1. Controller and contact
1.1 Responsible controller
elunos GmbH
Neue Mainzer Straße 31
60311 Frankfurt am Main
Germany
Represented by the Managing Director: Konstantin A. Leidig
Commercial register: Local Court Frankfurt am Main, HRB 138959
VAT ID: DE455362228
Email: info@elunos.ai
1.2 Contact for data protection matters
Contact: Felix Reuter
Email: datenschutz@elunos.ai
Postal address: elunos GmbH, Neue Mainzer Straße 31, 60311 Frankfurt am Main
2. Definitions
The terms used in this privacy policy follow the definitions in Art. 4 GDPR, in particular personal data (Art. 4 No. 1), controller (Art. 4 No. 7), processor (Art. 4 No. 8) and special categories of personal data (Art. 9 (1)).
3. Types of data processed
- Usage data (e.g. IP address, date and time of access, pages visited, referrer URL, browser type, operating system)
- Master data (first name, last name, position, company name)
- Contact data (email address, phone number, postal address)
- Content data (content of enquiries, demo bookings, messages)
- Contract data (subject of the contract, term, customer category)
- Voice and conversation data in connection with the use of elunos.ai (see section 8)
4. Manner and location of processing
4.1 Processing methods
elunos GmbH processes personal data lawfully and takes appropriate technical and organisational measures within the meaning of Art. 32 GDPR. Within elunos GmbH, only those persons who need it to perform their tasks have access.
4.2 Location of processing and third-country transfers
Processing takes place at the registered office of elunos GmbH and at the processors used (see section 9). Any transfer to third countries outside the European Economic Area, in particular to the USA, takes place exclusively on the basis of appropriate safeguards pursuant to Chapter V GDPR. These include in particular adequacy decisions of the European Commission (Art. 45 GDPR, including the EU-US Data Privacy Framework) and EU Standard Contractual Clauses (Art. 46 (2) lit. c GDPR).
4.3 Storage period
Personal data is only stored for as long as is necessary for the purposes of processing or as required by statutory retention obligations.
5. Purposes of processing
- Providing and operating the website https://elunos.ai
- Responding to enquiries and carrying out demo bookings
- Initiating, concluding and performing contracts with business customers and service providers
- Providing the voice AI service via the elunos.ai platform (see section 8)
- Complying with legal obligations and ensuring IT security
6. Operation of this website
6.1 Hosting
This website is hosted by Vercel Inc. (USA), acting as a processor. When the website is accessed, technically necessary connection data is processed. The legal basis is our legitimate interest in secure and efficient operation (Art. 6 (1) lit. f GDPR). Domain management and DNS resolution are handled by Cloudflare, Inc. (USA). For transfers to the USA, the EU-US Data Privacy Framework and EU Standard Contractual Clauses apply.
6.2 Server log files
Each time the site is accessed, information transmitted by your browser is automatically collected: IP address, date and time, page accessed, referrer URL, and browser and operating system information. This data serves operational security and error analysis (Art. 6 (1) lit. f GDPR) and is only stored for a short time.
6.3 Cookies and analytics
We use technically necessary cookies that are required to operate the website. We use analytics and marketing services (e.g. Google Analytics) only with your explicit consent (Art. 6 (1) lit. a GDPR, § 25 (1) TDDDG). As long as no consent has been given, no such services are loaded. You can withdraw any consent given at any time with effect for the future.
7. Contact and demo booking
When you book a demo or contact us, we process the data you provide (in particular name, email address, phone number, company and message) to handle your request and carry out the appointment. The legal basis is Art. 6 (1) lit. b GDPR (pre-contractual measures) and Art. 6 (1) lit. f GDPR (legitimate interest in business communication).
Booking and enquiry data is stored in a database operated by Supabase, Inc. (USA). For sending confirmation and reminder emails (including a calendar entry) we use Resend, Inc. (USA). To manage prospects, we forward the data to our CRM system. These service providers are bound as processors under Art. 28 GDPR; for transfers to the USA, EU Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework apply.
8. elunos.ai voice AI service
8.1 Description and roles
elunos.ai is a platform for designing and operating AI-based phone and chat agents. For calls on elunos GmbH's own lines, elunos GmbH is the controller. For calls to elunos.ai customers, the respective customer is the controller; elunos GmbH acts as a processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.
8.2 Data processed and notice
We process in particular voice data, automatic transcripts, conversation metadata (phone number, date, time, duration, outcome) and the content data communicated by the caller. At the start of each call, the caller is transparently informed that this is an AI voice agent and for what purposes the conversation is processed. If a recording is made, explicit consent is obtained beforehand (Art. 6 (1) lit. a GDPR).
No biometric identification: Voice processing serves exclusively to convert speech to text, to control the dialogue and to synthesise speech from a predefined voice ID. No biometric template of the caller is created. Where callers communicate special categories of personal data (e.g. health data), processing is based on Art. 9 (2) GDPR. A solely automated decision in an individual case within the meaning of Art. 22 GDPR does not take place in regular operation.
9. Processors and subprocessors
All engagements are secured by data processing agreements pursuant to Art. 28 GDPR and appropriate safeguards pursuant to Chapter V GDPR.
- Vercel Inc. (USA): Hosting and delivery of this website. Safeguards: EU-US Data Privacy Framework, EU Standard Contractual Clauses.
- Cloudflare, Inc. (USA): DNS management for the elunos.ai domain. Safeguards: EU-US Data Privacy Framework, EU Standard Contractual Clauses.
- Supabase, Inc. (USA): Database for booking and enquiry data. Safeguards: EU Standard Contractual Clauses.
- Resend, Inc. (USA): Sending of transactional emails. Safeguards: EU Standard Contractual Clauses.
- ElevenLabs Inc. (USA, EU branch in Warsaw): Voice AI platform for speech recognition, conversation control and speech synthesis, including the conversation models from Anthropic, OpenAI and Google as subprocessors. Safeguards: EU-US Data Privacy Framework, EU Standard Contractual Clauses, contractual European Data Residency and zero-retention mode for sensitive industries.
10. Newsletter and direct marketing
Where we inform existing customers by email about our own similar services, the legal basis is Art. 6 (1) lit. f GDPR in conjunction with § 7 (3) UWG. Newsletter subscriptions use a double opt-in process based on your consent (Art. 6 (1) lit. a GDPR), which can be withdrawn at any time via the unsubscribe link or by email to datenschutz@elunos.ai.
11. Rights of data subjects
You have the following rights under the GDPR:
- Access (Art. 15 GDPR)
- Rectification (Art. 16 GDPR)
- Erasure (Art. 17 GDPR)
- Restriction of processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR)
- Objection (Art. 21 GDPR)
- Withdrawal of consent (Art. 7 (3) GDPR)
- Complaint to a supervisory authority (Art. 77 GDPR)
12. Right to object
Where personal data is processed on the basis of Art. 6 (1) lit. f GDPR, you have the right to object at any time for reasons arising from your particular situation. You may object to processing for direct marketing purposes at any time (Art. 21 (2) GDPR).
13. Exercising your rights
Please send requests informally to elunos GmbH:
Email: datenschutz@elunos.ai
Postal address: elunos GmbH, Neue Mainzer Straße 31, 60311 Frankfurt am Main
14. Competent supervisory authority
The Hessian Commissioner for Data Protection and Freedom of Information
Postfach 3163, 65021 Wiesbaden, Germany
datenschutz.hessen.de
15. Changes to this privacy policy
We reserve the right to adapt this privacy policy to changed legal situations or changes to our services. The current version is always available at elunos.ai.