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Privacy Policy

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other order enquiries.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

2. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

mobilistics GmbH
Hohe Str. 102
44139 Dortmund

Phone: +4923129294930
E-mail: info@mobilistics.de

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Use of the vpchat application

In the logged-in area we store your conversations, messages, folders, templates, masking settings and masking and usage counters; this data is assigned to your account and your organisation. You can delete your account yourself at any time in the settings; if you are the last administrator of an organisation with further members, first transfer the administrator role. The data listed is removed without a grace period, as is your contact record in our CRM system (see section 10). Invoice records remain with our payment provider Stripe for as long as statutory tax and commercial retention periods apply; they are assigned to the organisation, not to your account. The organisation’s customer record at Stripe also remains, including the email address with which the subscription was taken out.

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Designation of a data protection officer

We have appointed a data protection officer.

Stephan Hansen-Oest
So ist gut GmbH
Im Tal 10a
24939 Flensburg

Phone: +49 461 40 68 245 5
E-mail: sh@so-ist-gut.de

Recipients of personal data

In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information free of charge about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at vpchat@mobilistics.de.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Encrypted payment transactions on this website

If you are under an obligation to share your payment information (e.g. card details) with us after you have entered into a fee-based contract with us, this information is required to process payments.

Payment transactions using common modes of paying (e.g. credit and debit cards) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

3. Recording of data on this website

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Consent management (Cookiebot)

On the public pages of this website (not in the logged-in application) we obtain and document your consent to analytics cookies via the consent management platform Cookiebot. The provider is Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark. When you open a page, a connection to Cookiebot’s servers is established; in the process, your IP address and technical information about your browser are transmitted. Cookiebot stores your choice in a cookie in your browser and logs it as proof of your consent (including the time, a consent ID and your IP address in shortened form).

You can change or withdraw your choice at any time via the Cookiebot icon on this website. The legal basis is Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR (proof of consent); storage on your device is based on Section 25(2) No. 2 TDDDG.

Matomo Tag Manager and web analytics with Matomo

On the public pages we load the Matomo Tag Manager from our own analytics server statistics.mobilistics.de. It controls which tools are loaded and initially loads only the consent management. Loading it necessarily transmits your IP address and information about your browser to this server. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is to load the tools we use centrally and only after your consent.

Only if you consent to the “Statistics” category in the consent management do we use the web analytics tool Matomo. We operate Matomo ourselves; we do not pass the collected data on to third parties. Matomo sets cookies (_pk_id for up to 13 months, _pk_ses for 30 minutes, _pk_ref for up to 6 months) and processes:

  • the pages viewed and the time and duration of the visit,
  • the page you came from, including campaign parameters from the address (e.g. utm parameters or the click ID gclid of an ad),
  • information about your browser, operating system, device and screen, as well as your IP address,
  • clicks on links and interactions with form fields and media, without the content you enter,
  • the achievement of goals we define, such as clicking the start button, submitting the contact form or booking an appointment.

The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). You can withdraw it at any time with effect for the future via the Cookiebot icon.

Contact by email or phone

If you contact us by email or phone, we process your enquiry including the personal data it contains in order to handle it. The legal basis is Art. 6(1)(b) GDPR if your enquiry relates to a contract or is required for its performance, and otherwise Art. 6(1)(f) GDPR (responding to enquiries). We delete the data as soon as it is no longer required for handling your enquiry and no statutory retention periods apply.

Contact form (HubSpot)

On the “Kontakt” (contact) page you can write to us using a form. The form is provided by HubSpot (HubSpot Ireland Limited, Dublin, Ireland). It only loads once you click “Formular laden” (load form); before that, no connection to HubSpot is established. We store your decision in your browser’s local storage (localStorage) so that you are not asked again on your next visit. You can withdraw it at any time via “Einwilligung für HubSpot widerrufen” (withdraw consent for HubSpot) below the form.

Loading the form transmits your IP address and information about your browser to HubSpot. The details you enter in the form (salutation, first and last name, company, email address and your message) are stored, together with a note that the enquiry came via vpchat, in our CRM system HubSpot (see section 10) so that we can handle your enquiry. If you tick the box in the form to receive further notifications from us, we also process your data for that purpose on the basis of your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time. The legal basis for loading the form is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG); for handling your enquiry it is Art. 6(1)(b) GDPR if your enquiry aims at a contract, and otherwise Art. 6(1)(f) GDPR.

Appointment booking (Cal.com)

On the “Demo” page you can book an appointment via the service Cal.com (Cal.com, Inc., USA). The calendar only loads once you click “Kalender anzeigen” (show calendar); you store and withdraw your decision in the same way as for the contact form. Loading the calendar transmits your IP address and information about your browser to Cal.com. In addition, we pass campaign parameters from the address of this page (e.g. utm parameters or the click ID gclid of an ad) on to Cal.com so that we can see how a booking came about.

If you book an appointment, Cal.com processes the details you provide (in particular name, email address, chosen time and your message) and makes them available to us. The legal basis for loading the calendar is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG); for arranging the appointment it is Art. 6(1)(b) GDPR. Cal.com also processes data in the USA; see section 11.

Live detection on the “Funktionen” (features) page

On the “Funktionen” page you can try out which personal data vpchat detects in a text. We transmit the text you enter there (at most 600 characters) to our server. Detection runs exclusively on our own infrastructure (see section 9); the text is neither stored nor passed on to AI providers. To prevent misuse, we limit the number of requests per visitor. For this we use a non-reversible value (hash) derived from your IP address, which is discarded at the latest about one hour after your last request. Please do not enter real data of third parties there. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in demonstrating our service and preventing misuse.

4. eCommerce and payment service providers

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data for the establishment, content arrangement and modification of our contractual relationships. Data with personal references to the use of this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to use our services or required for billing purposes. The legal basis for these processes is Art. 6(1)(b) GDPR.

The collected customer data shall be deleted upon completion of the order or termination of the business relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice to any statutory archiving periods.

Data transfer upon closing of contracts for services and digital content

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments.

Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur.

The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.

Payment services

We integrate payment services of third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank account details, credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this website:

Stripe

The provider for customers within the EU is Stripe Payments Europe, Ltd,1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter “Stripe”).

During the ordering process, Stripe additionally collects your billing address and, if you provide it, your VAT identification number in order to determine the VAT. We make invoices available to you in the application; they are stored with Stripe. If you choose PayPal during the ordering process, PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, additionally processes your payment data.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://stripe.com/de/privacy and https://stripe.com/de/guides/general-data-protection-regulation.

Details can be found in Stripe’s Privacy Policy at the following link: https://stripe.com/de/privacy.

5. User account and authentication

A user account is required to use vpchat. Registration, sign-in, single sign-on (SSO) and the management of users and organisations are handled via the service WorkOS (WorkOS, Inc., 9450 SW Gemini Dr #45828, Beaverton, OR 97008, USA). In particular, your name, your email address, your membership of an organisation, your role (e.g. administrator or member) and session and sign-in information (including IP address and browser) are processed. On our behalf, WorkOS also sends the emails for confirming your address, resetting your password and invitations. If you sign in via an external provider (for example with a Google or Microsoft account), WorkOS receives that provider’s details; a profile picture stored there is loaded by your browser directly from that provider. WorkOS processes this data on our behalf; we do not keep our own local copy of user and organisation master data.

The legal basis is Art. 6(1)(b) GDPR (performance of the usage contract) and Art. 6(1)(f) GDPR (secure provision of the service). For the transfer of data to the USA, see section 11.

6. Cookies and storage in the browser

In the logged-in application we only use technically necessary cookies and storage:

  • an encrypted session cookie that keeps you signed in (set via the WorkOS sign-in library),
  • a cookie with your language setting (“NEXT_LOCALE”),
  • in your browser’s local storage (IndexedDB), a list of the titles of your most recently used conversations so that the sidebar loads quickly; it is removed when you sign out, leave an organisation or delete your account,
  • in localStorage, settings such as the most recently selected model, the state of the sidebar and the colour scheme,
  • in sessionStorage, temporarily, the text of a message that could not be sent because there was no subscription, so that it is sent after the ordering process; it ends at the latest when you close the browser tab; in addition, two flags without personal data for navigating the settings.

The legal basis is Section 25(2) No. 2 TDDDG in conjunction with Art. 6(1)(b) and (f) GDPR. We do not use any analytics or advertising tools in the application. On the public pages of the website, analytics cookies are added after your consent, as well as the storage of your decision regarding the contact form and appointment booking; see section 3.

7. AI-powered chat services and automatic masking

The core of our service is a chat interface through which you can send requests (prompts), messages and file attachments to large language models (AI models). These inputs may contain personal data – including data of third parties (e.g. your customers or employees) that you enter as a user.

Masking before transmission: Before a request is forwarded to an external AI provider, it passes through our self-operated masking proxy. There, personal data is detected using a detection model operated on our infrastructure and additional rule-based checks (for example for IBANs, credit card numbers and German tax identification numbers) and replaced with placeholders. Because we keep the mapping between placeholder and original value, this is legally pseudonymisation, not anonymisation. The mapping is kept in a volatile cache (Redis) on our own infrastructure. It serves exclusively to replace the placeholders in the AI response with the original values and is automatically deleted once no masked request has been received from your account in the same organisation for one hour. In the same cache we keep the detection result for texts already checked for up to one hour in order to process repeated requests faster. If you delete your account, we delete both immediately. Automatic detection works in line with the state of the art but is not error-free and cannot guarantee that all personal data is detected and replaced. You should therefore not rely solely on masking and should check every input on your own responsibility before sending it to see whether it contains personal or confidential data. Responsibility for the content of your inputs remains with you.

When content is transmitted without masking: In the following cases the AI provider receives content in plain text:

  • if you switch masking off for a conversation, provided your organisation permits this; this then applies to the entire request, including earlier messages and the system instruction,
  • images, which can only be uploaded while masking is switched off,
  • values that you expressly release for a message, terms that you store as “never mask”, and data types whose masking you switch off,
  • values you mask by hand without adding them to your catalogue, from the next message in the same conversation onwards, because they apply only to the message in which you marked them,
  • when naming a new conversation (see below), terms from your masking catalogue and values masked by hand, unless automatic detection finds them as well,
  • information that automatic detection does not recognise.

Conversation titles: To name a new conversation, we send the beginning of your first message (at most 500 characters) to the selected model. Automatic detection applies, but not your masking catalogue or values masked by hand.

Storage of your chat history: We store your conversations, messages, any reasoning content, templates (system prompts) you create and the terms in your masking catalogue in our database so that you can find your history again. For file attachments we store the name, type and size, not the content. This stored content may contain the personal data you entered in plain text; masking protects the transfer to external AI providers, not the storage of your own history. The content remains stored until you delete the conversation or your account; cancelling a subscription does not delete it. The legal basis is Art. 6(1)(b) GDPR; where we process content on behalf of your company, see section 12.

Statistics and usage metering: For your Privacy Dashboard, we store for each masking operation only the type and number of detected data categories – never the plain text of the detected data. To enforce usage limits, we also record technical usage data (e.g. the number of tokens processed and the costs calculated from them per model).

8. Recipients: external AI providers

To answer your requests, we transmit the text – masked as described in section 7 – to external providers of language models. Which provider receives it depends on the model you select:

  • OpenRouter (OpenRouter, Inc., USA) – an intermediary service that forwards requests to the models of Anthropic (Claude), OpenAI (GPT) and Google (Gemini), either directly to the manufacturer or to a cloud provider that hosts the model (for example Amazon Web Services, Google Cloud or Microsoft Azure). These providers also receive the request and process it in the USA as well. With every request we transmit a pseudonymous identifier derived from your account and organisation, from which OpenRouter cannot infer your identity; it serves to link related requests. With every request we instruct OpenRouter to use only providers that do not use inputs to train their models. For the models of Anthropic and Google we additionally require endpoints without storage of content (zero data retention). This additional restriction does not apply to the models of OpenAI; under its terms, OpenAI may store requests temporarily, for example to detect misuse.
  • Mistral AI (Mistral AI SAS, Paris, France) – server location in the EU.
  • Nebul (Nebul B.V., Netherlands) for the open-source model GLM 5.2 FP8 – inference exclusively in the EU; request and response content is not used for training and is processed only transiently during inference.

Some providers briefly cache parts of recurring requests in order to answer them faster. If masking is switched on, this cache also contains only the masked version.

The legal basis is Art. 6(1)(b) GDPR (provision of the service you requested). For the transfer to the USA, see section 11.

9. Hosting and technical infrastructure

We operate the service on the managed cloud of cloudriven, a brand of mobilistics GmbH, and thus on our own server hardware. It is housed in an ISO/IEC 27001-certified colocation data centre of WIIT AG (formerly myLoc managed IT AG) in Düsseldorf, Germany. All application data (in particular conversations, messages, settings and statistics and usage data in our PostgreSQL database), the masking cache (Redis) and the detection model are processed on this own infrastructure in Germany and are not outsourced to external cloud services. Exceptions are the account master data held by WorkOS (section 5), the billing data held by Stripe (section 4) and the data in our CRM system (section 10). The legal basis is Art. 6(1)(b) and (f) GDPR.

10. Customer relationship management

To manage our customer relationships, we transmit data on prospects and customers to our CRM system HubSpot (HubSpot Ireland Limited, Dublin, Ireland). The data is hosted in a data centre within the European Union. For user accounts with a confirmed email address, we transmit name, email address, registration date, membership of an organisation, subscription status, number of seats and the end of a trial, and, during free initial use, whether the first message was sent and whether the allowance has been used up. In addition, there are enquiries via the contact form (section 3). We do not transmit the content of your conversations. Processing for advertising purposes takes place only on the basis of separate consent. Otherwise, the legal basis is Art. 6(1)(f) GDPR (management of the business relationship). If you delete your account, we also delete your contact record in HubSpot; HubSpot keeps deleted records for up to 90 days for restoration and then removes them permanently.

11. Transfer of data to third countries

Some of the service providers mentioned process data wholly or partly in the USA, in particular WorkOS, Stripe, OpenRouter, the model providers Anthropic, OpenAI and Google and the cloud providers through which OpenRouter obtains their models, and Cal.com. HubSpot stores your data in the EU but belongs to a group headquartered in the USA. A transfer only takes place where an adequate level of data protection is ensured – for example on the basis of an adequacy decision of the EU Commission (EU-US Data Privacy Framework, insofar as the respective provider is certified) or on the basis of the EU Commission’s standard contractual clauses (Art. 46(2)(c) GDPR) together with supplementary safeguards. Where requests are transmitted in masked form, the AI providers receive the detected personal data only as placeholders; undetected information and the exceptions listed in section 7 may reach them in plain text.

12. Data processing on behalf and allocation of roles

Insofar as you use our service as a company and enter personal data of third parties (e.g. your customers or employees), we process this data on your behalf and according to your instructions. In this respect, you are the controller and we are the processor within the meaning of Art. 28 GDPR; on request, we conclude a data processing agreement (DPA) with you for this purpose. With regard to your own account, contract and billing data, we are the controller within the meaning of Art. 4(7) GDPR.

Last updated: 12.10.2026