Version datenschutz-2026-10-24-entwurf · As of 24 October 2026 · Deutsche Fassung (maßgeblich)
This translation is for information only. The German version is legally binding: Datenschutzerklärung
Privacy Policy
For prontoweb.io, the WhatsApp conversation with ProntoWeb, the payment page pay.prontoweb.io and the “Website subscription”.
1. Controller
tiro UG (haftungsbeschränkt)
Solinger Straße 3, 10555 Berlin, Germany
Managing director: Paul Kunhardt
Email: prontoweb@tiro-agent.com
2. In short
- This site sets no cookies and uses no tracking. That is why there is no cookie banner.
- When you visit the site, technically necessary access data arises (section 3).
- When you write to us on WhatsApp, we process your messages to design and maintain your website. In the conversation, an AI assistant replies (section 4).
- When you pay, payment runs through Stripe. We do not see your card or account details (section 5).
- We send contract emails through Resend (section 6).
- We delete your conversation 90 days after the end of the contract (section 7).
3. Visiting this site (hosting)
The site is delivered by Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. When you visit, Vercel processes technically necessary data on our behalf: IP address, time, requested address, browser and operating system identifier. This data serves to deliver and secure the site (Art. 6(1)(f) GDPR) and is kept by Vercel only briefly. We have a data processing agreement with Vercel; transfers to the USA are based on the EU Standard Contractual Clauses and the EU-US Data Privacy Framework, in which Vercel participates.
We serve fonts ourselves. Visiting the site does not open a connection to any other provider.
4. The WhatsApp conversation
The button “Write on WhatsApp” opens WhatsApp on your device with a prepared message. Data reaches us only once you send it. From then on we process:
- your phone number and your WhatsApp display name,
- the content of your messages, including voice messages, photos, videos and documents you send us,
- the information you give about your business, club or congregation (name, location, services, opening hours, contact persons, images), and the information for your legal notice.
The purpose is what you want from us: an initial conversation, creating the draft of your website, publishing the website and then maintaining it according to your instructions. The legal basis is the initiation and performance of the contract with you (Art. 6(1)(b) GDPR). The content you approve for your website appears publicly on your website — that is its purpose.
4.1 WhatsApp / Meta
WhatsApp is operated by WhatsApp Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (part of Meta). WhatsApp’s privacy terms apply to the transmission of your messages. We use the WhatsApp Business Platform; WhatsApp receives metadata of the communication (numbers, times); the content is end-to-end encrypted between your device and our service provider.
4.2 Message transmission
The connection to WhatsApp runs through Twilio Inc., 101 Spear Street, San Francisco, CA 94105, USA, as processor. Twilio forwards messages and media between WhatsApp and our system. Transfer to the USA on the basis of the EU Standard Contractual Clauses.
4.3 Processing by AI models
In the conversation, an AI assistant of ProntoWeb replies. Texts, image descriptions and the design of your website are also created with language models. If the assistant cannot proceed, or if you ask for it, a person from our team looks at the conversation.
For this, your messages and images are processed by language models of Anthropic, PBC, 548 Market St, San Francisco, CA 94104, USA. We reach the models directly at Anthropic or via the AI Gateway of Vercel Inc. (address in section 3). Anthropic and Vercel act as processors; according to its terms, Anthropic does not use the data to train its models. Transfer to the USA on the basis of the EU Standard Contractual Clauses.
Mistral AI SAS, Paris, France, transcribes voice messages into text as processor. Processing stays in the EU.
Contract, payment, cancellation and deadlines are not decided by the language model but by our program according to fixed rules; the messages about them are fixed texts.
4.4 Storage and operation
We store the conversation history, information about your business, the photos and files you send us, and your customer account with Supabase Inc. on servers in Frankfurt am Main (EU). Our programs that receive and answer messages run at Railway Corp. (USA) on servers in the Netherlands (EU). Vercel delivers the draft and the finished website. All three act as processors; insofar as data reaches the USA, on the basis of the EU Standard Contractual Clauses.
Draft pages load an invisible image from our server at Railway. This tells us whether the draft link was opened. Your finished website does not contain this image.
If our system reports a disruption, our team learns about it through Slack (Slack Technologies, USA). The name of your business may appear, but not the content of your messages.
5. Payment
If you pay for your website, payment runs through Stripe Payments Europe, Limited, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland, on our payment page pay.prontoweb.io. You enter your card or account details directly with Stripe; we do not see them. Stripe tells us whether, when and how much was paid, together with your name, your email address, your billing address and, if you provide it, your VAT ID. We also store which version of the terms you agreed to, and when. Invoices and the customer portal, where you can cancel, are also provided by Stripe. The legal basis is the performance of the contract (Art. 6(1)(b) GDPR) and our obligation to retain invoices (Art. 6(1)(c) GDPR). For fraud prevention and legal obligations, Stripe also processes payment data as an independent controller; the Stripe privacy policy applies to that.
6. Emails about the contract
Contract emails are sent through Resend (Plus Five Five, Inc., USA) as processor, from the service’s EU region. These are the confirmation of the contract with the terms in the accepted version and the cancellation policy, the confirmation of a cancellation, and notices of changes to price or terms. For this, Resend processes your email address, the content of the email and delivery data (time, delivery or error). We do not use your email address for advertising. The legal basis is the performance of the contract and of our statutory information obligations (Art. 6(1)(b) and (c) GDPR). Insofar as data reaches the USA, on the basis of the EU Standard Contractual Clauses.
7. How long we store data
- Conversation: as long as your contract runs, the conversation remains stored. We delete it 90 days after the end of the contract. If no contract is concluded, we delete it 90 days after the end of the conversation.
- Website content: when the contract ends, the website goes offline. Up to 30 days afterwards we send you your texts and images on request; after that we delete the website’s data.
- Invoices and accounting records: ten years, as required by the German Fiscal Code (Abgabenordnung).
At your request we delete earlier, unless a statutory retention obligation binds us — a message on WhatsApp or by email is enough.
8. The visitors to your website
You are responsible for the data of the visitors to your website; we process it on your behalf under the Data Processing Agreement. A live website sets no cookies, has no form and builds no visitor profiles. We create your privacy policy from your information.
9. Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on Art. 6(1)(f) (Art. 21). Just write to us — on WhatsApp or by email. You can also lodge a complaint with a data protection supervisory authority; the authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59–61, 10555 Berlin.
10. Changes
If our service providers or processes change, we update this policy beforehand. Every version carries an identifier and remains available at its address; the version published at prontoweb.io/datenschutz applies.