This section is not part of the contract, but a non-binding text template. Customers who use anny AI are required under Art. 13/14 GDPR to add information about the use of the AI assistant across the activated channels to their privacy policy.
The following text can serve as a starting point and should be adapted to your individual circumstances and the channels you actually use. A legal review by your own legal counsel is recommended.
Sample text: Addition to the privacy policy for users of anny AI Use of anny AI (AI-based assistant across various communication channels)
For our digital customer communication and scheduling/booking processes, we use the product anny AI, a service of anny GmbH, Cäcilienstraße 30, 50667 Cologne (hereinafter “anny”). anny AI can be provided across various channels, for example phone, WhatsApp, WhatsApp Call, Instagram, a web chat widget on our website, as well as, for internal purposes, Slack or MS Teams.
Please adapt this list to the channels you actually use.
What is anny AI? anny AI is an AI-powered product and feature portfolio that processes requests automatically and supports booking processes. Incoming interactions are received automatically. At the start of the interaction, you are informed in a channel-appropriate way that you are communicating with an AI system (on voice channels through an announcement, on text channels through a notice in the chat).
What data is processed?
As part of an interaction, the following personal data may be processed depending on the channel:
- Your channel-specific identifier (e.g. phone or WhatsApp number, Instagram handle, and for our web chat widget your IP address as well as session/device data, and for Slack/MS Teams your internal user ID)
- Interaction content (voice, text, or message data) that you express in your exchange with the AI assistant Date, time, and duration of the interaction
- Transcripts, message histories, and summaries generated by the AI assistant
- Booking data, if you place a booking or scheduling request
- Recording of the conversation (audio), if you use a voice channel and the recording feature is enabled
- Purpose and legal basis of the processing
Your data is processed for the purpose of handling your requests, booking inquiries, and other requests, as well as to ensure our availability across the channels used. The legal basis is Art. 6(1)(b) GDPR (performance of a contract or pre-contractual measures) as well as Art. 6(1)(f) GDPR (legitimate interest in efficient communication and availability).
When a conversation is recorded via a voice channel, you are expressly informed at the start and asked for your consent. The legal basis for the recording is your consent under Art. 6(1)(a) GDPR. Consent can be withdrawn at any time with effect for the future.
If our web chat widget uses cookies or comparable technologies that are not strictly necessary for operation, we obtain your consent for this under Section 25 TDDDG or Art. 6(1)(a) GDPR.
For internal channels (Slack, MS Teams), use toward employees is governed by Section 26 BDSG / Art. 88 GDPR; in addition, operational regulations or works agreements may apply.
Processing on behalf
We have concluded a data processing agreement with anny GmbH in accordance with Art. 28 GDPR.
Your data is generally processed within the European Union. Where, in an individual case, specific features or channels (e.g. certain voice models or the messaging services WhatsApp/Instagram) technically require processing outside the EU, the transfer takes place on the basis of appropriate safeguards under Art. 46 GDPR (e.g. EU standard contractual clauses and additional protective measures). Other storage and processing takes place in Europe as far as technically possible.
Retention periods
Your data is stored only as long as necessary to achieve the purpose of processing:
- Call recordings (audio, voice channels only): automatic deletion after 7 days, unless set otherwise by the customer
- Transcripts, message and conversation histories: deletion in accordance with contractually defined periods; at the latest 60 days after the end of the contract, unless statutory retention obligations exist
- Booking data: in accordance with the general retention periods of our privacy policy
Automated decision-making
The AI assistant does not make fully automated decisions within the meaning of Art. 22 GDPR that produce legal effects concerning you or similarly significantly affect you. Booking inquiries captured by the assistant are further processed by our system; you can contact us at any time to correct or cancel a matter.
Your rights
Toward us as the controller, you have at all times the right to access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), and the right to data portability (Art. 20 GDPR). Where processing is based on a legitimate interest, you have a right to object under Art. 21 GDPR. To exercise your rights, please contact: [Name of the company], [email address of the company’s data protection contact]
You also have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for you is: [data protection supervisory authority responsible for you]
End of the template: please adapt to your individual circumstances and have it reviewed legally
