Supplement to Your Privacy Policy
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We recommend including the following text in your privacy policy. Please note that this suggestion does not constitute legal advice. Please review this template and adjust it to your specific needs. It is advisable to have the template reviewed by a qualified legal advisor to ensure that it complies with all legal requirements.
## Use of the Chat Service / Conversational Platform (LoyJoy)
**1. Description and Scope of Data Processing**
We use the services of <a href="https://www.loyjoy.com">LoyJoy GmbH</a>, Kapuzinerstraße 20, 48149 Münster, Germany ("LoyJoy"), on our website to improve our services and offer you various features (e.g., customer service chat, product advice, surveys).
When you open the chat widget, technically necessary data is processed to ensure communication and security. This includes:
* IP address (anonymized and not stored persistently)
* Date and time of access
* Browser information (user agent, device type)
* Referrer URL (the previously visited page)
* Content of the chat communication (chat history)
During the chat, you may voluntarily provide further personal data (e.g., name, email address, phone number) to process your request.
*[Optional, if used: If you communicate with the chat via WhatsApp, your phone number will also be processed.]*
**2. Use of Artificial Intelligence (AI)**
To answer your inquiries and improve the service experience, we partially use technologies based on generative Artificial Intelligence. Your inputs are forwarded to a specialized AI service provider (acting as a sub-processor for LoyJoy) to generate a context-aware response. It is contractually ensured that your inputs are **not** used to train the provider's AI models.
**3. Local Storage**
LoyJoy does not use cookies for tracking or advertising purposes. To ensure technical functionality (e.g., restoring the chat history when reloading the page), data is stored in the so-called "Local Storage" of your browser. This storage is technically necessary for the use of the service. The data remains local on your device and is automatically deleted after a maximum of 14 days.
**4. Legal Basis**
* **Art. 6(1)(f) GDPR (Legitimate Interest):** For providing the chat service, ensuring technical functionality, and answering inquiries.
* **Art. 6(1)(b) GDPR (Performance of a Contract):** If your inquiry is aimed at the conclusion or performance of a contract (e.g., product purchase, appointment booking).
* **Art. 6(1)(a) GDPR (Consent):** If explicit consent is requested for specific actions (e.g., newsletter subscription within the chat).
**5. Recipients and Data Transfer (Cloudflare)**
The data is hosted on servers within the **European Union**. We have concluded a Data Processing Agreement (DPA) with LoyJoy in accordance with Art. 28 GDPR.
For security and content delivery (Web Application Firewall, CDN), LoyJoy uses services from **Cloudflare, Inc.** (San Francisco, USA). Due to technical reasons, data transfer may also occur via Cloudflare's infrastructure.
**Data transfer to the USA:** Cloudflare is certified under the **EU-U.S. Data Privacy Framework (DPF)**. As a result, an adequacy decision by the EU Commission pursuant to Art. 45 GDPR applies, ensuring a secure level of data protection.
**6. Storage Duration**
* **Live Chats & Bot Interactions:** Chat data is stored for **30 days** by default and then deleted or anonymized.
* *[Optional] Loyalty Data: Data related to loyalty programs (e.g., points) may be stored for up to 720 days.*
* **Analytics:** Anonymized data may be aggregated and stored for statistical purposes for up to 3 years.
**7. Your Rights**
Since LoyJoy processes data on our behalf, you can assert your data subject rights (access, deletion, objection, etc.) directly against us. In particular, you have the right to object to the processing based on Art. 6(1)(f) GDPR at any time.