Privacy Policy

Last updated: July 31, 2026

1. Controller

DefoAI UG (haftungsbeschränkt)
Wiltinger Straße 11, 13465 Berlin, Germany
Email: [email protected]

This Service is intended for users aged 16 and over.

2. Data We Process, Why, and on What Legal Basis

Data Purpose Legal Basis (GDPR Art. 6)
Email address, display name Account authentication and communication Contract (Art. 6(1)(b))
Ad platform data (Google Ads, Microsoft Advertising — authorised via OAuth) Importing, managing, and syncing your ad campaigns Contract (Art. 6(1)(b))
Subscription and payment status Managing your subscription and billing Contract (Art. 6(1)(b))
Product usage data, including masked session recordings, heatmaps and aggregated feature-usage statistics Understanding and improving the Service (Microsoft Clarity and Google Analytics for Firebase, only with your consent) Consent (Art. 6(1)(a))
Advertising interaction data (pages viewed, signups and subscriptions, linked to a pseudonymous account identifier) Measuring which of our own advertising campaigns lead to signups (Reddit Ads conversion pixel, only with your consent) Consent (Art. 6(1)(a))
IP address (at login) Security and fraud prevention (Cloudflare Turnstile) Legitimate interest (Art. 6(1)(f))

The Reddit Ads pixel receives a pseudonymous account identifier so a signup can be attributed to the advertisement that led to it. We do not send your email address or telephone number to Reddit.

Ad platform data (Google Ads, Microsoft Advertising) is used solely to provide the Service and is not shared with third parties beyond what is necessary for that purpose. We do not use it to train AI models or for advertising. Our use of Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

3. Recipients and Data Transfers

We do not sell your data. We share data only with the following service providers, who process it on our behalf under contractual data protection obligations:

Provider Role Location Safeguard
Google (Firebase) Authentication EU / USA Standard Contractual Clauses
Microsoft (Clarity) Product analytics (session recordings & heatmaps) EU / USA Standard Contractual Clauses
Google (Analytics for Firebase) Product analytics (aggregated usage and conversion statistics) EU / USA Standard Contractual Clauses
Reddit Advertising measurement (conversion pixel, only with your consent) USA Standard Contractual Clauses
Stripe Payment processing USA Standard Contractual Clauses
Cloudflare Infrastructure & bot protection EU / Global Standard Contractual Clauses
Upstash Database Ireland (EU) Within EEA
EdenAI AI provider routing France (EU) Within EEA
OpenAI AI text generation (via EdenAI) USA Standard Contractual Clauses

We may disclose data where required by law or to protect legal rights.

4. Retention

5. Your Rights

Under GDPR, you have the right to: access your data, rectify inaccuracies, erasure ("right to be forgotten"), restrict processing, data portability, object to processing based on legitimate interest, and withdraw consent at any time (without affecting prior lawful processing).

To exercise any of these rights, contact us at [email protected]. You also have the right to lodge a complaint with your national data protection authority. In Germany: Bundesbeauftragter für den Datenschutz und die Informationsfreiheit (BfDI).

6. Security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, or disclosure.

7. Cookies

Category Provider Purpose Retention
Strictly necessary Google (Firebase) Authentication session Until sign-out
Strictly necessary DefoAI Stores your cookie consent choice Persistent
Functional Stripe Payment fraud prevention Up to 1 year
Analytics (consent required) Microsoft (Clarity) Masked session recordings & heatmaps to understand and improve the Service Up to 1 year
Analytics (consent required) Google (Analytics for Firebase) Aggregated usage and conversion statistics to understand and improve the Service Up to 14 months
Advertising (consent required) Reddit Measuring which of our own advertising campaigns lead to signups and subscriptions Up to 1 year
Advertising (consent required) DefoAI Browser storage entry growomatAttribution, recording which of our own advertising campaigns brought you to the site (the utm_* parameters in the link you followed, the advertising platform's click identifier, the referring site and the first page you opened). It lets us measure which campaigns lead to signups. It is written only if you accept, and is never used to build a profile of you or shared with third parties. 30 days

You can accept or decline analytics and advertising cookies via the banner on first visit, or change your choice at any time via Cookie Preferences in the application footer.

If you go on to create an account, the campaign information described above is saved once to your account record so we can measure the effectiveness of our own advertising. It is recorded at registration only and is never updated afterwards. Like the other details we keep about your account, it is deleted when you delete your account (see Your rights).

8. Changes

We will notify you of material changes to this policy by updating the date above. Continued use of the Service constitutes acceptance of the updated policy.

9. Contact

DefoAI UG (haftungsbeschränkt)
[email protected]