Privacy Policy

Draft – have this reviewed by a lawyer before launch. Last updated: [DATE]. The German version is legally binding.

1. Controller

UFMOSA UG (haftungsbeschränkt), Bellevuestraße 1, 10785 Berlin, Germany Email: support@pontumi.com Data protection officer: [TO COMPLETE or "not appointed, not required" – check]

2. What we process

Account data: email address, optional name, a salted password hash (bcrypt), language, privacy settings, time you accepted the terms.

Chats and files: your messages, the models' answers, and the text extracted from files you upload (PDF, Word, text, code). We don't keep the original files, only the extracted text.

Usage data: per request the model, provider, token counts, cost, time and status – without the message content.

Billing data: Stripe customer and subscription IDs, plan, payment status, amounts. Card details never reach our servers; Stripe processes them directly.

Technical data: IP address and browser details in server logs, to secure the service (for example against brute-force attacks).

Cancellations: if you cancel via "Cancel contract", we store the name, email, type, reason and time of the declaration.

3. Purposes and legal bases

• Providing the workspace, billing, support: performance of contract (Art. 6(1)(b) GDPR).
• Keeping invoice and payment records: legal obligation (Art. 6(1)(c) GDPR, § 147 AO, § 257 HGB).
• Security, abuse prevention, enforcing plan limits: legitimate interest (Art. 6(1)(f) GDPR).

We don't use your chats to train AI models and we don't sell personal data.

4. AI providers

When you send a message, the message, the conversation so far and the text of attached files go only to the provider of the model that answers, through its official API. In Compare, the same request goes to each selected model; when merging, the answers go to the merging model.

For each provider: [TO COMPLETE: contracting entity, data processing agreement, transfer mechanism (e.g. EU-US Data Privacy Framework or Standard Contractual Clauses), provider-side retention, "no training" commitment under API terms].

Personal data redaction (optional): with "Hide personal data from providers" on, we replace email addresses, phone numbers, IBANs and card numbers with placeholders before sending, and restore them only in the answer shown to you. Other personal details (for example names or addresses) are not detected.

EU-only mode (optional): when on, we only use models whose provider processes data in the EU.

5. Other service providers

• Hosting: [TO COMPLETE: e.g. Hetzner Online GmbH, Gunzenhausen; data centre in Germany] – processor.
• Payments: Stripe Payments Europe, Ltd., Dublin, Ireland – independent controller for payment processing.
• Email (password reset, cancellation confirmation): [TO COMPLETE: SMTP provider, location] – processor.

6. Retention

• Chats and files: until you delete them or your account.
• Usage data: [TO COMPLETE, e.g. 24 months], then deleted.
• Invoice and payment records: 10 years (statutory); after account deletion without a link to your account.
• Sign-in sessions: 30 days.
• Password reset links: 1 hour.
• Server logs: [TO COMPLETE, e.g. 14 days].

Deleting your account in Account settings takes effect immediately: account, chats, files and usage data are deleted and any running subscription is cancelled.

7. Cookies

We only use strictly necessary cookies: a session cookie (sign-in) and a language cookie. In the workspace your browser stores your last selected models locally. There is no tracking, advertising or analytics. Fonts are served from our own server.

8. Your rights

You have the right to access, rectification, erasure, restriction, data portability and objection (Art. 15–21 GDPR). You can download a full copy of your data as JSON in Account settings at any time. You can complain to a supervisory authority, for example the Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59–61, 10555 Berlin. [TO CHECK]