Data processing agreement (AVV)

As of 11 October 2026. This agreement under Art. 28 GDPR applies to business customers who use BankingMCP for their business. It takes effect with the service contract; no signature is needed (Art. 28(9) GDPR). The German version is binding; this translation is for convenience.

1. Parties and scope

The processor is Escher Consulting GmbH, Höhenweg 2c, 44265 Dortmund, Germany ("BankingMCP"). The controller is the customer who uses BankingMCP as a business within the meaning of Section 14 of the German Civil Code ("customer").

This agreement applies where BankingMCP processes personal data on the customer's behalf while providing the service, in particular data about the customer's employees, clients and business partners that appears in account transactions. For consumers who use BankingMCP for their own purposes, only the privacy policy applies.

Where this agreement and the terms of service conflict on data protection, this agreement prevails.

2. Subject, nature, purpose and duration

The subject is making the customer's bank accounts available over the Model Context Protocol (MCP) to AI assistants the customer connects. BankingMCP retrieves accounts, balances and transactions through a regulated account information service and passes them to the assistant that asked. Access is read-only.

Processing covers retrieving, transmitting, briefly holding in memory, storing the master data and logs listed below, and erasing.

Processing lasts as long as the service contract.

3. Types of data and data subjects

Types of data: account master data (name, IBAN, account type and currency of connected accounts), balances, transactions including counterparties' names and account details and payment references, logs of assistant access (time, type of query and account concerned), and the email address the customer signs in with.

Data subjects: the customer and its owners, the customer's employees, clients, suppliers and other business partners, as far as they appear in transactions.

Special categories of personal data (Art. 9 GDPR) are not processed deliberately, but may appear in payment references written by third parties.

4. Instructions

BankingMCP processes the data only on the customer's documented instructions. The customer gives them through the service contract and through the settings it makes in the service, for example by connecting banks or by adding, deactivating or removing assistants.

Further instructions are given in text form to hello@banking-mcp.com. If BankingMCP considers an instruction unlawful, it tells the customer without delay (Art. 28(3) GDPR).

The customer itself causes data to be sent to an AI assistant by giving that assistant an MCP address. Providers of AI assistants (for example Anthropic, OpenAI or Mistral AI) are not sub-processors of BankingMCP. Whether the customer needs its own agreement with them is the customer's decision.

5. BankingMCP's obligations

BankingMCP does not process the data for its own purposes. In particular, transactions are not used for advertising, not sold and not used to train AI models.

Everyone with access to the data is bound to confidentiality or subject to a statutory duty of secrecy (Art. 28(3)(b) GDPR).

BankingMCP supports the customer with appropriate measures in answering data subject requests (Art. 12 to 22 GDPR) and with the obligations under Art. 32 to 36 GDPR, as far as it has the information needed.

BankingMCP notifies the customer without undue delay after becoming aware of a personal data breach, with the details the customer needs for its notification under Art. 33 GDPR.

6. Technical and organisational measures

Hosting: the application and database run on servers of Hetzner Online GmbH in data centres in Germany (Nuremberg and Falkenstein).

Data minimisation: balances and transactions are not stored; they are retrieved from the account information service for each request from an assistant. Only account master data and access logs (90 days) are stored.

Bank credentials: the customer enters them only in the account information service's form; BankingMCP never receives them.

Encryption: all connections are encrypted with TLS and enforced with HSTS. MCP addresses and keys are encrypted with AES-256-GCM; session keys, sign-in codes and recovery codes are stored only as hashes. Nightly database backups are encrypted with AES-256 and deleted after 14 days.

Access control: sign-in with one-time codes, optionally with two-factor authentication. Each assistant gets its own address, which the customer can deactivate at any time with immediate effect. Sign-in and query attempts are rate-limited. The web server writes no access logs.

BankingMCP keeps these measures up to date with the state of the art, without lowering the level of protection.

7. Sub-processors

The customer authorises the following sub-processors: finAPI GmbH, Munich (account information service supervised by BaFin, bank connection); Hetzner Online GmbH, Gunzenhausen (hosting, database and backups in Germany); Sendinblue SAS (Brevo), Paris (sending sign-in codes and service emails within the EU).

BankingMCP contractually binds every sub-processor to a level of protection equivalent to this agreement. BankingMCP informs the customer by email at least 30 days before adding or replacing a sub-processor. The customer may object for good cause under data protection law; if no agreement is reached, the customer may terminate the contract as of the change.

Billing through Stripe concerns the contract between the customer and BankingMCP and is not carried out on the customer's behalf, so Stripe is not a sub-processor under this agreement.

8. Place of processing

Processing takes place in Germany and the European Union. BankingMCP and its sub-processors transfer data to a third country only under the conditions of Art. 44 et seq. GDPR and after informing the customer.

9. Evidence and audits

On request, BankingMCP provides the information needed to demonstrate compliance with this agreement. The customer, or an auditor it appoints who is bound to confidentiality, may check compliance after timely notice, usually 14 days, during normal business hours and without disrupting operations. Written information is the primary means of evidence.

10. Deletion and return

When the customer disconnects a bank or deletes its account, BankingMCP deletes the data concerned immediately, disconnects the bank at the account information service, and removes the data from the encrypted backups within 14 days. Statutory retention obligations remain unaffected.

Since balances and transactions are not stored, there is no further data to return. The customer can view account master data in its account at any time before deletion.

11. Liability and final provisions

Liability is governed by Art. 82 GDPR and otherwise by the liability rules of the terms of service.

BankingMCP announces changes to this agreement to the customer in good time. If a provision is invalid, the rest of the agreement remains valid. German law applies.