Impressum, privacy & terms
Last updated 23 September 2026. English version for convenience; the German version prevails once published.
Draft under legal review. This text becomes binding only after a lawyer has checked it.
Impressum (§ 5 DDG)
Unlock Germany is an independent platform with carefully selected partners. Our partners pay us for introductions. It is operated by Pontaro.
Provider
Pontaro
Owner: Artur Jarosiewicz
Rathenower Straße 42, 10559 Berlin, Germany
VAT ID: DE455914223
Pontaro is a sole proprietorship and is not entered in the commercial register.
Contact
Email: info@unlock-germany.de
Phone: +49 151 708 10001
Licences
Unlock Germany and Pontaro hold no licence under §§ 34c, 34d, 34f or 34i of the German Trade Regulation Act (GewO) and do not advise on or broker insurance, investments, pensions, loans or property. That is done only by our partners, under their own licences; each partner gives you its mandatory information, including its registration, before any advice begins. Our partners are listed on the partners page.
Responsible for content (§ 18 Abs. 2 MStV)
Artur Jarosiewicz, at the address above.
Consumer dispute resolution
We are neither willing nor obliged to take part in dispute resolution before a consumer arbitration board (§ 36 VSBG).
Privacy notice (Art. 13 and 14 GDPR)
1. The short version
- Unlock Germany is an intermediary. We explain, give you tools and introduce you to partners. The partner provides the service; we collect and store what is needed to get you there.
- Your data stays in our system. A partner's advisors can open your request there, and only when you book a call or ask for an introduction on that partner's topic. We do not export your data to partners. Reading the site or taking the check shows nothing to a partner.
- Our partners pay us a fee for each introduction. You pay us nothing. We never pass your data to anyone for their own advertising.
- Calculators run on your device. Check answers leave your browser only when you ask us to email your result.
- Analytics, including our page-view statistics and Google Analytics, start only after you accept them, and you can switch them off at any time.
2. Controller and contact
The controller is the provider of Unlock Germany named in the Impressum above: Pontaro, owner Artur Jarosiewicz, Rathenower Straße 42, 10559 Berlin, Germany. Privacy requests: info@unlock-germany.de. We have not appointed a data protection officer, because the law does not require one for a business of our size (§ 38 BDSG); the address above reaches the person responsible.
3. What we process, why, and on which legal basis
3.1 Visiting the site. Our hosting provider processes the technical data of each request (IP address, time, page, browser, referrer) in server logs, to deliver the site and keep it secure. Legal basis: legitimate interest in a working, secure site (Art. 6(1)(f)). When you send us a form or book a call, we note the country of the request and the browser language with it, and estimate a likely country of origin from them for statistics. The estimate is a guess from those two signals, used only to see which countries our audience comes from; it never decides how anyone is treated. Legal basis: legitimate interest in knowing who we reach (Art. 6(1)(f)). The site is hosted in the EU (Frankfurt).
3.2 Necessary cookies and local storage. Your language, your sign-in, your cookie choice, the link to your saved checklist, and what you typed into a tool so it is still there when you return. Stored because the function you use needs it (§ 25(2) TDDDG). List in section 11.
3.3 Page-view statistics, with your consent. If you accept "Analytics" in the cookie settings, we count page views with a random visitor identifier in a first-party cookie (tx_vid, one year). For each page view we store the page path, the country of the request, the browser language and the estimated country of origin (3.1). No name, no email, no cross-site tracking, and it is never joined with the rest of the analytics in 3.4. Without that consent no page view is recorded and the cookie is not set; if you withdraw, we stop and the cookie is deleted. Legal basis: consent (Art. 6(1)(a), § 25(1) TDDDG).
3.4 Analytics, with your consent. If you accept "Analytics" in the cookie settings, three things start: the page-view statistics in 3.3, our own statistics and Google Analytics. Withdraw at any time in the cookie settings, and all three stop. Legal basis: consent (Art. 6(1)(a), § 25(1) TDDDG).
Our own statistics. We record which menu items, buttons and partner links are used, where people click, how far they scroll, device type and screen width, and which version of a page you saw when we test two. It is kept under a separate random identifier (tx_analytics_aid), never with your name or email. Without this consent you always see the standard version of a page and nothing about a test is stored on your device. We run this part ourselves; no advertising network and no outside service is involved.
Google Analytics. Provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, which processes the data for us as our processor under Google's data processing terms (Art. 28). No Google script is loaded and no Google cookie is set before you consent. It runs in Google's Consent Mode: analytics storage is allowed only after your consent, while advertising storage, ad user data and ad personalisation are always refused. Google signals and ad personalisation are switched off, and so is every setting that shares our data with Google (benchmarking, technical support, Google products and services, account specialists). According to Google, Google Analytics does not log or store IP addresses. We see statistics only: pages viewed, approximate location (city and country), device, browser, language, the site you came from, time on a page, scrolling and clicks on links to other sites. Google Analytics sets two cookies (section 11) and keeps the data for 2 months (section 8). Google may transfer data to Google LLC in the United States (section 7). If you withdraw consent, Google Analytics stops and its cookies are deleted.
3.5 Recommendation links. If you arrive through the personal link of a consultant or a member, we note whose link it was. If you accept "Recommendations" in the cookie settings, your browser remembers it for 30 days, so the introduction is credited if you contact us later; legal basis: consent (Art. 6(1)(a), § 25(1) TDDDG), which you can withdraw in the cookie settings at any time. Without that consent nothing is stored on your device: we remember the link only while you are on the site, and if you send us a form during that visit, the request is credited to that consultant. Legal basis for that: our legitimate interest in crediting introductions correctly (Art. 6(1)(f)).
3.6 The free check and your report. The check asks about your situation in broad categories: employment, whether your health insurance is public or private, liability and income cover, pension, employer benefits, housing, tax, investing, career or company plans, and whether you may leave Germany. It does not ask about your health; please do not enter health information anywhere on this site. When you ask us to email your result, we store your email, first name if given, your answers and the result, send a confirmation link, and after you confirm, the result. Our team is told that a result was requested. There are two separate boxes on the form. The first, required, is your consent to the email with your result; legal basis: consent (Art. 6(1)(a)). The second, optional, is your consent to occasional tips by email, the only marketing email we send; legal basis: consent (Art. 6(1)(a), § 7(2) UWG). Leaving it unticked changes nothing about your result. Neither consent covers calls or introductions: those happen only if you book or ask. Withdraw either at any time through the unsubscribe link or by writing to us.
3.7 Tools and the arrival checklist. Calculators compute on your device. Your browser keeps your inputs and which tools you used; neither is sent to us. If you save your checklist, we store your email address and your progress (done, notes, dates, reminders), confirm the address by link, and email the reminders you set. Legal basis: providing the function you asked for under our terms (Art. 6(1)(b)).
3.8 The guide, occasional tips and the community list. Email address, name if given, and for the community list what you tell us about your project. The guide form has two separate boxes: the first, required, is your consent to the email with the guide; the second, optional, is your consent to occasional tips by email, the only marketing email we send. Leaving it unticked changes nothing about the guide, and neither consent covers calls or introductions. You confirm by link and can unsubscribe at any time. Legal basis: consent (Art. 6(1)(a)), for the tips together with § 7(2) UWG; we keep a record of each consent to be able to prove it (Art. 7(1)). Founders Night registration runs on Luma and the community chat on WhatsApp. Your browser contacts them only when you click through; they are services of their own, and in a WhatsApp group other members see your phone number.
3.9 Booking a call. Name, email, topic, language and time slot. We use them to arrange the call and to send the confirmation with a link to reschedule or cancel. Calls are Microsoft Teams meetings created in our Microsoft 365 account, with you and the advisor as attendees. The invitation hides the attendees from each other, so neither of you sees the other's email address in it. Microsoft processes the meeting for us (section 6). We do not record or transcribe calls. Depending on the topic, the call is held by our team or by an advisor of the partner for that topic; the booking form names who the call is with before you confirm. The advisor receives your first name and the topic through our backoffice notification (section 5). Legal basis: providing the service you asked for under our terms (Art. 6(1)(b)). Afterwards we may email you once to ask how the call went, because that helps us assess our partners. Legal basis: our legitimate interest in the quality of our service (Art. 6(1)(f)) together with § 7(3) UWG. You can object at any time, before or after that email, free of charge except for the usual cost of sending a message: every such email has an unsubscribe link, or write to us.
3.10 Company, funding and partner requests, and housing links. Name, email, and what you tell us about the request. We store it to contact you and prepare the introduction. Legal basis: Art. 6(1)(b). For housing there is no form on this site, and nothing you type here reaches our housing partner. A link to Athaus carries only our referral code and campaign tags (UTM parameters), so Athaus knows the visit came through us; it carries no personal data. What you enter on the Athaus site, you give to Athaus directly.
3.11 Your account and the referral programme. There is no public sign-up. After a meeting, our team may open an account for you, so you can follow the meeting and what comes out of it. You receive an activation email and set your own password; nothing is active until you do. We store your email address, a hash of your password (never the password), your referral code, who referred whom, the resulting rewards and your payout requests. We do not store bank details. As a referrer you see totals, not what a named person bought. Legal basis: Art. 6(1)(b); for reward and payout records, statutory retention (Art. 6(1)(c)). You can ask for deletion on your account page.
3.12 Managing requests, and what partners tell us. Everything sent under one email address is kept as one record with its history, so you do not repeat yourself and the follow-up comes in your language. For each introduction we record its status, whether the call took place and, where the partner reports it, whether a contract came about and its value. That last part comes from the partner, not from you (Art. 14). We do not receive the content of your advice, contracts or policies. Legal basis: Art. 6(1)(b) and our legitimate interest in running introductions, billing partners correctly and assessing our partners (Art. 6(1)(f)).
3.13 Writing to us. Your message and contact details, to answer you. Legal basis: Art. 6(1)(b) or (f).
4. What you have to provide
Nothing. Reading, the calculators and the check work without personal data. Required fields on a form are the minimum for what the form offers; without them we cannot send your result or the guide, arrange the call or make the introduction.
5. When a partner sees your data
We do not send your data out to partners: no exports, no lists, no file transfers. A partner's advisors work on your request inside our own system, under our access rules.
- When. Only when you book a call on a partner's topic or ask for an introduction.
- Who. The partner for that topic, as named on our partners page: our finance partner tecis Finanzdienstleistungen AG, Hamburg (insurance, investments, pensions, financing); Andrual Technologies UG (haftungsbeschränkt), Berlin, which runs Athaus.ai (housing; today you reach Athaus only through links, 3.10); Estrach & Jung Consulting UG (haftungsbeschränkt), Berlin (company financing and funding); and Pontaro (business development). Pontaro is also the provider of Unlock Germany and the controller (section 2), so a request about business development stays with the same controller. Founders Night receives no data from us: registration and the group chat run on Luma and WhatsApp (3.8). A new partner is named here before it receives any data.
- What. Your contact details, the topic, your language, and what you told us about the request, including your check result where it matters for the call. Nothing the first conversation does not need.
- How. Through a personal, restricted login to our system. Advisors see their own company's requests only, access is logged, and we can withdraw it at any time. When a request comes in, the advisor gets a short notice with your first name and the topic, and signs in to see the rest. The calendar invitation for your call is sent from our Microsoft 365 account with the attendees hidden from each other, so the advisor does not see your email address in it and you do not see theirs.
- Links. A link from our site to a partner's site carries our referral code and campaign tags (UTM parameters), and nothing about you. What you enter on the partner's site, you give to the partner directly.
- Legal basis. The introduction is the service you asked us for (Art. 6(1)(b)).
- Whose responsibility. We stay responsible for the data in our system. What the partner does with you from the call onwards (advice, offers, contracts, its own records) is the partner's own responsibility as a separate controller, under its privacy policy.
- What comes back. Whether the call took place and whether a contract came about (section 3.12).
Ask us at any time which partners could see your request, or tell us to stop an introduction that has not happened yet.
6. Service providers
These companies process data for us under a data processing agreement (Art. 28) and only on our instructions.
| Provider | What for | Where |
|---|---|---|
| Vercel | Hosting, server logs, photos of our team | EU region (Frankfurt); US company |
| Neon | Database | EU region (Frankfurt); US company |
| Resend | Sending emails | US company |
| Microsoft | Teams meetings, calendar, our mailbox | EU Data Boundary |
| Google (Google Ireland Limited) | Website statistics (Google Analytics), only with your consent | EU; US parent company (Google LLC) |
7. Transfers outside the EU
Our data is stored in the EU. Some providers are US companies or belong to one, so access from the United States cannot be fully excluded, and Google may transfer Google Analytics data to Google LLC in the United States. Those transfers rely on the EU-US Data Privacy Framework where the provider is certified (Art. 45), otherwise on EU standard contractual clauses (Art. 46(2)(c)). Google LLC is certified under the Framework, and Google's data processing terms add standard contractual clauses. Ask us for a copy.
8. How long we keep it
| Data | Kept for |
|---|---|
| Server logs | 30 days |
| Page-view statistics and our own analytics | 13 months, then deleted or aggregated |
| Google Analytics | 2 months, then only aggregated reports |
| Email addresses never confirmed | 30 days |
| Check results, guides, tips, community list | Until you withdraw, at most 24 months after your last activity. Proof of consent: 3 years longer. |
| Saved checklists | Until you delete them, at most 24 months after last use |
| Requests, bookings and introductions that led nowhere | 3 years from the end of the year of last contact |
| Accounts | Until you ask for deletion, then deleted within 30 days |
| Introductions we billed, referral rewards and payouts | Up to 10 years where commercial and tax law requires it (§ 257 HGB, § 147 AO) |
Records of advice and contracts are kept by the partner that advised you, under its own duties, not by us.
9. Your rights
Access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18) and data portability (Art. 20). You may withdraw any consent at any time with effect for the future (Art. 7(3)): the unsubscribe link, the cookie settings or an email to us. We answer within one month and may ask you to confirm it is you. You may complain to a supervisory authority, for example where you live; the one competent for us is the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin.
Right to object (Art. 21). Where we rely on legitimate interest (Art. 6(1)(f)), you may object at any time on grounds relating to your situation. If you object to direct marketing, we stop, without weighing anything. An email to the address in section 2 is enough.
10. No automated decisions
The check applies fixed rules to your answers and shows its reasoning. Inside our system, a rule-based score orders incoming requests so urgent ones are answered first; it uses what you told us, and a person decides what happens next. You can object to it (section 9). Neither has a legal or similarly significant effect on you, and no decision in the sense of Art. 22 is made by a machine. We do not use your data to train AI models.
11. Cookies and local storage
| Name | Purpose | Lifetime | Needs consent |
|---|---|---|---|
ug_lang | Your language | 1 year | No |
| Sign-in session cookie | Keeps you signed in | 1 hour | No |
| Sign-in security cookies | Protect the sign-in form and remember where to return after it | Until you close the browser | No |
tecis_checklist_link | Keeps your saved checklist linked to your email after you confirm it (3.7) | 6 months | No |
tx_analytics_consent, ug_referral_consent, tx_analytics_asked | Your cookie choice | 1 year | No |
tx_vid | Page-view statistics (3.3) | 1 year, or until consent withdrawn | Yes |
tx_analytics_aid | Random identifier for analytics (3.4) | 1 year | Yes |
Local storage: tx_exp_* | Which version of a tested page you saw (3.4) | Until cleared or consent withdrawn | Yes |
_ga | Google Analytics, third party: tells visitors apart (3.4) | 2 years, or until consent withdrawn | Yes |
_ga_JXEHM4C4MY | Google Analytics, third party: keeps the state of your visit (3.4) | 2 years, or until consent withdrawn | Yes |
ug_ref, ug_via, local storage ug_referral | Recommendation link memory (3.5) | 30 days | Yes |
| Local storage: check answers, checklist, tool inputs, tools used | Stays on your device until you clear it or send a form | Until cleared | No |
12. Security
Encrypted connections, EU hosting, access limited by role, passwords and access tokens stored only as hashes, and a log of who opened which record. If something goes wrong with your data, we tell you and the authority as the law requires.
13. Children
Unlock Germany is for adults. We do not knowingly collect data from anyone under 18; if you believe we have, write to us and we delete it.
14. Changes
We update this notice when the processing changes, for example when a partner or provider is added. The date at the top shows the current version; account holders hear about material changes by email.
Terms of use
1. Who and what
These terms apply between you and the provider of Unlock Germany named in the Impressum above ("we") when you use this website, its tools, the free check, the booking of calls, the community list or an account. You need to be at least 18 for the forms, the booking and the account. Questions: info@unlock-germany.de.
They do not cover your relationship with a partner. Advice, contracts, a housing search or an event with one of our partners follow that partner's own terms and privacy policy (section 4).
2. What we do
- We explain. Guides, checklists and answers in plain English and German about insurance, money, housing, funding, work and leaving Germany.
- We give you tools. Calculators, the arrival checklist and the free check, which sorts your situation into topics and shows which deserve attention first. The free check and the tools give general orientation based on your own answers, not advice or a product recommendation (section 3).
- We introduce you. We arrange a free call or an introduction with the partner we selected for a topic, and we stay reachable while the partner works with you. Arranging is our part; what is said and offered in a partner's call is the partner's.
All of this is free for you and without obligation (section 5). You can reschedule or cancel a call through the link in your confirmation email.
3. What we do not do
- Finance. We hold no licence under §§ 34c, 34d, 34f or 34i of the German Trade Regulation Act (GewO). We do not advise on, recommend, compare, arrange or conclude insurance, investment, pension or loan products. That is done only by our finance partner, under its own licences, and you receive its mandatory customer information before any advice begins.
- Law and tax. Our content is general information, not legal or tax advice for your case. For that, ask a lawyer or a tax advisor.
- Housing. We do not list, show or negotiate properties. Search, applications and any brokerage happen on our housing partner's platform; the partner holds its own licence as an estate agent under § 34c GewO.
- The whole market. We work with a short list of partners on purpose. This site is not a comparison of all providers in Germany.
Tools, the check and its result give general orientation, computed from your own answers and the assumptions shown with each tool. They are estimates: not advice, not an assessment of your needs, not a product recommendation, not an offer. Rules and figures change, and we cannot promise every number is current on the day you read it. Please do not make a financial, legal or tax decision on a tool result alone.
4. Partners, and whose contract it is
Our partners and what each one does are listed on the partners page. For all of them:
- A contract about a partner's service is between you and the partner only. We are not a party to it and cannot accept or decline anything for the partner.
- The partner provides its service in its own name and on its own responsibility: its advice, offers, prices, platform and contracts. Its terms, customer information and privacy policy apply.
- An introduction obliges you to nothing. Compare, pause or walk away at any point.
- We carefully assess partners based on expertise, reputation, experience with internationals and service quality. If something goes wrong with a partner, tell us and we will help you raise it. Claims under your contract are against the partner.
Finance: tecis Finanzdienstleistungen AG. Calls about insurance, investments, pensions and financing are held by advisors of our finance partner, acting for the partner under its licences. The booking shows you who holds your call before you confirm it.
Housing: Athaus.ai, run by Andrual Technologies UG (haftungsbeschränkt), Berlin. We link to Athaus with our referral code; the search and everything after it happen on the Athaus platform, under its terms.
Company financing and funding: Estrach & Jung Consulting UG (haftungsbeschränkt), Berlin. Its funding advisory is a separate agreement between you and Estrach & Jung, on its terms and fees, agreed before any work starts.
Business development: Pontaro. Pontaro is also the provider of Unlock Germany until Unlock Germany is registered. As a partner it follows the same rules as every other partner and pays a fee for each introduction (section 5). The first conversation is covered by these terms and is free; any consulting after it is a separate agreement with Pontaro, made in writing before work starts.
Community: Founders Night. Events are run by their organiser, not by us. Registration is on Luma and the chat on WhatsApp, each under its own terms.
Links. We do not control partner sites or other linked sites and are not responsible for their content.
5. What it costs, and how we are paid
Our partners pay us a fee for each introduction. You pay us nothing. A partner may charge for its own services under its own terms. The partner pays our fee from its own earnings; it is not added to your price.
6. Your account
- An account is optional and there is no public sign-up: after a meeting, our team may open one for you, so you can follow the meeting and what comes out of it. The agreement for it starts when you activate the account through the link we email you and set your password.
- One account per person, with your own email address. Keep your password to yourself and tell us if someone else may have used your account.
- You can end it at any time, without notice, on your account page. We can end it with four weeks' notice by email, or without notice for good cause, such as a serious or repeated breach of section 8.
- These terms stay available at this address. We do not keep a separate copy for each user; ask us for an earlier version if you need one.
- As a consumer you may withdraw from the account agreement within 14 days of activating it, without giving reasons, by telling us (for example by email to the address in section 1). The account is free, so there is nothing to pay back; deleting it on your account page ends it at any time anyway.
7. Referral programme
Account holders can share a personal link. If someone who arrives through it becomes a partner's customer and we are paid for the introduction, you receive a reward: a percentage of the fee we receive for that introduction. The rate shown in your account on the day of the referral applies; we may change it for future referrals. Rewards become available once we have been paid, and we transfer them on request to the bank account you name, within 30 days, with no minimum amount. Private individuals and businesses may take part; a business invoices its rewards to us, with VAT where it applies.
- Share your link only with people who would want it, and tell them you may receive a reward. No spam, no advertising on our brand name, no misleading claims, no referring yourself.
- Point people to Unlock Germany; do not describe or recommend specific financial products. That may need a licence you do not have.
- Rewards may be taxable. Declaring them is up to you.
- We may withhold or reclaim rewards obtained by fraud or by breaking these rules. We may end the programme for the future with four weeks' notice; rewards already earned stay yours.
8. Fair use
Give correct information, and only your own data or data you may share. Do not harm the site or others: no scraping or automated mass retrieval, no attempts to get around security or reach other people's data, no fake bookings, nothing unlawful or abusive in forms, calls or the community. We may block access where this is breached.
9. Our content, and availability
Texts, tools, graphics, brand and software are protected by copyright and trademark law. Use them for your own, non-commercial purposes and link to them freely; republishing, commercial use or feeding them into another service needs our written permission.
The site is free and we work to keep it available and correct, but we do not promise uninterrupted availability, and we may change, pause or end individual tools. Your saved data is handled as the privacy notice describes.
10. Liability
- We are fully liable for intent and gross negligence, for injury to life, body or health, under the Product Liability Act, and where we gave a guarantee or fraudulently concealed a defect.
- For slight negligence we are liable only if we breach an essential obligation: one that makes the proper use of our service possible in the first place and on which you may regularly rely. Liability is then limited to the foreseeable damage typical for this kind of service.
- Otherwise our liability for slight negligence is excluded. The same limits apply to our legal representatives, employees and agents.
Within these limits we answer for our own part: how we inform, select and introduce. The partner answers for its service (section 4).
11. Changes to these terms
Without an account, the version published when you use the site applies. With an account, we email you at least six weeks before a change takes effect. A change that touches the core of the agreement or disadvantages you applies only if you agree. Other changes apply unless you object within that period, and the email will say so. If you do not agree or you object, the old terms continue, and either side may end the agreement under section 6.
12. Law, language and disputes
- German law applies, without the UN sales convention (CISG). If you are a consumer living in another country, that country's mandatory consumer protection still protects you.
- For merchants, the courts in Berlin have exclusive jurisdiction. For consumers, the statutory courts apply.
- These terms exist in English and German. Once the German version is published, it prevails.
- We are neither willing nor obliged to take part in dispute resolution before a consumer arbitration board (§ 36 VSBG). Complaints about advice or a product go to the partner concerned and to the arbitration bodies named in its customer information.
- If a provision is or becomes invalid, the rest stays in force and the statutory rules replace the invalid part.