1. Data Controller and Contact Information

The data controller within the meaning of the General Data Protection Regulation (GDPR) is:

SmarterWaysProductions
Ricky Tom Kluegl
Saarlandstrasse 93
55411 Bingen am Rhein
Germany

Contact:
Email: support@smarterwaysproductions.com
Website: smarterwaysproductions.com

If you have any questions about data protection, you can contact us at any time. Additional contact details can be found in our Legal Notice.

2. Principles of Data Processing

The protection of your personal data is very important to us. We process your data only based on applicable data protection laws, in particular the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG).

Our principles:

• Data minimization: We only collect data that is actually necessary for our services
• Local AI: Your AI conversations and data remain on your computer – we have no access
• No profiling: We do not create user profiles for advertising or other purposes
• Transparency: You always know what data we process, how and why
• Your control: You can request information, correction or deletion of your data at any time

3. Types of Data Processed

a) Technical Data (automatically collected)

With each visit to our website, the following technical data is automatically collected:

• IP address (anonymized after 24 hours)
• Date and time of access
• Browser type and version
• Operating system
• Pages accessed and downloads
• Referrer URL (which page you came from)
• Amount of data transferred

Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in technical provision and security of the website)

b) Contact Data

When you contact us via our contact form or email, we store:

• Your name
• Your email address
• Your message
• Time of contact

Purpose: Processing your inquiry and communication with you
Legal basis: Art. 6 para. 1 lit. b GDPR (contract initiation) or lit. f GDPR (legitimate interest)
Storage period: Until complete processing of your inquiry, at most 3 years

c) Purchase and Customer Data

When purchasing our AI licenses, we process:

• Name and email address
• Billing address (if required)
• Purchased products and licenses
• Purchase date and transaction ID
• Payment method (not the payment data itself)

Purpose: Contract fulfillment, billing, license provision, support
Legal basis: Art. 6 para. 1 lit. b GDPR (contract fulfillment) and lit. c GDPR (legal obligation)
Storage period: 10 years (tax law retention obligation)

4. Payment Processing via Steam

Our products are distributed via Steam (Valve Corporation). Steam acts as the marketplace and payment processor, which means:

• Steam handles all payment processing
• Steam processes all payment data
• Steam creates the invoice and handles taxes
• We do not receive or store any payment information

Data we receive from Steam: Only confirmation of purchase (no personal payment data)
Steam's Privacy Policy: store.steampowered.com/privacy_agreement
Legal basis: Art. 6 para. 1 lit. b GDPR (contract fulfillment)

5. Website Hosting and Technical Service Providers

a) Firebase Hosting

Our website is hosted via Firebase Hosting by Google. Firebase may collect technical data:

• IP address
• Browser information
• Access times

Firebase's Privacy Policy: Firebase Privacy Policy
Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in reliable hosting)

b) Google Fonts

We use Google Fonts to display fonts. Your IP address is transmitted to Google in the process.

Google's Privacy Policy: Google Privacy Policy
Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest in uniform display)

6. Cookies and Local Storage

Our website only uses technically necessary cookies and local storage:

• Session cookies: For basic website functionality
• No tracking cookies: We do not use cookies for advertising or tracking

Detailed information can be found in our Cookie Policy.

7. Local AI Software and Data Protection

What makes our AI products special:

• Primarily local: Core functions and AI conversations remain on your computer
• No access to content: We have no access to your AI chats or documents
• Limited internet connection: Only required for license verification and future online features
• Your control: You have complete control over your local data
• No profiling: We do not create profiles based on your AI usage

The only data transmitted is license information and optionally support requests when you explicitly contact us.

8. Data Security

We implement technical and organizational measures to protect your data from loss, manipulation and unauthorized access:

• SSL/TLS encryption for all data transmissions
• Secure server infrastructure with trusted providers
• Regular security updates
• Access control and authorization concepts
• Regular data backups

9. Data Transfer to Third Countries

Some of our service providers (such as Firebase, Google, Steam) are based in the USA or other third countries. Data transfer is based on:

• EU-US Data Privacy Framework (for certified US companies)
• EU Standard Contractual Clauses
• Adequacy decisions by the EU Commission

10. Your Rights as Data Subject

You have the following rights regarding your personal data:

1. Right to information (Art. 15 GDPR): You can request information about the data we process
2. Right to rectification (Art. 16 GDPR): You can request correction of incorrect data
3. Right to erasure (Art. 17 GDPR): You can request deletion of your data (as long as no legal retention obligations exist)
4. Right to restriction (Art. 18 GDPR): You can request restriction of processing
5. Right to data portability (Art. 20 GDPR): You can receive your data in a common format
6. Right to object (Art. 21 GDPR): You can object to processing
7. Right to withdrawal (Art. 7 GDPR): You can withdraw given consents at any time
8. Right to complaint (Art. 77 GDPR): You can complain to a data protection supervisory authority

How to exercise your rights:
Send an email to: support@smarterwaysproductions.com
Or use our contact form

11. Retention Periods

We store your data only as long as necessary for the respective purposes:

• Contact inquiries: 3 years after completion of communication
• Purchase and billing data: 10 years (tax law retention obligation)
• Technical log data: 30 days (IP addresses anonymized after 24 hours)
• Support data: 3 years after last contact

12. Protection of Minors

Our services are not directed at persons under 16 years of age. We do not knowingly process data from minors under 16 years without consent from legal guardians.

13. Changes to this Privacy Policy

We may change this privacy policy at any time to adapt it to new legal requirements or to take into account changes to our services.

For significant changes, we will inform you:

• Through a notice on our website
• By email (if you are a customer)
• The date of the last change can be found at the beginning of this statement

14. Contact for Privacy Questions

For privacy questions, you can contact us at any time:

• Email: support@smarterwaysproductions.com
• Contact: contact@smarterwaysproductions.com
• Contact form: Click here
• Mail: SmarterWaysProductions, Saarlandstrasse 93, 55411 Bingen am Rhein, Germany

We strive to respond to all privacy inquiries within 30 days.