Data Privacy Policy
0. Controller and Applicability
This Privacy Policy describes how personal data is processed by:
Coderilla GmbH
Alte Kasernstrasse 16
97082 Würzburg
Germany
Email: data-privacy@coderilla.de
The responsible party decides alone or jointly with others on the purposes and means of processing personal data (e.g. names, contact details, etc.).
1. Information We Collect
We collect information you provide directly to us, such as when you create an account, use our services or contact us for support.
- Account information (name, email address, profile picture)
- Profile preferences
- Communication data when you contact us
- Usage data and analytics
Scribe Spark is not intended for minors under 16 years; we do not knowingly collect such data.
2. How We Use Your Information
We use your information to provide, maintain and improve our services, process transactions, personalize content, communicate with you, ensure security and prevent fraud.
- Service delivery and personalization
- Contract management
- Support and communications
- Usage analysis for service improvements
- Fraud detection and security monitoring
2.1 Legal Bases for Processing
- Art. 6(1)(a) GDPR – your explicit consent (e.g. marketing emails)
- Art. 6(1)(b) GDPR – performance of a contract with you (e.g. account creation)
- Art. 6(1)(c) GDPR – legal compliance obligations
- Art. 6(1)(f) GDPR – our legitimate interests (e.g. service optimization, fraud prevention)
3. Information Sharing
We do not sell or rent your personal data. We may share your data only in the following cases:
- With your consent
- If required by law or legal authority
- To protect our rights and property
- To our trusted service providers who process your data under confidentiality agreements
3.1 Service Providers and Data Processors
We use a limited number of trusted third-party providers to operate and improve Scribe Spark. Each provider processes personal data only on our behalf and under a data-processing agreement in accordance with Art. 28 GDPR. Where transfers occur outside the EU/EEA, they are protected by the EU–US Data Privacy Framework or by Standard Contractual Clauses (SCCs) approved by the European Commission.
| Processor | Purpose of Processing | Location / Safeguard |
|---|---|---|
| Google Cloud Platform (Google Ireland Ltd.) | Hosting infrastructure, authentication, database and media storage | Data centers in EU (Frankfurt) and if applicable, Google LLC (US) under EU–US Data Privacy Framework & SCCs |
| Stripe Payments Europe Ltd. | Payment processing and subscription management | EU / US – SCCs & Data Privacy Framework |
| Mailgun Technologies Inc. | Transactional email delivery (e.g. notifications) | US – Data Privacy Framework & SCCs |
| OpenAI Ireland Ltd. / OpenAI LLC | AI content generation features | EU + US – SCCs & Data Privacy Framework |
| Google Analytics 4 (only if consented) | Usage analytics to improve product experience | EU + US – Data Privacy Framework & SCCs |
When you choose to connect your Instagram or Facebook account, Scribe Spark interacts with the Meta Platforms APIs (Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland). Through this connection, we access and process the information that you authorize—such as page or profile identifiers, content engagement, media captions and publishing permissions—to enable scheduling and posting features. We do not obtain any additional personal data from Meta beyond what is necessary for these features. Processing is based on your consent (Art. 6 (1)(a) GDPR) and the contractual necessity to provide the integration (Art. 6 (1)(b) GDPR). For more details on how Meta processes data, please refer to the Meta Privacy Policy.
We ensure that all processors are carefully selected, bound by confidentiality obligations and process data only to the extent necessary for their assigned purpose. The list of active processors may be updated from time to time as our services evolve.
4. Cookies and Local Storage
Our application uses only technically necessary cookies and local storage entries. These are required to enable secure login sessions and to ensure the proper functioning of our services.
We do not use cookies or similar technologies for analytics, tracking, or advertising purposes. Session-related information is stored only for the duration of your active session or as long as required to provide the respective functionality.
With your consent, we may also use analytics cookies (Google Analytics 4) to understand how our services are used and to improve user experience. You can withdraw your consent at any time via the cookie settings.
5. Data Security
We use appropriate technical and organizational measures—such as encryption, access controls and regular security reviews—to protect your data. However, no method of data transmission or storage is fully secure.
6. International Transfers
Your personal data may be transferred to countries outside the EU/EEA. Such transfers are protected by GDPR-approved safeguards, such as standard contractual clauses.
7. Data Retention
We retain personal data only as long as necessary to provide services, comply with legal obligations, or resolve disputes. Some data (e.g. transactional records) may be retained longer if required by law.
8. Your Rights
Under GDPR, you have the right to:
- Access, correct or delete your personal data
- Restrict or object to processing
- Withdraw consent at any time
- Request data portability
- Lodge a complaint with a supervisory authority (e.g., Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 27, 91522 Ansbach, Germany)
You can exercise your rights by contacting us via data-privacy@coderilla.de. We will respond within one month as required by Art. 12 GDPR.
9. Changes to This Policy
We may update this policy occasionally. The most recent version will always be published here with an updated “Last updated” date.
10. Contact
For privacy-related inquiries, please contact: data-privacy@coderilla.de
Coderilla GmbH
Alte Kasernstrasse 16
97082 Würzburg
Germany
Version 0.2.0 - Last updated: 11/3/2025