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Legal

Privacy Policy

Last updated:

This English version is provided for convenience only. In case of doubt, the German version prevails.

1.Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) for the processing of personal data on this website is:

lytra GmbH
Agnes-Pockels-Bogen 1
80992 München (Munich)
Germany

Represented by the managing directors Etienne Fieg and Benedikt Stefan Vogler
Email: info@lytra.ai
Phone: +49 15679 761600

If you have any questions about data protection or wish to exercise your rights, you can contact us at any time using these details.

2.Overview

In this privacy policy we inform you, in accordance with Art. 13 and 14 GDPR, which personal data we process when you visit our website, for which purposes and on which legal basis, and which rights you have. Personal data means any information relating to an identified or identifiable natural person (Art. 4(1) GDPR).

Our website is deliberately designed to collect as little data as possible: apart from cookieless web analytics with etracker (Section 8), we do not use tracking tools, tracking pixels, advertising or marketing cookies, or social media plugins. Fonts, program libraries and videos are delivered from our own server. Beyond etracker, a connection to third-party providers is only established if you activate the booking calendar on our demo page (Section 7) or follow an external link (Section 9).

This privacy policy applies to our website. Where we process personal data on behalf of our customers within our platform, this is governed by the data processing agreement concluded with the respective customer; in that respect, our customer is the controller.

3.Hosting and server log files

Our website is hosted by Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland (“Google Cloud”), and delivered from data centres within the European Union. We have concluded a data processing agreement with Google Cloud pursuant to Art. 28 GDPR.

Each time our website is accessed, the server automatically records information transmitted by your browser and stores it in so-called server log files:

  • IP address of the requesting device,
  • date and time of access,
  • page or file requested, amount of data transferred and HTTP status code,
  • referrer URL (the previously visited page), if transmitted,
  • browser and operating system used (user agent).

This processing is necessary to provide the website to you technically and to ensure its stability and security, in particular to detect and prevent attacks and misuse. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in the purposes mentioned. The data is not combined with other data sources or analysed for marketing purposes. Log files are deleted after 30 days at the latest, unless individual entries are required for longer to investigate a specific security incident.

Google Cloud belongs to the Google group, whose parent company Google LLC is based in the USA. Access from the USA can therefore not be completely ruled out. Google LLC is certified under the EU-US Data Privacy Framework; in addition, Google has concluded the European Commission’s standard contractual clauses (see Section 10).

4.Cookies and browser storage

We do not use cookies for analytics, advertising or marketing purposes on our website; our web analytics with etracker also works without cookies (Section 8). We only use your browser’s session storage (sessionStorage) for one technically necessary entry:

  • lytra:langScroll – briefly remembers your reading position when you switch between the German and English versions, so that you can continue reading at the same point; the entry is deleted immediately after the page change.

This entry contains no identifiers that could be used to identify you or track you across websites. It is not transmitted to us or to third parties and is deleted automatically as soon as you close the browser tab or window. Storing it is strictly necessary to provide the digital service you have expressly requested and therefore does not require consent (Section 25(2) no. 2 of the German Telecommunications Digital Services Data Protection Act, TDDDG). Where personal data is processed in this context, the legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in a user-friendly presentation of our website.

HubSpot cookies are only set if you have consented to loading the booking calendar (Section 7). You can view and delete stored entries at any time in your browser settings.

5.Fonts, program libraries and videos

The font used on our website and the JavaScript libraries we use (including Lenis for scrolling behaviour and lottie-web for animations) are loaded locally from our server. No connection is established to Google Fonts or to any other external content delivery network; the only externally loaded script is the etracker analytics script (Section 8).

The video featuring a statement from our CEO on the home page is likewise provided from our own server; video platforms such as YouTube are not embedded. Retrieving it only generates the server log data described in Section 3.

6.Contact form and contacting us

If you send us an enquiry via the contact form, we process the data you provide: your business email address and your company (mandatory fields) and – optionally – your first and last name, company size and your message. If you contact us by email or phone, we process the data you share with us in doing so.

We use this data exclusively to handle your enquiry, to get in touch with you and – if requested – to arrange a product demonstration. The legal basis is Art. 6(1)(b) GDPR where your enquiry is aimed at concluding or performing a contract, and otherwise Art. 6(1)(f) GDPR; our legitimate interest lies in the efficient handling of enquiries addressed to us and in maintaining our business contacts. As our offering is directed exclusively at businesses, this generally concerns contact persons at our existing or prospective business customers.

The data is transmitted in encrypted form. Where we use service providers to handle enquiries (for example for email or customer relationship management), they are contractually bound by our instructions as processors. We delete your data once your enquiry has been conclusively dealt with and no further communication is expected, but no later than twelve months after the last contact, unless a contract is concluded. Statutory retention obligations, for example for commercial and business letters (Section 257 of the German Commercial Code, HGB; Section 147 of the German Fiscal Code, AO), remain unaffected.

You are neither legally nor contractually obliged to provide your data. However, without an email address and your company we cannot process your enquiry.

7.Demo booking via HubSpot Meetings

On our “Request a demo” page you can book an appointment for a product demonstration directly via an embedded booking calendar. The calendar is provided by HubSpot, Inc., 2 Canal Park, Cambridge, MA 02141, USA; the contracting party for customers in the European Economic Area is HubSpot Ireland Limited, One Sir John Rogerson’s Quay, Dublin 2, Ireland (together “HubSpot”).

The calendar is only loaded after you have consented to this by clicking “Load calendar” on that page. When it loads, a connection is established to HubSpot servers (meetings-eu1.hubspot.com and static.hsappstatic.net); in the process, in particular your IP address, browser and device information and the address of the referring page are transmitted to HubSpot. HubSpot sets cookies and similar technologies (e.g. “__hstc”, “hubspotutk”, “__hssc” and “__hssrc”) to provide the calendar and to recognise returning visitors. Depending on the cookie, they are stored from the end of the browser session up to six months.

If you book an appointment, we process the data you enter via HubSpot – in particular your first and last name, email address, the selected time slot and any further voluntary information such as your company or your request – in order to arrange the appointment, send you a confirmation and invitation, and prepare the demo.

The legal basis for loading the calendar and setting the cookies is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). Your booking data is processed to take pre-contractual steps at your request (Art. 6(1)(b) GDPR) and on the basis of our legitimate interest in organising appointments efficiently (Art. 6(1)(f) GDPR). Your consent is not stored and applies only to that page view; without a new click, the calendar is not loaded again. You can delete cookies that have already been set in your browser settings at any time. You can of course also arrange an appointment without HubSpot by emailing info@lytra.ai.

HubSpot processes the booking data on our behalf under a data processing agreement (Art. 28 GDPR) and stores it in data centres in the EU. However, a transfer to HubSpot, Inc. in the USA or access from there cannot be ruled out. HubSpot, Inc. is certified under the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023, Art. 45 GDPR); in addition, the European Commission’s standard contractual clauses are in place (Art. 46(2)(c) GDPR). We delete the booking data as soon as it is no longer required for arranging the appointment and the subsequent communication, but no later than twelve months after the appointment, unless a contract is concluded or statutory retention obligations apply. Further information is available in HubSpot’s privacy policy.

8.Web analytics with etracker

To analyse and improve the use of our website, we use the web analytics service etracker, provided by JustRelate Deutschland GmbH, Kitzingstraße 15, 12277 Berlin, Germany (“etracker”).

We use etracker in cookieless mode: no cookies are set and no information is stored on or read from your device for analytics purposes. When you access our website, the etracker script is loaded from etracker servers (code.etracker.com), and usage data is transmitted to etracker – in particular the pages visited, date and time of access, the referring page, browser and operating system, screen resolution and your IP address. Your IP address is shortened immediately and is not stored in full; the data is not used to identify you and is not combined with other data sources or merged across different websites. Our evaluations are based exclusively on anonymised data.

The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in the needs-based design, statistical analysis and continuous improvement of our website. etracker processes the data on our behalf under a data processing agreement (Art. 28 GDPR), exclusively on its own servers within the European Union; data is not passed on to third parties or used by etracker for its own purposes.

You can object to this processing at any time (Section 13), for example by sending an informal message to info@lytra.ai. You can also prevent the analysis by blocking JavaScript or the domain code.etracker.com in your browser or with a content blocker. Further information is available in etracker’s data protection information.

9.External links

Our website contains links to external services, in particular to LinkedIn, YouTube, our careers portal at Personio, High-Tech Gründerfonds (HTGF) and Google Maps. These are simple hyperlinks; no plugins, scripts or content from these providers are embedded in our website. Data is only transmitted to the respective provider when you click the link and visit its website.

The respective provider is solely responsible for data processing on those websites; please refer to its privacy information. For applications submitted via our careers portal, the privacy information for applicants provided there applies.

10.Recipients and transfers to third countries

Within our company, only those persons who need access to your data to fulfil the purposes described are granted such access. External recipients are the service providers named in this policy (Google Cloud as hosting provider, etracker for web analytics, HubSpot for the booking calendar) and, where applicable, further processors, for example for email and IT operations, whom we have carefully selected and contractually bound pursuant to Art. 28 GDPR. Beyond this, we only disclose data where we are legally obliged to do so or where this is necessary for the establishment, exercise or defence of legal claims. We do not sell personal data.

Data is only transferred to countries outside the EU or EEA to the extent described in this policy and where the requirements of Art. 44 et seq. GDPR are met – in particular on the basis of an adequacy decision of the European Commission (for the USA: the EU-US Data Privacy Framework) or standard contractual clauses. You can request a copy of the appropriate safeguards using the contact details in Section 1.

11.Retention period

We store personal data only for as long as necessary for the respective purpose, unless you have consented to longer storage or statutory retention periods – in particular under commercial and tax law of up to ten years – require longer storage. The specific periods are set out in the sections above. Once the purpose no longer applies or the periods have expired, the data is routinely deleted or, where deletion is not possible, its processing is restricted.

12.Your rights

Under the GDPR, you have the following rights vis-à-vis us with regard to personal data concerning you:

  • 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 to processing (Art. 21 GDPR, see Section 13).

You may withdraw any consent you have given at any time with effect for the future (Art. 7(3) GDPR); this does not affect the lawfulness of processing carried out before the withdrawal. An informal message to the contact details given in Section 1 is sufficient to exercise your rights.

Without prejudice to any other remedy, you also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the member state of your habitual residence, place of work or place of the alleged infringement. The authority responsible for us is the Bavarian Data Protection Authority (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA), Promenade 18, 91522 Ansbach, Germany, www.lda.bayern.de.

13.Right to object under Art. 21 GDPR

Where we process your personal data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you have the right to object to this processing at any time on grounds relating to your particular situation. We will then no longer process your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

If your data is processed for direct marketing purposes, you may object to this processing at any time without giving reasons; your data will then no longer be used for this purpose. Please send your objection to info@lytra.ai.

14.Data security

For security reasons, our website uses SSL/TLS encryption. You can recognise an encrypted connection by “https://” in the address bar and the padlock symbol in your browser. When encryption is active, the data you transmit to us cannot be read by third parties. In addition, we take appropriate technical and organisational measures pursuant to Art. 32 GDPR to protect your data against loss, manipulation and unauthorised access, and continuously adapt them to the state of the art.

15.No automated decision-making

We do not use automated decision-making, including profiling, within the meaning of Art. 22 GDPR.

16.Changes to this privacy policy

We will amend this privacy policy if our website, the services we use or the legal requirements change. The version published on this page at any given time applies.