Privacy Policy

This Privacy Notice for Peply GmbH (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Download and use our mobile application PEPLY, or any other application of ours that links to this Privacy Notice.
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@peply.ai.

Summary of Key Points

This summary provides key points from our Privacy Notice. You can find more details by clicking the links following each key point or using the table of contents below.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
• Do we process any sensitive personal information? In some jurisdictions, certain data (e.g., racial or ethnic origin, sexual orientation, religious beliefs) may be considered “special” or “sensitive.” We may process such information when necessary with your consent or as otherwise permitted by law. Learn more about sensitive information we process.
• Do we collect any information from third parties? We do not collect information from third parties.
• How do we process your information? We process your information to provide, improve, and administer our Services; communicate with you; for security and fraud prevention; and to comply with law. We may also process your information for other purposes with your consent. Learn more about how we process your information.
• In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
• How do we keep your information safe? We have organizational and technical measures to protect your personal information, but no electronic transmission or storage can be guaranteed 100% secure. Learn more about how we keep your information safe.
• What are your rights? Depending on your location, you may have certain rights regarding your personal information. Learn more about your privacy rights.
• How do you exercise your rights? The easiest way is by emailing us at datenschutz@peply.ai or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. Depending on how you interact with us and the Services, the personal information we collect may include:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Usernames
• Passwords
• Contact preferences

Sensitive Information

When necessary, with your consent or as otherwise permitted by applicable law, we may process the following categories of sensitive information:

• Biometric data

All personal information that you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information—such as your IP address and/or browser and device characteristics—is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, approximate location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

• Log and Usage Data. Service‑related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, which we record in log files. Depending on how you interact with us, this may include IP address, device information, browser type and settings, and information about your activity in the Services (such as date/time stamps, pages and files viewed, searches, and features used), device event information (such as system activity, error reports or “crash dumps”), and hardware settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services; communicate with you; for security and fraud prevention; and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, including:

• To deliver and facilitate services to the user. To provide you with the requested service.
• To respond to user inquiries and offer support. To respond to your inquiries and resolve issues.
• To send administrative information. To send details about products and services, changes to terms and policies, and other similar information.
• To protect our Services. As part of efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. To better understand how our Services are used so we can improve them.
• To save or protect an individual’s vital interest. When necessary to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason under applicable law—such as your consent; to comply with laws; to provide you with services; to fulfill our contractual obligations; to protect your rights; or to pursue our legitimate business interests.

The GDPR and UK GDPR require us to explain the valid legal bases we rely on. As such, we may rely on:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. Where necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract.
• Legitimate Interests. Where reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms (e.g., analyzing how our Services are used to improve and engage users; diagnosing problems; preventing fraudulent activities).
• Legal Obligations. Where necessary for compliance with our legal obligations (e.g., to cooperate with law enforcement or regulatory agencies, to exercise or defend legal rights, or to disclose information as evidence in litigation).
• Vital Interests. Where necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to safety.

In legal terms, we are generally the “data controller” under European data protection laws for the personal information described in this Privacy Notice, since we determine the means and/or purposes of the data processing we perform. This Privacy Notice does not apply to personal information we process as a “data processor” on behalf of our customers. In those situations, the customer is the “data controller” responsible for your personal information; we process your information on their behalf in accordance with their instructions. For our customers’ privacy practices, please review their privacy policies and direct any questions to them.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations and/or with the following third parties.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will keep your personal information only as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it. If deletion is not possible (for example, because your personal information is stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the Internet or information storage technology can be guaranteed 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at datenschutz@peply.ai.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions (such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, subject to local law.

Depending on your location, you may have the right to (i) request access and obtain a copy of your personal information; (ii) request rectification or erasure; (iii) restrict the processing of your personal information; (iv) if applicable, data portability; and (v) not be subject to automated decision‑making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the details in How can you contact us about this notice?

We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we rely on your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details in How can you contact us about this notice?. This will not affect the lawfulness of processing prior to withdrawal, nor processing conducted in reliance on lawful bases other than consent.

If you have questions or comments about your privacy rights, email us at datenschutz@peply.ai.

9. CONTROLS FOR DO‑NOT‑TRACK FEATURES

Most web browsers and some mobile operating systems and applications include a Do‑Not‑Track (“DNT”) feature or setting you can activate to signal your preference not to have your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you in a revised version of this Privacy Notice.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Steffen Vietz, by email at datenschutz@peply.ai, by phone at +49 151 1527 22 99, or by post at:

If you are a resident in the European Economic Area, we are the “data controller” of your personal information. We have appointed Dr.-Ing. Hannes Vietz as our representative in the EEA. You can contact them regarding our processing by email at datenschutz@peply.ai, by phone at +49 171 5467942, or by post to:

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you; details about how we have processed it; correct inaccuracies; delete your personal information; or withdraw your consent to our processing. These rights may be limited in some circumstances by applicable law. To submit a request, please email us at datenschutz@peply.ai.