Privacy Policy
1. Privacy at a Glance
General Information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data with which you can be personally identified.
Data Collection on This Website
Who is responsible for data collection on this website? Data processing on this website is carried out by the website operator. You can find their contact details in the section "Information on the Responsible Party" in this privacy policy.
2. General Information and Mandatory Information
Data Protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
Information on the Responsible Party
The responsible party for data processing on this website is:
B A Media Group FZE LLC
Business Centre, Sharjah Publishing City Free Zone
Sharjah
United Arab Emirates
3. Data Collection on This Website
Cookies and Local Storage
Without your consent these pages set a single cookie, cc_cookie. It remembers for six months that you have seen the cookie notice, so it does not appear on every visit. We also keep the company details of the legal texts in your browser's local storage for 24 hours (bitter-shortcodes), so they are not fetched on every page view. Both are technically necessary (Art. 6(1)(f) GDPR, Section 25(2) TDDDG). We set no advertising cookies; we set cookies for audience measurement only with your consent (section "Google Analytics"). In addition, the live chat keeps the entries named in the next section.
Live Chat
For questions about Spendora we offer a live chat in which an AI assistant answers. It runs on fonella, a service of WBA Systems GmbH, Kienberger Allee 4, 12529 Schönefeld, Germany, which operates the chat on our behalf (Art. 28 GDPR). So that the page loads quickly, your browser fetches the chat window from fonella.ai only after your first input on the page or a few seconds after loading; fonella receives your IP address and the details your browser sends with every request. The chat sets no cookies. It keeps a random id in your browser's storage (fonella-chat-session) that links your chats across tabs and later visits and stays until you delete it; the history of the current conversation and whether the chat window has been opened are kept only until you close the tab. The legal basis is our legitimate interest in answering your questions directly on the page and without waiting (Art. 6(1)(f) GDPR); you can delete the entries at any time in your browser's settings.
When you write, we process your messages with everything you state in them, together with the id, the language, the address and title of the page you write on, your IP address, information about your browser and the time, in order to answer your question (Art. 6(1)(b) and (f) GDPR). The chat asks the Spendora interface for the current coin packages; our server receives only the requested language and an id of the conversation, not your messages. The answers are generated automatically by a language model, as is the short summary we receive by e-mail and push notification after the chat. For this, your messages and the conversation so far are sent to OpenRouter, Inc. in the USA, which forwards them, depending on availability, to a language model of OpenAI, Anthropic, Google or Meta. The transfer to the USA is based on the standard contractual clauses of the EU Commission (Art. 46(2)(c) GDPR). The chat is stored on servers of Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg, in the Frankfurt region, and deleted once your request has been dealt with and no retention obligation applies. To prevent abuse, messages are counted per IP address and minute, and this count is deleted after about a day (Art. 6(1)(f) GDPR). Where we rely on our legitimate interest in offering the chat and answering requests quickly, you may object at any time on grounds relating to your particular situation (Art. 21(1) GDPR). OpenRouter's privacy notice: openrouter.ai/privacy.
Telephone enquiries
Calls to the phone number shown on this website are answered by an AI-powered phone assistant. At the start of the call you are told that you are speaking with an AI-powered phone assistant.
The controller is B A Media Group FZE LLC, Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates (see imprint). The telephony platform is operated as a technical service provider by WBA Systems GmbH, Kienberger Allee 4, 12529 Schönefeld, Germany, with its service fonella.
We process your phone number, if it is transmitted, the number you called, the date, time and duration of the call, the content of the conversation as speech and as text (transcript), an automatically generated summary, and any details you give during the call, for example your name, email address or a callback number.
During the call your speech is converted into text. An AI language model generates a reply, which is read out by speech synthesis. After the call a summary is created, the transcript and summary are translated, and contact details you mentioned are identified. We are notified of the call by email and, where enabled, by push notification. The call is not recorded as audio.
The following service providers are used:
- sipgate GmbH, Düsseldorf, Germany: phone number and call routing.
- Vapi Inc., 150 Spear Street, Suite 1000, San Francisco, CA 94105, USA: handling of the conversation and the summary. For this Vapi uses Deepgram, Inc., San Francisco, USA (speech recognition), Google LLC, Mountain View, USA (Gemini language model) and ElevenLabs, Inc., New York, USA (speech synthesis).
- OpenRouter, Inc., USA: translation of transcript and summary and identification of contact details, using models from Google, with OpenAI or Meta as fallback.
- Amazon Web Services EMEA SARL, Luxembourg: storage in data centres in Frankfurt am Main.
- Mailgun Technologies, Inc. (Sinch), USA: sending the notification email via its EU region.
The legal basis is Art. 6(1)(b) GDPR where your call relates to entering into or performing a contract, and Art. 6(1)(f) GDPR otherwise. Our legitimate interest is to receive and answer enquiries at any time, including outside business hours.
Data is transferred to the USA in the process. Vapi bases transfers from the EU on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).
We delete the data as soon as it is no longer needed for the purpose described, or at your request, unless statutory retention obligations apply. Vapi also stores the transcript, the course of the conversation, the summary and technical logs and deletes them on request. According to WBA Systems GmbH, the call data is not used to train AI models. Under its terms of service Vapi does not pass it on to third parties for their model training, but may use it, without reference to us or to you, to improve its own service, for example speech recognition.
If you prefer not to speak with the AI assistant, you can also reach us by email at the address given in the imprint. Your rights of access, rectification, erasure, restriction of processing, data portability and objection, and your right to lodge a complaint with a supervisory authority (Art. 15 to 21 and 77 GDPR), also apply to this data.
Google Analytics
With your consent in the category "Statistics" of the cookie notice, we use Google Analytics 4 to measure how these pages are used. The controller is B A Media Group FZE LLC (see the section "Information on the Responsible Party"); the service is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, which acts as our processor. Without your consent your browser loads nothing from Google and no connection to Google is made; until then the consent for analytics and advertising storage is set to "denied" in Google's Consent Mode. If you agree, your browser loads the script from googletagmanager.com, and Google sets the cookies _ga and _ga_7ZS8MSJFX3 with a lifetime of 14 months. What is recorded: the pages viewed, the time, where the visit came from (referrer), details about your browser, device, screen size and language, and the approximate location derived from your IP address; Google does not store the IP address in Google Analytics 4. Advertising features, the combination with data from Google accounts and personalised advertising are switched off (Google signals off). The data is stored for 14 months and then deleted.
The legal basis is your consent (Art. 6(1)(a) GDPR) and, for storing and reading the cookies, Section 25(1) TDDDG. Google may transfer data to Google LLC in the USA; it is certified under the EU-US Data Privacy Framework, on which the EU Commission's adequacy decision rests (Art. 45 GDPR), and the standard contractual clauses additionally apply (Art. 46(2)(c) GDPR). You can withdraw your consent at any time with effect for the future: under "Cookie settings" in the footer of every page, where you switch off "Statistics"; the _ga cookies are then removed and nothing is measured any more. The lawfulness of the processing carried out until then is not affected. Google's privacy notice: policies.google.com/privacy.
4. Your Rights
You have the right at any time to receive free information about the origin, recipient, and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. For this purpose, as well as for further questions on the subject of data protection, you can contact us at any time.
Last updated: October 25, 2026