Privacy Policy

This is an English translation for convenience. The service is directed exclusively at businesses (Unternehmer within the meaning of § 14 BGB). In case of any discrepancy, the German version prevails.

1. Data Controller

Data Controller under the General Data Protection Regulation (GDPR):
Igor Zelikovsky
Digitalkin AI (trade name)
Bleicherfeldstraße 31, 33689 Bielefeld, Germany
Email: contact@digitalkin.co

2. Hosting and Server Log Files

This website is hosted by Vercel Inc. (340 S Lemon Ave #4133, Walnut, CA 91789, USA). When the pages are accessed, the server automatically processes technically necessary data (including IP address, date and time of access, page accessed, browser type). The legal basis is our legitimate interest in the secure and stable operation of the website (Art. 6 para. 1 lit. f GDPR). Any transfer to the USA is based on the EU Standard Contractual Clauses. Fonts are served locally from our own server; no external font services (e.g. Google Fonts) are embedded.

3. Language Detection (Geolocation)

To select the appropriate language version, our server evaluates the country code provided by the hosting infrastructure, which is derived from your IP address. Only the country code is processed; the IP address is not stored in this context. Your language choice is stored solely in your browser (localStorage) and is not transmitted to us. The legal basis is our legitimate interest in a user-friendly presentation (Art. 6 para. 1 lit. f GDPR).

4. Analytics (Vercel Analytics)

We use Vercel Analytics for anonymous, aggregated analysis of site usage. No cookies are set and no profiles of individual visitors are created; the data collected does not allow any conclusions to be drawn about your identity. The legal basis is our legitimate interest in the statistical evaluation and improvement of our offering (Art. 6 para. 1 lit. f GDPR).

5. Contact Form

If you complete the contact form, we process the data you provide (name, email address, and optionally company and message) in order to handle your enquiry. For immediate notification, these details are forwarded to us via the messaging service Telegram (Telegram FZ-LLC, Dubai, United Arab Emirates). There is no EU Commission adequacy decision for the UAE; the transfer therefore takes place on the basis of your enquiry and for the performance of pre-contractual measures. The legal basis is Art. 6 para. 1 lit. b and lit. f GDPR. If you wish to avoid this transfer, please contact us directly by email.

Phone: Calls to +49 521 96377655 are answered by the AI assistant of Digitalkin AI, which says so at the start of the call. The data processed is described in the privacy policy of digitalkin.co, section 6.

6. Data Retention

Personal data is deleted as soon as the purpose of processing no longer applies or statutory retention periods expire. Enquiries submitted via the contact form are deleted once they have been fully processed, unless statutory retention obligations apply.

7. Cookies

This website does not set any tracking or marketing cookies and does not embed any cookie-based analytics tool. Your language choice is stored solely in your browser's local storage (localStorage); this is not a cookie and the value is not transmitted to us.

8. Data Security

Transmission is encrypted via SSL/TLS. We apply security measures in line with the current state of the art.

9. Prizma platform: data from Facebook and Instagram

Businesses can connect their Facebook Page or Instagram professional account to the Prizma platform (app.prizma.to). For the people who comment on or write to such an account, the business is the controller. We process their data on its behalf as a processor (Art. 28 GDPR).

What we process: public comments on the business's posts (text, time, name or username of the author, platform IDs); messages that people send to the business in Messenger or Instagram Direct, including any name and phone number written in them; the access token the business grants when it connects its account.

Why: to show comments and messages to the business in Prizma; to send replies on its behalf, for example a request for a phone number; to recognise whether a comment or message is an enquiry; to create that enquiry, with the contact details and the message, in the business's own CRM.

We do not use this data for advertising, do not sell it and do not use it to train AI models.

Service providers: the data is stored on servers of Hetzner Online GmbH in Germany. To recognise whether a comment or message is an enquiry, its text is sent to DeepSeek (Hangzhou, China). If DeepSeek does not respond, the text is sent to OpenAI (USA) instead. No adequacy decision of the EU Commission exists for China.

Retention: as long as the business uses the module. When the business has us disconnect its account or removes our app in its Facebook or Instagram settings, the comments, messages and tokens of that account are deleted automatically within 30 days. Enquiries already created in the business's CRM are kept by the business under its own rules.

Deletion: anyone can ask us to delete their data, see Data deletion.

10. Prizma platform: YouTube

Prizma uses YouTube API Services to publish videos to a business's own YouTube channel. By connecting a channel, the business agrees to the YouTube Terms of Service. How Google handles data is described in the Google Privacy Policy.

What we access: when a business connects its channel with its Google account, we receive an access token and the channel's ID, name and picture. We use the token to upload the videos the business schedules in Prizma, with the title, description and privacy setting it chose; to post the first comment under such a video; to set its thumbnail; and to check whether YouTube has finished processing it. We do not read the channel's other videos, comments, subscribers or analytics.

What we store: the token (encrypted), the channel ID, name and picture, and the IDs of videos Prizma uploaded. Channel name and picture are refreshed or deleted at least every 30 days. The data is stored on servers of Hetzner Online GmbH in Germany. We do not share it with third parties, do not use it for advertising and do not use it to train AI models. This website and the Prizma platform set no advertising or tracking cookies.

Prizma's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Revoking access: the business can disconnect YouTube in Prizma at any time. We then revoke the token with Google and delete the stored channel data within 7 days. Access can also be revoked on the Google security settings page; we then delete the data within 30 days. Questions about this data: contact@digitalkin.co.

11. Prizma platform: LinkedIn

Prizma publishes posts to LinkedIn on behalf of a business: either to the LinkedIn profile of the person who connects LinkedIn, or to a LinkedIn Page where that person is an administrator or content admin.

What we access: when a business connects LinkedIn, we receive an access token and a refresh token, the member's LinkedIn ID, name and profile picture, and the list of LinkedIn Pages the member administers with their names and logos. We use them to publish the posts the business approved in Prizma (text, images, video or documents) to the profile or Page it chose, and to show whether publishing worked. We do not read comments, reactions or profiles of other LinkedIn members.

What we store: the tokens (encrypted), the member's ID and name, the ID of the chosen Page and the IDs of posts Prizma created. Page names and logos are refreshed or deleted at least every 8 weeks. The data is stored on servers of Hetzner Online GmbH in Germany. We do not share it with third parties, do not use it for advertising, sales or recruiting, do not add it to any CRM and do not use it to train AI models.

Revoking access: the business can disconnect LinkedIn in Prizma at any time. We then delete the tokens immediately and the other stored LinkedIn data within 7 days. Access can also be removed in LinkedIn under Settings, Data privacy, Permitted services; we then delete the data within 30 days. Legal basis: Art. 6(1)(b) GDPR, performance of our contract with the business. Questions about this data: contact@digitalkin.co.

12. Your Rights under GDPR

You have the right to:

• Request access to your personal data (Art. 15 GDPR)
• Request correction of inaccurate data (Art. 16 GDPR)
• Request erasure of your data (Art. 17 GDPR)
• Restriction of processing and data portability (Art. 18, 20 GDPR)
• Object to processing (Art. 21 GDPR)
• Lodge a complaint with a supervisory authority (Art. 77 GDPR)

To exercise your rights, contact us at contact@digitalkin.co