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Draft, 12 October 2026

Privacy Policy

Draft, not yet legally reviewed. This page must be checked by a qualified German or EU legal professional before public launch. Text marked like [this] is a placeholder for the operator's real details.

This notice explains which personal data Pontumi processes, why, and which rights you have under the General Data Protection Regulation (GDPR). It describes the service exactly as it is built today. Details only the operator can give are marked and listed at the end.

1. Controller

The controller is the operator named in the Impressum: [company legal name, address, privacy contact email]. Data protection officer: [name and contact, or a statement that none is required].

2. Data we process

  • Account data: email address, a salted password hash, sign-in sessions, the version and time of the Terms and Privacy Notice you accepted. If you sign in with Google, we receive your verified email address and your Google account identifier, nothing else.
  • Conversation data: the prompts you write, the replies you receive, the model used and timestamps.
  • Attachments: photos, PDFs, text files and videos you add to a message. They are kept in private storage linked to your account and are only served to you after sign-in.
  • Voice input: when you use the microphone, the recording (at most 60 seconds) is sent to Google for transcription. Pontumi does not store the recording; only the transcribed text ends up in the input field.
  • Usage records: for each request, the provider and model, token counts, an estimated cost, credits, status, latency and a request ID. We do not log your prompt text in these records.
  • Billing data: Stripe customer and subscription IDs, plan, payment status and billing period. Card details are handled by Stripe and never reach our servers.
  • Technical data: IP address and browser data in server logs for security and abuse prevention.

3. Purposes and legal bases

  • Providing the service and your account, including conversations, attachments and voice input: Art. 6 (1) (b) GDPR (contract).
  • Billing and tax records: Art. 6 (1) (b) and (c) GDPR.
  • Security, abuse and cost protection, quota enforcement: Art. 6 (1) (f) GDPR (legitimate interest in a secure and sustainable service).

Pontumi does not use your conversations to train AI models and does not sell personal data.

4. AI providers that receive your prompts

When you send a message, your prompt, the conversation context and the attachments of that conversation are transmitted only to the provider of the model that answers, through its official API. If a model is temporarily unavailable and Pontumi answers with another model of the same provider, the answer is labelled with the model that wrote it.

  • OpenAI (OpenAI): [legal entity, country, data processing agreement status, transfer mechanism, provider retention period]
  • Anthropic (Claude): [legal entity, country, data processing agreement status, transfer mechanism, provider retention period]
  • Google (Gemini): [legal entity, country, data processing agreement status, transfer mechanism, provider retention period]
  • Mistral AI (Mistral): [legal entity, country, data processing agreement status, transfer mechanism, provider retention period]
  • xAI (Grok): [legal entity, country, data processing agreement status, transfer mechanism, provider retention period]
  • Microsoft Azure (Azure OpenAI): [legal entity, country, data processing agreement status, transfer mechanism, provider retention period]
  • Octodus (Octo): [legal entity, country, data processing agreement status, transfer mechanism, provider retention period]

Some providers are located outside the EU or EEA. Transfers rely on [EU-US Data Privacy Framework certification or Standard Contractual Clauses, per provider].

Microsoft Azure OpenAI is a subprocessor for GPT-4.1 and GPT-4.1 mini requests, including conversation context and selected attachments. Copilot models on Azure OpenAI means GPT via Azure, not a Microsoft Copilot subscription or integration. EU Data Zone deployment is required before activation; setup is pending. The operator must confirm the deployment type, Microsoft contracting entity, data processing agreement, retention and any transfer safeguards before offering access.

5. Other processors

  • Hosting, database and file storage: [hosting provider, data centre location]
  • Payments: Stripe Payments Europe, Ltd. [confirm entity and agreement]
  • Sign-in with Google (only if you choose it): Google. [confirm entity]
  • Email delivery: Pontumi sends no emails at the moment (no verification or password reset mail).

6. Retention

Conversations and their attachments are kept until you delete them. Pontumi does not delete chats automatically at the moment. A cleanup for chats older than 30 days exists as an operator command, but it is not scheduled and has not been switched on; we will update this notice before any automatic deletion starts. You can delete a conversation, including its attachments, in the workspace at any time. Account deletion requests are recorded for manual processing and do not immediately delete your account or data. Sign-in sessions expire after 7 days. Usage and billing records are kept as long as billing and statutory retention duties require ([period confirmed by the operator, e.g. up to 10 years for accounting records under German law]).

7. Cookies

We use a strictly necessary session cookie to keep you signed in and protect forms, and a language cookie when you choose a language. There is no advertising or analytics tracking. See Cookie settings.

8. Your rights

You have the right of access, rectification, erasure, restriction, data portability and objection (Art. 15 to 21 GDPR), and the right to withdraw consent at any time. To delete your account and data, use the deletion request. You may lodge a complaint with a supervisory authority, in particular the one where you live or the one responsible for the operator: [competent German state data protection authority].