The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage ceases to apply. Storage may also take place where this is provided for by European or national legislators in EU regulations, laws, or other provisions to which the controller is subject. The data will also be blocked or deleted at the latest when a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or fulfillment of a contract.

When using the app, various processors may be recipients of personal data if they take over a partial service of the processing process. Categories of recipients of personal data are in particular:

• Hosting service provider
• IT service provider for maintenance and support purposes
• Other processors engaged to provide and improve our app

If recipients of personal data are located outside the EU or the EEA, Seneration GmbH actively creates suitable guarantees for legally compliant data transfer to third countries, e.g. by concluding standard data protection clauses in accordance with Art. 46 para. 2 lit. c GDPR.

Seneration GmbH can process aggregated data from the user base of onesome for the further development of the application and internal company services. In this case, Seneration GmbH acts as the data controller and processes the related information on user behavior exclusively in anonymized form.

You may request confirmation from the controller as to whether personal data concerning you are being processed by him.

If there is such processing, you can request information from the controller about the following:

• the purposes for which the personal data are processed;
• the categories of personal data which are processed;
• the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
• the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage duration;
• the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
• the existence of a right of appeal to a supervisory authority;
• any available information on the origin of the data, if the personal data are not collected from the data subject;
• the existence of automated decision making including profiling pursuant to Art. 22 para. 1 and 4 GDPR and at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information on whether personal data concerning you is transferred to a third country or to an international organization. In this context, you may request information about the appropriate safeguards pursuant with Article 46 of the GDPR in connection with the transfer.

You have a right to rectification and/or completion vis-à-vis the data controller, insofar as the personal data processed concerning you are inaccurate or incomplete. The responsible party shall make the correction without undue delay.

Under the following conditions, you may request the restriction of the processing of personal data concerning you:

• if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful and you refuse the erasure of the personal data and instead leave the restriction of use of the personal data;
• the controller no longer needs the personal data for the purposes of processing, but you need them for the assertion, exercise or defense of legal claims, or
• if you object to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.

Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of their storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

a) Obligation to Erase Data

You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete such data without undue delay, if one of the following reasons applies:

• The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
• You withdraw your consent on which the processing is based pursuant with Art. 6 para. 1 S. 1 lit. a or Art. 9 para. 2 lit. a GDPR was based, and there is no other legal basis for the processing.
• You object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. GDPR.
• The personal data concerning you has been processed unlawfully.
• The deletion of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
• The personal data concerning you has been processed in relation to information society services offered pursuant to Art. 8 para. 1 GDPR collected.

b) Information to third parties

If the controller has made the personal data concerning you public and is responsible pursuant to. Art. 17 para. 1 GDPR to erase them, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers processing the personal data that you, as data subject, have requested erasure of all links to or copies or replications of such personal data.

c) Exceptions

The right to erasure does not exist insofar as the processing is necessary to

• to exercise the right to freedom of expression and information.
• for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public health pursuant to Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 DSGVO;
• for archiving purposes in the public interest, scientific or historical research purposes, or for statistical purposes in accordance with Art. 89 par. 1 GDPR, insofar as the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
• for the assertion, exercise or defense of legal claims.

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed about these recipients by the data controller.

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that

• the processing is based on consent pursuant to Art. 6 para. 1 S. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to… Art. 6 para. 1 S. 1 lit. b GDPR and
• the processing is carried out with the help of automated procedures.

In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other individuals must not be adversely affected.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 S. 1 lit. e or f GDPR, to object; this also applies to profiling based on those provisions.

The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the possibility, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.

You have the right to withdraw your consent for data protection at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

• is necessary for the conclusion or fulfillment of a contract between you and the responsible party,
• is permitted by legislation of the Union or the Member States to which the controller is subject and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or
• is done with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or b GDPR applies and appropriate measures have been taken to safeguard your rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in 1. and 3. above, the controller shall take reasonable steps to safeguard the rights and freedoms of, and the legitimate interests of, the data subject, which shall include, at least, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.

Each time our app is called up, our system automatically collects data and information from the computer system of the calling computer.

The following data is collected:

• Information about the browser type and version used
• Operating system of the user
• Internet service provider of the user
• Date and time of access
• IP address

This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

The app is hosted using the infrastructure of Microsoft Corporation, 1 Microsoft Way, Redmond, WA 98052, USA. In this context, the service provider may have access to the data mentioned above. To ensure data protection compliance and lawful data transfers to third countries, appropriate data processing agreements as well as suitable safeguards have been implemented, for example through the conclusion of standard contractual clauses pursuant to Art. 46 para. 2 lit. c GDPR. The server location of the data processing is geographically in Germany.

The temporary storage of the IP address by the system is necessary to enable delivery of the web app to the user’s computer. For this purpose, the user’s IP address must be stored for the duration of the session.

The storage in log files is done to ensure the functionality of the app. In addition, we use the data to optimize the app and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 para. 1 S. 1 lit. f GDPR.

The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 S. 1 lit. f GDPR.

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of data collection for the provision of the app, this is the case when the respective session has ended.

In the case of data storage in log files, this is the case after no later than seven days. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.

Our web app uses cookies. Cookies are text files that are stored in the user’s internet browser or by the internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string that enables the unique identification of the browser when the website is accessed again.

We use cookies to make our app more user-friendly. Some elements of our app require that the calling browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

• Language settings
• Log-in information

We also use cookies on our app that enable an analysis of the user’s surfing behavior. These are only set with the user’s consent in the case of statistical cookies.

In this way, the following data can be transmitted:

• Entered search terms
• Frequency of page views
• Use of website functions

The user data collected in this way is pseudonymized by technical precautions. It is therefore no longer possible to assign the data to the accessing user. The data is not stored together with other personal data of the users.

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our web app cannot be provided without the use of cookies. For these, it is necessary that the browser can be recognized even after a page change.

We need cookies for the following applications:

• Remember search terms
• Language settings

The user data collected through technically necessary cookies are not used to create user profiles.

Analytics cookies are used for the purpose of improving the quality of our app and its content. Through the analysis cookies, we lean how the app is used and can thus constantly optimize our offer.

Technically necessary cookies

Name: Web App onesome Cookies
Provider: Owner of this website
Purpose: Technically necessary information for using the website
Cookie Name: webapp.onesome.de
Cookie Duration: 365 days

Name: Stripe
Provider: Stripe Payments Europe
Purpose: For processing purchases made through the onesome app. Information about cookies from websites connected to onesome can be found on the respective websites.
Cookie Name: .s.stripe and m.stripe.network

Statistical cookies

Name: Web App onesome Cookie
Provider: Owner of this website
Purpose: For session ID tracking via Matomo. Information about cookies from websites connected to onesome can be found on the respective websites.
Cookie Name: webapp.onesome.de
Cookie Duration: 365 days

The legal basis for the processing of personal data using technically unnecessary cookies is Art. 6 para. 1 S. 1 lit. a GDPR.

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 S. 1 lit. f GDPR.

On our app, it is possible to contact us via the email address provided. In diesem Fall werden die mit der Email übermittelten personenbezogenen Daten des Nutzers gespeichert.

The data will be used exclusively for the processing of the conversation.

In the case of contact by email, this also constitutes the necessary legitimate interest in processing the data.

The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 para. 1 lit. f GDPR. If the email contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data transmitted via email, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified.

On our app, we offer users the opportunity to register by providing personal data. Die Daten werden dabei in eine Eingabemaske eingegeben und an uns übermittelt und gespeichert. Eine Weitergabe der Daten an Dritte findet nicht statt. The following data is collected as part of the registration process:

• Email adress
• Last name
• First name
• Date and time of registration
• Employment type (optional)
• Gender (optional)
• Year of birth (optional)

As part of the registration process, the user’s consent to the processing of this data is obtained.

The identification of the user is necessary to ensure the use of the application within the framework of the contract of use of the application concluded between Seneration GmbH and you within the framework of your registration and creation of a user account.

The legal basis for the processing of personal data in the context of creating a user account and using personal data for the described functionalities is the user’s consent pursuant to Art. 6 Abs. 1 S. 1 lit. GDPR in conjunction with Art. 9 para. 2 lit. a GDPR.

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected.

We utilize features of the technology provided by OneSignal, located at 201 San Antonio Circle Suite #140, Mountain View, CA, USA.

OneSignal enables us to send registration emails and follow-up emails related to the use of onesome.
When using the app, we ask whether we may send messages in the future (push notifications) to inform you about news and updates.

During this process, OneSignal stores cookies on your device. The following personal data is processed by OneSignal in particular:
– First and last name
– Email address
– IP address, system configuration
– Visited websites using the SDK, information about the visits
– Information about the end user’s browser, such as browser language type and operating system – version (e.g., Android, iOS), network provider, language settings, time zone
– Cookie ID
– Push notification message

The data is processed and stored in Europe and the United States.
OneSignal is certified under the Data Privacy Framework. For more information about OneSignal and data protection at OneSignal, please visit https://onesignal.com/privacy_policy

The utilization of OneSignal is intended for sending registration emails, follow-up emails, and push notifications related to the use of onesome (reminder emails, product marketing emails, etc.). After registering with onesome, you can customize settings within the web app to receive follow-up emails.

The processing of users’ personal data is primarily based on the user’s consent according to Article Art. 6 para. 1 S.1 lit. a GDPR.

Your personal information will be stored for as long as necessary to fulfill the purposes described in this privacy policy or as required by law, e.g., for tax and accounting purposes.
If you withdraw your consent to receive emails, the corresponding personal data will also be deleted.

On our website, we use functions of the content delivery network Microsoft Azure CDN of Microsoft Corporation, One Microsoft Way, Redmond, WA 8052-6399, USA (hereinafter referred to as: Microsoft Azure CDN). A content delivery network (CDN) is a network of geographically distributed servers connected via the internet that is used to deliver content, in particular large media files such as videos. Microsoft Azure CDN provides web optimization and security services that we use to improve the loading times of our website and to protect it from misuse. When you access our website, a connection is established to Microsoft Azure CDN servers in order to retrieve content, for example. In this process, personal data may be stored and analyzed in server log files, in particular user activity, especially which pages have been visited, as well as device and browser information, especially the IP address and operating system.

For more information about the collection and storage of data by Microsoft Azure CDN, click here: https://www.microsoft.com/de-de/TrustCenter/Privacy/default.aspx

Part of the data processing agreement with Microsoft includes so-called EU Standard Contractual Clauses (Art. 46 para. 2 S. 1 lit. c GDPR). These are considered appropriate safeguards for the transfer and processing of personal data outside the EU. A copy of the standard data protection clauses can be requested by sending us an informal e-mail.

Leverage Microsoft Azure CDN capabilities to deliver and accelerate online applications and content.

The collection of this data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be collected.

Your personal information will be retained for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law.

Our platform offers AI functionalities to best support users in their personal development journey.

Basic AI Features: Automated summaries & practice recommendations

After completing our coaching journeys or individual stages, each user receives a summary based on their responses. The AI system only receives the absolute minimum amount of information: the plain text of your answers, without any metadata or personal details. The AI system itself does not store any data.

This summary is stored in our database after the data has been processed by the AI system. Additionally, based on the responses provided, the AI recommends a practice for integration into everyday life. The practice is selected from a curated pool maintained by us. All data received by the AI system is strictly limited to the response texts and contains no personal data that would allow conclusions to be drawn about the user’s identity. The data is not used for training or fine-tuning AI models.

The AI system is hosted by onesome on Microsoft Azure within the EU.

Optional Additional Feature: onesome AI Companion

We also offer the onesome AI Companion – an AI-based chat assistant that interactively supports users within onesome. The companion enables users to answer questions about their goals, challenges, and concerns in a chat-like format (similar to messenger apps) in order to receive tailored content. The system processes only voluntarily entered text and context-related information, such as the current journey, recently completed journeys, upcoming community sessions, or the time of use. This information is provided to our AI system via Retrieval-Augmented Generation (RAG) from our database. All services are hosted by onesome on Microsoft Azure within the EU.

The AI system itself does not store any personal data. However, in order to meaningfully continue the conversation and “remember” previous messages and insights, chat histories are encrypted and pseudonymized and stored in a separate database within the EU (region: Sweden Central).

This data enables the companion to suggest suitable content, remind you of relevant sessions, and respond to your concerns with empathy. During an active dialogue, the onesome AI Companion uses your previous messages to meaningfully continue the conversation and provide personalized responses.

Users can request the deletion of their existing chat histories at any time. If a user account is fully deleted, all conversation histories are automatically removed. The data is not used for training or fine-tuning AI models.

Security Measures

To protect our users and ensure system integrity, we implement technical security mechanisms for both AI functionalities:

• Abuse Monitoring (Microsoft Azure)

This is an automated security feature operated by Microsoft Azure. It detects suspicious user input (e.g., abusive, harmful, or unauthorized content) based on predefined criteria. The review is AI-based and fully automated – no content is analyzed by humans.

• Content Filtering

Additionally, a filtering mechanism is enabled that detects high-risk content (e.g., violence, discrimination, or illegal statements) before output and automatically suppresses or modifies it to protect users from problematic responses.

• Manual Review in Exceptional Cases

Only if an input is clearly classified as critical can a targeted manual review by authorized Microsoft personnel occur in rare exceptional cases and only if the issue arises repeatedly. Even then, the review is limited strictly to the flagged individual prompt—never the full chat history. Such access is permitted only within the EU and requires prior approval from Microsoft’s responsible management (Just-in-Time Approval). In this case, Microsoft personnel have no information about the identity of the person who submitted the prompt. If inputs are repeatedly flagged as abusive or potentially dangerous, authorized onesome staff will review the respective prompts and take appropriate action (e.g., warnings or account suspension).

All data processing takes place exclusively within the EU, preferably on servers located in Germany. The AI never has access to personally identifiable data – tracing back to a specific individual through the AI system is not possible.

Processing via the basic function serves the purpose of providing the core functionalities of the platform and delivering a personalized summary and practice recommendation to users, in order to optimize their learning experience and the integration of content into their daily lives.

The onesome Companion aims to support users individually in discovering content, reflecting, and integrating insights, while offering them continuous and interactive guidance.

The processing of personal data by KI is necessary for the performance of the contract pursuant to Art. 6 para. 1 lit. b GDPR, as the provision of summaries and exercise recommendations is an essential function of the platform and is necessary for the use of the service.

The Companion is part of the contractually agreed platform services. The processing of personal data via the Companion is therefore generally based on Art. 6 para. 1 lit. b GDPR (performance of a contract). Users can deactivate the onesome AI Companion in the settings, however, this may result in significantly limited usability of certain features.

To ensure technical functionality, platform stability, and protection against misuse, we process certain data on the basis of Art. 6 para. 1 lit. f GDPR (legitimate interests). Our legitimate interest lies in maintaining the security, integrity, and availability of the platform, as well as protecting users from potentially harmful behavior.

In individual cases, processing may also be based on Art. 6 para. 1 lit. f GDPR, insofar as this is necessary to safeguard our legitimate interests in the establishment, exercise, or defense of legal claims, for example in cases of criminal acts, breaches of contract, or misuse of the platform.

Personal data processed in the context of using our AI features serves to fulfill the respective contractual relationship. The data is stored only for as long as necessary to fulfill the contract. Once the purpose of processing no longer applies or statutory retention periods (e.g., under commercial or tax law) have expired, the data will be deleted or – where possible and appropriate – anonymized to ensure that any reference to individuals is permanently excluded.

Old chat histories with the onesome AI Companion can be deleted upon request via email (support@onesome.de) or by deleting the account. If the account is fully deleted, all conversation histories will also be removed.