Legal

Privacy Policy for the AI Assistant

Last updated: September 2026

Preamble

baoo Technologies GmbH (hereinafter „Homie“) develops and operates AI-based chatbots for automated customer advice in online shops and in bricks-and-mortar retail. This privacy policy is addressed to end users who interact via the AI assistant embedded in a merchant's website.

Data protection and data security are our highest priority. This policy transparently informs you how Homie processes data in connection with the use of the chatbot.

Note: This policy applies exclusively to the AI assistant. A separate privacy policy applies to the processing of personal data within the merchant dashboard (app.yourhomie.ai).

1. Introduction and scope

Homie takes the protection of personal data seriously. This privacy policy informs you how Homie processes data in connection with the use of the AI-based chatbot (hereinafter the „chatbot“ or „AI assistant“).

The controller within the meaning of the GDPR for the data processing by Homie described below is:

baoo Technologies GmbH
c/o Projekton Salierring 32
50677 Cologne, Germany
Email: hi@yourhomie.ai

Please note: The merchant whose website or app embeds the AI assistant is independently responsible under data protection law for its own data processing. That merchant's privacy policy applies in addition.

2. Collection and use of data

2a. Standard operation – anonymous/pseudonymous use

In standard operation, Homie does not collect or process any personal data of chatbot users. Users do not need to register with Homie or provide any personal data to use the service. Users can submit product- and assortment-related queries to the chatbot anonymously.

Only the content of the question is processed in order to generate a suitable answer. The processing required for answering by AI models is carried out pseudonymously; no personal data is stored or linked to an identifiable person.

Conversation data is not used to train AI models. The contractual arrangement for this is set out in the data processing agreement (DPA) with the respective merchant.

If you have inadvertently entered personal data, please contact us at hi@yourhomie.ai so that we can remove this data.

2b. Optional features – e.g. lead qualification and support handover

Where the merchant has activated optional features such as lead qualification or support handover, end users may voluntarily enter personal data (e.g. name, email address) as part of these features.

In this case, the following applies:

  • The data is used exclusively for the purpose of the further processing configured by the merchant (e.g. forwarding to the merchant's support or CRM).
  • The respective merchant is responsible under data protection law for the processing of this data. In this context, Homie acts as a processor pursuant to Art. 28 GDPR on the basis of a DPA concluded with the merchant.
  • End users are informed of the respective merchant's data protection provisions immediately before entering their data and consent to this processing by submitting the data.
  • The legal basis for the processing is the user's consent pursuant to Art. 6(1)(a) GDPR.

3. Third-party providers used and data disclosure

3a. AI processing – OpenAI

To answer user queries in our AI assistant, conversation content is transmitted to OpenAI Ireland Limited (1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland). EU Data Residency: All inputs and responses are processed and stored exclusively on servers within the EU. A transfer of data to the USA for storage is excluded.

Homie has concluded a data processing agreement with OpenAI which ensures that conversation data is not used to train AI models.

Note: Homie reserves the right to also use other AI providers on a technical level. We will inform you in good time about material changes.

3b. Hosting – Vercel

The AI assistant is provided via the infrastructure of Vercel Inc. (340 S Lemon Ave #4133, Walnut, CA 91789, USA). Vercel is certified under the EU-US Data Privacy Framework. We have concluded a DPA with Vercel pursuant to Art. 28 GDPR.

3c. Other disclosure

Beyond this, Homie does not disclose any data to third parties unless this is necessary to perform the contract with the merchant, the user has consented, or there is a legal obligation.

4. Data security

Homie uses appropriate technical and organisational security measures (TOMs) to protect data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorised access by third parties – taking into account the state of the art, the implementation costs, and the nature, scope, context and purpose of the processing.

Homie's security measures are continuously improved in line with technological developments.

5. Rights of data subjects

As a data subject, you have the following rights:

  • Right of access (Art. 15 GDPR)
  • Right to rectification (Art. 16 GDPR)
  • Right to erasure (Art. 17 GDPR)
  • Right to restriction of processing (Art. 18 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to object (Art. 21 GDPR)
  • Right to lodge a complaint with the competent supervisory authority (Art. 77 GDPR)

To exercise your rights, please contact: hi@yourhomie.ai or our data protection officer (see section 6).

Note: Since Homie does not collect any personal data in standard operation, it is technically not possible to identify individual users for the purpose of access or erasure. Where personal data has been processed as part of optional features (section 2b), please contact the respective merchant directly as the controller.

6. Data protection officer

For any questions regarding data protection and the exercise of your rights, you can contact our data protection officer at any time:

baoo Technologies GmbH
Data protection officer: Maximilian Mertin, Intersoft Consulting
Email: mmertin@intersoft-consulting.de

7. Changes to this privacy policy

Homie reserves the right to adapt this privacy policy in the event of changes to the services used or the legal situation. The current version is available at yourhomie.ai/datenschutz/ki-assistent. The date of the last change is indicated at the top of the document.