Privacy Policy
1. Introduction and Controller
We are pleased that you are using our application (hereinafter "App") and our website. Data protection is not a necessary evil for us, but a quality feature. In the following, we inform you transparently about the processing of your personal data in accordance with the General Data Protection Regulation (GDPR).
Controller within the meaning of the GDPR:
Scintilla Media UG (haftungsbeschränkt)Pappelallee 78-79
10437 Berlin
Email: datenschutz@scintilla-media.de
Commercial Register: HRB 261684 B
Register Court: District Court Berlin-Charlottenburg
Managing Director: Mario Hau
2. Data Protection when using our App
2.1 Basic Principle: Stateless Processing (No Storage)
Our App serves to convert text fragments (keywords) into formulated texts (e.g., speeches). We pursue the approach of data minimization through technology: We do not permanently store the content you enter on our own servers. The process is as follows:
- You enter text in the App and submit it.
- The text is passed once through our technical infrastructure, processed, and the result is sent back to your device.
- After delivery, the data (input and result) exists exclusively locally on your end device.
2.2 Technical Service Providers and Data Transfer
Since we do not host our own AI models but use specialized interfaces, transferring input data to our technical partners is technically mandatory.
The Processing Chain: The data passes through the following stations:
- Middleware: For technical orchestration, we use n8n (n8n GmbH / n8n Inc.), connected via a webhook.
- API Gateway: The interface is provided via CometAPI.
- AI Model: Content generation is performed by Google Gemini (Google LLC / Google Ireland Limited).
Legal Basis: Processing is carried out for the performance of the contract (provision of App functionality) pursuant to Art. 6 (1) lit. b GDPR. Without this transfer, the App does not work.
Note on Google Gemini & Abuse Detection: Even though we do not store data ourselves, we point out that providers of AI models (here Google) may temporarily store input data (usually up to 30 days) to detect abuse and violations of terms of use (e.g., Hate Speech) ("Abuse Monitoring"). According to provider information, this data is not used to train AI models for paid interfaces.
Third Country Transfer: Since some of our service providers (Google, n8n, CometAPI) may have servers or parent companies in the USA, data transfer to a third country (USA) may occur. We secure this transfer through appropriate Data Processing Agreements (DPA) and, if available, through the certification of providers under the EU-US Data Privacy Framework (DPF) or through EU Standard Contractual Clauses (SCC).
2.3 App Store Distribution
The App is distributed via the Apple Mac App Store. Apple processes data independently (e.g., your Apple ID, purchase history, device identifiers), over which we have no influence. Apple is responsible for this processing. Please note Apple's privacy policy.
3. Data Protection on our Website
3.1 Server Log Files
When visiting our website, the hosting provider automatically stores information in so-called server log files, which your browser automatically transmits. These are:
- Browser type and browser version
- Operating system used
- Referrer URL (the previously visited page)
- Hostname of the accessing computer
- Time of the server request
- IP address (possibly anonymized)
This data is not combined with other data sources. The collection of this data is based on Art. 6 (1) lit. f GDPR. We have a legitimate interest in the technically error-free presentation and optimization of our website.
3.2 Google Analytics
We use functions of the web analysis service Google Analytics on our website. The provider is Google Ireland Limited. Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
Legal Basis: The use of Google Analytics is based exclusively on your consent pursuant to Art. 6 (1) lit. a GDPR. Consent is requested via our cookie banner ("Consent Manager"). You can revoke your consent at any time.
IP Anonymization: We have activated IP anonymization. Your IP address will be shortened by Google within the EU or the EEA before transmission to the USA.
Order Processing: We have concluded a contract for order processing with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
We value your privacy
We use cookies to improve your experience and analyze our traffic. By clicking 'Accept', you consent to our use of cookies in accordance with our Privacy Policy.
4. Your Rights
You have the right to free information about the origin, recipient, and purpose of your stored personal data at any time. You also have a right to correction, blocking, or deletion of this data. Since we do not store user content in the App ourselves ("Stateless"), we technically often cannot fulfill requests for information regarding content ("Where there is nothing, nothing can be reported").
For questions about this and other topics related to data protection, you can contact us at any time at the email address given above.
