AI Act Content Signer EU AI Act · Art. 50

Privacy Policy

Last updated: November 2026. This is a courtesy translation of our German privacy policy. In case of discrepancies, the German version (Datenschutzerklärung) is the authoritative one.

The protection of your personal data matters to us. This policy informs you, in accordance with Articles 12 and 13 of the General Data Protection Regulation (GDPR), in a precise, transparent and intelligible form about the data processed when you visit this website. On this preview site we process only the data that is technically necessary or that you actively send us.

1. Controller

The controller responsible for data processing within the meaning of the GDPR is:
TOTEMA – Prozesse. Neu gedacht.
Owner: Slaveyko Kirilov Nikolov
An der Leite 19
96193 Wachenroth
Germany
E-mail: contact@aiactcontentsigner.de

The controller within the meaning of the GDPR is the natural person named above as the owner of the sole proprietorship. "AI Act Content Signer" is an offering of TOTEMA.

2. Data Protection Officer

The requirements for an obligation to appoint a Data Protection Officer (Art. 37 GDPR, § 38 BDSG) are currently not met. Please direct any data protection questions to the contact details given in section 1 and section 19.

3. Subject matter and scope of this policy

This privacy policy applies to the website aiactcontentsigner.de in its current form: a purely informational preview site before launch.

This website offers no registration, no customer account, no payment processing and no processing of content for detection or signature purposes. The following sections therefore describe only the processing that takes place when this website is accessed and when contact is made via the e-mail addresses provided. Once the service launches, this policy will be extended to cover the processing added at that point (section 18).

4. General information

This website is deliberately operated without advertising tracking, without profiling and without third-party advertising networks. In particular we do not use services such as Google Analytics, Google Fonts, YouTube or Matomo, and we set no advertising or analytics cookies. Fonts and stylesheets are loaded exclusively from this website itself. The one exception is the anonymous reach measurement with the self-hosted analytics software Umami on our own server, which sets no cookies and stores nothing in your browser – it is described in detail in section 6.

Personal data means any data with which you can be personally identified. We process as little data as possible (data minimisation, Art. 5(1)(c) GDPR).

5. Hosting and server log files

This website is hosted by the European provider Scaleway (data centre within the European Union). A data processing agreement pursuant to Art. 28 GDPR is in place with the provider.

When the website is accessed, the web server automatically stores information in server log files that your browser transmits: browser type and version, operating system used, referrer URL, hostname of the accessing computer, IP address (IPv4 and IPv6) and the time of the server request. This data is not used to identify individuals and is not combined with other data sources. Purpose: technically error-free provision of the website, evaluation of system security and stability, and defence against and investigation of attacks. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest lies in the secure and stable operation of this website. Retention: the log files are deleted after 30 days.

To defend against attacks on the web server, the IP address may be processed briefly in an in-memory counter (rate limit). This information is not stored permanently and is not passed on to third parties (Art. 6(1)(f) GDPR).

6. Reach measurement with Umami

For the statistical evaluation of page views we use Umami, open-source analytics software without cookies and without advertising tracking. The evaluation runs on our own server at stats.totema.de, operated at our hoster Scaleway in a data centre in the European Union (see section 5). No data is transferred to third parties and none is shared with advertising networks.

Data processed: the page you opened (address and page title), the referrer URL, browser type and version, operating system, device type, screen size, the language reported by your browser and – derived from your IP address – the country the request came from. The IP address itself is not stored: server-side it is used only to determine the country and to compute a session identifier, and is then discarded. That session identifier is pseudonymous (a hash computed server-side from IP address, browser signature, website ID and a regularly rotating random value); it serves exclusively to build session and visit statistics and is not combined with other data sources.

No cookies, nothing stored on your device: the measurement script sets no cookies and writes no entries to your browser's local storage. The only thing it reads there is a switch called umami.disabled, which exists only if you have switched the measurement off yourself (see below). Consent under § 25(1) TDDDG is therefore not required, and there is no cookie banner on this site.

Purpose: anonymous reach measurement – which pages are read and how visitors reach the site – in order to improve this website. There is no profiling, no cross-website tracking and no evaluation of you as a person. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest lies in the anonymous evaluation and improvement of our offering. Retention: see section 13.

Objection: you may object to the reach measurement at any time with effect for the future (Art. 21(1) GDPR). To do so, set the switch named above in your browser's developer console: localStorage.setItem("umami.disabled", 1). The measurement script checks that switch on every request and will then transmit no further data. A short informal message to contact@aiactcontentsigner.de works just as well.

"Do Not Track": if your browser reports the "Do Not Track" signal (navigator.doNotTrack = 1), the measurement script transmits no data at all when you open our pages. You can enable that signal in your browser settings; whether and how it is reported is up to the browser – many browsers have since removed support, while Firefox and some privacy extensions still report it. The umami.disabled switch works in every browser regardless.

Only the two landing pages (aiactcontentsigner.de and the English version /en/) are measured. The legal pages Imprint and Privacy Policy are not measured.

7. SSL/TLS encryption

For security reasons and to protect the transmission of confidential content, this site uses SSL/TLS encryption. You can recognise an encrypted connection by the fact that the browser address bar changes from "http://" to "https://". With encryption enabled, the data you transmit to us cannot be read by third parties.

8. Launch notification

On this site you can ask to be notified once when the service launches. For this we process your e-mail address and the content of your message in order to send you this single launch notification (currently planned for 1 December 2026).

Clicking the notification link does not establish a connection to our server: the message is created solely in your e-mail client and sent by you. We only process your address once you have sent that message. Because you send us the message yourself, no additional confirmation of your address (double opt-in) is required – your message also serves as evidence of your consent.

Legal basis: your consent pursuant to Art. 6(1)(a) GDPR in conjunction with § 7(2) UWG; you give this consent by sending us the message containing the relevant notice. Retention: we store your address until this notification is sent and delete it immediately afterwards, unless statutory retention obligations prevent this. Withdrawal: you may withdraw your consent at any time with effect for the future (Art. 7(3) GDPR) – a short informal message to contact@aiactcontentsigner.de is enough.

Your address will not be used for other advertising purposes or for a newsletter, and will not be passed on to third parties.

9. Contact by e-mail

If you contact us by e-mail – for example via one of the addresses given or via one of the contact links provided – we process your e-mail address, the content of the message, the time of the message and the technical transmission data. Purpose: handling and answering your enquiry. Legal basis: Art. 6(1)(b) GDPR insofar as your enquiry is aimed at entering into or performing a contract, otherwise Art. 6(1)(f) GDPR (legitimate interest in answering enquiries).

E-mail sending and the mailboxes are operated by a service provider in the European Union acting as a processor pursuant to Art. 28 GDPR (see section 11).

10. Cookies and local storage

This website sets no tracking or analytics cookies and no advertising or personalisation cookies. The reach measurement with Umami described in section 6 also uses no cookies and writes nothing to your browser's local storage; it only reads the objection switch umami.disabled there, which exists only if you set it yourself.

Beyond that, this preview site stores nothing in your browser: no cookies are set and no entries are written to local storage. Switching between German and English is a plain link to the other page and needs no storage – your choice is not kept in your browser. Consent under § 25(1) TDDDG is therefore not required, and there is no cookie banner on this site. Only once the service launches may features arrive that need local storage (the session in the login area, for instance); this policy will be extended in advance accordingly (section 18).

11. Recipients and categories of recipients

We use service providers to operate this website. They process data exclusively within the framework of a data processing agreement pursuant to Art. 28 GDPR and only on our instructions:

Your data is not passed on for any other purpose or to any other third parties.

12. Transfers to third countries

We process your data for this website within the European Union. No personal data is transferred to third countries (outside the EU or the EEA) for the operation of this website.

Should processing with a third-country connection become necessary for the later service, we will inform you in advance in this policy and state the legal basis for the transfer (in particular standard contractual clauses pursuant to Art. 46(2)(c) GDPR).

13. Retention periods

We store personal data only for as long as is necessary for the purposes stated in this policy or as required by statutory retention periods.

14. Your rights as a data subject

Under the GDPR you have the following rights:

To exercise your rights, a short informal message to contact@aiactcontentsigner.de is sufficient. We may request proof of identity in order to prevent unauthorised access requests. Such verification is only carried out to the extent necessary to prevent unauthorised access requests (proportionality, Art. 5(1)(c) GDPR).

15. No automated decision-making

No automated decision-making, including profiling, within the meaning of Art. 22 GDPR takes place. The reach measurement described in section 6 does not evaluate individuals either – it counts page views.

16. No obligation to provide data

You are not obliged to provide us with personal data. This website can be used without providing any personal data. However, a launch notification or a contact enquiry requires you to give us your e-mail address; without it we cannot reply to you.

17. Right to lodge a complaint with a supervisory authority

In the event of data protection infringements you have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The competent supervisory authority is the Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 18, 91522 Ansbach, Germany.

18. Currency and scope of this policy

This privacy policy is currently valid and last updated in November 2026. It applies to the preview website described above. Before the service launches it will be extended to cover the processing added at that point – in particular account and API keys, processing of submitted content for detection and signature, the verification and audit log, and payment processing and invoicing. These additional processing activities will only take place after the updated privacy policy has been published. We may need to amend this policy as our service develops or as statutory or regulatory requirements change.

19. Contact

If you have any questions about the collection, processing or use of your personal data, or about access, rectification, blocking or erasure of data, please contact:

TOTEMA – Prozesse. Neu gedacht.
Owner: Slaveyko Kirilov Nikolov
An der Leite 19
96193 Wachenroth
Germany
E-mail: contact@aiactcontentsigner.de

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