Privacy Policy

Last updated: April 27, 2026

In Dumpling Software products, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that are collected and recorded by Dumpling Software and how we use it. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

Consent

By using our website or products, you hereby consent to our Privacy Policy and agree to its terms.

Information we collect

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

  • Usage data, such as the prompts and selected context, including how you interact with our website and services. We do not collect any other information from your opened web pages.
  • Technical information, such as your IP address, browser type, and device information.

When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.

How we use your information

We use the information we collect in various ways, including to:

  • Provide, operate, and maintain our website
  • Improve, personalize, and expand our website
  • Understand and analyze how you use our website
  • Develop new products, services, features, and functionality
  • Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
  • We may also disclose your personal information if required by law or to protect the rights and safety of Dumpling Software and its users.
  • Send you emails
  • Find and prevent fraud

Log Files

Dumpling Software follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

CCPA Privacy Rights (Do Not Sell My Personal Information)

Under the CCPA, among other rights, California consumers have the right to:

  • Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
  • Request that a business deletes any personal data about the consumer that a business has collected. - Request that a business that sells a consumer's personal data, not sell the consumer's personal data.
  • If you make a request, we have 45 days to respond to you. If you would like to exercise any of these rights, please contact us.

GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

  • The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
  • The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
  • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

Legal Bases for Processing

We process your personal data on the following legal bases under the GDPR:

  • Performance of a contract (Article 6(1)(b) GDPR): to provide the Service to you, to administer your account, to process payments, and to provide customer support.
  • Compliance with a legal obligation (Article 6(1)(c) GDPR): to comply with tax, accounting, anti-money-laundering, and other legal obligations to which we are subject.
  • Legitimate interests (Article 6(1)(f) GDPR): to operate, secure, and improve the Service; to prevent fraud and abuse; to communicate with you about the Service; to defend our legal rights; and to support the orderly transfer of the business in connection with any sale, merger, or other restructuring.
  • Consent (Article 6(1)(a) GDPR): where we ask for your specific consent to process your personal data for a particular purpose, such as marketing communications. You have the right to withdraw your consent at any time.

Recipients and International Data Transfers

We share your personal data with the following categories of recipients:

  • Service providers and sub-processors we engage to operate the Service, including cloud infrastructure providers, AI / large language model providers, payment processors, email and communications providers, customer support platforms, and analytics and monitoring providers. A current list of our sub-processors is available at chatwith.tools/legal/subprocessors.
  • Government and regulatory authorities, where we are required to do so by law.
  • Acquirers and successor entities, as further described in the Business Transfers section below.

Some of these recipients are located outside the European Economic Area, including in the United States. Where we transfer personal data outside the EEA to a country that does not benefit from an adequacy decision under Article 45 GDPR, we rely on appropriate safeguards under Article 46 GDPR, which currently include the European Commission's Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914), supplemented by additional technical, organisational, and contractual measures where appropriate. You may request a copy of the safeguards we rely upon by contacting us at the address set out at the end of this Policy.

Business Transfers

If we are involved in a merger, acquisition, sale of assets, financing, restructuring, bankruptcy, receivership, or similar event, your personal data may be transferred to the acquirer, successor entity, or other relevant counterparty as part of that transaction or proceeding. Such a transfer is necessary for the legitimate interests of operating, financing, and disposing of our business.

Where the transfer involves a recipient located outside the European Economic Area, we will put in place appropriate safeguards under Article 46 GDPR, including the European Commission's Standard Contractual Clauses where applicable.

Where required by applicable law, we will notify you of any such transfer and provide information about the recipient. We will use reasonable efforts to ensure that the recipient continues to process your personal data in a manner consistent with this Policy or otherwise notifies you of any material changes.

Retention

We retain your personal data for as long as needed to provide the Service to you and for the legitimate purposes set out in this Policy. The specific retention periods we apply are as follows:

  • Account data and contact information: for the duration of your account, plus a reasonable period thereafter to address questions or claims that may arise after account closure.
  • Content you submit to the Service (chat transcripts, uploaded documents, and similar): for the duration of your subscription. Upon termination of your subscription, content is deleted within thirty (30) days, unless an earlier deletion is requested by you in writing or a longer retention is required by applicable law. For users on the free version of the Service, content may be retained to facilitate continued use and may be deleted after one (1) year of account inactivity.
  • Billing and tax records: for the periods required by applicable tax and accounting law, typically between six (6) and ten (10) years under German law.
  • Server logs and security event data: for a limited period required to operate, secure, and audit the Service, typically not exceeding twelve (12) months.

Where we no longer have a legitimate basis to retain your personal data, we will delete it or anonymise it.

Right to Lodge a Complaint

In addition to the other rights described in this Policy, you have the right to lodge a complaint with a data protection supervisory authority. Our lead supervisory authority is the Berliner Beauftragte für Datenschutz und Informationsfreiheit (Berlin Commissioner for Data Protection and Freedom of Information), Friedrichstr. 219, 10969 Berlin, Germany — mailbox@datenschutz-berlin.de. You may also lodge a complaint with the supervisory authority of the EU Member State where you reside, where you work, or where you believe a violation of the GDPR has occurred.

Children's Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. Dumpling Software does not knowingly collect any Personal Identifiable Information from children under the age of 16. If you think that your child provided this kind of information on our website or products, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:

Dumpling Software UG

Kollwitzstrasse 76 10435 Berlin, Germany

support@chatwith.tools