Privacy Policy
Privacy briefly explained
KIsy processes data so that you can use the website, the web app, and the coaches. This includes, for example, your email address, your account, your chat messages, technical data, and security information.
When you write to a coach, your messages may be processed so that KIsy can respond. Coaches are AI systems and not humans. KIsy can make mistakes.
Please do not enter passwords, secrets, or unnecessarily private information. Also, do not enter other people's data if you are not authorized to do so.
KIsy is not intended to replace diagnoses, therapies, crisis intervention, or professional decisions. If you write about health, bullying, violence, anxiety, crises, or very personal things, particularly sensitive information may arise. You should only enter such information if it is really necessary.
We do not sell your data. We do not create advertising profiles. We do not share your data for advertising purposes. However, to operate KIsy, we use technical service providers, for example for hosting, AI functions, payment, security, and analytics.
If you are under 18, you may only use KIsy if a legal guardian has permitted this and an adult account holder has set up, authorized, or paid for the account.
If you have any privacy questions, you can reach us at datenschutz (at) kisy.io.
This summary is for comprehensibility. Detailed information can be found in the following sections.
Status: May 2026
1. General Information
The protection of your personal data is important to us. With this Privacy Policy, we inform you about which personal data we process when you use KIsy, for what purposes this is done, on what legal basis this is based, and what rights affected individuals have.
This Privacy Policy applies to the website, the web app, and other digital offerings of KIsy, provided that no separate privacy policy indicates alternative processing.
2. Data Controller
The Data Controller within the meaning of Article 4 No. 7 of the General Data Protection Regulation (GDPR) is:
KIsy Coaching GmbH
Am Dornbusch 17
37297 Berkatal
Hesse, Germany
E-Mail: info (at) kisy.io
Privacy Contact:
E-Mail: datenschutz (at) kisy.io
3. Categories of Personal Data
Depending on your usage, we process in particular the following categories of personal data:
- Master data, such as name, e-mail address, user ID, age, or date of birth, if requested,
- Contract and account data,
- Payment and billing data, if paid services are used,
- Communication data when contacting us,
- Usage data and technical transmission logs,
- Content of chat histories, text inputs, uploads, and other content provided by the user,
- Device and browser information,
- Technical system logs (e.g., deployed model and system versions, age or account holder status),
- Security-relevant events (e.g., displayed warnings, interruption, cancellation, or refusal events),
- Consent and preference data, if applicable.
4. Processing upon Mere Website Visit
4.1 Server Log Files
When you visit our website or web app, our system or our hosting provider automatically processes technically necessary connection and protocol data. This may include in particular:
- IP address,
- Date and time of access,
- Accessed page or requested resource,
- Browser type and version,
- Operating system,
- Referrer URL,
- Access status and amount of data transferred.
The processing takes place to ensure the security, stability, delivery, and functionality of our offering, as well as to detect and defend against attacks, abuse, and malfunctions.
The legal basis is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the secure and functional operation of our platform.
Server log files are generally only stored as long as necessary for the aforementioned purposes. Unless longer retention is necessary for the investigation of abuse or security incidents, deletion usually takes place within 14 days.
4.2 Hosting
The KIsy platform is hosted on servers by Amazon Web Services (AWS). According to our current system configuration, the servers used for this are located within the EU, specifically in Frankfurt am Main, Germany. Insofar as we use external hosting or infrastructure service providers, this is done on the basis of Data Processing Agreements (DPA) or other legally permissible grounds.
The legal basis is Art. 6 para. 1 lit. f GDPR and, to the extent the processing is necessary for the performance of a user contract, Art. 6 para. 1 lit. b GDPR.
5. Registration, User Account, and Contract Execution
5.1 Registration and Account Management
When a user creates or manages an account, we process the data necessary for this, in particular:
- Name or display name,
- E-mail address,
- Password in a technically protected format,
- Age or date of birth, if applicable,
- Account settings and preferences.
The processing requires the setup, management, and use of the user account as well as the fulfillment of the user agreement. The legal basis is Art. 6 para. 1 lit. b GDPR.
Where specific information is not strictly necessary for the fulfillment of the contract, we mark it as voluntary or handle it accordingly.
5.2 Minors and Parent Accounts
KIsy is an educational offering aimed at users aged 10 and above. Minors may only use KIsy if a legal guardian has permitted its use and the account has been set up, managed, paid for, or explicitly authorized by an adult person.
The contractual partner for paid services is the adult account holder. The processing of personal data in connection with registration, account management, contract execution, technical provision, and security generally takes place to provide the service, fulfill the user agreement with the adult account holder, and ensure the safe and legally compliant use of KIsy.
KIsy does not base the provision of the actual service on the data protection consent of minor users. If, exceptionally, consent should be required for individual additional processing operations, such processing will only take place once the legal requirements for this have been met.
6. Use of AI Features, Chat Histories, and Uploads
6.1 Processing of Inputs and Outputs
The core of the service consists of interactions with AI systems. When users enter text, speak via voice/audio inputs, ask questions, upload files, or transmit other content to KIsy, we process this data to provide the requested functions and generate answers or other outputs. Voice data is processed strictly for communication purposes and not for biometric identification.
In particular, the following may be processed: Chat messages, prompts, uploaded images or documents, usage metadata, and system-generated answers. The legal basis is Art. 6 para. 1 lit. b GDPR.
6.2 No Unnecessary Sensitive Details
KIsy is a learning, practice, idea, explanation, and reflection service. KIsy is not designed to specifically collect, categorize, diagnostically evaluate special categories of personal data within the meaning of Art. 9 GDPR, or to use them to create health, therapy, personality, political, religious, or other special profiles.
Users should not enter any unnecessary sensitive information in chats, text inputs, uploads, or other content. This includes in particular information on health, mental health, diagnoses, therapy, medication, sex life, sexual orientation, religious or philosophical beliefs, political opinions, ethnic origin, genetic or biometric data, as well as secrets, passwords, or confidential information of third parties.
Functions relating to bullying, conflicts, communication, cooking, crafting, and similar topics serve as general learning, reflection, idea, and formulation aids. They are not intended for diagnosis, therapy, crisis intervention, medical advice, psychological treatment, legal advice, or other professional evaluation of sensitive personal circumstances.
If users nevertheless voluntarily provide sensitive information as part of an input, KIsy will only process this information within the framework of the communication initiated by the user, for the technical provision of the requested function, to generate the response, for the security of the service, to prevent abuse, for error analysis, to process support requests, or, if necessary, to establish, exercise, or defend legal claims.
KIsy does not use sensitive information for advertising, data sales, advertising profiles, credit profiles, health profiles, therapy profiles, or other special personality profiles.
KIsy may reject sensitive inputs, display emergency or safety instructions, refuse to respond, shorten content, delete content, or restrict functions if this is necessary to protect users, minors, third parties, for product safety, to prevent abuse, or to comply with legal requirements.
The legal basis for the processing of ordinary personal data in the context of use is Art. 6 para. 1 lit. b GDPR, insofar as the processing is necessary to provide the requested function or to execute the contract. For security, abuse prevention, error analysis, product safety, support, and legal defense, the legal basis is Art. 6 para. 1 lit. f GDPR. Insofar as processing is necessary to fulfill legal obligations, the legal basis is Art. 6 para. 1 lit. c GDPR. Insofar as special categories of personal data are affected in connection with the establishment, exercise, or defense of legal claims, the processing in this respect is based on Art. 9 para. 2 lit. f GDPR.
If there is no sufficient legal basis for a specific input or specific content, KIsy is entitled to reject, restrict, or terminate the processing.
6.3 Storage of Chat Histories, Uploads, and Security Logs
Insofar as chat histories, uploads, or similar content are stored or displayed within the product, this is done to provide the respective function, to improve the user experience, for error analysis, abuse detection, product safety, and, if applicable, to process support requests.
The legal bases are Art. 6 para. 1 lit. b GDPR and, where necessary, Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the secure, stable, traceable, and economically viable provision of the service, in abuse prevention, in product safety, and in legal defense.
To ensure product safety, abuse prevention, and legal defense, extended security and product safety logs may be stored during critical interactions. This may include, in particular, user prompt, AI output, timestamps, deployed system and coach versions, model providers, displayed warning notices, as well as security, interruption, cancellation, or refusal events.
Chat histories and similar content are generally only stored as long as necessary for the provision of the service, support, abuse prevention, security, product safety, legal defense, or legal obligations.
If deletion functions are provided in the product, users can remove content there themselves. Technically necessary backup copies or residual data may persist for a limited transitional period.
KIsy is entitled not to store, to shorten, to delete, to anonymize individual content, chat histories, or uploads, or to reject further processing if this is necessary for reasons of security, youth protection, product safety, abuse prevention, data protection, or for legal reasons.
6.4 AI Transparency (EU AI Act)
KIsy uses artificial intelligence to generate responses and other outputs. Users interact with AI systems and not with humans. KIsy points this out within the product, in particular through notices such as "KIsy can make mistakes. Coaches are AI, not humans."
The generated AI content may be incomplete, inaccurate, misleading, outdated, unsuitable, or dangerous. It does not replace a human professional, in particular no medical, therapeutic, psychological, pedagogical, legal, technical, manual, safety-related, financial, or other professional advice.
KIsy is not intended for emergencies, crisis situations, or acute hazard situations. In such cases, appropriate human, professional, or official bodies must be contacted.
7. Payment Processing and Paid Services
When paid services are used, we process the necessary contract and billing data. The actual payment processing may be carried out by external payment service providers, notably Stripe or a comparable provider.
In this context, the following data may be processed: Name, billing data, e-mail address, transaction data, payment status, and optionally partial information regarding the chosen payment method.
We generally do not receive full payment details such as complete credit card numbers, but only transaction-related information as far as necessary for contract processing. The legal basis is Art. 6 para. 1 lit. b GDPR. Insofar as payment service providers process data under their own responsibility, their privacy policies apply supplementary. Statutory retention obligations under commercial and tax law remain unaffected.
8. Service Providers and Recipients
We attach great importance to the protection of your data. There is expressly no promotional transfer of personal data to third parties, no data sales, and no creation of advertising profiles. The use of carefully selected technical service providers (e.g., hosting, AI interfaces, payment processing) is strictly purpose-bound, insofar as this is absolutely necessary for the operation, security, and provision of KIsy and is secured under data protection law.
8.1 AI Service Providers
To provide the AI functions, we may integrate external AI service providers, in particular OpenAI for text functions and ElevenLabs for voice or audio functions, or comparable providers.
In this context, it may be necessary to transmit inputs, voice or audio data, uploads, excerpts from chat histories, and technically necessary metadata to these providers so that the requested functions can be provided and responses generated.
We choose, as far as available and economically reasonable, privacy-friendly and restrictive configurations. To the extent permitted by the respective interfaces used, we use configurations in which customer content is not used by default to train general models.
Voice or audio data are processed to provide the respective communication function. KIsy does not use voice data for the biometric identification of users. The creation of voice profiles, voice cloning, or comparable functions does not take place unless this is explicitly provided as a separate function and an independent legal basis is created for this.
The legal basis is Art. 6 para. 1 lit. b GDPR, insofar as the processing is necessary to provide the requested function. For security, abuse prevention, error analysis, product safety, and legal defense, the legal basis is Art. 6 para. 1 lit. f GDPR.
8.2 Other Recipients or Categories of Recipients
Personal data may be shared, where necessary, with the following recipients or categories of recipients:
- Hosting and infrastructure service providers,
- AI service providers,
- Payment service providers,
- IT, security, and support service providers,
- Communication and e-mail service providers,
- Analytics and monitoring service providers,
- Tax advisors, legal counsel, auditors, or other professionally bound consultants,
- Authorities, courts, or other public bodies, provided we consider ourselves legally obliged to do so.
Any further disclosure occurs only if a legal basis exists or effective consent has been obtained.
9. Third-Country Transfers
As part of our services, personal data may be transferred to countries outside the European Union (EU) or the European Economic Area (EEA), especially to the USA, if service providers used are based there or use sub-processors there.
In such cases, we ensure an adequate level of data protection. If no statutory exception applies directly, we base the transfer in particular on:
- an Adequacy Decision of the European Commission,
- Standard Contractual Clauses (SCC) of the European Commission,
- supplementary technical and organizational protective measures,
- or other legally recognized transfer mechanisms.
10. Audience Measurement, Analytics, and Cookies
10.1 Technically Necessary Cookies and Comparable Storage Technologies
We may use technically necessary cookies or comparable technologies if these are required to provide fundamental functions of our offering, such as login, security, session management, or load balancing. The legal basis for the processing of personal data is Art. 6 para. 1 lit. b GDPR or Art. 6 para. 1 lit. f GDPR, depending on the function. If accessing information stored on the end device is absolutely necessary, this happens based on the applicable statutory regulations.
10.2 Audience Measurement and Product Analytics
We may use a privacy-friendly configured analytics tool, in particular Matomo Cloud, to understand usage patterns, detect errors, improve stability, and further develop our offering.
We configure Matomo to be as privacy-friendly as possible, in particular without tracking cookies, with IP anonymization, without advertising user profiles, without data sales, and without merging with data from third-party advertising networks.
The legal basis is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the improvement, stabilization, security, and economic further development of our offering.
If an analysis function is used in the future that requires a storage of information on the end device that is not technically necessary or an access to information in the end device that is not technically necessary, we will only use this function once the legal requirements for this have been met.
10.3 External Fonts and Display Resources
For the uniform presentation and technical design of our website, external fonts, CSS, JavaScript, or other display resources may currently be integrated, in particular Google Fonts and AOS resources via unpkg or comparable providers.
When such external resources are loaded, the user's browser technically establishes a connection to the servers of the respective provider. In this process, connection data such as the IP address, browser and device information, the requested resource, referrer information, and the date and time of access may be processed.
The integration serves the uniform, stable, and user-friendly presentation of our website. The legal basis is Art. 6 para. 1 lit. f GDPR, insofar as the respective integration is permissible under data protection law without prior consent. Our legitimate interest lies in a technically functional and uniformly displayed website.
We are reviewing and planning to replace external display resources with locally hosted resources where practically possible, or to avoid non-essential external resources. Where consent is required for individual resources under applicable law, such resources may only be used once the legal requirements have been met.
11. Contact and Support
When users contact us via e-mail, contact form, or other means, we process the provided data to handle the request, to communicate with the user, and, if applicable, for contract execution. This may particularly include name, e-mail address, communication content, timestamps, and other provided information.
The legal basis, depending on the content of the request, is Art. 6 para. 1 lit. b GDPR or Art. 6 para. 1 lit. f GDPR. Inquiries and associated communications are deleted once processing concludes and no statutory retention duties or legitimate interests preclude deletion.
12. Storage Duration
We only store personal data for as long as this is necessary for the respective purposes or we are legally obliged to do so. In particular, the following criteria apply:
- We generally store account data until the account is deleted or until the contractual relationship is terminated. Thereafter, we only store them further insofar as statutory retention obligations or legitimate interests, in particular security, clarification of abuse, payment processing, or legal defense, require further storage.
- We regularly store contract, payment, and billing data in accordance with commercial and tax law retention obligations for six or ten years.
- Server log files are generally deleted within 14 days, unless longer storage is required to investigate abuse, security incidents, technical faults, or legal violations.
- We store communication and support data until the processing of the respective request has been completed and thereafter only insofar as statutory retention obligations or legitimate interests require further storage.
- Chat histories and uploads are generally stored as long as they are displayed in the user account, are required for the respective function, or are required for reasons of support, security, abuse prevention, product safety, or legal defense. If the user deletes chat histories or uploads in the product, they are removed from the active display. Technically necessary backup copies or residual data may persist for a limited transitional period.
- Extended security and product safety logs during critical interactions, in particular user prompt, AI output, timestamps, system and coach versions, model providers, as well as warning, interruption, cancellation, or refusal events, can be stored for up to 36 months, insofar as this is necessary for product safety, abuse prevention, error analysis, compliance, or legal defense. Longer storage only takes place insofar as a concrete security incident, a legal dispute, an official inquiry, legal obligations, or other legitimate reasons make this necessary.
As far as possible and appropriate, data is deleted, anonymized, or reduced to the necessary extent as soon as personalized storage is no longer required.
13. Obligation to Provide Data
The provision of certain personal data necessary for registration, contract execution, payment processing, security, or technical provision is obligatory for completing a contract or accessing certain features. Without this data, we may be unable to provide the user account, specific functionalities, or paid services.
14. Automated Decisions in Individual Cases
A purely automated decision-making process pursuant to Art. 22 GDPR having legal effects or similarly significant impacts does currently not take place, unless we explicitly point this out in an individual case. The mere fact that AI-based content is generated does not inherently constitute a decision within the meaning of Art. 22 GDPR.
15. Rights of the Data Subject
Affected individuals have the following rights in accordance with statutory provisions:
- Right of Access pursuant to Art. 15 GDPR,
- Right to Rectification pursuant to Art. 16 GDPR,
- Right to Erasure (Right to be Forgotten) pursuant to Art. 17 GDPR,
- Right to Restriction of Processing pursuant to Art. 18 GDPR,
- Right to Data Portability pursuant to Art. 20 GDPR,
- Right to Object pursuant to Art. 21 GDPR,
- Right to withdraw granted consent with effect for the future, where processing exceptionally relies on consent,
- Right to lodge a complaint with a supervisory data protection authority.
To exercise these rights, a notification to datenschutz (at) kisy.io is sufficient.
16. Right to Object pursuant to Art. 21 GDPR
Insofar as we process personal data based on legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR, affected individuals have the right to object to this processing at any time on grounds relating to their particular situation. If an affected individual objects, we will no longer process the relevant personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or if the processing serves the establishment, exercise, or defense of legal claims.
17. Right to Lodge a Complaint with a Supervisory Authority
Individuals have the right to lodge a complaint with a data protection supervisory authority, specifically in the Member State of their habitual residence, their place of work, or the place of the alleged infringement. The competent supervisory authority for us is:
Der Hessische Beauftragte für Datenschutz und Informationsfreiheit
(Hessian Commissioner for Data Protection and Freedom of Information)
Postfach 3163
65021 Wiesbaden
Germany
18. Changes to this Privacy Policy
We reserve the right to amend this Privacy Policy with effect for the future if this is required due to legal, technical, regulatory, or organizational changes, or if new services/processing activities are introduced. The version applicable at the time of your visit or use always applies.