Privacy Policy

1. Controller

The controller for the website uds-system.de is German UDS Universe GmbH, Marlene-Dietrich-Allee 14, 14482 Potsdam, email: info@uds-system.de. Further details in the Imprint.

In customer areas (an organisation's own address, for example company.uds-system.de) the respective organisation is the controller; we process the data there as a processor under Art. 28 GDPR. If the organisation has provided its own Privacy Policy, it is shown there.

2. Principles

• Database, files and sign-in are located in the European Union (Frankfurt am Main).
• Language models from the EU take priority; a provider outside the EU is used only as a fallback and is named below.
• No advertising networks, no sale of data, no profiles.
• The microphone is never permanently on. It only listens after you have switched it on yourself.

3. Visiting the website

Visiting the website creates technically necessary server logs (IP address, time, requested address, browser identifier). They serve delivery and operational security and are deleted after a short time. The legal basis is Art. 6(1)(f) GDPR.

For features that incur costs (conversations with Maike, speech recognition, speech output) we count usage per connection and day to limit misuse. We do not store the IP address for this, only a check value (hash) formed with a secret key, together with the daily counter.

Forms are protected against automated access (bot detection by the host, a check field, rate limiting).

4. Hosting and delivery

The application is delivered via Vercel Inc. (USA); server functions run preferably in Frankfurt. The database is operated by Supabase in the Frankfurt region (EU). Safeguards under Art. 44 et seq. GDPR are in place with providers outside the EU (adequacy decision or standard contractual clauses).

To measure the reach of the website we use Vercel Web Analytics and Speed Insights. They work without cookies and without storing the IP address; they record the page visited, referring page, country, device type and loading times in aggregated form (Art. 6(1)(f) GDPR).

6. Cookies and browser storage

Technically necessary are: the sign-in cookie once you sign in, the cookie for the selected language and the cookie that stores your choice in the cookie notice. In browser storage we keep settings, such as where you moved Maike or whether subtitles are on. These values do not leave your device. The legal basis is Section 25(2) TDDDG. More under Cookies.

7. Contact, callback and trial access

When you write to us or request a callback or trial access, we store organisation, name, email, phone number if given, your selection and your message in order to handle the request (Art. 6(1)(b) and (f) GDPR). We notify our team by email. On request we delete the request; an informal message is sufficient.

8. Orders and payment

For an order we process the name of your organisation, your name, your email, the seats and building blocks chosen, and your logo and colours in order to perform the contract (Art. 6(1)(b) GDPR). Payment is processed by Stripe Payments Europe Ltd. (Dublin); card details go directly to Stripe, we do not receive them. We keep invoices for ten years (Section 147 AO, Section 257 HGB).

We send emails (access, confirmations, invoices) via the Resend service (Resend, Inc., USA) on the basis of standard contractual clauses.

9. Conversations with Maike and the Talents

Maike, the assistant on the website, and the Talents answer questions with the help of language models. Your question and the conversation so far are sent to Mistral AI (Paris, EU). Only if Mistral is unavailable does Anthropic (USA) answer, on the basis of standard contractual clauses. We do not store the conversation on our servers; it stays in your browser. Answers are labelled as AI-generated.

Spoken answers are generated by ElevenLabs from the answer text; only that text is sent to ElevenLabs, nothing about you.

If you speak to Maike or a Talent, this only happens after you have pressed the microphone button and your browser has confirmed the permission. The audio is then streamed to Gladia (Paris, EU) and converted into text. We do not store recordings. You can switch the microphone off at any time and type instead.

In a conversation with a Talent you can turn on your camera so that the Talent can see you. This only happens after you have pressed the “Turn on camera” button, confirmed the short notice and your browser has granted permission. While the camera is on, your browser sends single, downscaled still images — at the greeting, with your questions and at most a few times when something in the picture clearly changes — to Mistral AI (Paris, EU), where they are used only for that one reply. These images are not sent to any other provider, not even the fallback. We do not store any images or recordings, not even in logs. The Talent only mentions obvious things such as clothing or an object in your hand; it does not estimate age or origin, does not interpret emotions and does not recognise anyone. You can turn the camera off at any time; it turns off by itself when the conversation ends.

The legal basis is Art. 6(1)(f) GDPR (answering your questions) and, for voice input and camera images, your consent (Art. 6(1)(a) GDPR), which you can end at any time by switching off the microphone or the camera. Please do not share sensitive data in these conversations.

10. Using the learning platform

In customer areas we process on behalf of the organisation: account (name, email, role), learning progress, answers, exam results and issued credentials. Courses are created and narrated using the language models, speech synthesis and speech recognition of the providers named above; course content, not personal data, is sent to the models.

Own avatars are created only with the documented, revocable consent of the person depicted; image and voice are stored separately. We render the videos on our own GPU servers rented from an infrastructure provider.

Credentials can be verified via QR code without an account; only the details printed on the credential are shown.

11. Measuring the impact of shared content

If an organisation shares courses or presentations via a link, we count how often and how far they are viewed. IP address and browser identifier are read only during the request and immediately combined irreversibly with a key that changes daily. The IP address is not stored, not even truncated; the same person cannot be recognised the next day.

Only coarse classes are stored: operating system, browser and device class, and the approximate location (country, region, city) that our host derives from the IP address. Cities appear in the analysis only above a minimum number of viewers. A random identifier for recognising returning viewers is used only with your consent in the “Statistics” category. An organisation uses personal links only if it has confirmed a legal basis for them.

12. Recipients

• Supabase (database, storage, sign-in) — Frankfurt region, EU
• Vercel Inc. (delivery, server functions, reach measurement) — USA, server functions preferably Frankfurt
• Mistral AI (language model; with the camera on, also single images from the Talent conversation) — Paris, EU
• Anthropic PBC (language model, fallback only) — USA
• ElevenLabs (speech output, text only)
• Gladia (speech recognition, only after you switch on the microphone) — Paris, EU
• Stripe Payments Europe Ltd. (payment) — Dublin, EU
• Resend, Inc. (email delivery) — USA
• Infrastructure provider for GPU servers (avatar videos)

13. Retention

We keep data only as long as necessary for the respective purpose: requests until they are dealt with and beyond that only as long as a contract may result; contract data for the term; invoices for ten years; data of a trial tenant until 30 days after the end of the trial.

14. Your rights

You have the right of access, rectification, erasure, restriction of processing, data portability and objection (Art. 15–21 GDPR). You can withdraw consent at any time with effect for the future. An informal message to info@uds-system.de is sufficient.

You can lodge a complaint with a supervisory authority, for example Der Hessische Beauftragte für Datenschutz und Informationsfreiheit, Gustav-Stresemann-Ring 1, 65189 Wiesbaden, Germany.

No automated decision-making within the meaning of Art. 22 GDPR takes place.