Privacy Policy

This Privacy Policy explains how Yanay Brook, trading as “Montella” (“Montella”, “we”, “us”), processes personal data when you visit our website, communicate with us, or use the Montella platform and AI agents (together, the “Service”). We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

1. Controller and Contact

Controller (Verantwortlicher): Yanay Brook, trading as “Montella”, Oskar-Helene-Park 36, 14195 Berlin, Germany.

Contact for data protection matters: team@montella.dev. Full provider details are in our Impressum at https://montella.dev/impressum.

We have not appointed a Data Protection Officer, as we are not required to do so under Art. 37 GDPR / § 38 BDSG. You can raise any data protection matter using the contact details above.

2. Scope of this Policy and Our Two Roles

(1) This Policy covers personal data for which Montella is the controller, that is, where we decide why and how data is processed. This includes visitors to our website, people we contact for business development, our business contacts and clients’ representatives, and users of our own accounts and tools.

(2) Where we act only as a processor, that is, where we run our AI agents or platform on data provided by a business client, the client is the controller and decides the purposes of processing. That processing is governed by a data processing agreement (Auftragsverarbeitungsvertrag, Art. 28 GDPR) between us and the client, not by this Policy. If you are an individual whose data a client processes through the Service, please contact that client to exercise your rights (see Section 10).

3. Your Data Protection Rights

Where Montella is the controller, you have the following rights, subject to the conditions in the GDPR:

Right to complain (Art. 77): You may lodge a complaint with a supervisory authority. The authority competent for Montella is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit, BlnBDI), Alt-Moabit 59–61, 10555 Berlin.

4. Website Use and Hosting

(1) When you visit our website, our hosting providers automatically process server log data, including your IP address, browser type and version, the pages you visit, and the date and time of access. This is necessary to deliver the website securely and reliably.

(2) Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in operating a secure, functioning website. Retention: server logs are retained for 30 days and then deleted.

(3) Our website and our platform are hosted by Vercel, Inc. (USA); the platform database is operated by Neon, Inc. in the EU (Frankfurt). Transfers to the USA are protected by the EU Standard Contractual Clauses (see Sections 14–15). Fonts are served from our own domain; no request is made to Google Fonts.

(4) Pages of the platform that show a property on a map load the map in your browser from Google Maps Platform (Google LLC, USA), or from the OpenStreetMap Foundation (UK) where Google is not configured. Because your browser fetches the map itself, those providers receive your IP address, your browser's user agent and the area of the map being viewed, and act as independent controllers for that data. Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in showing a property where it stands.

5. Cookies and Consent

(1) We use cookies and similar technologies that are strictly necessary to operate the website and the Service. These do not require consent (§ 25(2) TDDDG; Art. 6(1)(f) GDPR).

(2) Google Analytics: on montella.dev we use Google Analytics 4 (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to see how the website is used, and only after you accept it in the cookie bar. Until then, and if you decline, nothing from Google is loaded and no analytics cookie is set. Once accepted, Google sets cookies (`_ga`, `_ga_*`, up to 13 months) and receives your truncated IP address, the pages you view and how you got here; Google may transfer this data to the USA, protected by the EU-US Data Privacy Framework and the EU Standard Contractual Clauses. Legal basis: your consent (§ 25(1) TDDDG; Art. 6(1)(a) GDPR). You can withdraw it at any time through "Cookie settings" in the footer; the cookies are then no longer set. We do not use advertising cookies.

6. Contacting Us

(1) If you contact us by email or leave your address in a form on our website or on the platform (such as the request for access on the login page), we process the data you provide (such as your name, email address and message) to handle your enquiry and any related correspondence.

(2) Legal basis: Art. 6(1)(b) GDPR where your enquiry relates to a contract or pre-contractual steps; otherwise Art. 6(1)(f) GDPR (our legitimate interest in responding to enquiries). Retention: for as long as needed to handle your enquiry and any follow-up, then deleted unless retention is required by law.

7. Business Development and Marketing (B2B)

(1) We identify and contact decision-makers and representatives at businesses in the real estate sector to offer our services. We may use publicly available professional data and business networks (e.g. LinkedIn) and process your name, job title, employer, business contact details, public professional profile and our interaction history with you.

(2) We also send business emails (including reports) and measure delivery, opens and clicks to understand engagement. For this we process your business email address, name, employer and email-engagement data.

(3) Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in B2B direct marketing and in measuring its effectiveness. We keep our outreach targeted and relevant, and § 7 UWG is observed. Retention: prospect data is kept for up to 24 months from the last meaningful contact; email-engagement logs for 12 months; then deleted or anonymised.

(4) Your choice: you can object to this processing at any time (Art. 21 GDPR) using the contact details in Section 1 or the opt-out in our messages, and we will stop contacting you.

8. Business Relationship and Contact Management

(1) We maintain records of our business contacts, prospects and clients’ representatives, including name, role, employer, business contact details, notes, meeting history and deal status, to manage our relationships and pipeline.

(2) Legal basis: Art. 6(1)(f) GDPR (managing business relationships) and, where steps are taken toward a contract at your request, Art. 6(1)(b) GDPR. Retention: for the duration of the business relationship; dormant contacts are reviewed and pruned periodically.

9. The Montella Platform and AI Agents

(1) When you use the Service under your own account, we process your account and usage data (such as your name, business email, role, login and activity data) to provide, secure, maintain and support the Service, and we process the content you submit (“Inputs”) to generate outputs for you.

(2) Legal basis: Art. 6(1)(b) GDPR (performance of the contract for the Service) and Art. 6(1)(f) GDPR (securing and improving the Service).

(3) Sign-in attempts: every attempt to sign in, successful or not, is recorded with the address entered, the IP address, the browser's user agent and the outcome, so that repeated failures on an account or from one address can be refused and looked into. Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in keeping accounts from being broken into. Retention: 90 days, then the row is deleted.

(4) How the Service is used, and improving it: we record which parts of the Service each signed-in user opens and what they do there, with the time and the user's account. For example, which table or record they opened, which field they edited, which file they uploaded, and which tool their connected AI client called and whether it succeeded. We record the names of our own features and the identifier of the record concerned, never what was entered or the value of a field. When we look at these records we see the record by the name the Service shows for it. Only named Montella staff can see these records, and they are never shown to your employer or to anyone in your organisation. Montella's own staff are not recorded. Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in understanding how the Service is used so we can decide what to build and fix. You can object to this at any time under Art. 21 GDPR (see Section 3); we will then stop recording your use for this purpose and delete those records. The log of your AI client's calls stays in your organisation's audit log for its own period (Section 9(6)), and we stop using it for this purpose. Retention: 12 months, then deleted. Beyond that, we may use aggregated and anonymised data, which no longer identifies you or any individual, to analyse and improve the Service. We do not use your Inputs or content to train general-purpose AI models for other customers without your consent.

(5) Where a feature of the Service generates outputs with an AI model, Inputs may be transmitted to a model provider acting on our behalf; where available we use EU endpoints and no-training options. At the date of this Policy the platform itself calls no model provider. Where you connect your own AI client to your workspace (see Section 9(6)), that client is your choice and your recipient.

(6) Your own AI client: the Service can expose your workspace to an AI client you operate (for example Claude, ChatGPT or Cursor) through a connection you create and can revoke. Data that client reads is sent to its provider under that provider's terms and your agreement with them; we log each call (who, when, which tool, how many records) and keep the fields that can name a person for 10 days and the rest for 12 months. The user, time, tool, outcome and record count of each call, never its arguments, are also part of the usage records described in Section 9(4).

10. Where We Act as a Processor for Business Clients

(1) A core part of the Service is running AI agents and workflows on data provided by our business clients (for example, letting and outreach support, reporting, and back-office automation). In that case the client is the controller and Montella is the processor. We process such personal data only on the client’s documented instructions under an Art. 28 GDPR data processing agreement.

(2) For that processing, the client's records (for example leases and their parties, bank statement lines and their counterparties, members and contacts) are stored in the client's own workspace in our EU database for as long as the client's agreement provides, and returned or deleted on its instruction. Nothing is pooled across clients. No special categories of personal data (Art. 9 GDPR) are processed unless the client has expressly agreed this in writing with additional safeguards.

(3) Your rights: if you are an individual whose personal data a client processes through the Service, please direct requests to that client as the controller. We will support the client in responding, and will forward any request we receive directly to the relevant client without undue delay.

(4) One exception to the above: the records of how you use the Service described in Section 9(4) are kept by Montella as controller, for its own purpose, and this Policy governs them.

11. Automated Processing and AI Transparency

(1) The Service uses artificial-intelligence models to generate outputs. Outputs are produced by automated means and may be inaccurate or incomplete; they are intended to support, not replace, human decision-making, and are reviewed by a person before being relied upon.

(2) We do not use the Service to make decisions based solely on automated processing that produce legal or similarly significant effects on you within the meaning of Art. 22 GDPR. Where we or our clients would deploy such processing, appropriate safeguards and human oversight are put in place.

(3) Where required by applicable law, including Regulation (EU) 2024/1689 (the EU AI Act), we disclose that content is AI-generated or that you are interacting with an AI system.

12. Accounting, Invoicing and Legal Obligations

(1) To issue invoices, keep our books and meet tax obligations, we process billing and transaction data (such as name, business/billing address, contact and payment data, and invoice data), and share it with our accountant, the tax authority (Finanzamt, via ELSTER), our bank and DATEV, as required.

(2) Legal basis: Art. 6(1)(c) GDPR (legal obligations under the HGB, AO and UStG) and Art. 6(1)(b) GDPR (contract performance). Retention: statutory retention periods apply, generally 8–10 years (§ 147 AO, § 257 HGB).

13. Investor and Other Business Relations

We process contact and correspondence data of investors and other business partners to manage those relationships. Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in these relationships) and Art. 6(1)(b) GDPR for pre-contractual steps. Retention: for the duration of the relationship, then pruned when no longer relevant.

14. Recipients and Sub-processors

We use carefully selected service providers who process personal data on our behalf under data processing agreements (Art. 28 GDPR), and disclose data to statutory recipients where legally required. The main recipients are:

Because our platform processing is transient, several providers process personal data only in transit rather than storing it. We do not sell personal data.

15. International Data Transfers

Some recipients are located outside the EU/EEA (in particular in the USA). Where we transfer personal data to such recipients, we rely on appropriate safeguards under Chapter V GDPR, primarily the EU Standard Contractual Clauses, and, for providers certified under the EU-US Data Privacy Framework, an adequacy decision. You may request a copy of the relevant safeguards using the contact details in Section 1.

16. Data Retention

We keep personal data only as long as necessary for the purposes described above or as required by law. In summary:

17. Data Security

We implement appropriate technical and organisational measures to protect personal data (Art. 32 GDPR), including individual accounts and least-privilege access, strong unique passwords, encryption in transit (TLS), data minimisation, access logging, and a documented process for detecting and handling personal data breaches. We keep these measures under review as the Service develops.

18. No Processing of Children’s Data

The Service is intended for businesses and professionals and is not directed at children. We do not knowingly process the personal data of children.

19. Changes to this Policy

We may update this Policy to reflect changes to the Service or to legal requirements. The current version is always available on our website with the “Last updated” date shown above. Where changes are material, we will take reasonable steps to inform affected users.

20. How to Contact Us

For any question about this Policy or to exercise your rights, contact: Yanay Brook, trading as “Montella”, Oskar-Helene-Park 36, 14195 Berlin, Germany, team@montella.dev.