Privacy Policy for “K9 AI”

Last updated: 08.06.2025

1. Who we are

Felix Mennen
Ostlandring 59, 31303 Burgdorf, Germany
E‑mail: felix@xz3.dev

2. Scope of this Policy

This policy explains how the K9 AI mobile application (“App”), the associated backend services and the website k9ai.xz3.dev process personal data when you:

It addresses the European General Data Protection Regulation (“GDPR”) and the German Federal Data Protection Act (“BDSG”). If you access the App from outside the EEA, local mandatory laws may also apply.

3. Data we process, purposes & legal bases

Category Data points Purpose Legal basis Retention*
Account data Google/Apple user‑ID, e‑mail address, name (if provided), authentication tokens Create & secure your account, synchronise subscriptions, allow password‑free login contract; legitimate interest (security) Until account deletion
Profile & preferences Dog’s name, breed, age, training goals, language, notification settings Personalise training content & AI responses contract Until account deletion; dog profile can be edited/deleted at any time
AI Content Text, photos, videos you voluntarily submit to the chat Provide AI‑generated answers and training plans contract; explicit consent for sensitive data (e.g. images with people) Until account deletion
Usage & device data IP address, device model, OS version, app version, crash logs Ensure service delivery, prevent abuse, debug & improve legitimate interest (app stability & security) 90 days (logs)
Analytics & event data Screen views, feature clicks, funnel events Understand feature adoption & improve UX via PostHog consent 12 months or until consent withdrawal
Marketing / newsletter (opt‑in) E‑mail address, open & click rates Send product news & offers consent Until you unsubscribe
Support & feedback Messages, screenshots, contact details Respond to your request, reproduce bugs contract Until ticket closed + 6 months

*Back‑ups may persist for up to 4 weeks longer; data will not be restored except for disaster recovery.

4. Data processors & sub‑processors

Processor Service Location of processing
Hetzner Online GmbH Server hosting, file storage Germany
Google Ireland Ltd. Google Sign‑In, Google Cloud AI (“Gemini”) EU datacentres; may replicate to US
Apple Distribution International Ltd. Sign in with Apple EU; may replicate to US
OpenAI Ireland Operations, Ltd. AI processing (ChatGPT, embeddings, moderation) US
PostHog Inc. (EU Cloud) Product analytics EU
Revenuecat Subscription Management EU; may replicate to US

5. International Data Transfers

K9 AI is designed to store and process your personal data inside the European Economic Area (EEA) wherever technically feasible. In a few situations—such as when we employ specialised AI models or receive 24/7 infrastructure support—data may need to travel to countries outside the EEA ("third countries"). When that happens we apply layered safeguards so that your data enjoys protection that is essentially equivalent to EU standards (Art. 44 et seq. GDPR).

  1. Adequacy Decisions
    The European Commission has formally recognised certain jurisdictions as providing an adequate level of data protection. One example is the EU–US Data Privacy Framework (effective 10 July 2023). If a K9 AI partner is self‑certified under such a framework (e.g. Google LLC), we may transfer data to them without further authorisation.
  2. Standard Contractual Clauses (SCCs)
    For providers that are not covered by an adequacy decision, we execute the Commission‑approved SCCs (2021/914/EU). These legally binding contracts require the recipient to: Current processors bound by SCCs include OpenAI USA and Apple Inc.

6. Cookies & similar technologies

The mobile App stores only essential tokens in the device’s secure storage. The marketing website uses:

You can revoke consent at any time in the App settings or by clearing cookies.

7. Automated decision‑making & profiling

K9 AI generates personalised dog‑training advice using large language models (LLMs). The output is not legally binding, and no fully automated decisions with legal or similarly significant effect are made (Art. 22 GDPR). Human support is available via felix@xz3.dev.

8. Children’s privacy

K9 AI is not intended for children under 18. We do not knowingly process such data. Parents who believe their child has provided data should contact us for deletion.

9. Changes to this Policy

We may update this notice to reflect changes in law or the App. Material changes will be announced at least 14 days in advance via in‑app notice or e‑mail (if we have your address). The version date at the top will change accordingly.

10. Contact

Questions? Reach us at felix@xz3.dev or by post at the address in (1). We aim to reply within 72 hours.