Privacy Policy

1. Introduction

Usertune ("we", "our", or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our real-time content personalization platform and related services (the "Service").

We are located in Berlin, Germany, and process personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

By using our Service, you consent to the collection and use of information in accordance with this Privacy Policy.

2. Data Controller Information

The data controller for your personal data is:

3. What Personal Data We Collect

3.1 Information You Provide Directly

• Account Information: Name, email address, password, company name
• Billing Information: Payment details processed securely through Stripe
• Profile Information: Any additional information you choose to provide
• Communication: Messages you send to our support team
• Content: Any content you upload or create using our Service

3.2 Information We Collect Automatically

• Usage Data: How you use our Service, features accessed, time spent
• Device Information: IP address, browser type, operating system
• Log Data: Server logs, error reports, performance data
• Cookies: See our Cookie Policy below

3.3 Information from Third Parties

• Payment Processors: Transaction information from Stripe
• Analytics: Aggregated usage statistics from analytics providers

4. Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contract Performance: To provide our Service and fulfill our obligations
• Legitimate Interest: To improve our Service, security, and customer support
• Consent: For marketing communications and optional features
• Legal Obligation: To comply with applicable laws and regulations

5. How We Use Your Personal Data

We use your personal data for the following purposes:

• Service Provision: To provide, maintain, and improve our personalization platform
• Account Management: To create and manage your account
• Communication: To respond to inquiries and provide customer support
• Billing: To process payments and manage subscriptions
• Security: To protect against fraud and unauthorized access
• Analytics: To understand how our Service is used and improve performance
• Legal Compliance: To comply with applicable laws and regulations
• Marketing: To send promotional communications (with your consent)

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following circumstances:

• Service Providers: Trusted third parties who assist in operating our Service (e.g., Stripe for payments)
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with mergers, acquisitions, or asset sales
• With Your Consent: When you explicitly consent to sharing

All third-party service providers are contractually bound to protect your data and use it only for specified purposes.

7. International Data Transfers

Your personal data is primarily processed within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure adequate protection through:

• European Commission adequacy decisions
• Standard Contractual Clauses approved by the European Commission
• Other appropriate safeguards as required by GDPR

8. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this Privacy Policy:

• Account Data: Until you delete your account, plus 30 days for backup deletion
• Billing Records: 7 years for tax and accounting purposes
• Support Communications: 3 years for quality assurance
• Usage Analytics: 24 months in aggregated, anonymized form
• Legal Requirements: As required by applicable law

9. Your Rights Under GDPR

As a data subject, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a portable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for consent-based processing

To exercise these rights, contact us at [email protected]. We will respond within 30 days.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption in transit and at rest
• Regular security assessments and updates
• Access controls and authentication
• Staff training on data protection
• Incident response procedures

While we strive to protect your data, no internet transmission is 100% secure. We cannot guarantee absolute security.

11. Cookies and Tracking

We use cookies and similar technologies to enhance your experience:

• Essential Cookies: Required for Service functionality
• Performance Cookies: Help us analyze Service usage
• Functional Cookies: Remember your preferences
• Marketing Cookies: Deliver relevant advertisements (with consent)

You can control cookies through your browser settings. Note that disabling certain cookies may limit Service functionality.

12. Customer Data Processing

When you use our Service to personalize content for your users, you act as the data controller and we act as the data processor. In this relationship:

• You determine the purposes and means of processing
• You must have a legal basis for processing personal data
• You must provide appropriate privacy notices to your users
• We process data only according to your instructions
• We maintain appropriate security measures

Our Data Processing Agreement (DPA) governs this relationship and is available upon request.

13. Children's Privacy

Our Service is not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last updated" date
• Sending email notification for significant changes

Your continued use of the Service after changes constitutes acceptance of the updated Privacy Policy.

15. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority if you believe we have not complied with data protection laws. In Germany, you can contact:

16. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

We aim to respond to all privacy-related inquiries within 30 days as required by GDPR.