Privacy Policy — Franzl-App
Last updated: July 2026 Controller: franzdesign FlexCo, Pfeilgasse 7, 1080 Vienna, Austria (FN 664047s, Commercial Court Vienna), represented by Franz Dinhobl (Managing Director) Email: hi@getfranzl.com
1. Overview
Franzl-App ("App") optimizes energy consumption in your home. This privacy policy explains how we process personal data under the GDPR (EU 2016/679) and the Swiss FADP.
2. Data We Process
Account Data
- Email address (login, notifications)
- Display name
- Authentication via Firebase Auth (Email/Password, Google, Apple Sign-In) — password management is handled by Google Firebase; we do not store passwords
Household Data
- Household name, timezone, location (lat/lon for solar forecast)
- Household members (email, role)
- Tariff configuration (electricity price, feed-in tariff)
Device Data
- Device categories (PV, battery, EV charger, heat pump, etc.)
- Power values (watts, kWh, SOC percent, temperature)
- Entity mappings to Home Assistant, manufacturer and model (where detected)
Energy Data (Time Series)
- Solar production, grid import/export, battery charge/discharge
- Home consumption, EV charging power, electricity prices (current + forecast)
- Storage: Exclusively on your local Home Assistant installation (the Franzl Gateway) — local-first architecture
Usage Data
- App version, platform (iOS/Android)
- Pseudonymized telemetry events (feature use, errors) — no clear name, opt-in consent at first launch, revocable anytime in settings
- Push notification token
Vehicle Data (optional, when a vehicle API is connected)
- Vehicle name, type, battery capacity
- SOC (state of charge) via the vehicle cloud API
- API token (encrypted with AES-256-GCM, stored locally on your installation)
3. Legal Basis
| Processing | Legal basis |
|---|---|
| Account management | Art. 6(1)(b) GDPR (performance of a contract) |
| Energy optimization | Art. 6(1)(b) GDPR (performance of a contract) |
| Push notifications | Art. 6(1)(a) GDPR (consent) |
| Telemetry & crash reports (pseudonymized) | Art. 6(1)(a) GDPR (consent); § 165(3) TKG 2021 — revocable anytime |
| Solar forecast (location) | Art. 6(1)(b) GDPR (performance of a contract) |
| Vehicle API connection | Art. 6(1)(a) GDPR (consent) |
| Website server logs | Art. 6(1)(f) GDPR (legitimate interest in secure operation) |
4. Local-First Architecture
Your energy data never leaves your home.
- All time-series data (power, consumption, production) is stored exclusively on your local Home Assistant installation (the Franzl Gateway)
- Optimization runs entirely locally — no cloud computing
- Remote access uses Cloudflare Tunnel — an encrypted tunnel directly to your Franzl Gateway, with no intermediate server of ours; Cloudflare forwards connections and stores no energy data
5. Installer Access
If you commission an installer for setup or maintenance and assign them a corresponding role (installer/admin) in the App, they can access the device, status and live energy values of your household (e.g. for device discovery, diagnostics, remote maintenance). Access is limited to the households assigned to them, is logged, and never includes your account password. You can revoke the role at any time. The installer is separately responsible under data protection law for their own service.
6. Cloud Services (Minimal)
| Service | Purpose | Data | Provider |
|---|---|---|---|
| Firebase Auth | Login, token management | Email, auth token | Google (EU servers, SCCs) |
| Firebase Cloud Messaging | Push notifications | Push token, message text | Google (EU servers, SCCs) |
| Firebase Crashlytics | Crash reports (only with consent) | Pseudonymized crash logs, device model, install ID | Google (EU servers, SCCs) |
| Cloud Firestore | Gateway health sync, subscription status, device verification statistics (see 6a) | Household status, subscription tier, aggregated device reliability counters | Google (EU servers, SCCs) |
| Cloudflare Tunnel | Remote access | Connection data (no content) | Cloudflare (global edge, EU-compliant) |
| Forecast.Solar | Solar forecast | Location (lat/lon), PV output | Forecast.Solar (EU) |
| RevenueCat | In-app purchases | Purchase ID, subscription status | RevenueCat (US, EU-US DPF) |
| Vehicle API (Tesla Fleet API / Volkswagen Group) | Read vehicle SOC, optional charge control | Vehicle SOC, capacity, encrypted API token | Tesla (US) / Volkswagen (EU) — only when you connect your vehicle (opt-in) |
6a. Device Verification Statistics (Product Quality and Safety)
So that we can reliably tell whether control of specific device brands and models works in the field (and fix defects before they cause harm), your Franzl Gateway transmits a daily aggregated verification statistic to our cloud (Cloud Firestore, EU servers):
- What is transmitted: per detected device profile (manufacturer/model class, e.g. "wallbox brand X") cumulative counters — how many control commands were sent, confirmed or failed, and how many optimizer decisions were confirmed by measurement.
- What is NOT transmitted: no energy time series, no readings, no timestamps of individual events, no device names you assigned, no location data.
- What it reveals: the statistic shows which device brands are operated in your household — not when or how you use them.
- Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in the product safety and defect resolution of a system that switches physical devices (heating, vehicle charging). You may object at any time (Art. 21 GDPR, contact see section 2); transmission is then disabled for your household.
7. Transfers to Third Countries
- RevenueCat (USA): Where the provider is certified under the EU-US Data Privacy Framework (DPF), transfers rely on the EU Commission's adequacy decision of 10 July 2023 (Art. 45 GDPR); additionally or otherwise on Standard Contractual Clauses (SCCs) under Art. 46(2)(c) GDPR including a transfer impact assessment.
- Google (Firebase): Processing primarily on EU servers; where a transfer to the US occurs, Google Ireland Ltd./Google LLC is certified under the EU-US DPF (Art. 45 GDPR), complemented by SCCs.
- Tesla (Vehicle API, USA): Only relevant if you actively connect a Tesla vehicle. This transfer is based on your explicit consent (Art. 49(1)(a) GDPR) given when connecting the vehicle; you can revoke it at any time by disconnecting the vehicle.
- No server of our own — auth via Firebase (EU servers), remote access via Cloudflare Tunnel.
8. Data Retention
| Data | Duration |
|---|---|
| Account data | Until account deletion |
| Energy data (local) | Unlimited, on your installation (you control deletion) |
| Solar forecasts (local) | 60 days (training data for the local forecast correction, automatic cleanup) |
| Device verification statistics (cloud) | For the lifetime of the household; removed with household deletion |
| Push token | Until sign-off |
| Telemetry events | 90 days |
| Subscription data | Until contract end + statutory retention periods |
| Email enquiries | Until the matter is conclusively dealt with, then deleted (unless a statutory retention obligation applies) |
9. Your Rights (GDPR Art. 15–22)
- Access (Art. 15), rectification (Art. 16), erasure (Art. 17: account + all cloud data), portability (Art. 20: export as JSON), objection (Art. 21), withdrawal of consent (Art. 7(3): push, vehicle API, telemetry — anytime)
- Account deletion: directly in the App (More → Delete account) or via getfranzl.com/account-loeschen
- Contact: hi@getfranzl.com
- Supervisory authority: Austrian Data Protection Authority (Österreichische Datenschutzbehörde), Barichgasse 40-42, 1030 Vienna, dsb@dsb.gv.at
10. Data Security
- TLS 1.3 for all connections
- Firebase ID token with short expiry (1 hour, auto-renewed)
- Authentication via Firebase Auth (password management by Google)
- Vehicle API tokens: AES-256-GCM encrypted, stored locally on your installation
- No local storage of passwords
- Regular security updates (OTA)
11. Cookies & Tracking
The App uses no cookies and no tracking (no Google Analytics, no Facebook Pixel, no advertising SDKs). The getfranzl.com website also sets no cookies, so no cookie banner is required.
12. Website Hosting
The getfranzl.com website is hosted by Hostinger (Hostinger International Ltd., EU data centres). The web server processes technically necessary connection data (IP address, timestamp, requested page, user agent) in server log files (Art. 6(1)(f) GDPR — secure operation). Logs are automatically deleted after a short period.
12a. Email Communication
When you write to us at hi@getfranzl.com, we process your sender address and the content of your message in order to handle your request. The legal basis is Art. 6(1)(b) GDPR for contract and support enquiries, Art. 6(1)(c) GDPR where you exercise your data subject rights (section 9), and otherwise Art. 6(1)(f) GDPR (responding to enquiries).
The mailbox is operated by Hostinger (Hostinger International Ltd., EU data centres) as a processor. Transport is TLS-encrypted where the sending server supports it; there is no end-to-end encryption. Please do not send us passwords.
13. Changes
Changes to this privacy policy are shown in the App. For material changes we will inform you by email.
Last updated: July 2026 (EU-US DPF, pseudonymization, installer access, legal-basis table, named vehicle providers)