Privacy Policy

for hello-email.com, app.hello-email.com, our YouTube channel and our podcast — Last updated: November 2026

1. Controller

Bergstein Media Ltd Arch. Makariou III 55, Flat 102 7550 Kiti, Cyprus Email: support@hello-email.com

A data protection officer has not been appointed, as the statutory requirements of Art. 37(1) GDPR do not apply.

2. Your Rights

With regard to your personal data, you have the following rights against us: access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), data portability (Art. 20 GDPR), and the right to object to processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR). You may withdraw any consent you have given at any time with effect for the future (Art. 7(3) GDPR). You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR); the authority competent for us is the Commissioner for Personal Data Protection of the Republic of Cyprus – you may, however, also contact the supervisory authority of your place of residence.

2a. Our YouTube Channel

We operate a YouTube channel at https://www.youtube.com/@hello-email-de, where we publish videos about Hello Email. For users in the European Economic Area and Switzerland, the YouTube platform is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

Processing by Google. When you visit our channel or watch our videos, Google processes personal data, in particular your IP address, device and browser information, your usage behaviour and, if you are signed in, data from your Google account. Google uses cookies and similar technologies for this purpose and, where required, obtains your consent for them itself. We have no influence on this processing; to that extent, Google processes the data under its own responsibility and for its own purposes. Data may also be transferred to Google LLC in the USA; Google LLC is certified under the EU-U.S. Data Privacy Framework (adequacy decision, Art. 45 GDPR). For details, please see Google's privacy policy: https://policies.google.com/privacy

Statistics (YouTube Analytics). As the channel operator, Google provides us with statistics on the use of our channel, such as view counts, watch time, subscriber development, traffic sources and the distribution of viewers by age group, gender and country. We receive these statistics in aggregated form only; they do not allow us to draw conclusions about individual viewers. Insofar as Google also processes viewers' data to compile these statistics for us, Google and we may be joint controllers pursuant to Art. 26 GDPR in accordance with the case law of the Court of Justice of the European Union (judgment of 5 June 2018, C-210/16). The legal basis for our involvement is our legitimate interest in presenting our offering and evaluating the reach of our videos (Art. 6(1)(f) GDPR).

Comments and interactions. If you comment on our videos, like them or subscribe to our channel, we can see, depending on your YouTube settings, your channel name, your profile picture and the content of your comment. Comments are publicly visible. We process this information only within YouTube in order to reply to comments and moderate the comment sections (Art. 6(1)(f) GDPR); we do not export it and do not combine it with our customers' data. Comments remain stored until you or we delete them. Please do not share confidential details about your Hello Email account in comments; for support requests, please use our support chat or support@hello-email.com.

Your rights. You can exercise your rights under Section 2 against both us and Google. Since only Google has direct access to the user data, the most effective way is to contact Google directly; we will forward requests we receive to Google where necessary.

2b. Our Podcast "Die E-Commerce Revolution"

We publish the podcast "Die E-Commerce Revolution". It is available via our podcast website https://die-e-commerce-revolution.podigee.io/ and via podcast apps and platforms such as Apple Podcasts and Spotify.

Hosting via Podigee. The podcast and the podcast website are hosted by Podigee GmbH, Revaler Straße 28, 10245 Berlin, Germany, which acts as our processor (Art. 28 GDPR). When you play or download an episode, retrieve the RSS feed or visit the podcast website, Podigee processes your IP address, the date and time of the request, the file or page requested and information about the podcast app or browser used (user agent). Without this data, the content cannot be delivered to your device. Podigee uses the requests to compile statistics for us, such as the number of downloads and streams per episode. IP addresses are stored for this purpose in anonymised form only; we receive the statistics exclusively in aggregated form. On the podcast website, Podigee sets a session cookie for technical operation, which is deleted when you close your browser; we do not use analytics, advertising or tracking cookies there. The legal basis is our legitimate interest in providing our podcast and measuring its reach (Art. 6(1)(f) GDPR).

Podcast apps and platforms. If you listen to our podcast via a podcast app or platform such as Apple Podcasts or Spotify, the respective provider processes your data under its own responsibility and in accordance with its own privacy policy; we have no influence on this. Where a platform provides us with statistics, we receive them exclusively in aggregated form. To the extent that joint controllership under Art. 26 GDPR exists in this respect, the legal basis is our legitimate interest in measuring reach (Art. 6(1)(f) GDPR); you may then exercise your rights under Section 2 against both us and the platform.

Guests. We publish the names, voices and contributions of our podcast guests, as well as the details mentioned in the show notes, with their consent (Art. 6(1)(a) GDPR) or on the basis of the agreement made with them (Art. 6(1)(b) GDPR).

Contact. You can send enquiries about the podcast to marketing@bergstein-media.com.

Part A – Website (hello-email.com)

3. Hosting and Delivery (Bunny CDN)

Our website is delivered via the content delivery network of BUNNYWAY d.o.o., Ljubljana, Slovenia (EU). When you visit the site, technically necessary server log data is processed (IP address, date/time, requested resource, browser/operating system identifiers, referrer). The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in the secure, stable and performant provision of the website. Log data is deleted after a short period unless it is needed to investigate attacks. A data processing agreement pursuant to Art. 28 GDPR is in place with Bunny.

4. Web Analytics (Umami, self-hosted)

We use the analytics software Umami, which we operate on our own servers in the EU. Umami works without cookies and without storing information on, or accessing information stored on, your device; IP addresses are not stored permanently, and analysis is carried out exclusively in anonymous and aggregated form. Consent under Section 25(1) of the German TDDDG is therefore not required. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in the statistical analysis of website usage). You may object to this processing at any time (Art. 21 GDPR).

5. Support Chat (LibreDesk, self-hosted)

For the support chat on our website and in our software (app.hello-email.com) we use the open-source software LibreDesk, which we operate on our own servers at Hetzner Online GmbH (Germany). No external chat provider is involved; chat content is not transmitted to third parties. A data processing agreement pursuant to Art. 28 GDPR is in place with the hosting provider.

When you open our website or our software, the chat button is loaded exclusively from our own servers. No cookies are set and no information is stored on or read from your device at that point; only the server log data described in Section 3 is generated.

Only when you send a message in the chat do we set two technically necessary first-party cookies ("libredesk-session-…" and "libredesk-visitor-…"). Their sole purpose is to assign your conversation to you, allow you to continue it on a later visit, and, where needed, forward unanswered messages to you by email. The cookies have a lifetime of 30 days. As this storage is strictly necessary for the chat service you have expressly requested, no consent is required (Section 25(2) no. 2 of the German TDDDG, Art. 5(3) ePrivacy Directive). If you are logged in to our application, the chat is linked to your customer account when it loads so that we can handle your request without asking you to identify yourself again; in that case the session cookie is set as soon as the application opens.

In the chat we process the messages and attachments you enter, voluntary details such as your name and email address, the time of the message and your IP address, as well as the addresses and titles of the pages of our website or our software you visit during an ongoing chat (at most the last 20 pages, stored for 24 hours) so that our support team can better understand your question. If you leave an email address and close the chat before our reply arrives, we forward the reply to you by email; your email reply is added to the same conversation. Requests you send by email to support@hello-email.com are handled in the same system. Our email mailboxes, including support@hello-email.com, are operated on our behalf by Proton AG, Route de la Galaise 32, 1228 Plan-les-Ouates, Switzerland (Art. 28 GDPR); LibreDesk retrieves incoming emails from this mailbox and sends our replies through it. Proton stores emails in encrypted form in data centres in Switzerland, Germany and Norway. An adequacy decision of the EU Commission exists for Switzerland (Art. 45 GDPR).

The legal basis is Art. 6(1)(b) GDPR (handling your request in the context of the contract or pre-contractual measures) and Art. 6(1)(f) GDPR (legitimate interest in efficient and traceable customer support). We delete chat histories once your request has been fully resolved and no statutory retention obligations apply, and in any event no later than 24 months after the last message. You can delete the cookies at any time via your browser; the conversation can then no longer be continued.

6. Embedded Videos (YouTube and Loom, two-click solution)

Our website embeds videos from YouTube (Google Ireland Ltd. / Google LLC, USA) and Loom (Atlassian, Inc., USA). The embedding uses a two-click solution: initially you only see a locally hosted preview image; only once you click is the video loaded and a connection to the provider's servers established, which may then set cookies or access your device. The legal basis is your consent given by clicking (Section 25(1) TDDDG, Art. 6(1)(a) GDPR). Google and Atlassian are certified under the EU-U.S. Data Privacy Framework.

7. Google Ads Integration (Customer Match)

You can connect your Google Ads account (Google Ireland Ltd. / Google LLC) to the software to automatically sync your recipient lists as customer lists (Customer Match) to Google Ads. When connecting, you grant us access via the Google OAuth dialog to the scopes https://www.googleapis.com/auth/adwords (manage your Google Ads account) and https://www.googleapis.com/auth/datamanager (Google Data Manager API); we do not request any further Google permissions beyond these.

For synchronisation, the email addresses of the recipients you select are SHA-256 hashed on our side and transmitted to the Google Ads Data Manager API exclusively in hashed form over an encrypted connection. We do not transmit any email addresses in plain text. Google uses this data to match the recipients to Google accounts in your Google Ads account and to provide the customer list for your campaigns. We use the granted access exclusively for this purpose.

Who we share Google user data with: We do not sell Google user data and we do not share, transfer or disclose it to third parties. The only recipient of the hashed customer lists is your own Google Ads account (Google Ireland Ltd. / Google LLC). The OAuth access and refresh tokens and the account information retrieved from Google (Google Ads customer IDs and account names) are stored exclusively on our own systems operated by Google Cloud / Firebase (Google Ireland Ltd. / Google LLC) (see Sections 11 and 17); these providers process the data solely on our behalf as processors pursuant to Art. 28 GDPR and have no right to use it for their own purposes. Beyond this, we disclose Google user data only where we are legally required to do so or where this is necessary for security purposes (for example, to investigate abuse). We do not transfer or disclose Google user data to third parties for purposes other than the ones described in this section.

How we protect Google user data: Google user data is encrypted in transit (TLS) and at rest. OAuth access and refresh tokens are stored in encrypted form; access is restricted to the systems that technically require it. Our staff do not access this data except with your explicit consent for troubleshooting, for security purposes or where required by law. We request only the minimum scopes necessary for this feature.

Retention and deletion: If you disconnect the integration in the software or revoke our access in your Google Account, we delete the access and refresh tokens immediately and the retrieved account information within 30 days. Upon termination of your contract, Section 15 applies. Customer lists already created in Google Ads remain in your Google Ads account and can be deleted there by you. You may also request deletion at any time by emailing support@hello-email.com.

Limited Use: We use Google user data solely to provide the Customer Match feature described in this section. We do not use it for our own advertising, for third-party advertising, for profiling, for determining creditworthiness, or to develop, improve or train AI or machine-learning models. Hello Email's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

The legal basis for processing your connection and account data is Art. 6(1)(b) GDPR. Where we transmit recipient data to Google on your behalf, we act as a processor (Art. 28 GDPR); you, as the customer, are responsible for compliance with the Google Ads policies and for the data-protection lawfulness of using Customer Match (in particular for obtaining any required consents from your recipients). You can revoke the connection at any time in the software settings or via your Google account; customer lists already synced can be deleted in Google Ads.

7a. Meta Integrations (Custom Audiences, Lead Ads and Conversions API)

You can connect your Meta business account to the software via Facebook Login for Business. In the EU, Meta's services are provided by Meta Platforms Ireland Limited, Block J, Serpentine Avenue, Dublin 4, Ireland ("Meta"). The integration offers three optional features, which you activate separately:

• Meta Ads Sync (Customer List Custom Audiences): You can sync recipient segments you select in the software as customer lists to your own Meta ad account in order to use them as audiences for your campaigns on Facebook and Instagram.
• Lead Ads integration: Contacts who submit one of your Meta lead forms (Instant Forms) are transferred automatically to your Hello Email account.
• Conversions API: Purchases in your shop and sign-ups via our sign-up forms can be transmitted as events to your Meta dataset (Meta Pixel) so that you can measure and optimise your Meta campaigns.

Which data we access: When connecting, you grant us the following permissions via the Meta authorisation dialog: ads_management, ads_read, business_management, leads_retrieval, pages_manage_ads, pages_manage_metadata, pages_read_engagement, pages_show_list. We do not request any further Meta permissions. On this basis we process the following data from your Meta account ("Meta Platform Data"): the access tokens issued by Meta, the app-scoped user ID of the person establishing the connection, and the IDs and names of the business portfolios, ad accounts, Facebook Pages and lead forms you select.

Meta Ads Sync: For synchronisation, the email addresses of the recipients in the segments you select are normalised and SHA-256 hashed on our side and transmitted to your ad account via the Meta Marketing API exclusively in hashed form over an encrypted connection. We do not transmit these identifiers in plain text. Meta uses this data to match the recipients to Meta accounts and to create the audience. Under Meta's Customer List Custom Audiences Terms, Meta Platforms Ireland Limited acts as your processor and deletes the uploaded customer list data after the matching process is completed, unless you choose optional features offered by Meta. Please note that contacts who unsubscribe or are deleted in the software are not automatically removed from audiences already created in Meta; you can remove them there or delete the audience in Meta Ads Manager.

Lead Ads integration: When a person submits one of your lead forms, Meta notifies us and we retrieve the submitted data on your behalf via the Meta Graph API: the information requested in your form (e.g. name, email address, phone number, answers to your custom questions and any consent checkboxes ticked), the time of submission and the IDs of the form, ad, campaign and Page. We store this data as a contact in your Hello Email account. You decide which data your lead form collects. As the controller, you are responsible for informing the persons concerned (in particular through a link to your privacy policy in the lead form) and for obtaining any consent required for email marketing.

Conversions API (purchase and sign-up events): If you activate this feature, we transmit the following events server to server via the Meta Conversions API to the Meta dataset (Meta Pixel) you select: purchases in your shop (event "Purchase") and sign-ups via our sign-up forms (event "Lead"). Each event contains the event name, the time and an event ID; purchase events additionally contain the order value, currency, order ID and the IDs and quantity of the products purchased. To enable Meta to match the event to a Meta account, we also transmit the email addresses of the persons concerned, which we normalise and SHA-256 hash before transmission. In addition, we transmit the Meta lead ID ("lead_id") for persons captured via a Meta lead form; in accordance with Meta's specifications, this identifier is transmitted unhashed. You decide in the settings whether and which events are transmitted. Meta uses the events to measure your campaigns, to attribute conversions to your ads and to target and optimise the delivery of your ads.

Roles and legal basis: We process the data from your Meta account to provide the integration on the basis of Art. 6(1)(b) GDPR and, where the person establishing the connection is not our contractual partner, on the basis of Art. 6(1)(f) GDPR (our legitimate interest in providing the integration requested by our customer). Where we transmit recipient data to Meta or retrieve lead data from Meta on your behalf, we act as your processor (Art. 28 GDPR; see Section 13); you, as the customer, are the controller. Meta acts towards you on the basis of your own agreements with Meta (for customer lists as your processor under the Customer List Custom Audiences Terms; for lead forms under Meta's Lead Ad Terms; for the Conversions API under Meta's Business Tools Terms). For events transmitted via the Conversions API, Meta acts as your processor for matching and measurement; for the collection and transmission of event data for the targeting and delivery of ads, you and Meta are joint controllers (Art. 26 GDPR, Controller Addendum of Meta), and Meta is an independent controller for its subsequent processing. As the controller, you must ensure that a legal basis exists for transmitting the events to Meta; according to the German data protection supervisory authorities, this generally requires the consent of the persons concerned. Meta is therefore not a sub-processor of ours (see Section 17).

Who we share Meta Platform Data with: We do not sell Meta Platform Data or lead data, and we do not share, transfer or disclose them to third parties, with the following exceptions: (a) the hashed customer lists and the events, which we transmit on your instruction to your own Meta ad account or dataset; (b) the processors that operate our systems on our behalf: access tokens and account information are stored exclusively on our own systems operated by Google Cloud / Firebase (Google Ireland Ltd. / Google LLC), and lead data is stored like your other contact data in our infrastructure (see Sections 11 and 17); these providers process the data solely on our behalf pursuant to Art. 28 GDPR and may not use it for their own purposes; (c) where we are legally required to disclose it. Data we receive via Meta for one customer is stored separately from the data of other customers and is never combined with data of other customers. If Meta requests it under its Platform Terms, we provide Meta with the names and contact details of the customers who use the Meta integrations (Art. 6(1)(b) and (f) GDPR).

How we protect this data: Meta Platform Data and lead data are encrypted in transit (TLS) and at rest. Access tokens are stored in encrypted form; access is restricted to the systems that technically require it. Our staff do not access this data except with your explicit consent for troubleshooting, for security purposes or where required by law. We request only the permissions necessary for these features.

No other use: We use data received via Meta interfaces exclusively to provide the features described in this section on your behalf. We do not use it for our own advertising or for third-party advertising, for profiling, or for decisions on eligibility (e.g. creditworthiness), and we do not use it, not even in anonymised or aggregated form, to develop, improve or train AI or machine-learning models. The anonymised data used for our own model training (see Section 12) does not include any data received via Meta.

Retention and deletion; how to request deletion:

• You can disconnect the integration at any time in the software settings or remove Hello Email in your Facebook account settings under "Business integrations" or "Apps and websites". We then delete the access tokens immediately and the account information retrieved from Meta within 30 days.
• Lead data already transferred forms part of your contacts in Hello Email. You can delete individual contacts in the software at any time; in all other respects Section 15 applies.
• Customer lists already created in Meta remain in your Meta ad account and can be deleted there by you.
• Events already transmitted via the Conversions API are processed by Meta under its terms; we cannot delete them at Meta. You can stop the transmission at any time by deactivating the feature.
• You can request the deletion of all data we have received via Meta at any time by emailing support@hello-email.com with the subject "Meta data deletion". We carry out the deletion within 30 days and confirm it to you.
• If you request the deletion of your data via your Facebook settings ("Apps and websites"), Meta notifies us automatically. We then initiate the deletion and provide you with a confirmation code and a link where you can check the status of your request.
• If you submitted your data via a lead form of one of our customers, that customer (the company whose form you completed) is the controller. Please address your requests to that company; we forward any requests we receive without undue delay.

Reporting security issues: You can report security vulnerabilities in Hello Email at any time to support@hello-email.com (subject: "Security").

8. Demo Booking and Video Conferences (Proton Calendar, Proton Meet)

To book a demo, we link to an appointment booking page of the calendar service Proton Calendar provided by Proton AG, Route de la Galaise 32, 1228 Plan-les-Ouates, Switzerland. By clicking the link you leave our website. The data you enter when booking (name, email address, selected time slot, optional message) is processed by Proton on our behalf (Art. 28 GDPR); Proton's own privacy policy additionally applies to the technical access data (e.g. IP address) generated when you open the booking page.

We conduct the demo and other online appointments (e.g. onboarding and support calls) as video conferences via Proton Meet. You can join via the link sent to you without your own Proton account. We process the display name you choose, your audio and video data, screen shares and chat messages, as well as technical connection data (e.g. IP address, time and duration of participation). The content of the video conference (audio, video, screen shares, chat) is end-to-end encrypted; according to Proton, Proton itself has no access to it. We do not record video conferences.

The legal basis is Art. 6(1)(b) GDPR (conducting the appointment you requested or pre-contractual measures) and otherwise Art. 6(1)(f) GDPR (legitimate interest in secure and efficient communication). Proton stores data in data centres in Switzerland, Germany and Norway; an adequacy decision of the EU Commission exists for Switzerland (Art. 45 GDPR). We delete appointment data as soon as it is no longer required for conducting and following up on the appointment (see Section 15).

Part B – "Hello Email" Software (app.hello-email.com)

9. Registration and Login

An account is required to use the software. For this purpose we collect your email address and any company details you provide. Login is passwordless via a sign-in link sent to your email address. Authentication is handled via Firebase Authentication (Google Ireland Ltd. / Google LLC). The legal basis is Art. 6(1)(b) GDPR (performance of contract).

To protect the sign-in page against automated access (bots) we use Friendly Captcha, provided by Friendly Captcha GmbH, Am Anger 3-5, 82237 Wörthsee, Germany, as a processor (Art. 28 GDPR). Friendly Captcha sends your browser a computational puzzle that is solved in the background; interaction on your part is usually not required. In the process, your IP address, technical details about your browser and device (e.g. browser type, language, screen resolution), interaction data on the sign-in page and the solution to the puzzle are transmitted to Friendly Captcha and analysed to assess whether the request originates from a human user. Friendly Captcha does not use cookies, does not store any data persistently in your browser, anonymises IP addresses by one-way hashing before storage and does not use the data to identify individuals or for advertising purposes. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in protecting our systems and our customers' accounts against abuse. Insofar as information on your device is accessed for this purpose, this is strictly necessary to provide the sign-in process you have requested (Section 25(2) no. 2 of the German TDDDG). Friendly Captcha operates a globally distributed server infrastructure; depending on your location, your request may be answered by a server outside the EEA. Transfers to Friendly Captcha's sub-processors outside the EEA are safeguarded by the EU Commission's standard contractual clauses (Art. 46(2)(c) GDPR).

10. Contract and Payment Data

For billing purposes we process contract, invoicing and payment data (Art. 6(1)(b) GDPR). The seller and contracting party is Bergstein Media Ltd. Payments are processed via Stripe (Stripe Payments Europe, Ltd., Dublin, Ireland; data is transferred to Stripe, LLC, USA) or Mollie (Mollie B.V., Amsterdam, Netherlands). To pay, you are redirected to a payment page operated by Stripe or Mollie; we ourselves do not receive or store complete card or bank account details. For the actual payment processing, fraud prevention and compliance with their regulatory obligations (e.g. anti-money-laundering), both payment providers process your payment data as independent controllers; their privacy notices apply in this respect. Where Stripe additionally stores and manages customer, subscription and invoicing data on our behalf (e.g. name, email address, billing address, subscription status, payment history), Stripe acts as our processor (Art. 28 GDPR) on the basis of the Stripe Data Processing Agreement. The associated transfer to the USA is safeguarded by the certification of Stripe, LLC under the EU-U.S. Data Privacy Framework (Art. 45 GDPR). Mollie acts exclusively as an independent controller. We retain invoicing and accounting data to comply with statutory retention obligations (Art. 6(1)(c) GDPR).

11. Provision of the Software; Infrastructure

To provide the software we use processors pursuant to Art. 28 GDPR, in particular: Hetzner Online GmbH (Germany), UAB Space Hosting (Lithuania), Google Cloud / Firebase (Google Ireland Ltd. / Google LLC), Amazon Web Services (AWS – Frankfurt and Ireland regions, including email sending via Amazon SES), Twilio Inc. / SendGrid (USA, email sending) and BUNNYWAY d.o.o. (Slovenia, media delivery). Where data is transferred to the USA in this context, the providers are certified under the EU-U.S. Data Privacy Framework or standard contractual clauses pursuant to Art. 46(2)(c) GDPR have been concluded. A current list of our sub-processors can be found in Section 17 of this policy.

12. AI Features

The software creates email content using generative AI. For this purpose, we transmit the inputs required for the respective feature to the following model providers: OpenAI (USA; DPF-certified), Google (USA/Ireland; DPF-certified), Anthropic (USA; standard contractual clauses) and OpenRouter (USA; standard contractual clauses, zero-data-retention configuration). Under the API agreements concluded with these providers, transmitted content is not used by them to train their models. The legal basis is Art. 6(1)(b) GDPR and, in all other respects, Art. 6(1)(f) GDPR.

Voice input (speech-to-text): You can also dictate your inputs for the AI features as a voice message instead of typing them. Your device's microphone is accessed only after your explicit permission in the browser and only for the duration of the recording you have started; this access is strictly necessary to provide the feature you have explicitly requested (Section 25(2) no. 2 of the German TDDDG). The recording is transmitted in encrypted form to our servers and from there to the speech-to-text service of ElevenLabs (Eleven Labs Inc., 169 Madison Ave #2484, New York, NY 10016, USA), where it is converted into text (transcription). The resulting text is then processed in the same way as a typed input (see above). The data processed comprises the audio recording of your voice, the spoken content and technical details of the request (e.g. time, language and duration of the recording). Please do not mention personal data of third parties in voice messages unless this is necessary for the feature you want to use. Neither we nor ElevenLabs analyse your voice in order to identify you; no voice profiles are created and no biometric data for the purpose of uniquely identifying a person (Art. 9 GDPR) is processed. ElevenLabs processes the data as our processor (Art. 28 GDPR) on the basis of a data processing agreement and does not use transmitted recordings or transcripts to train its models. The audio recording is held on our systems only for the duration of the transmission and transcription and is deleted immediately afterwards; only the resulting text is retained as part of your content in the software (see Section 15). We delete the transcript generated at ElevenLabs there immediately after retrieving it, using the interface provided for this purpose. Processing by ElevenLabs takes place in the USA; Eleven Labs Inc. is certified under the EU-U.S. Data Privacy Framework, so the transfer is based on the EU Commission's adequacy decision (Art. 45 GDPR). The legal basis is Art. 6(1)(b) GDPR. Where you mention personal data of your own customers or recipients in your voice messages, we process this data on your behalf (see Section 13); in this respect ElevenLabs acts as our sub-processor (see Section 17).

Our own model training: To improve our software and AI features we use exclusively anonymised and aggregated data from which no person can be identified. Personal data of our customers or of our customers' recipients is not used for training purposes.

13. Processing on Behalf of Our Customers (Recipient Data)

Where our customers use the software to process personal data of their own customers and newsletter recipients (e.g. email addresses, order and interaction data, including via integrations with Shopify, Klaviyo and Meta Lead Ads; see also Sections 7 and 7a), we act exclusively as a processor pursuant to Art. 28 GDPR on the basis of a data processing agreement. The controller is the respective customer (shop operator). Data subjects should contact the respective shop to exercise their rights; we support our customers in responding.

14. Communications and Existing-Customer Information

We send you transactional emails required for the performance of the contract (Art. 6(1)(b) GDPR). In addition, we inform existing customers by email about our own similar products and features (Art. 6(1)(f) GDPR); you may object to this at any time, e.g. via the unsubscribe link in every email, without incurring any costs other than transmission costs at basic rates.

Email correspondence: For our business email communication (e.g. contract, invoicing and support correspondence) we use the email service of Proton AG, Route de la Galaise 32, 1228 Plan-les-Ouates, Switzerland, as a processor (Art. 28 GDPR). Emails are stored there in encrypted form; the data centres are located in Switzerland, Germany and Norway. An adequacy decision of the EU Commission exists for Switzerland (Art. 45 GDPR). The legal basis is Art. 6(1)(b) GDPR and otherwise Art. 6(1)(f) GDPR (legitimate interest in secure and efficient business communication).

15. Storage Periods and Deletion

We store personal data only for as long as necessary for the purposes stated. Upon termination or your deletion request, account data and content stored in the software are deleted from the production systems within 30 days. To protect against ransomware and data loss we maintain immutable backups (object lock), which are automatically deleted no later than 12 months after creation; backup data is used exclusively for recovery, and in the event of a restore, previously deleted data is deleted again. Statutory retention obligations (in particular for invoicing data) remain unaffected.

16. No Automated Decision-Making

No automated decision-making within the meaning of Art. 22 GDPR that produces legal effects concerning you takes place.

17. List of Sub-Processors

To provide our services we use the following sub-processors within the meaning of Art. 28(2) and (4) GDPR. Where providers process personal data in the USA, the transfer is based on the adequacy decision for the EU-U.S. Data Privacy Framework ("DPF", Art. 45 GDPR) or on the EU Commission's standard contractual clauses ("SCC", Art. 46(2)(c) GDPR). Where providers process personal data in Switzerland, the transfer is based on the EU Commission's adequacy decision for Switzerland ("AD Switzerland", Art. 45 GDPR).

Not sub-processors: integrations with your own accounts. If you connect your own accounts with third-party platforms, in particular Google Ads (Google Ireland Ltd. / Google LLC; Customer Match, see Section 7) and Meta (Meta Platforms Ireland Limited; Custom Audiences, Lead Ads and Conversions API, see Section 7a), we transmit data to these platforms or retrieve data from them on your instruction. These providers act on the basis of your own agreements with them and are not sub-processors of ours.

We notify customers by email at least 30 days before adding or replacing a sub-processor. Customers may object to the change on serious data protection grounds; the details are governed by the data processing agreement.