interest, at most once a day per browser we increment a counter for the country of the request. Our hosting derives the country from the network zone; we do not store the IP address. Only the country code and a number are stored. No person can be identified; the statistics are public at /honeycomb/stats.
6. Account and sign-in
For Pro access we store your email address, the account creation time, the expiry date of Pro access, the Stripe payment reference and your preferred language. Sign-in links are valid for 15 minutes and deleted afterwards. Legal basis: Art. 6 (1) (b) GDPR (contract). Storage: Upstash Redis, Frankfurt data centre (Upstash Inc., processor with standard contractual clauses). Retention: until you ask us to delete the account, at the latest three years after the last Pro access expired.
7. Payment
Payments are processed by Stripe Payments Europe Ltd. (Ireland). Stripe receives your payment details and email address and processes them as an independent controller, including for fraud prevention. We receive no full card data from Stripe, only payment status, amount, currency and reference. Legal basis: Art. 6 (1) (b) GDPR. We log your consent to immediate performance (§ 356 (5) BGB) with a timestamp and keep it for three years (Art. 6 (1) (c) and (f) GDPR, burden of proof). Stripe's privacy notice: stripe.com/privacy.
8. Email
Sign-in links and order confirmations are sent via Resend Inc. (USA, processor with standard contractual clauses). Recipient address, subject, content and delivery status are processed. We send no marketing emails. You receive a reminder before Pro access expires only if you opted in within your account.
9. Market data
Market data is fetched by our server from public sources (FRED, Yahoo Finance). No user data is transmitted in the process.
10. Your rights
You have the right of access, rectification, erasure, restriction, data portability and objection (Art. 15 to 21 GDPR) and the right to lodge a complaint with a supervisory authority, e.g. the Berlin Commissioner for Data Protection and Freedom of Information. We delete account and data on an informal email to hello@brightcomb.com, unless retention obligations apply (invoice data: ten years, § 147 German Fiscal Code).
11. Security
Transmission is encrypted only (TLS). Accounts have no password, so no password leaks. Sign-in and calculation endpoints are rate limited.