Privacyverklaring

1. Controller

The controller for the processing of personal data under the General Data Protection Regulation is Pangolin UG (haftungsbeschränkt) i. Gr., Hansestraße 3, 59590 Geseke, Germany, represented by its managing director Tobias Stöber.

No data protection officer has been appointed, as the legal conditions for that do not apply.

In case of doubt, the German version of this text applies.

2. This website

The website belg.app is served as a static site by Cloudflare Pages. It sets no cookies, loads no fonts from third-party servers and contains no analytics or advertising tools. There is no contact form.

When the site is requested, the delivery network processes technically necessary connection data such as the IP address, in order to deliver the page at all and to fend off attacks. The legal basis is Art. 6(1)(f) GDPR.

In the bottom right corner there is a chat that answers questions about the app. It only starts once you open it and write something. What you type there is sent, together with the texts of this website, to Anthropic PBC as a processor, so that the answer is generated there. We do not store the conversations; they live only in your browser window and are gone when the tab is closed. To limit abuse, the number of questions per IP address is counted; what is stored for that is a counter, not the content. The legal basis is Art. 6(1)(f) GDPR, our legitimate interest being information about our own product. Please do not enter personal data there; for anything personal write to [email protected].

On the start page you can sign up to be told when Belg launches (waiting list). For this we process the email address you enter, plus the language of the page and the note that the sign-up came from belg.app. The sign-up runs through Brevo GmbH, Köpenicker Straße 126, 10179 Berlin, as a processor. It first sends a confirmation email: only once you open the link in it does the address go on the list (double opt-in). The legal basis is your consent under Art. 6(1)(a) GDPR. You can withdraw it at any time, through the unsubscribe link in every email or informally to [email protected]; the address is then deleted. If you do not open the confirmation link, the address is never added to the list. To limit abuse, the number of sign-ups per IP address is counted here as well; what is stored is a counter, not the address.

3. What the app processes

Belg is a service for households. A household's data is tied to that household and separated from other households at database level (row level security).

The following is processed:

• Account data: the email address of the adults, for signing in by magic link or passkey. Children are created by their parents and sign in without an email address of their own.
• Household data: names of members, roles, missions, prices, shop entries and the balance of the currency together with its entries.
• Photo proofs: pictures children upload for a mission. They are shown only to the adults of the same household.
• School data: WebUntis credentials, timetable, homework and tests of the respective child, if you set up the school connection.
• Learning data: vocabulary, learning progress, reading class and arithmetic levels.
• AI chats: transcripts of conversations with BelgAI, including the homework chats. The transcripts stay with us inside your household, the individual request goes to the AI provider to be answered.
• Location: during a help call, the child's precise location, which the adults of the household see while the help call is running. For the weather, the approximate location. Both only if you allow location on the device, and never in the background.
• Sound: voice messages in a help call and, if you speak to BelgAI, the recording of that question. Reading practice analyses the voice with the device's speech recognition; we keep no recording of it.
• Calendar: events, if you connect the device calendar to Belg.
• Account view (parents only): balances and transactions of your bank accounts, if you connect an account.
• Your own content: documents, shopping and to-do lists, pictures and songs you create in the app.
• Usage data: which parts of the app are used. We analyse this ourselves on our server, without advertising or analytics services of other providers.
• Technical data: push tokens of the devices, error reports and server logs.

4. Purpose and legal basis

Processing serves the provision of the service you agreed with us. The legal basis is Art. 6(1)(b) GDPR (performance of a contract).

To prevent misuse, to find errors and to keep the system secure, we process log data on the basis of Art. 6(1)(f) GDPR. Our legitimate interest is the secure operation of the service.

The school connection is set up by you, and whether your children may use BelgAI is your decision. As long as you do not release it, no data is processed for it.

5. Children's data

Children cannot sign themselves up for Belg. An adult of the household creates them and assigns their role. The decision about processing a child's data therefore sits with those holding parental responsibility.

Adults of the same household see their children's content, including the chats with BelgAI. This is deliberate and is not hidden from the children in the app.

6. Who else sees the data

We pass data on only as far as operation requires. In use are:

• Hetzner Online GmbH, Gunzenhausen, for servers and database. The servers are located in Germany.
• Apple Distribution International, for delivery of the app, for notifications on the device and for billing the subscription.
• Google Ireland Limited, for delivery of the Android app through Google Play and for notifications on Android devices (Firebase Cloud Messaging).
• Expo (650 Industries, Inc., USA), which relays notifications to Apple and Google and delivers app updates. Transferred are the device's push token and the text of the notification.
• WebUntis, operated by Untis GmbH, if you set up the school connection. Transferred is what is needed to fetch the timetable and to file a sick note.
• Anthropic PBC (USA), for BelgAI's answers and the homework help, if you use BelgAI. Transferred are the respective request together with the context needed for the answer, for homework help the photo of the task, and the age band. No name and no address. If you do not use BelgAI, nothing is transferred there.
• OpenAI (USA), when you speak to BelgAI (speech to text, reading the answer aloud, live conversation) and for drawn pictures, for example for shop entries or memory hooks. Transferred are the recording or the text of the picture request. Zero Data Retention applies to our account at OpenAI: nothing is stored there after the answer.
• Google Cloud (Text-to-Speech), for pronunciation in the vocabulary module. Only the word or sentence to be read aloud is transferred.
• sunoapi.org, for songs you create in the app. Transferred are the lyrics and the requested style.
• GIPHY, when you search for GIFs in the chat. The search term is transferred. We fetch a chosen GIF to our server; your device does not talk to GIPHY itself.
• Enable Banking Oy (Finland), a licensed account information service, when parents connect a bank account. Balances and transactions are retrieved, only after your consent at the bank.
• Open-Meteo, for weather and rain radar. The device queries it with the approximate location.
• Sentry (Functional Software, Inc.), data centre in the EU, for crash reports of the app. Transferred are technical details about the error and the device, no names and no content.
• Brevo GmbH, Berlin, for the waiting list on this website. Transferred is the email address you enter there yourself, plus the language of the page. If you do not sign up, nothing is transferred there.

7. What the device does itself

Some things are handled by your device's operating system, not by Belg: speech recognition in reading practice (Apple or Google), the map in a help call (Apple Maps, on Android Google Maps) and Sign in with Apple. Apple's or Google's privacy terms apply to these.

We do not sell data, show no advertising and use no advertising identifier.

8. How long

We store a household's data for as long as the household exists. If you delete your household, the associated data is removed.

Server logs are deleted after a short period. Statutory retention periods under commercial and tax law remain unaffected, but concern billing rather than the contents of your household.

9. Your rights

You have the right to information about the data stored about you, to rectification, to erasure, to restriction of processing, to data portability and to object to processing based on a legitimate interest.

In the app, under settings, you will find a deletion request that removes the household with all its content. You can also request deletion from us informally.

You also have the right to complain to a supervisory authority. The competent authority is the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia.