vpchat - Privacy-First AI Assistant

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.).

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 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.

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. account number if you give us the authority to debit your bank account) 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 (Visa/MasterCard, debit to your bank account) 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.

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”).

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 our paid services. Registration, sign-in, single sign-on (SSO) as well as the management of users and organisations are handled via the service WorkOS (WorkOS, Inc., 9450 SW Gemini Dr #45828, Beaverton, OR 97008, USA). In this context we process in particular your name, your e-mail address, your organisation membership, your role (e.g. administrator or member) and session and login information. This data is processed by WorkOS on our behalf; we do not keep our own local copy of the user and organisation master data.

The legal basis is Art. 6(1)(b) GDPR (performance of the usage agreement) and Art. 6(1)(f) GDPR (secure provision of the service). Regarding the transfer of data to the USA, please see the section “Transfer of data to third countries”.

6. Cookies and session management

We use strictly necessary cookies only. These are in particular an encrypted session cookie used to keep you signed in (set by WorkOS) and a cookie storing your language preference (e.g. “NEXT_LOCALE”). These cookies are required to operate the service; the legal basis is Section 25(2) no. 2 TDDDG in conjunction with Art. 6(1)(f) GDPR. We do not use any tracking, advertising or analytics cookies and do not embed any third-party analytics or tracking services.

7. AI-powered chat services and automatic anonymisation

At 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.

Automatic anonymisation prior to transmission: Before a request is forwarded to an external AI provider, it passes through our self-operated anonymisation proxy. There, personal data is automatically detected by a locally operated recognition model and replaced with neutral placeholders. The mapping between placeholder and clear text is retained only for the duration of processing in a volatile cache (Redis, operated by us) – by default for no longer than one hour – and is then automatically deleted. It is used solely to replace the placeholders in the AI response with the original values again. Both detection and caching take place on our own infrastructure; the detected clear text is not transmitted to the AI providers. Automatic detection reflects the state of the art but does not operate without errors and cannot guarantee that all personal data is detected and replaced. You should therefore not rely solely on the automatic anonymisation and should review each input before sending it to check whether it contains personal or confidential data. You remain responsible for the content of your inputs.

Storage of your chat history: We store your conversations, messages, any reasoning content and the templates (system prompts) you create in our database so that you can find your history again. This stored content may contain the personal data you entered in clear text; the automatic anonymisation protects transmission to external AI providers, not the storage of your own history. The legal basis is Art. 6(1)(b) GDPR.

Statistics and usage metering: For your privacy dashboard we store, per anonymisation event, only the type and the number of detected data categories – never the clear text of the detected data. To enforce usage limits we also record technical usage data (e.g. the number of tokens processed and the resulting cost calculated per model).

8. Recipients: external AI providers

To answer your requests, we transmit the anonymised text – as described above – to external providers of language models. Which provider is used depends on the model you select. Your content is not used to train the models. We use the following providers:

OpenRouter (OpenRouter, Inc., USA) – a routing/gateway service that forwards the anonymised request to the language model you select. Only anonymised content is transmitted.
Mistral AI (Mistral AI SAS, Paris, France) – server location in the EU, without retention of the transmitted content.
Nebius (Nebius B.V., Amsterdam, Netherlands) for open-source models – server location in the EU, without retention of the transmitted content.

The legal basis is Art. 6(1)(b) GDPR (provision of the service you requested). Regarding the transfer to the USA, please see the section “Transfer of data to third countries”.

9. Hosting and technical infrastructure

We operate the service on our own server hardware. It is located in an ISO/IEC 27001-certified colocation data centre of myLoc managed IT AG (now trading as WIIT AG) in Düsseldorf, Germany. All application data (in particular conversations, messages, settings as well as statistics and usage data in our PostgreSQL database), the anonymisation cache (Redis) and the recognition model are processed on this own infrastructure in Germany and are not outsourced to external cloud services. The legal basis is Art. 6(1)(b) and (f) GDPR.

10. Customer relationship management

To manage our customer relationships, we transmit master data of prospects and customers (name, e-mail address, organisation membership, subscription status) to our CRM system HubSpot (HubSpot Ireland Limited, Dublin, Ireland). This data is hosted in a data centre within the European Union. Processing for advertising purposes only takes place on the basis of separate consent. Otherwise the legal basis is Art. 6(1)(f) GDPR (management of the business relationship).

11. Transfer of data to third countries

Some of the aforementioned service providers (in particular WorkOS, OpenRouter and Stripe) process data wholly or partly in the USA or other third countries. 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 European Commission (EU-US Data Privacy Framework, where the respective provider is certified) or on the basis of the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR) together with supplementary safeguards. Where requests are transmitted in anonymised form, no personal data in clear text is made accessible to the AI providers.

12. Data processing 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; upon request we will provide you with a data processing agreement (DPA) 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: 23.06.2026