1. Controller pursuant to GDPR
René Gäng
Kolpingstraße 62
68753 Waghäusel
Germany
Email: info@combany.de
For questions regarding data protection, please contact us at the email address above.
2. Data collected
To provide the app's features, we collect and process the following data:
- Voice and text input (chat, assistant): Temporarily transmitted to OpenAI and Microsoft Azure for processing.
- Documents/images: Stored locally, temporarily transmitted to OpenAI/Azure for analysis.
- Calendar entries and reminders: Stored locally on your device.
- Language settings and app usage: Stored locally.
3. Purpose and legal basis of processing
Processing is carried out exclusively to provide the app's features (Art. 6 para. 1 lit. b GDPR – contract performance) and based on your consent (Art. 6 para. 1 lit. a GDPR) for AI features.
4. Data sharing with third parties
- OpenAI LLC (USA): For LLM analysis and translation.
- Microsoft Azure (EU region preferred): For speech-to-text/text-to-speech.
Transfer to third countries (USA) based on Standard Contractual Clauses (SCC) and Transfer Impact Assessment (TIA). OpenAI stores API data for a maximum of 30 days and does not use it for training (when using the API).
5. Storage duration
- Locally: Until you delete the data or uninstall the app.
- At OpenAI/Azure: According to their policies (max. 30 days for API data).
6. Your rights
Under the GDPR, you have the following rights:
- Right of access (Art. 15 GDPR)
- Right to rectification (Art. 16 GDPR)
- Right to erasure (Art. 17 GDPR)
- Right to restriction of processing (Art. 18 GDPR)
- Right to data portability (Art. 20 GDPR)
- Right to object (Art. 21 GDPR)
Consent can be revoked at any time (e.g. by email to info@combany.de) with effect for the future.
You have the right to lodge a complaint with the competent supervisory authority (e.g. the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg).
7. Permissions
The app requires the following permissions:
- Microphone: For voice input and voice control
- Camera: For photographing documents
- Storage: For saving documents and settings
You can revoke all permissions at any time in your device's system settings.
8. Data security
We employ technical and organizational measures to protect your data. Communication with external services is encrypted via HTTPS.
9. Changes
We update this policy as needed – the current version can be found in the app and at combany.de.