Privacy at Botti.

This is a translation for your convenience. In case of doubt, the German version is authoritative.

1. Controller

Coolblack GmbH
Südfeldwiese 14
32107 Bad Salzuflen
Germany
Email: info@coolblack.gmbh

2. Website

When you visit this website, the web server processes technically necessary connection data, in particular IP address, time, requested address, browser identification and response status. This serves secure provision and fault analysis (legal basis: Art. 6(1)(f) GDPR). The logs are overwritten automatically after a short time. The server is located in a data centre in Germany. The website uses no advertising trackers, no analytics cookies and no externally loaded fonts.

3. Local app data

Botti works without registration; there is no user account with a name or email address. On the device, Botti stores among other things:

• HTML apps you created or imported, including title and editing state,
• data from Botti's controlled data store, kept separately per app,
• permission decisions for native app tools,
• local AI usage figures such as requests and reported tokens,
• a device-bound, non-transferable session identifier for the secure Botti platform.

This local data is not transmitted to Coolblack merely by being stored. It can be removed using the app's built-in functions or by deleting the app.

4. AI features: Botti server and Microsoft Azure

For the AI chat and the Workshop, the app sends your input and the context needed to process it to the Botti server (located in Germany) with transport encryption. When improving an app, the context may also contain the current HTML state. The Botti server forwards the request to our processor for an answer:

Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland — through the Microsoft Azure AI Foundry service.

The AI models used there are operated and hosted exclusively by Microsoft. We may adjust which model generation answers in order to improve the service — this changes nothing about Microsoft as our processor or the commitments in this policy. Important: no data is transmitted to the respective model makers.

The following applies:

• Only the request text and the technical context are transmitted. Your name, account data, device identifiers or your device's IP address are not transmitted; Microsoft sees only the Botti server as the sender.
• The Botti platform stores neither inputs nor AI answers. Only technical billing figures are stored (token amounts, model, cost value, time) under a random, pseudonymous account identifier.
• The credentials for the AI service are held exclusively in encrypted form on the Botti server, never in the app.

Where processing takes place. Our AI resource is located in the Azure region Sweden. For the regular case — chat, planning, building apps and currently also the repair stage — we use data zone deployments: those requests are processed within the EU data zone. Individual processing stages may switch to globally deployed variants; such requests may also be processed by Microsoft outside the EU. In either case the resource's data storage remains in Sweden. For transfers outside the EU, the European Commission's Standard Contractual Clauses apply, together with the commitments in the Microsoft Product Terms (Data Protection Addendum); Microsoft is additionally certified under the EU-US Data Privacy Framework.

The legal basis for the AI processing is Art. 6(1)(b) GDPR (provision of the feature you use); processing takes place as processing on our behalf under Art. 28 GDPR. Even so, please do not enter sensitive data or personal data of third parties into AI inputs. An app you built yourself can request Botti AI only through the controlled native bridge and after a separate app permission.

Your permission in the app. Before the first AI request, the app explains on a dedicated card what is transmitted and to whom, and explicitly asks for your permission. Nothing is transmitted without your consent; local features remain usable. You can withdraw your permission at any time in Settings under “Privacy & Legal → AI transmission” — the app will then ask again before the next AI use.

5. Speech and microphone

For voice input, Botti uses Apple's Speech framework and the device microphone; recognition happens on the device as far as the system supports it. Depending on device, language and system setting, Apple may process speech data for recognition. Botti starts recording only after the iOS permission and a deliberate user action.

6. Camera, photos and location

Apps you build yourself receive no free device access. They can only request declared Botti tools. Botti first shows an app-specific explanation; afterwards, iOS may additionally ask for a system permission. The data captured or selected is made available to the running app for the requested processing and stays on the device. A location request is limited to the current location while in use.

7. Public internet and map data

With its own permission, a built app can retrieve public data through the controlled Botti server. Direct network access from the app, internal addresses and credentials in a data address are blocked. For nearby places, Botti can query OpenStreetMap through an Overpass service; search criteria, radius and, where applicable, the current coordinate are transmitted to that service. The external source receives Botti's server address, not your device's IP address.

Botti does not permanently store coordinates or answers from this data tool. To relieve external sources, results may be cached briefly in memory. The built app must display the respective source. Completeness, accuracy and terms of use of public data are the responsibility of the respective provider.

8. Private handover and Botti Energy

During a private export, no credentials, permissions, AI histories, local app data or usage figures are transferred. For the optional handover bonus, the Botti server processes only a random transfer ID, pseudonymous installation identifiers, the time and a confirmation of a first active use protected by Apple App Attest. The content of the app handed over and any inputs within it are not transmitted for the bonus check.

The Botti Energy account is kept server-side under a random account identifier. What is accounted for is the amount of energy, technical token values, cost value, type of use and time (legal basis: Art. 6(1)(b) GDPR). The internal administration shows only aggregated statistics — no inputs, answers, app titles or device identifiers.

Handover to a nearby device. You can hand an app you created directly to another device near you. To do so, Botti looks over the local network (Wi-Fi and Bluetooth) for other Botti installations expecting a handover at that same moment; iOS asks you for local network permission the first time. The app is transferred directly and encrypted from device to device. It is never stored on our servers and we cannot see its content; we only learn that a transaction number has been redeemed. Botti is visible to other devices only while a handover is actually in progress.

Your name during the handover. If you are signed in to Game Center, your display name there is transmitted to the receiving device so the other person can see whom the app came from. Without a Game Center sign-in, the handover stays anonymous. The name is stored only locally on the receiving device and is not written into the app itself: if that person later hands the app on, your name does not travel with it.

Reporting problematic apps. Apps handed over come from the person who created them. As we neither store nor distribute them, we cannot review content in advance. Using “Report app”, you can point us to problems by email; we follow up on every report.

9. Crash reports (optional)

If an app you built crashes, Botti may offer to send us a technical crash report. This only happens with your explicit consent (toggle in the crash notice or in Settings; default: off). A report contains technical details only: name and version of the affected app, the error message including the most recent script errors, device model, iOS version, a low-memory indicator and the time. It contains no inputs, no content of your apps and no account data; the report is stored without any link to your pseudonymous account identifier. Its sole purpose is debugging and improving the Workshop. The legal basis is Art. 6(1)(a) GDPR (consent); you can withdraw it at any time via the toggle in Settings with effect for future reports. If you choose to send the report, the subsequent repair of the crashed app is free of charge.

10. Game Center

Taking part in the Botti leaderboards is voluntary and switched off by default. If you switch it on, Apple's Game Center signs you in and we transmit three values to Apple: the number of apps you have handed over, the energy returned as a result and the ratio between the two (efficiency). We transmit no app content, no names and no device identifiers. Which player name appears next to your result is up to you in Game Center; Apple is independently responsible for that service. If you switch participation off again, all transmissions end immediately. The legal basis is Art. 6(1)(a) GDPR (your consent by switching participation on).

11. Retention and deletion

Inputs and AI answers are not stored on the Botti platform. Server-side security challenges expire after a few minutes, energy reservations after roughly 15 minutes. Energy and billing entries are kept permanently under the pseudonymous account identifier so the balance remains traceable; for future purchases, statutory retention obligations may apply in addition. You delete local data using the app's functions or by deleting the app; that also forfeits access to the pseudonymous account identifier. You can send deletion and access requests to info@coolblack.gmbh at any time.

12. Your rights

Within the statutory requirements, you have in particular the rights to access, rectification, erasure, restriction, data portability and objection, as well as a right to lodge a complaint with a data protection supervisory authority. Please note: as Botti accounts are pseudonymous, we can only match a request if your device still holds the associated account identifier (Art. 11 GDPR). Requests: info@coolblack.gmbh.