Privacy Policy

Last updated: January 2025

1. Data Controller

The data controller within the meaning of the General Data Protection Regulation (GDPR) and other applicable data protection laws is:

Doblyx AI GmbH
Schildbach 42
8230 Hartberg
Austria

Represented by: Eric Dobler (Managing Director)
Email: office@doblyx.com
Phone: +43 676 5800866

2. General Information on Data Processing

The protection of your personal data is important to us. We process personal data only insofar as it is necessary to provide a functional website and our content and services. Personal data is processed only with the user's consent or when processing is permitted by law.

3. Your Rights as a Data Subject

You have the following rights regarding your personal data processed by us:

  • Right of Access (Art. 15 GDPR): You may request information about your personal data processed by us.
  • Right to Rectification (Art. 16 GDPR): You may request the correction of inaccurate or the completion of incomplete personal data stored by us.
  • Right to Erasure (Art. 17 GDPR): You may request the deletion of your personal data stored by us, unless processing is required for exercising the right of freedom of expression, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims.
  • Right to Restriction of Processing (Art. 18 GDPR): You may request the restriction of processing of your personal data.
  • Right to Data Portability (Art. 20 GDPR): You may request to receive your personal data in a structured, commonly used, and machine-readable format or to have it transmitted to another controller.
  • Right to Object (Art. 21 GDPR): You may object to the processing of your personal data at any time if the processing is based on Art. 6(1)(e) or (f) GDPR.
  • Right to Withdraw Consent (Art. 7(3) GDPR): You may withdraw your consent at any time. The lawfulness of processing carried out on the basis of consent before its withdrawal is not affected.

Right to Lodge a Complaint with a Supervisory Authority (Art. 77 GDPR):
Austrian Data Protection Authority
Barichgasse 40-42, 1030 Vienna, Austria
Email: dsb@dsb.gv.at
Website: www.dsb.gv.at

4. Hosting and Content Delivery

4.1 Website Hosting (GoDaddy)

Our website is hosted by GoDaddy. The provider is GoDaddy Operating Company, LLC, 2155 E. GoDaddy Way, Tempe, AZ 85284, USA.

When you visit our website, the following data is automatically collected (server log files): IP address of the requesting device, date and time of the request, time zone difference to GMT, content of the request (specific page), access status/HTTP status code, data volume transferred, referrer URL, browser used, operating system and its interface, and language and version of the browser software.

Processing is based on Art. 6(1)(f) GDPR. Our legitimate interest lies in the technical provision and security of our website.

GoDaddy is certified under the EU-US Data Privacy Framework.

4.2 Application Hosting (Hostinger)

For our automation solutions and services, we use the hosting services of Hostinger International Ltd., 61 Lordou Vironos Street, 6023 Larnaca, Cyprus.

Processing is based on Art. 6(1)(b) GDPR (contract performance) and Art. 6(1)(f) GDPR (legitimate interest in the secure and efficient provision of our services).

4.3 Website Creation (Framer)

Our website was created with Framer and is partially delivered via their infrastructure. The provider is Framer B.V., Rozengracht 207B, 1016 LZ Amsterdam, Netherlands.

When using Framer, technical data such as IP address and browser information may be processed. Processing is based on Art. 6(1)(f) GDPR.

5. SSL/TLS Encryption

This website uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content. You can recognize an encrypted connection by the browser address bar changing from "http://" to "https://" and by the lock icon in your browser bar.

6. Contact

When you contact us by email or phone, the data you provide (e.g., name, email address, phone number, content of your inquiry) is stored by us to process your request.

The legal basis for processing is Art. 6(1)(b) GDPR (pre-contractual measures or contract performance) and Art. 6(1)(f) GDPR (legitimate interest in processing inquiries).

The data will be deleted once it is no longer necessary for the purpose of its collection and no statutory retention obligations apply.

7. Cookies and Consent Management

7.1 General Information on Cookies

Our website uses cookies. Cookies are small text files stored on your device by your browser. They help make our website more user-friendly and effective.

Some cookies are "technically necessary" and are set automatically as they are required for the website to function. Other cookies (e.g., for analytics or marketing) are only set with your consent.

7.2 Cookiebot (Consent Management)

We use Cookiebot to manage your cookie preferences. The provider is Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark.

Cookiebot stores your consent so that it does not need to be requested again on each page visit. The following data is processed: your IP address (anonymized), date and time of consent, browser information, the page URL, and an anonymous random key.

The legal basis is Art. 6(1)(c) GDPR (legal obligation to document consent).

8. Our Services — AI-Powered Lead Qualification and Automation

8.1 Overview of Our Services

We offer AI-powered automation solutions for businesses, particularly in the area of lead generation and qualification. Our services include automated processing of inquiries from various sources, qualification through AI-powered phone calls, and feedback of qualification data to advertising platforms for campaign optimization.

8.2 n8n Workflow Automation

We use n8n, a workflow automation platform, for automating business processes. It is operated on servers at Hostinger.

The following personal data may be processed as part of workflow automation: contact data (name, email, phone number), inquiry data from forms, conversation logs and qualification results, and processing metadata.

The legal basis is Art. 6(1)(b) GDPR (contract performance with our business clients) and Art. 6(1)(f) GDPR (legitimate interest of our clients in efficient processing of inquiries).

8.3 Voicery — AI-Powered Phone Assistant

We offer Voicery, an AI-powered phone assistant that conducts automated phone calls for lead qualification. When using Voicery, the following data is processed:

Phone number of the called party, voice recordings of conversations, transcriptions of conversations, qualification results and extracted information, and metadata such as timestamps, conversation duration, and call status.

Important Notice: When you are called by our system, you will be informed at the beginning of the call that it is an AI-powered conversation and that the call is being recorded. You have the option to end the call at any time.

The legal basis is Art. 6(1)(f) GDPR (legitimate interest of our business clients in efficient qualification of inquiries).

8.4 Data Storage and CRM Integration

We use the following services for storing and managing processed data:

  • HubSpot: Contact and qualification data is stored in HubSpot for customer relationship management. The provider is HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA. HubSpot is certified under the EU-US Data Privacy Framework.
  • Google Sheets: Google Sheets may be used for structured data storage and processing. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google is certified under the EU-US Data Privacy Framework.

The legal basis is Art. 6(1)(b) GDPR (contract performance). We conclude data processing agreements pursuant to Art. 28 GDPR with our business clients.

9. Lead Sources and Webhook Integrations

9.1 Real Estate Portals

We process inquiries received through real estate portals on behalf of our business clients.

  • ImmobilienScout24: Provider is Immobilien Scout GmbH, Invalidenstraße 65, 10557 Berlin, Germany. Processing is based on the consent given by the interested party when submitting the inquiry on the portal.
  • willhaben: Provider is willhaben internet service GmbH & Co KG, Landstraßer Hauptstraße 97-101, 1030 Vienna, Austria. Processing is based on the consent given by the interested party when submitting the inquiry on the portal.

Data transmitted through these portals typically includes: name, email address, phone number, message content, and information about the requested property.

9.2 Social Media Advertising Platforms

We also process inquiries generated through lead forms on social media platforms on behalf of our business clients:

  • Meta (Facebook/Instagram) Lead Ads: Provider is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Data processed: name, email address, phone number, and any additional information requested in the form. Legal basis is Art. 6(1)(a) GDPR (consent of the user when filling out the lead form).
  • LinkedIn Lead Gen Forms: Provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Data processed: name, email address, phone number, company, position, and any additional profile information. Legal basis is Art. 6(1)(a) GDPR (user consent).

10. Advertising and Conversion Tracking

10.1 Google Ads and Conversion Tracking

We use Google Ads to draw attention to our services through advertisements on external websites. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads also uses conversion tracking. When you click on an ad served by Google, a conversion tracking cookie is set. Additionally, conversion data (e.g., qualified leads) may be reported back to Google Ads to optimize advertising algorithms. This is done in pseudonymized form.

Legal basis is Art. 6(1)(a) GDPR (consent via the cookie banner). Google is certified under the EU-US Data Privacy Framework.

10.2 Meta Pixel (Facebook/Instagram)

We use the Meta Pixel (formerly Facebook Pixel). The provider is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

The Meta Pixel enables tracking user behavior after they were redirected to our website by clicking on a Facebook or Instagram ad. We also use the Meta Conversions API to transmit conversion events server-side to Meta. Transmission is done in hashed form.

Legal basis is Art. 6(1)(a) GDPR (consent via the cookie banner) and Art. 6(1)(f) GDPR (legitimate interest in optimizing advertising campaigns). Meta is certified under the EU-US Data Privacy Framework.

10.3 LinkedIn Insight Tag

We use the LinkedIn Insight Tag on our website. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

The LinkedIn Insight Tag enables the collection of data about visits to our website, including URL, referrer URL, IP address, device and browser properties, and timestamps. This data is used for conversion tracking and retargeting.

Legal basis is Art. 6(1)(a) GDPR (consent via the cookie banner). LinkedIn is certified under the EU-US Data Privacy Framework.

11. Social Media Presence

We maintain online presences on the following social networks:

  • Facebook: Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.
  • Instagram: Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.
  • LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

When you visit our social media pages, data about your usage behavior is collected by the respective provider. We have no influence on the data processed by the networks.

For Facebook and Instagram, there is joint controllership pursuant to Art. 26 GDPR for the processing of Insights data.

12. Payment Processing

12.1 Stripe

We use Stripe for payment processing. The provider is Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland.

During payment transactions, the following data is transmitted to Stripe: payment amount, payment method information, name and email address, and billing address if applicable.

Legal basis is Art. 6(1)(b) GDPR (contract performance). Stripe is certified under the EU-US Data Privacy Framework.

13. Local Fonts

This website uses locally hosted fonts. No connection to external servers (such as Google Fonts) is made. The fonts are loaded directly from our server, which means your IP address is not transmitted to third parties.

14. Affiliate Programs

Our website may contain affiliate links to third-party products or services, particularly to Voicery and related services. When you click on an affiliate link, a cookie is set to enable the attribution of sales.

Legal basis is Art. 6(1)(a) GDPR (consent via the cookie banner) and Art. 6(1)(f) GDPR (legitimate interest in monetizing our content).

15. Data Security

We implement technical and organizational security measures to protect your data against manipulation, loss, destruction, or unauthorized access. Our security measures are continuously improved in line with technological developments.

Our measures include: encryption of data transmission via SSL/TLS, access restrictions to personal data, regular security updates of our systems, and pseudonymization and anonymization of data where possible.

16. Data Transfer to Third Countries

Some of the services we use are based in the USA or other third countries. The transfer of personal data to these countries is based on:

  • EU Commission Adequacy Decisions (Art. 45 GDPR): In particular, the EU-US Data Privacy Framework for US companies. This applies to: Google, Meta, LinkedIn, HubSpot, Stripe, and GoDaddy.
  • EU Commission Standard Contractual Clauses (Art. 46(2)(c) GDPR): Where no adequacy decision exists.

17. Retention Period

We store personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by statutory retention periods.

  • Contract data: For the duration of the business relationship and beyond in accordance with statutory retention periods.
  • Lead data: In accordance with the agreement with our business clients, typically until the processing purpose is achieved or until withdrawal.
  • Voice recordings: After completion of processing and qualification, unless longer retention is required.
  • Statutory retention periods: 7 years for business documents pursuant to § 212 UGB (Austrian Commercial Code) and 7 years for tax-relevant documents pursuant to § 132 BAO (Austrian Federal Fiscal Code).

18. Data Processing on Behalf

Insofar as we process personal data on behalf of our business clients, we act as a data processor within the meaning of Art. 28 GDPR. In these cases, we conclude data processing agreements with our business clients that govern the data protection obligations.

In these cases, the business clients remain the data controllers within the meaning of the GDPR for the data of their end customers and prospects.

19. Automated Decision-Making

As part of our lead qualification process, data is processed by AI systems and qualification results are generated. This automated processing serves the pre-qualification of inquiries and has no direct legal effects on the data subjects.

The final decision on further processing of an inquiry lies with our business clients and their employees.

20. Changes to This Privacy Policy

We reserve the right to update this privacy policy to reflect changes in the legal situation or changes to our services. The current version is always available on our website.

21. Contact for Data Protection Inquiries

For questions about data protection or to exercise your rights, please contact:

Doblyx AI GmbH
Attn. Eric Dobler
Schildbach 42
8230 Hartberg
Austria
Email: office@doblyx.com
Phone: +43 676 5800866