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Privacy Policy

Last updated: 29 September 2026 · Pursuant to GDPR (EU 2016/679) and EU AI Act (EU 2024/1689). This English version is a convenience translation — the German version is the legally binding document.

1. Data Controller

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Email: ···

2. Cookies & Authentication

PURGIFIER uses only technically necessary cookies for authentication (session cookie). These cookies are required for you to log in and use the service.

No tracking cookies, no analytics cookies, and no third-party cookies are set. A cookie consent banner is therefore not required (§ 25 TDDDG — technically necessary cookies are exempt).

Legal basis: Art. 6(1)(b) GDPR (performance of contract) + § 25(2)(2) TDDDG.

3. Data Sharing with AI Service Providers (LLM Providers)

To perform text transformations, your text inputs are transmitted via API interfaces to the active AI provider:

  • Google Gemini (Google DeepMind, EU / USA)
  • OpenAI GPT-4o (OpenAI Inc., USA)
  • OpenRouter (OpenRouter, Inc., USA) as an intermediary to a model inference provider
  • Optional: Local model (LM Studio / Ollama — no external data transfer)

When OpenRouter is used, your inputs are transmitted to OpenRouter and forwarded to an inference provider available for the selected model. The provider and processing location may vary by model and endpoint.

Transmission occurs solely for the purpose of text transformation. No other personal data is transmitted (no email, no name, no user ID).

⚠ Important notice: Google Gemini and OpenAI contractually exclude training on inputs for the APIs used here. OpenRouter states that it does not train its own models on inputs or outputs. Our OpenRouter account is configured not to select providers whose known policies allow inputs to be used for model training. Inputs are still transmitted to and processed by OpenRouter and the selected provider to generate a response. The inference provider's retention period and processing location may vary; this setting is not a general zero-data-retention guarantee.

OpenRouter Privacy Policy · OpenRouter routing data policies

Legal basis: Art. 6(1)(b) GDPR (performance of contract) · USA transfer: EU-US Data Privacy Framework. OpenRouter may also transmit data internationally to OpenRouter and the provider selected for the model/endpoint; their privacy notices and applicable contractual transfer safeguards govern those transfers.

4. AI Transparency (EU AI Act 2026)

PURGIFIER is an AI-powered text transformation tool. Pursuant to the EU AI Act (Regulation (EU) 2024/1689), we transparently disclose the use of AI systems:

  • Risk classification: Minimal risk (not a high-risk AI system)
  • Purpose: Text rephrasing to reduce generic-sounding formulations
  • Models used: Google Gemini 2.5 Flash, OpenAI GPT-4o, OpenAI GPT-6 Luna via OpenRouter, optionally local models
  • Human oversight: The user decides on input, intensity, and use of results
  • No real-time biometrics, no social scoring, no manipulation

An AI transparency badge is displayed in the footer of every page, linking to this section.

5. Stored Personal Data

The following personal data is stored in our database:

  • Email address, name (provided during registration)
  • Password (stored encrypted, not recoverable)
  • Plan status (Free / Blitz / Pro), expiration date
  • Fair-use counter (word count per transformation, no text content)
  • Admin status, loyalty bonus status
No text content is stored: Neither your input texts nor the transformed results are stored in the database.

Storage location: Servers in Germany (Nuremberg / Falkenstein). Retention period: Account data until account deletion, then removal within 7 days. Usage counters are overwritten with each transformation.

Self-service account deletion: You can permanently delete your account at any time via Account → Danger Zone. All personal data (email, name, password) is removed immediately. Anonymised usage statistics and payment history (retained under Art. 6(1)(c) GDPR for 10 years for tax compliance) remain, without personal identifiers.

6. Abuse Prevention (Rate Limiting)

To prevent abuse, we temporarily store the following data to limit the number of requests per user:

  • IP address or user ID as key
  • Request counter with time window

No text content is stored in this process. All entries expire automatically after one hour at the latest. Processing occurs exclusively on the German server.

7. Email Delivery

For verification and password reset emails, we operate our own SMTP server. Emails are sent exclusively for account confirmation and password resets.

No disclosure to email marketing services, newsletter providers, or third parties.

8. Payment Processing (Creem)

Payment processing is handled by Creem as the EU Merchant of Record. Creem processes payment data (credit card, PayPal, etc.) in its own name.

PURGIFIER does not store any payment data (no credit card numbers, no bank details). We receive from Creem only a confirmation of the payment status via webhook.

Creem privacy policy: https://www.creem.io/privacy

9. Hosting Provider (Hetzner)

The website and all data are hosted on servers of Hetzner Online GmbH in Germany.

Hetzner Online GmbH · Industriestr. 25 · 91710 Gunzenhausen · Germany

A Data Processing Agreement (DPA) pursuant to Art. 28 GDPR has been concluded with Hetzner. Your data does not leave the EU.

10. External Service Providers and Data Processing

The following providers are involved in delivering the service. Their respective privacy and contractual terms govern their roles and processing:

  • Hetzner Online GmbH — Server hosting (Germany); Data Processing Agreement (DPA)
  • Google LLC (Google DeepMind) — LLM API; Data Processing Amendment; USA transfer: EU-US Data Privacy Framework
  • OpenAI Inc. — LLM API; Data Processing Agreement; USA transfer: EU-US Data Privacy Framework
  • OpenRouter, Inc. — API routing; forwards inputs to the inference provider selected for the model/endpoint. OpenRouter's Privacy Policy and any separately applicable data protection terms govern its processing; the selected provider's terms also apply to inference.
  • Creem Inc. — Payment processing as Merchant of Record (own data protection responsibility)

11. Your Rights (Data Subject Rights)

You have the right at any time to:

  • Access — What data we store about you (Art. 15 GDPR)
  • Rectification — Correction of inaccurate data (Art. 16 GDPR)
  • Erasure — Deletion of your data (Art. 17 GDPR) — self-service available at Account → Danger Zone
  • Restriction — Restriction of processing (Art. 18 GDPR)
  • Data portability — Export of your data (Art. 20 GDPR) — self-service available at Account → My Data (JSON or CSV)
  • Objection — Objection to processing (Art. 21 GDPR)

Please send requests to: ···

12. Right to Lodge a Complaint with a Supervisory Authority

If you believe that the processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

Competent supervisory authority (Baden-Württemberg): State Commissioner for Data Protection and Freedom of Information Baden-Württemberg (LfDI BW)

13. Server Logs

PURGIFIER logs server events (e.g. request errors, email delivery, LLM calls) exclusively in memory using an in-memory ring buffer (max. 200 entries). These logs are never written to disk and are discarded when the server restarts. They do not contain any text content from your posts.

Personal data such as email addresses and API keys are automatically redacted before logging. Only administrators can access the logs via the admin panel. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in operational security and error diagnosis).