This section is not part of the contract, but a non-binding text template. Customers using anny AI are obliged under Art. 13/14 GDPR to add information regarding the use of the AI assistant via the activated channels to their privacy policy.
The following text can serve as a starting point and should be adapted to individual circumstances and the channels actually used. 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 via various communication channels)
For our digital customer communication and appointment/booking processes, we use the product anny AI, a service provided by anny GmbH, Cäcilienstraße 30, 50667 Cologne, Germany (hereinafter referred to as "anny"). anny AI can be provided via various channels, e.g., telephone, WhatsApp, WhatsApp Call, Instagram, a web chat widget on our website, and — 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-supported product and feature portfolio that automatically processes inquiries and supports booking processes. Incoming interactions are received automatically. At the beginning of the interaction, you will be informed in a manner appropriate to the channel that you are communicating with an AI system (for voice channels via an announcement, for text channels via a notice in the chat).
Which data is processed?
In the context of an interaction, depending on the channel, the following personal data may be processed: Your channel-specific identifier (e.g., telephone or WhatsApp number, Instagram handle; for our web chat widget, your IP address as well as session/device data; for Slack/MS Teams, your internal user ID) Interaction content (voice, text, or message data) that you express during the exchange with the AI assistant Date, time, and duration of the interaction Transcripts, message histories, and summaries generated by the AI assistant Booking data, provided you submit a booking or appointment request Recording of the conversation (audio), provided you use a voice channel and the recording feature is activated.
Purpose and legal basis of processing
The processing of your data is carried out for the purpose of handling your concerns, booking inquiries, and other requests, as well as to ensure our availability via the channels used. The legal basis is Art. 6(1)(b) GDPR (performance of a contract or pre-contractual measures) and Art. 6(1)(f) GDPR (legitimate interest in efficient communication and availability).
If a conversation is recorded via a voice channel, you will be explicitly informed of this at the beginning and asked for your consent. The legal basis for the recording is your consent pursuant to Art. 6(1)(a) GDPR. This consent can be withdrawn at any time with effect for the future.
If our web chat widget uses cookies or similar technologies that are not strictly necessary for its operation, we will obtain your consent for this in accordance with Section 25 TDDDG (German Telecommunications-Telemedia Data Protection Act) or Art. 6(1)(a) GDPR.
For internal channels (Slack, MS Teams), the use concerning employees is governed by Section 26 BDSG (German Federal Data Protection Act) / Art. 88 GDPR; additionally, company regulations or works agreements may apply.
Data Processing
We have concluded a Data Processing Agreement with anny GmbH in accordance with Art. 28 GDPR.
The processing of your data generally takes place within the European Union. Insofar as individual functions or channels (e.g., certain voice models or the messaging services WhatsApp/Instagram) technically require processing outside the EU in individual cases, the transfer will take place on the basis of appropriate safeguards pursuant to Art. 46 GDPR (e.g., EU Standard Contractual Clauses and additional protective measures). Any other storage and processing will take place in Europe as far as technically feasible.
Storage periods
Your data will only be stored for as long as is necessary to achieve the purpose of processing: Call recordings (audio, voice channels only): automatic deletion after 7 days, unless otherwise configured by the customer Transcripts, message and conversation histories: deletion in accordance with contractually defined periods; no later than 60 days after the end of the contract, provided there are no statutory retention obligations Booking data: in accordance with the general storage periods of our privacy policy.
Automated decision-making
The AI assistant does not make any fully automated decisions within the meaning of Art. 22 GDPR that produce legal effects concerning you or similarly significantly affect you. Booking requests captured by the assistant are further processed by our system; you can contact us at any time to correct or cancel a transaction.
Your rights
You have the right to request 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) from us as the controller at any time. If the processing is based on a legitimate interest, you have the right to object pursuant to Art. 21 GDPR. To exercise your rights, please contact: [Name of the company], [Email address of the company's privacy contact]
Furthermore, you have the right to lodge a complaint with a data protection supervisory authority. The supervisory authority competent for you is: [Data protection supervisory authority competent for you]
End of template: please adapt to your individual circumstances and have it legally reviewed.
Further details can be found here: https://anny.co/agreement-anny-ai