This is a draft version currently under legal review; changes are possible.
Porcine Hosting Solution LLC, St. Petersburg Street 1, 0102 Tbilisi, Georgia. Contact for privacy requests: business@schweinerei.xyz. As we offer goods/services to persons in the EU, the GDPR applies under Art. 3(2). Whether we must appoint a data protection officer (Art. 37 GDPR) is currently under review.
This site is built around radical anonymity: no user account, no e-mail address required to use it, no IP-based tracking within the application.
Purchases of digital content are processed by our payment and distribution partner Paddle.com Market Limited. Processing during checkout (payment, invoice, tax, refunds) is governed by Paddle's own privacy notice (paddle.com/legal/privacy). We only receive the data from Paddle that is necessary for activation and support, kept to the required minimum.
Legal basis: Art. 6(1)(b) GDPR (contract performance); retention for tax/commercial-law reasons Art. 6(1)(c) GDPR, each only as long as legally required.
Recipients: Paddle and its payment service providers.
Third country: Paddle is based in the United Kingdom; transfers rely on appropriate safeguards (e.g. standard contractual clauses) where legally required.
After payment is confirmed we automatically grant access to the purchased content. We only process the data necessary for activation (e.g. transaction identifier, product, timestamp) on the principle of data minimisation.
Legal basis: Art. 6(1)(b) GDPR. Retention: for the duration of the access right plus statutory warranty periods.
Files may contain an individual watermark linked to your order to protect against unauthorised sharing. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in protecting the content).
Certain areas of the site display publicly visible entries (text, timestamp, language). No IP address is stored. Do not enter personal data about yourself or others in free-text fields – entries are visible to all visitors.
Legal basis: Art. 6(1)(f) GDPR (operating the service); where you voluntarily publish content, additionally Art. 6(1)(a) GDPR. Recipients: the public (accessible worldwide) and our hosting provider.
The chatbot answers user questions automatically. Inputs and outputs are stored without linking them to a person. Processing runs through external providers for hosting, the language model and knowledge search; data processing agreements under Art. 28 GDPR are or will be in place with these providers.
Legal basis: Art. 6(1)(b) and (f) GDPR. Third country: the providers used may be based outside the EU; transfers rely on appropriate safeguards where legally required.
AI transparency: the chat makes clear that you are talking to an AI system (Art. 50 AI Act). Do not enter sensitive personal data here either.
Texts and user inputs may be automatically translated into other languages. The same principles as under point 4 apply (external processing, data minimisation).
Legal basis: Art. 6(1)(b)/(f) GDPR.
Chat and activation services as well as the static site are operated via external hosting providers; these include, among others, a service acting as a front layer (proxy/CDN) and an object storage for media and downloads (e.g. trailers, purchased files, via time-limited link). When you open the site, your browser also sends a status request to our interface at an external hosting provider. Server/connection data (e.g. the IP address in access logs) can technically occur; the application itself does not store IP addresses.
Legal basis: Art. 6(1)(f) GDPR (secure operation). Third country: a hosting provider used may be based in the USA; transfers rely on appropriate safeguards where legally required. Data processing agreements under Art. 28 GDPR are or will be in place with our hosting providers.
We do not use cookies or track individual visitors, so no cookie banner is required. We do not carry out any reach measurement or analysis of user behaviour. Merely visiting and using the site (including the chat) does not load any third-party scripts or fonts; the libraries we use (e.g. for text rendering) are served from our own domain.
Local storage in your browser: The site stores entries in your browser's storage (localStorage) on your device that are needed for the service you asked for: language setting, display and audio settings, your progress and chat history, an access key after a purchase, and a randomly generated User ID once you open it in the "About" area. These entries stay on your device and are not used for advertising or analytics. Exception: a chat identifier (conversation ID) is sent to our server together with your chat questions so the conversation stays connected (see section 4). The User ID is currently not transmitted to the server. You can delete everything at any time via "[ forget ]" in the "About" area or in your browser settings; deleted purchases can then only be restored with the transaction ID from your receipt email. Legal basis: Section 25(2) no. 2 TDDDG (strictly necessary for the service you requested) and Art. 6(1)(b), (f) GDPR.
Purchase: Only when you click "Buy" or "Buy now" do we load the checkout of our payment partner Paddle (Paddle.com Market Limited, United Kingdom). This loads scripts from Paddle (cdn.paddle.com, buy.paddle.com) and from the services it embeds for fraud prevention, error monitoring and billing analytics (e.g. public.profitwell.com, o522631.ingest.sentry.io), and your IP address is transmitted to them. Paddle may use its own cookies or local storage access in the checkout that are technically necessary for payment processing; Paddle's own privacy notices apply (paddle.com/legal/privacy). After the purchase, access is activated through our interface (see point 2).
Legal basis: The checkout is loaded only at your explicit request (click on the buy button); in our assessment, storage access in the checkout is strictly necessary to provide the service you requested (Section 25(2) no. 2 TDDDG), and the data processing is based on Art. 6(1)(b) GDPR (pre-contractual steps/contract performance). In our assessment no consent is required.
Recipients/third country: Paddle and the services embedded by Paddle; Paddle is based in the United Kingdom, individual embedded services may be based in the USA. Transfers rely on appropriate safeguards (e.g. adequacy decision, standard contractual clauses) where legally required.
You have the right to access, rectification, erasure, restriction of processing, objection and data portability (Art. 15–21 GDPR) and the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). Because we deliberately design many features to be anonymous, identifying a request may be limited in individual cases (Art. 11 GDPR). Contact for privacy requests: business@schweinerei.xyz.