Transparency

In order for you to be able to trust us, we pledged to be as transparent as possible about our procedures, finances and decisions. Because of that, we have joined the Initiative for a Transparent Civil Society, an initiative by the German branch of Transparency International, which is allowed to audit us on a sample basis. They ensure that we will keep our promise of transparent management. On this page we summarized all the important information that we publish as part of that.

This information has been last updated on June 05, 2026.

This information is also available in our legal notice.

• Name: Datenanfragen.de e. V.
• Registered seat: Braunschweig, Germany
• Register: Register of associations of the district court of Braunschweig
• Registration number: VR 201732
• Address:
  Datenanfragen.de e. V
  Schreinerweg 6
  38126 Braunschweig
  Germany
• Date of foundation: June 14, 2018
• Transparency correspondent: Benjamin Altpeter (transparenz@datenanfragen.de or via the address mentioned above)

We publish the full constitution of our association on this site. As we are based in Germany, only the German version of our constitution is legally binding (official version of the constitution as a PDF).

Our purpose is the same as stated in our constitution but we also compiled and explained it here.

Resolutions of the general assembly are binding for the association’s work and complement the constitution. In accordance with the resolution of the general assembly of December 14, 2023, we publish here all resolutions of the general assembly with long-term effect (i.e., primarily permanent regulations, guidelines, and principles, but not resolutions that have only a one-time or short-term effect, such as the election or discharge of the board or planning for the coming year). Most of the documents are only available in German.

• Fee regulation
• Rules of procedure for the trust committee (German)
• Guidelines for the reimbursement of verified expenses (German)
• Travel policy (German)
• Lecture policy (German)
• Funding policy (German)
• Principles governing employment relationships (German)
• Criteria for free licenses (German)
• Code of conduct

Unless stated otherwise, both the constitution and the regulations are published under a CC0 license and may be freely reused by other associations as well as adapted for their own purposes.

As per the latest exemption notice of the Braunschweig-Wilhelmstraße tax office (tax number 14/209/11640) dated November 10, 2025 for the assessment period 2022 to 2024, we are exempt from corporate taxes as per § 5(1)(9) of the German Corporation Tax Act (KStG) and from trade taxes as per § 3(6) of the German Trade Tax Act (GewStG) for the advancement of:

• science and research (§ 52(2)(1)(1) of the German Fiscal Code (AO))
• consumer counselling and consumer protection (§ 52(2)(1)(16) AO)
• democratic government (§ 52(2)(1)(24) AO)

Compliance with the statutory requirements under §§ 51, 59, 60, and 61 AO was separately determined by the Braunschweig-Wilhelmstraße tax office (tax number 14/209/11640) in the assessment notice as per § 60a AO dated October 29, 2025. In accordance with our constitution, we advance:

• science and research (§ 52(2)(1)(1) AO)
• upbringing, adult education and vocational training (§ 52(2)(1)(7) AO)
• consumer counselling and consumer protection (§ 52(2)(1)(16) AO)
• democratic government (§ 52(2)(1)(24) AO)

The association is managed by the chairpersons of the board. The assessors check and support the chairpersons in their work. It is comprised of:

• Benjamin Altpeter, Chairman
• Lorenz Sieben, Chairman

• Malte Wessels, Assessor

In addition, the general assembly held of December 14, 2024, established a trust committee. The statutory purpose of the trust committee is to oversee the association’s employment of chairpersons and thereby prevent conflicts of interest. Most importantly, the trust committee must approve the hiring of chairpersons and has a veto right regarding certain decisions related to employment. The general assembly has enacted rules of procedure (German) for the trust committee, governing its composition, election, term of office, duties, and decision-making processes. The trust committee consists of:

• Malte Wessels, spokesperson

see Yearly report 2024 (German, p. 5 ff.)
see Yearly report 2023 (German, p. 5 ff.)
see Yearly report 2022 (German, p. 5 ff.)
see Yearly report 2021 (German, p. 5 ff.)
see Yearly report 2020 (German, p. 5 ff.)
see Yearly report 2019 (German, p. 5 ff.)
see Yearly report 2018 (German, p. 5 ff.)

The association has no staff.

Number of volunteers: 3

see Yearly report 2024 (German, p. 9 f.)
see Yearly report 2023 (German, p. 9 f.)
see Yearly report 2022 (German, p. 9 f.)
see Yearly report 2021 (German, p. 9 f.)
see Yearly report 2020 (German, p. 11 f.)
see Yearly report 2019 (German, p. 10 f.)
see Yearly report 2018 (German, p. 9 f.)

Financial assets at the end of 2025: 2,801.03 €
Financial assets at the end of 2024: 1,527.33 €
Financial assets at the end of 2023: 755.96 €
Financial assets at the end of 2022: 506.93 €
Financial assets at the end of 2021: 218.43 €
Financial assets at the end of 2020: 327.78 €
Financial assets at the end of 2019: 87.90 €
Financial assets at the end of 2018: 119.70 €

see Yearly report 2024 (German, p. 9 f.)
see Yearly report 2023 (German, p. 9 f.)
see Yearly report 2022 (German, p. 9 f.)
see Yearly report 2021 (German, p. 9 f.)
see Yearly report 2020 (German, p. 11 f.)
see Yearly report 2019 (German, p. 10 f.)
see Yearly report 2018 (German, p. 9 f.)

The association is in no corporate relationships with any third parties.

We publish this information on a yearly basis in conjunction with the publishing of the yearly report. For data protection reasons, we never publish the names of natural persons. If we receive multiple donations or membership fees by the same person, they are summed.

• Donation by natural person: 50.00 € (28.4 %)
• Donation by natural person: 250.00 € (14.2 %)

The following sections go beyond the ten pieces of information required by the Initiative for a Transparent Civil Society. We believe it is important to be transparent on these points as well.

Our board members work on a strictly voluntary basis and receive no payment from the association for their work. In some cases, however, members of the association can receive compensation from external organizations for lectures on topics that concern the association. Of course, no funds of the association are used for such compensated lectures, they are the private responsibility of the respective members.

The board has to publicly document lectures here for which board members have received compensation from external organizations. This is stipulated in our lecture policy (German).

• In June 2023, the data protection authority of Lower Saxony invited Benjamin Altpeter, Lorenz Sieben, and Malte Wessels to lead a workshop on using the Tweasel tools. For this, the data protection authority of Lower Saxony paid Benni and Lorenz a flat fee of €150.00.
• In September 2023, Topio e. V. invited Benjamin Altpeter and Lorenz Sieben to give a talk on data protection rights and data collection through mobile tracking as part of the lecture series “Digital Rights: Human Rights in the Digital Age.” For this, Topio paid them a total compensation of 300 €. After the talk, dinner was paid for both of them. Benni and Lorenz voluntarily decided to donate the entire compensation to the association.
• Malte was employed by Technical University of Braunschweig, and as part of that employment, gave lectures as per the lecture policy and was reimbursed for travel expenses.

• Malte was employed by Technical University of Braunschweig, and as part of that employment, gave lectures as per the lecture policy.

• In March 2020, the Humboldt University of Berlin invited Benjamin Altpeter and Lorenz Sieben to give a seminar on Datenanfragen.de (post in German) as a guest lecture at the HLCI. The Humboldt University has covered the train travel and accommodation costs and paid them a compensation of 250 € each. Benni and Lorenz voluntarily decided to donate half of the compensation to the association.

The association benefits when members apply for external grants on their own to fund their work on our projects. Awarded grants are documented here as per our funding policy (German). The listed grants did not go to the association, but are the sole responsibility of the respective members.

• The Federal Ministry of Education and Research funded the work of the Lorenz Sieben and Benjamin Altpeter GbR on the “Tweasel for Web” project with 47,481.00 € between September 2024 and February 2025 as part of the Prototype Fund (grant number 01IS24S28). The purpose of the project was to expand the Tweasel tools for analyzing tracking on websites and to develop a browser addon as a counterpart to the Tweasel platform for mobile apps. In the course of the project, an analysis of the top 10,000 websites in Germany was conducted, and the results were published via the request database and as an open dataset. Based on this, the TrackHAR library was extended for the web, with many new adapters added. Finally, a prototype of the addon was developed, which can analyze the network traffic of websites in an isolated context for tracking data transmissions and generate complaints based on this analysis.
  Project report (German)

• The NLnet Foundation has funded the work of the Lorenz Sieben and Benjamin Altpeter GbR and Carolin Gaus on the “Tracking weasel” project with 48,750.00 € between January 2023 and June 2024 through the NGI0 Entrust Fund with financial support from the European Commission’s Next Generation Internet program (grant number 2022-08-061). The purpose of the project was to develop tools and libraries for the automatic analysis of data protection violations caused by tracking in mobile apps, as well as to develop a platform to make this infrastructure accessible to users. As part of the project, the Tweasel libraries appstraction, cyanoacrylate, TrackHAR, ReportHAR, and parse-tunes, as well as the Tweasel CLI, were developed and presented at various events. Furthermore, an open database of tracking requests was published, and a prototype of the platform was developed.
  Project report to follow

• The German Federal Ministry of Education and Research funded the work of the Lorenz Sieben und Benjamin Altpeter GbR on the “An app for Datenanfragen.de” project with 29,426.00 € between March 2022 and August 2022 through the Prototype Fund (grant number 01IS22S20). The purpose of the project was to evaluate whether exercising one’s privacy rights could be further simplified with a native app. In the course of the project, the existing code base of the website was also refactored and modernised, a new, more intuitive interface for the request generator was implemented, the “My requests” feature was expanded, and a generator for admonitions and complaints was developed.
  Project report (German)

As an organization, we contribute our expertise and the practical experiences of both ourselves and our users to government consultation processes, and we support open letters issued by other organizations.

• March 2026: Comments on the consultation of the European Commission on the proposal for the Digital Omnibus
• February 2025: Co-signature of the open letter (German) against biogeographic origin analysis by Gen-ethisches Netzwerk
• November 2024: Participation in the stakeholder event by the European Data Protection Board on pay or okay (report)
• February 2024: Comments on the consultation on the European Commission’s second report on the application of the GDPR
• January 2024: Comments on the consultation by the European Data Protection Board on the Guidelines 2/2023 on Technical Scope of Art. 5(3) of ePrivacy Directive
• March 2022: Comments (German) on the consultation (German) of the Datenschutzkonferenz on the Guidelines for operators of telemedia services 2021
• March 2022: Comments on the consultation by the European Data Protection Board on the Guidelines 01/2022 on data subject rights - Right of access