Privacy Policy
This is a convenience translation. The German version is the authoritative one.
Privacy Policy
1. Privacy at a Glance: General Information
The following information provides a simple overview of what happens to your personal data when you visit this website or use our app. Personal data refers to any data that can be used to personally identify you. For detailed information on data protection, please refer to our Privacy Policy listed below this text. We use the collective term “Services” here to refer to the use of our website or our apps, as well as the associated servers and cloud services.
Data Collectionin Our Services Who Is Responsible for Data Collection?
Data processing on this website/app is carried out by the service provider. You can find the service provider’s contact information in the “Information on the Data Controller” section of this Privacy Policy.
How do we collect your data?
Your data is collected, on the one hand, when you provide it to us. This may include, for example, data you enter into a contact form.
Other data is collected automatically or with your consent by our IT systems when you visit the website or use our apps. This primarily consists of technical data (e.g., internet browser, operating system, or time the page was accessed). This data is collected automatically as soon as you use our services.
What do we use your data for?
Some of the data is collected to ensure the error-free provision of our services. Other data may be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right at any time to receive, free of charge, information about the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you may revoke this consent at any time with future effect. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to file a complaint with the competent supervisory authority.
You can contact us at any time regarding this matter or any other questions about data protection.
Analytics Tools and Third-Party Tools
When you visit this website, your browsing behavior may be statistically analyzed. This is primarily done using so-called analytics programs.
Detailed information about these analytics programs can be found in the following privacy policy.
2. Hosting
We host the content of our services with the following provider:
Hetzner
The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen (hereinafter “Hetzner”). For details, please refer to Hetzner’s privacy policy:
https://www.hetzner.com/de/rechtliches/datenschutz.
The use of Hetzner is based on Art. 6(1)(f) of the GDPR. We have a legitimate interest in ensuring that our services are presented as reliably as possible. If consent has been requested, processing is based exclusively on Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG, to the extent that the consent covers the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.
3. General Information and MandatoryData ProtectionNotices
The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations as well as this Privacy Policy.
When you use this website, various types of personal data are collected. Personal data is data that can be used to personally identify you. This Privacy Policy explains what data we collect and how we use it. It also explains how and for what purpose this is done.
Please note that data transmission over the Internet (e.g., when communicating via email) may be subject to security vulnerabilities. It is not possible to completely protect data from access by third parties.
Information on the Data Controller
The entity responsible for data processing on this service is:
Palugu Software GmbH, Berlin, Germany Email: info @ palugu.com Phone: +49 30 609 810 97
The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data (e.g., names, email addresses, etc.).
Retention Period
Unless a more specific retention period is stated in this Privacy Policy, we will retain your personal data until the purpose for which it was collected no longer applies. If you submit a valid request for erasure or revoke your consent to data processing, your data will be erased unless we have other legally permissible grounds for retaining your personal data (e.g., retention periods under tax or commercial law); in the latter case, the data will be deleted once these grounds no longer apply.
General Information on the Legal Bases for Data Processing on Our Services
If you have consented to data processing, we process your personal data on the basis of Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, provided that special categories of data are processed in accordance with Article 9(1) of the GDPR. In the event of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Article 49(1)(a) of the GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g., via device fingerprinting), data processing is additionally based on Section 25(1) of the German Telemedia Act (TDDDG). You may withdraw your consent at any time. If your data is necessary for the performance of a contract or for the implementation of precontractual measures, we process your data on the basis of Article 6(1)(b) of the GDPR. Furthermore, we process your data to the extent that it is necessary to comply with a legal obligation pursuant to Article 6(1)(c) of the GDPR. Data processing may also be based on our legitimate interest pursuant to Article 6(1)(f) of the GDPR. The following sections of this Privacy Policy provide information on the specific legal bases applicable in each individual case.
Recipients of Personal Data
As part of our business operations, we collaborate with various external parties. In some cases, this requires the transfer of personal data to these external parties. We disclose personal data to external parties only if this is necessary for the performance 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) of the GDPR, or if another legal basis permits the disclosure of data. When using data processors, we only transfer our customers’ personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.
Withdrawal of Your Consent to Data Processing
Many data processing operations are only possible with your explicit consent. You may withdraw consent that has already been given at any time. The lawfulness of the data processing carried out prior to the withdrawal remains unaffected by the withdrawal.
Right to object to data collection in specific cases and to direct marketing (Art. 21 GDPR) IF DATA PROCESSING IS BASED ON ART. 6(1)(e) E OR F OF THE GDPR, YOU HAVE THE RIGHT AT ANY TIME, FOR REASONS RELATED TO YOUR SPECIFIC SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. PLEASE REFER TO THIS PRIVACY POLICY FOR THE SPECIFIC LEGAL BASIS ON WHICH PROCESSING IS BASED. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA, UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OUTWEIGH YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING IS NECESSARY FOR THE ESTABLISHMENT, EXERCISE, OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) OF THE GDPR).
IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING, TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) OF THE GDPR).
Right to lodge a complaint with the competent supervisory authority
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the location of the alleged violation. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.
Right to Data Portability
You have the right to have data that we process automatically—based on your consent or in fulfillment of a contract—provided to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another data controller, this will only take place to the extent that it is technically feasible.
Access, Rectification, and Erasure
Subject to applicable legal provisions, you have the right at any time to receive, free of charge, information about your stored personal data, its origin and recipients, and the purpose of data processing, as well as the right to have this data corrected or erased, if applicable. You may contact us at any time regarding this matter or any other questions about personal data.
Right to Restriction of Processing
You have the right to request the restriction of the processing of your personal data. You may contact us at any time regarding this matter. The right to restriction of processing applies in the following cases:
If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data. If the processing of your personal data was or is unlawful, you may request the restriction of data processing instead of erasure.
If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure. If you have lodged an objection pursuant to Article 21(1) of the GDPR, a balancing of your interests against ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, such data—apart from its storage—may be processed only with your consent or for the purpose of asserting, exercise, or defense of legal claims, or to protect the rights of another natural or legal person, or for reasons of a substantial public interest of the European Union or a Member State.
SSL or TLS Encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address bar of your browser changes from “http://” to “https://” and by the lock icon in your browser’s address bar.
When SSL or TLS encryption is enabled, the data you transmit to us cannot be read by third parties.
4. Data Collection on This Website:Cookies
Our website uses so-called “cookies.” Cookies are small data packets that do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or your web browser deletes them automatically.
Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain third-party services within websites (e.g., cookies for processing payment services).
Cookies serve various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for advertising purposes.
Cookies that are necessary for carrying out the electronic communication process, for providing certain functions you have requested (e.g., the shopping cart function), or for optimizing the website (e.g., cookies for measuring web traffic) (necessary cookies), are stored on the basis of Article 6(1)(f) of the GDPR, unless another legal basis is specified. The service provider has a legitimate interest in storing necessary cookies to ensure the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Article 6(1)(a) of the GDPR and Section 25(1) of the TDDDG); consent may be revoked at any time.
You can configure your browser to notify you when cookies are set and to allow cookies only on a case-by-case basis, to block the acceptance of cookies in specific cases or generally, and to enable the automatic deletion of cookies when you close your browser. Disabling cookies may limit the functionality of this website.
You can find information about which cookies and services are used on this website in this Privacy Policy.
5. Data Collection in Our Apps
Frequency of Use Our service collects data on the frequency of use to improve user-friendliness and app performance. This information helps us tailor and optimize the apps to users’ needs. This data is collected anonymously and does not allow any conclusions to be drawn about your identity. Access to the Photo Gallery The app requires access to the user’s photo gallery to enable the storage of images created within the app. This access is granted only with the user’s explicit consent and is used exclusively for the purpose of storing images locally or retrieving them for further processing. Transfer of Data to Third-Party Providers The service also sends text entries and images to third-party providers to enable app functions. In doing so, data is processed and stored both within and outside the EU. We ensure that only the data entered or uploaded by the user is transmitted, and no additional personal data. Our third-party providers may receive information such as the IP address, the time, and basic device details during data transmission. We also store relevant data in a database to manage subscriptions and verify authorization.
6. Third-Party Services
The app uses the following third-party services:
- RevenueCat for subscription management: RevenueCat stores and processes data to manage subscriptions and billing. RevenueCat, Inc. Address: 1032 E Brandon Blvd #3003 Brandon, FL 33511, USA Privacy Policy: https://www.revenuecat.com/privacy/
- Replicate.com for AI services, specifically for image generation: This service is used to perform and provide image generation and image processing. Replicate, Inc., 2261 Market Street #4056, San Francisco, CA 94114, USA
These services may collect, store, and process certain data to ensure the proper functioning of the app.