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Privacy Policy

Last updated: 2/12/2026

1. Controller

The controller within the meaning of the GDPR is:

Lukas Weber
Achtstraße 29
88255 Baienfurt
Germany

Email: [email protected]

2. Overview of Data Processing

The following overview summarizes the types of data processed and the purposes of their processing:

  • WhatsApp messages: Text messages, voice messages, images, and documents that you send to our bot via WhatsApp
  • Phone number: Your WhatsApp phone number for identification
  • Usage data: Time of use, type of requests, quota used
  • Payment data: For paid features through our payment service provider

3. Legal Basis

We process your data on the following legal bases:

  • Consent (Art. 6(1)(a) GDPR): When you actively message our bot, you consent to the processing of your messages by AI services.
  • Contract performance (Art. 6(1)(b) GDPR): To provide our AI assistant services according to our Terms of Service.
  • Legitimate interests (Art. 6(1)(f) GDPR): For technical infrastructure, security, and abuse prevention.

4. AI Processing and Third-Party Providers

To provide our services, we use the following AI providers:

OpenAI (USA)

Text processing (GPT), speech transcription (Whisper), image analysis

Privacy: openai.com/privacy

FAL AI (USA)

Image generation and image editing

Privacy: fal.ai/privacy

Meta / WhatsApp Business API

Sending and receiving WhatsApp messages

Privacy: whatsapp.com/legal/privacy-policy

Stripe (USA)

Payment processing and subscription management

Privacy: stripe.com/privacy

EU Hosting Provider

Server infrastructure (Location: Germany/EU)

We have data processing agreements in place with all mentioned service providers pursuant to Art. 28 GDPR.

Data minimization: Your phone number is not transmitted to AI providers. Only the content of your requests is processed in pseudonymized form.

5. Data Transfers to Third Countries

Some of our service providers are based in the USA. The transfer is based on:

  • EU-US Data Privacy Framework (DPF) for certified companies
  • Standard Contractual Clauses (SCCs) of the EU Commission
  • Your explicit consent when using the service

6. Storage Duration

  • Chat memory: The last 10-30 messages or a maximum of 72 hours are stored encrypted to provide context for your conversation. After 30 days of inactivity, all data is automatically deleted.
  • Usage data: Statistics (message count, credits) are stored anonymized for 12 months.
  • Billing data: Invoice-relevant data is stored according to tax retention periods (10 years) - without chat content.
  • Generated media: Images and audio are automatically deleted from our servers after delivery.

7. Your Rights

You have the following rights regarding your personal data:

  • Right of access (Art. 15 GDPR): You can request information about your stored data.
  • Right to rectification (Art. 16 GDPR): You can request the correction of inaccurate data.
  • Right to erasure (Art. 17 GDPR): You can request the deletion of your data.
  • Right to restriction (Art. 18 GDPR): You can request the restriction of processing.
  • Right to data portability (Art. 20 GDPR): You can receive your data in a structured format.
  • Right to object (Art. 21 GDPR): You can object to the processing.
  • Right to withdraw consent: You can withdraw any consent given at any time.

To exercise your rights, please contact us at: [email protected]

8. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority about the processing of your personal data. The supervisory authority responsible for us is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg
(State Commissioner for Data Protection and Freedom of Information Baden-Württemberg)
Lautenschlagerstraße 20
70173 Stuttgart, Germany
www.baden-wuerttemberg.datenschutz.de

9. Cookies

Our website uses cookies. For detailed information, please see our Cookie Policy.

10. Data Security

We implement technical and organizational security measures to protect your data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons:

  • SSL/TLS encryption for all data transfers
  • Encryption of stored data (Encryption at Rest)
  • End-to-end encryption through WhatsApp
  • Regular security updates
  • Access restrictions and logging

11. Privacy Commands in the Bot

You can exercise your privacy rights directly via WhatsApp:

  • /forget - Deletes your chat history and memory
  • /settings privacy - Manage your privacy settings
  • /delete - Complete deletion of your account

12. Changes to This Privacy Policy

We reserve the right to adapt this privacy policy to reflect changes in legal requirements or changes to our service and data processing. The current version can always be found on this page.

Notice: Günther is an independent AI service and is not affiliated with WhatsApp Inc., Meta Platforms Inc., or their subsidiaries.

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