1. Controller

Oliver Seidel
consults.de
Weberstraße 19
15370 Fredersdorf
Germany

Email: info@viralwords.ai
VAT ID: DE335478661

2. Overview of Data Processing

The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects concerned.

3. Data Collected

We process the following personal data:

a) Registration Data

• Email address (required)
• Password (stored encrypted as bcrypt-Hash)
• Preferred language
• Time of registration

b) Usage Data

• Topics entered for content generation
• Generated content and selected platforms
• Credit transaction history

c) Payment Data

• Stripe customer ID
• Payment status and time of transaction
• Billing address (processed directly by Stripe, not stored by us)

d) Technical Data (Server Logs)

• IP address
• Access timestamp
• Browser type and operating system
• Pages accessed

4. Legal Basis

The processing of your data is based on the following legal grounds:

• Performance of contract (Art. 6 Abs. 1 lit. b GDPR) – Provision of the service, account management, credit system and payment processing
• Legitimate interest (Art. 6 Abs. 1 lit. f GDPR) – Server logs for ensuring IT security and abuse prevention
• Legal obligation (Art. 6 Abs. 1 lit. c GDPR) – Retention of tax-relevant data

5. Purposes of Processing

• Provision and operation of the ViralWords.ai service
• Account and access management
• Credit billing and payment processing
• Sending verification emails
• Technical support and contact enquiries
• Security and abuse prevention
• Compliance with legal retention obligations

6. Storage and Hosting

(1) All data is stored on dedicated servers at Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, at the Nuremberg location.

(2) Data is only transferred to third countries (outside the EU/EEA) in the context of payment processing via Stripe (see Section 8) and, where applicable, AI processing (see Section 7). In both cases, the transfer is safeguarded by appropriate guarantees.

(3) A data processing agreement (DPA) with Hetzner is in place.

7. AI Processing

(1) AI-powered content generation is carried out via an external AI API. The topics entered by the customer and the desired platforms are transmitted to the AI service. No personal data (such as email or username) is shared with the AI service — only the input data for content generation.

(2) The input data is used exclusively to generate the requested content and is not used for training AI models.

(3) The AI service provider may process data in countries outside the EU/EEA. Where a transfer to third countries takes place, it is based on EU Standard Contractual Clauses or adequacy decisions by the European Commission.

(4) The legal basis is the performance of contract (Art. 6 Abs. 1 lit. b GDPR), as AI processing is necessary for the provision of the contractual service.

8. Payment Service Provider (Stripe)

(1) For payment processing, we use Stripe, Inc., 354 Oyster Point Blvd, South San Francisco, CA 94080, USA (European branch: Stripe Payments Europe, Ltd., Dublin, Ireland).

(2) When making a purchase, the following data is transmitted to Stripe: email address, billing address, payment information, order details.

(3) Stripe processes this data as an independent controller in accordance with the Stripe Privacy Policy. For transfers to the USA, Stripe relies on EU Standard Contractual Clauses and the EU-US Data Privacy Framework.

(4) The legal basis is the performance of contract (Art. 6 Abs. 1 lit. b GDPR).

9. Email Dispatch

(1) For sending verification emails and contact confirmations, we use the SMTP server of our hosting provider Hetzner (mail.your-server.de).

(2) Only transactional emails are sent (verification, contact confirmation). No newsletter or email marketing takes place.

10. Cookies and Local Storage

(1) ViralWords.ai uses only technically necessary cookies for session management (vw_session). This cookie is used for authentication and is automatically deleted after 30 days.

(2) Additionally, the browser's Local Storage is used to save the user's language setting. This serves usability purposes.

(3) No tracking cookies, advertising cookies or third-party cookies are used. No tracking or analysis of user behaviour takes place.

(4) Since only technically necessary cookies are used, no consent is required under § 25 TDDDG.

11. Retention Period

• Account data: Until the account is deleted by the customer
• Generated content: Until the account is deleted
• Payment data: 10 years in accordance with commercial and tax law retention obligations (§ 147 AO, § 257 HGB)
• Server logs: 30 days
• Contact enquiries: 6 months after completion of the enquiry

12. Your Rights

As a data subject, you have the following rights under the GDPR:

• Right of access (Art. 15 GDPR) – What data we have stored about you
• Right to rectification (Art. 16 GDPR) – Correction of inaccurate data
• Right to erasure (Art. 17 GDPR) – Deletion of your data, provided no legal retention obligations apply
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR) – Provision of your data in a commonly used format
• Right to object (Art. 21 GDPR) – Objection to processing based on legitimate interests

To exercise your rights, contact us at: info@viralwords.ai

13. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority. The supervisory authority responsible for us is:

Die Landesbeauftragte für den Datenschutz und für das Recht auf Akteneinsicht Brandenburg (State Commissioner for Data Protection and Right of Access to Files, Brandenburg)
Stahnsdorfer Damm 77
14532 Kleinmachnow
www.lda.brandenburg.de

14. Changes to This Privacy Policy

We reserve the right to amend this privacy policy to adapt it to changed legal requirements or changes to the service. The current version is always available on this page.