Privacy Policy

Privacy Policy
for the AI app "Sapericus" (provided by Sapericus GmbH)

We at Sapericus GmbH ("we", "us", "our") are committed to providing a strictly confidential service that is developed in Germany and hosted in the EU.

This Privacy Policy explains how we collect, use, and, where applicable, share your personal data ("personal data") when you use our website, applications, and AI-powered services (collectively, the "Services" or "App").

1. What Personal Data We Collect

1.1 Data You Provide to Us

  • Account information: When you create an account for our App, we collect data such as your name, your email address, and other account information.
  • User Content: This includes all content that you enter into the AI features of the App, e.g. chat messages, files, or other uploaded information.
  • Communication information: When you contact us by email or through support channels, we store the information you provide (e.g. your name, your email address, and the message content).

1.2 Data We Receive Through Your Use

  • Log data: Technical data collected automatically (e.g. IP address, the device or browser type used, time and duration of use).
  • Usage data: Information about how you use our Services (e.g. features accessed, session histories).
  • Device information: Information about your device (e.g. operating system, device identifier).

1.3 Data From Other Sources

  • Security and integrity partners: In rare cases, we receive information from trusted partners who support us in the prevention of fraud, security threats, or abuse.

2. How We Use Personal Data

We use your data exclusively for the following purposes:

  1. Provision of the Services

    • Provision of the AI-powered coaching and chat features.
    • Ensuring stable and user-friendly operation.
    • Legal basis: Performance of the user contract (Art. 6(1)(b) GDPR).

  2. Communication and Support

    • Responding to support requests.
    • Informing you about material changes or new features.
    • Legal basis: Performance of the contract (Art. 6(1)(b) GDPR) as well as our legitimate interest in functioning user communication (Art. 6(1)(f) GDPR).

  3. Security and Abuse Prevention

    • Detection and prevention of unauthorized access, fraudulent activities, or other misuse of our Services.
    • Legal basis: Our legitimate interest in the secure and abuse-free operation of the App (Art. 6(1)(f) GDPR).

  4. Legal Requirements

    • Compliance with statutory obligations (e.g. retention obligations).
    • Establishment, exercise, or defense of legal claims.
    • Legal basis: Compliance with legal obligations (Art. 6(1)(c) GDPR) as well as legitimate interest in the pursuit of legal claims (Art. 6(1)(f) GDPR).

No Use of Your Data for AI Training
We do not use your personal data, including your content data (e.g. chat histories), to train, fine-tune, or otherwise further develop our own or third-party AI models. This commitment also applies to anonymized or aggregated data derived from your user input.

2a. Special Categories of Personal Data (Art. 9 GDPR)

In the course of a coaching dialogue, you may voluntarily disclose information that qualifies as special categories of personal data within the meaning of Art. 9 GDPR, in particular information about your health, mental state, ethnic origin, religious or philosophical beliefs, or your sex life.

Consent: The processing of such data takes place exclusively on the basis of your explicit consent pursuant to Art. 9(2)(a) GDPR. When you first launch the App, you will be asked for this consent in a separate confirmation step, separate from your acceptance of the Terms of Use and this Privacy Policy (Art. 7(2) GDPR). Without this consent, use of the App is not possible.

Renewed Consent Upon Changes: In the event of material changes to this Privacy Policy or to the scope of consent, we will obtain your consent again.

Voluntariness and Withdrawal: Consent is voluntary. You may withdraw your consent at any time with effect for the future by contacting privacy@sapericus.ai or by deleting your user account. The lawfulness of the processing carried out up to the withdrawal remains unaffected.

Note: Sapericus is not a substitute for medical, therapeutic, or psychological treatment. In the event of health complaints, please consult qualified professionals.

3. Sharing of Personal Data

Your data is shared with third parties, as a matter of principle, only where this is necessary for the purposes described in this Policy. This may occur, among others, in the following cases:

  • Processors: To provide our Services, we occasionally use external service providers (e.g. hosting or infrastructure providers). These process data exclusively on our behalf and on the basis of corresponding contracts (Art. 28 GDPR).
  • LLM Compute: In order to perform the AI computations, we rely on specialized data centers ("Compute Providers") where required. In doing so, your data is processed exclusively within the EU.
  • Legal Obligations: Where a legal obligation exists or where judicial or official orders require us to do so, we may share personal data with competent bodies (e.g. courts, authorities).

In all other cases, we process your data exclusively on our servers in Germany or the EU.

4. Data Transfer to the Licensor

If you use our Services under a license provided to you by a licensor (e.g. a company, an educational institution, or another organization), certain personal data (only the name and the email address) may be transferred to this licensor. This is necessary in order to technically enable license management and activation.

  • License Activation: To activate and manage your license, the licensor may receive access to personal information such as your name, your email address, or a user identifier. This serves to verify your authorization to use the licensed content and to properly activate the license.
  • Usage Analysis: The licensor receives only anonymized or aggregated usage statistics about the use of the licensed content (e.g. number of sessions conducted, general duration of use). Detailed interactions or personal content of your sessions are not shared.
  • No Access to Conversations or Content: The licensor has no access to the chat histories you have entered or to any other interactions with the AI.
  • Transparent Data Transfer: The prospective licensor who receives your personal data for the activation of the license is shown to you during registration. You can therefore understand at any time which organization receives access to your data. If you do not want the displayed company to receive your data, you cannot use the Service via a licensor.
  • Linking via Invitation Code: Alternatively, your licensor may provide you with an activation code (voucher code/voucher). By entering this code, your account is likewise linked to the licensor.

This data processing takes place on the basis of our legitimate interest (Art. 6(1)(f) GDPR) as well as for the performance of contractual obligations with the licensor (Art. 6(1)(b) GDPR).

5. Retention and Deletion

We store your personal data only for as long as is necessary to provide our Services or to comply with legal obligations. The provision of our Service ends with the deletion of your account. After account deletion, your data will be deleted in our production systems within 30 days. Data that is still located in backup copies (backups) at that time will be deleted as part of the regular backup rotation at the latest within 6 months. Thereafter, the data is fully deleted or anonymized.

Legal or contractual obligations (e.g. retention periods under tax and commercial law) may, where applicable, require certain data to be stored for a longer period.

6. Your Rights

Depending on the applicable data protection law (in particular the GDPR), you have the right:

  • to request access to the data we process about you,
  • to demand the rectification of inaccurate data,
  • under certain conditions, to request the erasure of your data,
  • to request the restriction of processing,
  • to object to the processing,
  • to request data portability, insofar as this is technically feasible,
  • to withdraw consent you have given at any time with effect for the future.

If you wish to exercise any of these rights, please contact us (see Section 10). If you are of the opinion that we are not processing your data lawfully, you also have the right to lodge a complaint with the competent data protection supervisory authority.

7. Security

We employ appropriate technical and organizational measures to protect your data against loss, misuse, or unauthorized access. Please note, however, that no internet or email transmission is entirely secure. You should therefore always handle the information you share online with care.

8. Children and Minors

Our Services are, as a rule, not intended for persons under 18 years of age. We do not request data from persons under 18 years of age. Should you suspect that data of a person under 18 years of age has been transmitted to us, please contact us immediately (see Section 9) so that we can delete it.

9. Changes to This Privacy Policy

We reserve the right to adjust this Privacy Policy from time to time, for example in the event of changes in legislation or the introduction of new services. The current version is always made available in the App and/or on our website.

In the event of material changes, we will inform you in good time before they take effect. In such a case, continued use of the App is only possible if you actively consent to the amended version. Insofar as the changes concern the scope of consent under Section 2a (Art. 9 GDPR), we will obtain your consent again in a separate confirmation step.

10. Contact

If you have questions about the processing of your personal data or wish to exercise one of your rights, please contact:

Sapericus GmbH
Roßhaldeweg 8
79100 Freiburg

privacy@sapericus.ai

As of: 14.04.2026