MIT-licensed proof-of-work CAPTCHA from Brno (BAU Software s.r.o.) with a public DPA and EU-only Cloud endpoints, though the Cloud itself runs on AWS.
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- CLOUD ACT
- MATERIAL
A single roll-up of ownership and CLOUD Act exposure.
Friendly Captcha GmbH, Wörthsee, Germany (HRB 260542, Munich Local Court)
German cookie-free proof-of-work CAPTCHA (Friendly Captcha GmbH) from 9 EUR/month, but the DPA is password-protected, no sub-processors are named and EU-only hosting is a paid tier.
Friendly Captcha, in the CAPTCHA & bot protection category, offers EU hosting with Germany as its hosting location, but a US parent or sub-processor leaves material CLOUD Act exposure.
Friendly Captcha is the best-known German name in this category, operated by Friendly Captcha GmbH in Wörthsee near Munich with no US parent or funding round found. It is also the listing where the marketing and the published documents diverge most, which is the reason for the 2/5. Three claims did not verify against the vendor's own pages: the DPA at friendlycaptcha.com/legal/dpa is password-protected, so no buyer can read it; there is no named sub-processor list, only categories of recipients; and EU-only hosting is not the default, because the homepage states data centres in the EU, US, Asia and around the world, with dedicated EU data centres appearing as an Advanced and Enterprise feature rather than a baseline. A WCAG 2.2 AA conformance "certified by TÜV" is claimed with no report or audit date published: Material. The product itself is a solid cookie-free proof-of-work widget and the company is genuinely German. What is missing is the evidence, and every item on that list is fixable by publishing a page.
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
Where ultimate control over the operating company sits.
Friendly Captcha is a cookie-free proof-of-work CAPTCHA from Friendly Captcha GmbH, based in Wörthsee near Munich and registered at the Munich Local Court under HRB 260542. It is probably the most widely recognised German entry in this category, and the product does the core job well: the widget runs a cryptographic puzzle in the visitor's browser instead of asking them to solve anything, sets no cookies, and works without a consent banner entry. Pricing runs from a free tier for non-commercial use through Starter at €9, Growth at 39 EUR and Advanced at 200 EUR per month.
It arrived in this directory through a vendor submission, and the submission is the reason the listing reads as it does. Three of the four compliance claims in it did not hold up against Friendly Captcha's own public pages on the day of audit. The data processing agreement at friendlycaptcha.com/legal/dpa returns a page saying the content is password-protected, so a prospective buyer cannot read the agreement before signing up. There is no named sub-processor list anywhere on the site; the privacy policy describes categories of recipients such as IT service providers, data storage and hosting. And EU-only hosting is not the default posture: the homepage states data centres in the EU, the US, Asia and around the world, the service-user privacy policy refers to 200+ data centres worldwide with standard contractual clauses, and dedicated EU-only data centres appear to be a feature of the Advanced plan at 200 EUR a month and of Enterprise, not of the entry tiers: Material.
A WCAG 2.2 AA conformance "certified by TÜV" is also claimed on the accessibility page without a linked report or audit date. None of this is a judgment on how well the widget blocks bots, and the company itself is German-owned with no US parent or funding round found in public records. It is a judgment on what a buyer can verify, which is what every listing on this site is scored on. Every one of these gaps is closable by publishing a page, and the score will be revisited when they are. Best fit today: teams who want the best-known German option and either accept the documentation gaps or are buying at the Advanced tier where EU-only data centres become available.
MIT-licensed proof-of-work CAPTCHA from Brno (BAU Software s.r.o.) with a public DPA and EU-only Cloud endpoints, though the Cloud itself runs on AWS.
Invisible proof-of-work form spam filter (Formspark team), free to 1,000 challenges a month, with a published sub-processor list that is mostly American and no legal entity named.
Vienna CAPTCHA (Captcha GmbH, part of the Krone Multimedia group) with named processors, from 8.90 EUR/month, but the site itself runs on AWS CloudFront and Google analytics.