Privacy Policy

1. Controller

2. EU Representative (Art. 27 GDPR)

As our company is based outside the European Union, we have designated the following representative in the EU pursuant to Art. 27 GDPR:

This representative acts as the point of contact for supervisory authorities and data subjects in the EU on all matters relating to data processing.

3. Overview of Processing Activities

This Privacy Policy informs you about the nature, scope and purpose of the processing of personal data in connection with our online offering and the associated websites, functions and content. Our company uses AI-assisted systems (voice agents, WhatsApp agents, chat assistants) for customer communication. Below we provide transparent information on all relevant processing operations.

4. Hosting and Server Log Files

When you visit our website, the web server automatically collects so-called server log files. These contain:

• IP address of the requesting computer
• Date and time of access
• Name and URL of the file retrieved
• Amount of data transferred
• Notification of successful retrieval
• Browser type and version
• Operating system of the user
• Referrer URL (previously visited page)

Processing is carried out on the basis of Art. 6(1)(f) GDPR (legitimate interest in ensuring error-free operation). Log files are automatically deleted after 14 days.

5. Contact and Forms

When you contact us via a form on our website, the submitted data (name, e-mail address, telephone number if applicable, company, message content) will be processed.

The legal basis is Art. 6(1)(b) GDPR (pre-contractual measures) and Art. 6(1)(a) GDPR (consent to contact by telephone and/or WhatsApp).

When submitting the form, you are asked for your explicit consent for us to contact you by telephone and/or via WhatsApp, including through AI-assisted communication systems (voice agents, WhatsApp agents). This consent is voluntary and may be withdrawn at any time with effect for the future.

Data will be deleted once it is no longer required for the purpose for which it was collected and no statutory retention obligations prevent deletion.

5a. Facebook Lead Ads

We collect personal data via Facebook Lead Ads forms (provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). Data you enter in the form (name, e-mail address, telephone number) is automatically transferred to our CRM system.

Within the Facebook form, you are asked for your explicit consent for us to contact you by telephone and/or via WhatsApp — including using AI-assisted systems. Legal basis: Art. 6(1)(a) GDPR (your consent).

6. AI-Assisted Communication (Voice Agents, WhatsApp Agents, Chat Assistant)

We use AI-assisted voice assistants (voice agents), chat systems (WhatsApp agents) and an AI chat assistant for customer communication. Below we inform you about the related data processing:

a) AI Voice Agent (Telephone Calls)

If you have given your consent to being contacted by telephone via a form on our website or via Facebook Lead Ads, you will receive an automated call from our AI-assisted voice agent (provider: Fonio GmbH, Germany).

The following data is processed:

• Your telephone number
• Date, time and duration of the call
• Call content (where the call is recorded or transcribed with your consent)
• Your answers and statements during the call

The voice agent identifies itself at the beginning of the conversation as an AI system (in accordance with Art. 50 of the EU AI Act). If the call is recorded or transcribed, you will be informed at the beginning of the call and your consent will be requested. Data processing takes place entirely in Germany.

Legal basis: Art. 6(1)(a) GDPR (your consent, which you provided via the contact form or Facebook form).

b) WhatsApp Agent

If you have given your consent, we will also contact you via WhatsApp using AI-assisted messages.

The following data is processed:

• Your telephone number / WhatsApp identifier
• Message content
• Timestamps of the communication
• Delivery status (sent, delivered, read)

WhatsApp communication is handled via the WhatsApp Business API (provider: 360dialog GmbH, Berlin, Germany, as technical service provider; Meta Platforms Ireland Ltd. as platform operator). The privacy terms of Meta/WhatsApp additionally apply.

Legal basis: Art. 6(1)(a) GDPR (your consent).

c) AI Chat Assistant

We use an AI-assisted chat assistant that communicates with you via WhatsApp. The assistant uses artificial intelligence to answer your questions and pre-qualify your enquiry (budget, needs, timeframe). The assistant identifies itself in all communications as an AI system in accordance with Art. 50 of the EU AI Act.

Processing is carried out on the basis of Art. 6(1)(b) GDPR (initiation of a contract) and Art. 6(1)(f) GDPR (legitimate interest in efficient customer communication).

d) Consent Documentation

We document your consents to data processing and AI communication with a timestamp in our CRM system. This documentation serves as proof of the consent granted pursuant to Art. 7(1) GDPR.

e) Withdrawal of Consent

You may withdraw your consent to contact by telephone and/or via WhatsApp at any time:

• By e-mail to info@vertriebspilot.ai
• By stating so during a call (e.g. “Please do not call me again”)
• By WhatsApp message with the word “STOP”

After withdrawal, no further automated contact will be made. Your withdrawal will be documented in our system with a timestamp. Data already processed will remain stored until statutory retention periods expire, unless you explicitly request erasure (see Section 15).

7. Appointment Scheduling

For online appointment scheduling we use Cal.com (Cal.com, Inc.). When booking an appointment, the following data is transmitted:

• Your name
• Your e-mail address
• Your telephone number
• The requested appointment

Processing is carried out on the basis of Art. 6(1)(b) GDPR (initiation of a contract). Appointment confirmation is sent by e-mail with a video conference link.

8. Services and Contract Performance

We process personal data of our customers to provide our services in the field of AI-assisted sales automation, in particular:

• Provision of digital consulting services
• Lead generation and customer communication
• CRM integration and automation
• Optimisation of sales processes

The legal basis is Art. 6(1)(b) GDPR (performance of a contract).

9. Use of Third-Party Providers and Tools

We use the following tools and services:

HubSpot (HubSpot, Inc., USA): CRM and marketing automation for lead nurturing and contact management. HubSpot processes your contact data, communication history and qualification information.

Anthropic (Claude API) (Anthropic, Inc., USA): For AI-assisted communication via chat and text processing. Your message content is transmitted to Anthropic for processing. Anthropic does not permanently store personal data from API requests and does not use it to train AI models.

Fonio (Fonio GmbH, Germany): Provision of voice agent technology for automated telephone contact. Data processing takes place in Germany.

360dialog (360dialog GmbH, Berlin, Germany): Technical service provider for the WhatsApp Business API. Data processing takes place in Germany.

Cal.com (Cal.com, Inc.): Online appointment scheduling and calendar management.

n8n (n8n GmbH, Berlin, Germany): Workflow automation for orchestrating communication processes. Data processing takes place on EU servers.

Google Analytics / Google Tag Manager (Google Ireland Ltd.): Analysis of visitor behaviour. IP anonymisation is enabled.

Google Ads (conversion tracking & remarketing) (Google Ireland Ltd., Ireland): To measure the success of our ads and, where applicable, for remarketing. A cookie may be set after you click on an ad. Processing takes place exclusively on the basis of your consent (Art. 6(1)(a) GDPR), which you provide via our consent banner; without consent, no such cookies are set and no data is transmitted. You can withdraw your consent at any time with effect for the future.

Stripe (Stripe, Inc., USA) / PayPal (PayPal (Europe) S.à r.l.): Payment processing for fee-based services.

Where these providers process data in the USA, the transfer is based on an adequacy decision of the European Commission (EU-U.S. Data Privacy Framework), provided the respective provider is accordingly certified, or on the basis of EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).

10. Facebook Conversions API and Advertising

To optimise our advertising campaigns, we transmit pseudonymised conversion data via the Facebook Conversions API (server-side) to Meta Platforms Ireland Ltd. The following data is transmitted:

• Hashed (encrypted) e-mail address
• Hashed (encrypted) telephone number
• Time and type of conversion (e.g. contact enquiry, appointment booking)
• Facebook Click ID (if available)

Meta uses this data exclusively to optimise ad delivery and to match it with Facebook user profiles. Data is hashed (SHA-256) prior to transmission so that Meta does not receive access to your plain-text data.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in effective advertising). You may object to the processing of data for advertising purposes at any time — by e-mail to info@vertriebspilot.ai or via the advertising settings in your Facebook account.

Meta Pixel (Facebook Pixel): In addition to the server-side Conversions API, we use the browser-side Meta Pixel by Meta Platforms Ireland Ltd., which records your interactions on our website to measure and optimise our advertising. The pixel is loaded exclusively after your consent via our consent banner (Art. 6(1)(a) GDPR); without consent, no data is transmitted to Meta. You may withdraw at any time with effect for the future.

11. Automated Pre-Qualification (Art. 22 GDPR)

Our system uses AI technology for outreach and lead qualification. This involves automated pre-qualification of your details: your budget, needs and timeframe are assessed and a qualification score (0–100) is calculated.

This assessment serves exclusively to prioritise you for a personal consultation. No purely automated rejection takes place — every interested party has the opportunity for personal contact. You have the right to request a review of the automated assessment by a human.

The decision as to whether and when an automated call or WhatsApp message is triggered is based on your active form submission and consent.

Should automated decisions with legal effect be deployed in the course of further developing our systems, we will inform you separately and obtain your explicit consent.

12. Cookies

This website uses cookies. Technically necessary cookies are set on the basis of Art. 6(1)(f) GDPR. Analytics and marketing cookies are only set with your explicit consent (Art. 6(1)(a) GDPR). On your first visit, you will be asked for consent via a cookie banner. You may withdraw your consent at any time with effect for the future.

13. Data Subject Rights

You have the right at any time to:

• Obtain information about your stored data (Art. 15 GDPR)
• Rectification of inaccurate data (Art. 16 GDPR)
• Erasure of your data (Art. 17 GDPR) — see also Section 15
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Object to processing (Art. 21 GDPR)
• Withdraw consents granted (Art. 7(3) GDPR)

Please address requests to: info@vertriebspilot.ai or to our EU representative Prighter Group GmbH (see Section 2).

14. Data Transfers to Third Countries

As our company is based in the USA, data is generally also processed in the USA. The following third-party providers process data outside the EU:

• HubSpot, Inc. (USA) — CRM data
• Anthropic, Inc. (USA) — AI communication content
• Meta Platforms, Inc. (USA) — conversion data (hashed)
• Cal.com, Inc. — appointment booking data

Where personal data of persons in the EU is processed, we ensure that appropriate safeguards exist pursuant to Art. 46 GDPR (EU Standard Contractual Clauses) or that an adequacy decision of the European Commission exists (EU-U.S. Data Privacy Framework).

The following providers process data exclusively in Germany/EU:

• Fonio GmbH (Germany) — Voice Agent
• 360dialog GmbH (Germany) — WhatsApp API
• n8n GmbH (Germany) — Workflow automation

15. Right to Erasure and Erasure Process

You have the right to request the erasure of your personal data (Art. 17 GDPR). Upon receipt of an erasure request, the following measures will be taken:

• Anonymisation of your contact data in our CRM system (name, e-mail, telephone number)
• Deletion of all conversation histories and notes
• Documentation of the deletion with timestamp
• Immediate cessation of all automated contact

Please send your erasure request to info@vertriebspilot.ai, stating your name and telephone number/e-mail address. We will process your request within 30 days.

16. Retention and Deletion Periods

Personal data is stored only for as long as is necessary for the respective processing purpose, unless you object to processing or statutory retention obligations require otherwise. Specifically:

• Contact data in the CRM: For as long as a legitimate interest in establishing a business relationship exists or until you object to processing
• Conversation transcripts and chat histories: For as long as a legitimate interest exists or until you object to processing
• Call recordings (audio): Maximum 180 days, thereafter automatically deleted
• Conversion data (Facebook CAPI): 90 days (managed by Meta)
• Booking data (appointments): For as long as a legitimate interest exists or until you object to processing
• Server log files: 14 days
• Contract data and invoices: 10 years (statutory retention obligation pursuant to Sec. 257 HGB, Sec. 147 AO)

Upon objection to data processing, your data will be deleted or anonymised without delay (see Section 15), provided no statutory retention obligations prevent this. Call recordings are automatically deleted after the 180-day period.

17. SSL/TLS Encryption

This website uses SSL/TLS encryption for security reasons. You can recognise an encrypted connection by the padlock symbol in the browser bar and the “https://” protocol.

18. Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority. The competent supervisory authority is:

19. Currency of this Policy

Version: 06 May 2026 (updated)

We reserve the right to update this Privacy Policy so that it always reflects current legal requirements.

20. Postal Mailing Service Provider

For the postal dispatch of personalised acquisition letters, we use the service provider Pingen AG, Pfingstweidstrasse 60, 8005 Zürich, Switzerland. The recipient’s address data and letter content are transmitted for print preparation. Transfer to Switzerland is based on the adequacy decision of the European Commission (Decision 2000/518/EC).

21. Hosting of Personalised Landing Pages (b.vertriebspilot.ai)

Hostinger International Ltd, 61 Lordou Vironos Street, 6023 Larnaca, Cyprus. Server location: Frankfurt am Main, Germany. Data processed:

• IP address (anonymised geo-lookup via ip-api.com, EU-compliant provider)
• User agent
• URL accessed, including personalised 4-character hash code
• Timestamp
• One technical functional cookie (“vp_test”, 30 days), used exclusively to filter out the operator in tracking logs. This is not a marketing cookie and therefore does not require consent under Sec. 25 TTDSG.

Retention period: 90 days in append-only logs, thereafter aggregated. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in measuring the effectiveness of direct outreach).

22. Email Notifications to the Operator

Upon registration in the live test or industry competitor analysis form, the operator receives a technical notification e-mail via the SMTP service Apple iCloud Mail (Apple Inc., One Apple Park Way, Cupertino, California 95014, USA). Transfer to the USA is based on Standard Contractual Clauses (SCCs).

23. AI Voice Assistant “Mia”

Following consent to live test requests, an AI voice assistant called “Mia” is activated via the WhatsApp Business API (360dialog GmbH, Berlin) for a one-time initial contact demo. In accordance with Art. 50 of the EU AI Act, the AI declares itself as artificial intelligence at the beginning of every interaction. Voice content is transcribed for quality assurance purposes.