Diesen Artikel auf Deutsch lesenText Module for Your Privacy Policy · Effective August 4, 2026
You use Komfortkasse to reconcile your postings. Under data protection law, you are responsible for this processing; Komfortkasse is your data processor. This means that you —not us—must inform your customers of this.
The following text block covers this. It is intentionally kept brief and refers to our privacy policy for details.
Please include it. Part of the processing described is based on a legitimate interest under Article 6(1)(f) of the GDPR, and this interest must be communicated to the data subjects—otherwise, the processing lacks a legal basis. The European Court of Justice has expressly ruled on this (judgment of January 9, 2025, C-394/23).
The text block
To be inserted as a separate section in your privacy policy, preferably after the section on orders and payments.
Payment Processing via KomfortkasseFor payments made by prepayment, invoice, and Cash on delivery, we use Komfortkasse, a service provided by LTC Information Services GmbH, Amraser Str. 119, 6020 Innsbruck, Austria. Komfortkasse reconciles postings with orders on our behalf. Depending on the services we have commissioned, Komfortkasse may also send Payment information after your order is placed and handle payment reminders, Pre-collection letters, and refunds. Komfortkasse acts as our data processor in this context; we remain responsible for the processing. If a payment cannot be automatically assigned to an order and the name of the payer is divergent from the name of the person who placed the order—for example, because a family member, your employer, or your own company paid on your behalf—Komfortkasse may clarify the specific case using publicly available sources: public registries, public business, subscriber, and address directories, as well as general search engines. This is done only if clarification appears likely to be successful. Artificial intelligence is also used in the search process and when evaluating the results; however, the decision as to which payment belongs to which order is always made by a human. The specific details determined during this process are not saved and are not disclosed to us; we are only informed which payment belongs to which order. Komfortkasse also performs statistical analysis of postings on our behalf to measure and improve the quality of payment reconciliation—including in comparison with simpler matching methods. The results consist exclusively of aggregated metrics that do not contain any personal references. The legal basis for both is Article 6(1)(f) of the GDPR. Our legitimate interest is to correctly and quickly assign incoming payments to the appropriate order: Otherwise, your order would not be shipped, you would receive reminders and pre-collection letters despite having paid the invoice, and your payment would have to be refunded to the sender’s account. Details regarding which specific data is processed, which sources are excluded, where the data comes from, how long it is saved, and to whom it is disclosed can be found in Komfortkasse’s Privacy Policy: komfortkasse.eu/datenschutz |
The Right to Object Section
This section must be separated from the rest of the text and highlighted —as a separate box, a separate section, or in bold—not as the last sentence in the running text. This is expressly required by Article 21(4) of the GDPR.
Your Right to ObjectYou have the right to object at any time, on reasons relating to your particular situation, to the processing described above, insofar as it is based on Article 6(1)(f) of the GDPR (Article 21(1) of the GDPR). We will then no longer process your data unless we can demonstrate compelling legitimate reasons for the processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims. Please send your objection informally to [your contact address]. |
Installation Notes
“We” always refers to you. Throughout this module, “we” refers to your shop, and “Komfortkasse” refers to us. Please keep this in mind when adapting the text. The difference is not merely linguistic: When clarifying unassignable payments, you as the merchant will only learn which payment belongs to which order—not what else was determined in the process. Text that blurs this distinction implies a greater intrusion than actually occurs.
The dispute goes to you, not to us. You are responsible; that’s why your address is listed there. If someone contacts us directly, we’ll redirect it to you.
Customize services if you want to be precise. The second sentence refers to payment information, payment reminders, Pre-collection letters, and refunds as “depending on which services we have commissioned.” This ensures the module is correct for any configuration. You can also remove the services you do not use—but you should not add anything that does not actually take place.
What you shouldn’t outsource to our pages. Four points belong in your own statement and not behind the link: that case-by-case verification may take place in public sources, the specifically named legitimate interest, your identity as the data controller, and the right to object. Everything else—data categories, excluded sources, data origin, retention period, remittees—is included in our privacy policy and covered by the link.
If you prefer the full text without a link— for example, because you do not link to external pages in your privacy policy—we will provide it upon request.
Questions
Questions about this module: datenschutz@Komfortkasse.eu
These texts are intended as drafting guides and do not constitute legal advice. Whether and how they fit into your privacy policy depends on its structure and your specific configuration.