Privacy Policy for Tontaube
Version: 8. September 2025
We, Cremer & Cremer Technologies UG (haftungsbeschränkt), located in Berlin, Germany, take the protection of your personal data seriously. This Privacy Policy informs you how we collect, process, and protect your data in connection with the use of our app Tontaube and its related services (“Services”). The processing is carried out in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
In this Privacy Policy, we use the term “Personal Data” as defined by the GDPR, meaning any data that is or can be potentially attributed to an identifiable individual.
1. Controller
The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) is our Data Protection Officer. If you have any questions about data protection, you can contact them at the following email address:
Jonathan Cremer
Herderstraße 22, 12163 Berlin, Deutschland
data-protection@craitech.io
2. Legal Bases for Processing
We base every processing of your personal data on one of the following legal bases of the GDPR (Art. 6):
- Contract — Art. 6(1)(b) Necessary to fulfill the user agreement and to provide you with the app’s features.
- Consent — Art. 6(1)(a) Applies to voluntary features such as newsletters or optional statistics. You can withdraw your consent at any time in the settings.
- Legitimate Interest — Art. 6(1)(f) Serves security purposes (abuse and fraud prevention), product improvement, and internal analysis, provided your interests do not override ours.
- Legal Obligation — Art. 6(1)(c) Required to comply with tax and commercial law retention obligations, as well as other legal requirements.
This overview shows why we process your data; the following sections specify which data is covered and for what purpose it is used.
3. Categories of Personal Data We Collect
(a) Data provided by You
| Category | Examples |
|---|---|
| Registration Data | Username / Pseudonym, email address, password hash, confirmation of legal age (if required) |
| Payment Data | Transaction ID, plan, payment status (via App Store, Google Play, or direct billing) |
| Content | Uploaded text, image, or PDF files |
| Voice Cloning | A short voice recording to create a personal synthetic voice. Stored encrypted and linked exclusively to your account. You can delete it at any time in the app. |
| Communication & Feedback | Support requests, error reports, feature requests |
| Verification Data (optional) | ID or address proof, if identity verification is necessary |
(b) Automatically Collected Data
| Category | Examples |
|---|---|
| App Interactions | Clicked buttons, viewed screens, timestamps |
| Generated Content | Audio texts, EPUB files |
| Content Organization | Playlists, listening progress, bookmarks, reading progress |
| Device Information | IP address (log storage max. 30 days), operating system, device model, app version |
| Diagnostic Data | Crash logs, performance metrics |
(c) Data from Third-Party Sources
| Source | What we receive |
|---|---|
| Payment Service Providers (e.g., Stripe) & App Marketplaces (Apple App Store, Google Play Store) | Confirmation of successful payments (Transaction ID, status), information on subscriptions, chargebacks |
| Authentication Providers | Name, email, avatar image, token (for Apple/Google login) |
4. Purposes of Processing and Legal Bases
| Purpose | Description | Legal Basis (Art. 6 GDPR) |
|---|---|---|
| Provision of Services | Create account, login, generate audio texts | lit. b |
| Payment Processing | Process purchases, create invoices, tax archiving | lit. b and lit. c |
| Voice Cloning & Audio Text Generation | Analyze uploaded texts/audio, create synthetic audios | lit. a – Consent; lit. b |
| Content Organization, Progress Saving | Save playlists, listening progress, and bookmarks | lit. b |
| Personalization & UX Optimization | Save preferences, in-app suggestions | lit. f |
| Security & Fraud Prevention | Analyze log/device data, IP logs | lit. f; where applicable lit. c |
| Customer Support & Communication | Respond to your inquiries, product notices | lit. b; lit. f |
| Error Analysis & Product Improvement | Crash reports, usage statistics | lit. f |
| Marketing Communication (optional) | Newsletters, surveys | lit. a – Consent |
When we rely on legitimate interest (lit. f), you can object to the processing at any time (see “Your Rights”).
5. Recipients of Your Data
5.1 Processors (Art. 28 GDPR)
| Service Provider | Location / Data Centers | Purpose | Guarantees |
|---|---|---|---|
| Google Cloud Platform & Firebase (Google Ireland Ltd.) | EU / worldwide | Hosting, database, file storage, push services, AI-powered Text-to-Speech & document conversion | DPA + DPF / SCCs |
| Cloudflare Inc. | USA / worldwide | Request routing, DDoS protection, blocking suspicious requests | DPA + DPF / SCCs |
| Google Analytics 4 (Google Ireland Ltd.) | EU / USA | Reach measurement, app statistics (no ads remarketing activated) | DPA + DPF / SCCs |
| OpenAI API (OpenAI Ireland Ltd. / OpenAI LLC) | EU / USA | AI-powered text and audio processing (zero-retention mode) | DPA + SCCs |
| RunPod Inc. | EU region (Frankfurt) / worldwide | Temporary GPU computing power for AI calculations | DPA + SCCs |
All of the above-mentioned processors process personal data exclusively according to our instructions and are contractually bound to confidentiality and to appropriate technical and organizational measures (Art. 28(3) GDPR).
5.2 Independent Controllers
| Recipient | Purpose | Legal Basis |
|---|---|---|
| Stripe Payments Europe Ltd. | Payment processing, fraud and money laundering prevention, legal accounting | Contract (Art. 6(1)(b)), legal obligation (lit. c) |
| Google AdMob & Google Advertising Partners | Display of (non-)personalized in-app advertising | Consent (Art. 6(1)(a)) via CMP |
| Apple Distribution International Ltd. (for users in Europe) | Processing of in-app purchases and subscriptions via the Apple App Store; providing purchase confirmations to us. | Contract (Art. 6(1)(b)) |
| Google Commerce Limited (for users in Europe) | Processing of in-app purchases and subscriptions via the Google Play Store; providing purchase confirmations to us. | Contract (Art. 6(1)(b)) |
If you consent to personalized advertising, Google AdMob will have access to your device ID and app interactions. You can withdraw this consent at any time in the app settings. Stripe, Apple, and Google process certain transaction and risk data independently to fulfill their regulatory obligations.
5.3 Other Recipients
- Other users – only upon your express instruction (e.g., when sharing your own texts/audio texts).
- Authorities / Courts – exclusively when legally required or for the enforcement of rights.
- Successors in the context of a merger, acquisition, or similar transaction.
6. International Data Transfer
Some of the mentioned service providers operate servers in third countries, particularly in the USA. The transfer of personal data only occurs if one of the following protective measures is in place:
- Standard Contractual Clauses (SCCs) of the EU Commission (Art. 46(2)(c) GDPR).
- EU–US Data Privacy Framework (DPF) for certified US companies (e.g., Google LLC, Cloudflare Inc., Stripe Inc.).
- Additional technical and organizational measures such as end-to-end encryption, regional data storage, access restrictions, and pseudonymization.
Copies of the SCCs or proof of DPF certification are available upon request at data-protection@craitech.io. Please note that US authorities may be legally authorized to access data stored there; we take appropriate measures to ensure the protection of your data in such cases as well.
7. Storage Period
| Data Type | Purpose | Retention Period | Deletion/Anonymization Criterion |
|---|---|---|---|
| Registration & Account Data | Provision of services (user agreement) | Until account deletion + 14 days | Automated deletion from production systems 14 days after account deletion, or immediately upon explicit request via email. |
| Voice sample (voice cloning) | Creation of a personal synthetic voice | Until you delete it or your account is deleted | Immediate removal following in-app deletion |
| Profile Data / Preferences | Personalized UX | Concurrent with account data | See above |
| Payment & Invoice Documents | Legal retention, bookkeeping | 10 years | Deletion after the expiration of the commercial and tax law period (§ 257 HGB, § 147 AO). |
| Business & Support Correspondence | Contract fulfillment, proof obligations | 6 years | Deletion after the expiration of the commercial law retention period (§ 257 HGB). |
| IP Log Files & Security Logs | IT security, abuse prevention | 30 days | Automatic rotation/anonymization jobs; longer storage only in case of security-relevant incidents. |
| Error & Performance Logs | Error analysis, product improvement | 90 days (pseudonymized) | Fully anonymized statistics may be retained indefinitely. |
| Legally Relevant Documents in Case of Disputes | Assertion/defense of claims | Until the conclusion of the proceedings + 3 years (statutory limitation period) | Deletion after case closure or expiration of the limitation period. |
| Backup Datasets | Data recovery | 30 days | Ring backup, automatic overwriting. |
Unless legal obligations prevent it, we will also delete or anonymize data earlier if you request it.
8. Cookies
We do not currently use cookies or similar tracking technologies that would require consent.
9. Your Rights
As a data subject, you have the following rights under the GDPR:
- Right of access (Art. 15 GDPR) – You can request a copy of your stored personal data.
- Right to rectification (Art. 16 GDPR) – You can have incorrect or incomplete data corrected.
- Right to erasure (‘right to be forgotten’, Art. 17 GDPR) – You can request that your data be deleted, provided no legal retention obligations prevent it.
- Right to restriction of processing (Art. 18 GDPR) – You can restrict the processing of your data under certain conditions.
- Right to data portability (Art. 20 GDPR) – You have the right to receive your data in a machine-readable format.
- Right to object (Art. 21 GDPR) – You can object to the processing of your data if it is based on legitimate interest.
- Right to withdraw consent (Art. 7(3) GDPR) – If you have given consent for data processing, you can withdraw it at any time with future effect.
9.1 Right to Lodge a Complaint with a Supervisory Authority (Art. 77 GDPR)
If you believe that the processing of your personal data violates the GDPR, you can contact a data protection supervisory authority. This can be the authority responsible for your place of residence or the supervisory authority responsible for us:
Berliner Beauftragte für Datenschutz und Informationsfreiheit Alt-Moabit 59–61 10555 Berlin Website: https://www.datenschutz-berlin.de
Alternatively, you can file a complaint with the data protection authority responsible for your place of residence.
To exercise your rights, please contact us at data-protection@craitech.io.
10. Automated Decision-Making
10.1 No Decisions with Legal or Similar Significant Effect
We do not make exclusively automated decisions that produce legal effects concerning you or similarly significantly affect you (Art. 22(1) GDPR).
10.2 Profiling for Advertising and Analytical Purposes
However, we use automated procedures to create pseudonymous usage and advertising profiles (“profiling” within the meaning of Art. 4 No. 4 GDPR):
- Personalized Advertising (Google AdMob) Your device ID/Ad-ID, app interactions and – if shared – demographic characteristics are processed by Google to tailor ads to your presumed interests.
- Reach Analysis (Google Analytics 4) For app optimization, we collect pseudonymous usage profiles (e.g., session duration, interaction paths).
Legal Basis: Your consent (Art. 6(1)(a) GDPR) or our legitimate interest in app security and product improvement (Art. 6(1)(f) GDPR), where consent is not required.
Your Choices:
- You can withdraw your consent at any time in the app settings.
- You have the right to object to profiling at any time (Art. 21(1) GDPR). An informal notification to data-protection@craitech.io is sufficient.
The profiles are used exclusively for the stated purposes; we do not use them to make automated decisions with legal effect (e.g., credit or insurance decisions).
11. Changes to this Privacy Policy
We reserve the right to update this Privacy Policy to adapt it to legal or technical changes. Material changes will be published on our website, and we will inform you in the app or by email about significant changes where required. If consent is necessary, we will obtain it before you continue to use the Services. Changes take effect upon publication, unless otherwise specified.