Nella

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Nella privacy notice

Last updated: [[LAURA: publication date]]

Nella is an AI voice character for adult women. This notice has two parts: A. the website and waitlist (live now) and B. the app (applies only when you use the app).

In short

1. Controller

Laura Bonomini (private individual)
[[LAURA: street and number]], [[LAURA: postcode]] Munich, Germany
E-mail: [[LAURA: privacy e-mail address]]

2. Data protection officer (DPO)

[[LAURA: DPO name and contact, or "DPO being appointed; until then write to (e-mail)"]]

A. Website and waitlist

3. Visiting the website

The website is hosted on Cloudflare Pages (Cloudflare, Inc., USA). To deliver pages and protect the site, Cloudflare processes your IP address and technical request data (browser, page, date and time).
Legal basis: Art. 6(1)(f) GDPR, legitimate interest in a secure, working website.
Transfer to the US: Cloudflare is certified under the EU-US Data Privacy Framework (Art. 45 GDPR); EU standard contractual clauses are in place as well (Art. 46(2)(c) GDPR).

Fonts are self-hosted: your browser does not contact external font services.

4. Cookies and analytics

The website uses no cookies and no analytics or tracking tools, so there is no banner.

5. Age confirmation

Before entering, we ask you to confirm you are at least 18. This confirmation (and the related consent checkbox) stays only in your browser and is not stored by us.

6. Waitlist

Data Why Where Legal basis
E-mail, first name, quiz character Tell you when Nella opens Brevo only (Sendinblue SAS, Paris, France, EU) Art. 6(1)(a) GDPR, your consent

Brevo processes the data on our behalf (Art. 28 GDPR). The website stores this data nowhere else. You can unsubscribe at any time via the link in every e-mail or by writing to [[LAURA: privacy e-mail address]].
Retention: until launch, at most 12 months from sign-up, or until you unsubscribe.
Providing data is optional, but without an e-mail we can't add you.

B. The app

This part applies only when you use the app, not when you visit the website.

7. Data processed in the app

What Data Provider and location Legal basis
Conversations with Nella Your voice in real time, the transcript during the session, Nella's replies, your IP address OpenAI (USA), United States Art. 6(1)(b) GDPR; Art. 9(2)(a), explicit consent, for special-category data
Nella's memory Short notes about you (e.g. names, appointments, preferences) Supabase Inc. (USA), database in Frankfurt Art. 6(1)(a) and Art. 9(2)(a), explicit consent

Transfer to OpenAI in the US: OpenAI is not certified under the EU-US Data Privacy Framework; the transfer relies on EU standard contractual clauses (Art. 46(2)(c) GDPR). For Supabase, EU standard contractual clauses cover any access from outside the EU. You can ask for a copy of the safeguards at [[LAURA: privacy e-mail address]].

Voice: we don't use your voice to identify you and don't analyse emotions from it. Training: we don't use your data to train AI models; OpenAI states it doesn't train on API data, but may keep abuse-monitoring logs (audio and text) for up to 30 days.

8. Health and other special-category data (Art. 9 GDPR)

While talking with Nella you might share things about your health, mood, sex life, religion or political views. This data is processed only with your explicit consent. You can withdraw it at any time by writing to [[LAURA: privacy e-mail address]]; withdrawal doesn't affect processing done before.

9. Nella is an AI and not an emergency service

Nella is an artificial intelligence, not a person and not a therapist (Art. 50 EU AI Act). If you are in danger, call 112.

10. Deleting Nella's memory

You can ask us to delete single notes or the whole memory [[LAURA: describe how it actually works in the app (button, voice command), or only "by writing to (e-mail)"]]. We delete within [[LAURA: deadline, suggested 7 days]]. OpenAI's logs are deleted on its schedule (up to 30 days).

Retention: memory until you delete it or your account; audio not stored by us; other app data [[LAURA: period]].

Both parts

11. Automated decisions

We make no automated decisions with legal or similarly significant effects on you (Art. 22 GDPR).

12. Your rights

You have the right to access, rectification, erasure, restriction, data portability, to object to processing based on legitimate interests, and to withdraw consent at any time (Art. 15–21 GDPR). Write to [[LAURA: privacy e-mail address]]. We reply within one month.

13. Complaints

You can complain to a supervisory authority (Art. 77 GDPR), in particular:

14. Adults only

Nella is only for people aged 18 and over. If we learn that a minor has signed up, we delete her data. Reports to [[LAURA: e-mail address]].

15. Changes

We publish every new version here, for example when the UG becomes controller or if we add analytics or payments.

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