Privacy Policy

Current Privacy Notice: 4 October 2026, app version 1.2.0.

This current information does not replace historical contractual documents or recorded acceptances. Earlier versioned notices remain preserved as historical documents.

This English version is provided for convenience. The German version controls.

This Privacy Notice describes personal-data processing in the Doli app, on doliapp.de, and during web purchases by business customers through Stripe Managed Payments.

At a glance

Question	Short answer
Does Doli store conversations?	No. Audio, transcript and translation are processed only for the current request (section 12).
Who processes the content?	Google Cloud Vertex AI in the EU multi-region as a processor, with zero data retention for the Doli project (sections 12 and 13).
Where are the servers?	Doli's real-time server at Hetzner in Nuremberg, accounts at Supabase in Frankfurt am Main.
Is content used for training?	No, neither by Doli nor by Google.
Does the website track visitors?	No. No analytics or marketing services (section 3).
What rights do I have?	Access, rectification, erasure and the further rights in section 17.

The sections below are authoritative; this overview only summarises them.

1. Controller

V-IZ Video-Integrationszentrum, sole proprietor Fuat Karacocuk, operating under the Doli product name

S 3, 2A, 68161 Mannheim, Germany; email: info@doliapp.de; phone: +49 1523 2756171

("Doli") is the controller for Doli's own processing described below. The separate DPA and Section 11 govern business Customer Data that Doli processes on instructions.

2. Website access

The website is hosted by Netlify, Inc. When the site is requested, technically necessary connection data may be processed, including IP address, date and time, requested address, transferred volume, status code, referrer, browser, and device information. This is necessary to deliver the site, defend against attacks, and investigate errors.

The legal basis is Article 6(1)(f) GDPR. Doli's legitimate interest is the secure and reliable operation of this offering. Doli does not create visitor profiles or run audience analytics from these data. Netlify may process data outside the European Economic Area using the transfer mechanisms identified in its contractual documentation, including adequacy decisions and EU Standard Contractual Clauses.

Doli does not maintain its own visitor or access logs. Technical hosting logs are processed only as long as required for operation, security, abuse prevention, and legal obligations; their specific retention follows the service agreed with Netlify and its technical security periods.

3. No website analytics or marketing services

doliapp.de uses no Doli analytics, advertising, heatmap, tracking, or social-media pixels. Doli creates no personalised advertising profiles and performs no cross-site tracking. When you move to the external Stripe/Link checkout or a selected sign-in provider, their own interfaces, technologies, and privacy notices apply.

4. Doli account and sign-in

Doli processes the email address, a technical Supabase user identifier (UUID), authentication and session data, and required security metadata. Email sign-in uses a time-limited one-time code. A customer account on the website exists for business customers only; they sign in there with the same Doli account and user identifier as in the app.

Where Apple or Google is selected and enabled as an optional sign-in route, Doli processes the identifier sent by that provider and—depending on the choice and availability—the name or email address. Apple or Google processes data arising from the selected sign-in flow under its own privacy notice. Choosing that sign-in route does not send Doli conversation content to the sign-in provider.

The purposes are creating and securing the account, cross-device access, purchase attribution, and providing Doli. The legal basis is primarily Article 6(1)(b) GDPR; security and abuse prevention additionally rely on Article 6(1)(f) GDPR. Account and product data are processed through Supabase. The Doli project is configured for the Frankfurt region; individual support, security, or subprocessor operations may also take place outside the EEA under the provider's contractual safeguards.

5. Language, allowance, and session metadata

Doli stores the selected app and source language, plan and entitlement status, billing periods, included minutes, used seconds, interpreting-session start and end times, and coarse technical error categories. These data are required to provide language settings, the minute allowance, restoration, and abuse prevention. The legal basis is Article 6(1)(b) GDPR; security processing additionally relies on Article 6(1)(f) GDPR.

Personal accounts receive 30 free minutes once (Section 6) and can take out Plus, Premium or Ultimate subscriptions, weekly or monthly (Section 7). All minutes of a period are available from its start; unused minutes lapse at the end of the period. Top-up minutes and yearly plans are no longer sold; top-up minutes already bought remain valid.

The current app does not ask for a usage purpose during initial setup or generate a plan recommendation from such choices. Purposes previously provided in older app versions (travel, living, work or company), past recommendations and their timestamps may still be stored in the account profile for internal, aggregate product evaluations. The basis is Article 6(1)(f) GDPR; the legitimate interest is improving usability and plan recommendations. Doli does not use these details to create advertising profiles and uses no third-party analytics SDK for this purpose. You may object on grounds relating to your particular situation by emailing info@doliapp.de. The details are processed for the duration of the account and follow the deletion rules for other profile data.

Doli does not store microphone recordings, transcripts, or translations as conversation history. Conversation content does not appear in the Doli profile.

6. Free start and abuse prevention

The 30 free minutes for personal accounts are available once per email address. To protect against automated sign-ups, Doli processes:

• a fingerprint of the email address computed with a secret key (HMAC-SHA-256). Upper and lower case, additions after a plus sign and dots in Gmail addresses are ignored. The fingerprint is pseudonymised, remains after account deletion and is deleted 24 months after the free start.
• on Apple devices, Apple DeviceCheck: the app sends a device token generated by Apple, which the Doli server passes on only to Apple. Doli asks Apple to keep two bits for this device for Doli and uses them as a counter of free starts (at most three per device and year). Apple keeps these bits; Doli stores no device identifier.
• a fingerprint of the IP address and the date computed with a secret key, to count free starts per network and day. These entries are deleted after 48 hours.

Email addresses of known disposable email services receive no free start. The legal basis is Article 6(1)(f) GDPR; the legitimate interest is preventing abuse of the free offer.

7. Purchases in the app

Personal customers buy Doli subscriptions only in the app: through the Apple App Store and, once Doli is available for Android, through Google Play. Personal customers cannot buy anything on doliapp.de. Apple and Google are independent controllers for the platform account, payment, renewal, cancellation, and refunds under their own terms and privacy notices, such as the Apple Privacy Policy. Doli receives no payment-method data.

Doli uses RevenueCat, Inc. (USA) as processor for purchase handling, activation, and restoration. For personal accounts, the app connects the account to RevenueCat after sign-in; the RevenueCat software library then processes technical customer information, product identifiers, and offerings and, for a purchase, the purchase flow. RevenueCat and Doli process the purchase status, transaction reference, period, and entitlement status together with the Doli user identifier. EU Standard Contractual Clauses apply to the transfer to the United States. The legal basis is Article 6(1)(b) GDPR; legally required records rely on Article 6(1)(c) GDPR.

8. Web purchases by business customers

Web purchases on doliapp.de through Stripe are reserved for business customers.

To prepare and attribute a web purchase, Doli processes in particular the email address and Supabase user identifier, Stripe customer reference, an internal purchase-intent UUID, plan and price reference, minute allowance, confirmed document versions and hashes, and the creation, expiry, and status details of the purchase process.

After checkout is opened or completed, Doli processes the required Stripe references for the Checkout, subscription, invoice, and event, as well as the provider status, payment status, service period, cancellation-at-period-end status, and—where applicable—information about a refund, dispute, reversal, or block. These references are bound server-side to the Supabase user identifier. Only a verified, paid, and uniquely attributable transaction creates a minute entitlement. A browser redirect alone is insufficient.

For a plan change, Doli additionally processes the previous and new plan, confirmed price and minute differences, unchanged current service period, acceptance time and separate change, invoice and schedule evidence. The original contract evidence is retained; a change does not reset minutes used.

For online cancellation and withdrawal declarations, Doli processes the name, confirmation email, contract identification, type of declaration, any cancellation reason and requested termination date, receipt time, evidence reference and delivery status. These forms require no sign-in. Evidence is stored privately; confirmations and the operator copy needed for processing are sent through STRATO. To prevent abuse, new declarations are counted using a hashed email reference within a limited time window. No location, device or conversation data is needed for this purpose.

The purposes are contract formation and performance, purchase and entitlement attribution, subscription management, fraud and duplicate-billing prevention, support, accounting, and legal evidence. The basis is primarily Article 6(1)(b) GDPR, Article 6(1)(c) GDPR for legally required evidence, and Article 6(1)(f) GDPR for security, fraud prevention, and bringing or defending claims.

Doli does not send microphone recordings, transcripts, translations, images, PDFs, or document content to Stripe or Link to process a web purchase. Such content is not included in checkout metadata. Doli does not receive full card numbers or full online-banking credentials.

9. Stripe Managed Payments and Link

Sold through Link, LLC ("Link SMP") provides Stripe Managed Payments and facilitates the transaction as merchant of record on behalf of Doli as seller. Link SMP is not the seller of the Doli service. Doli remains the controller for its own contract, entitlement, and evidence data.

During checkout, Link SMP, Stripe entities, or their Financial Partners may process in particular name, email address, phone number, billing address, payment-method data, technical online and device data, tax identification number, order date, amount, product, payment and subscription status, tax amount, refund or chargeback information, and support communications. Under the current Link Privacy Policy, a Link account is required to manage a subscription through Link. Depending on the flow offered by Link, checkout may initially be completed without signing in to Link. A tax identification number is sent to Link only if the purchaser provides it there or Link requests it under its terms. Providing it alone does not mean successful validation or automatically establish reverse charge or a tax exemption.

Under the Link terms, Stripe and Doli are independent controllers for personal data processed for their respective own purposes in connection with Link Consumer Services. Where a Stripe entity processes data solely on Doli's documented instructions, it acts as processor for that processing. Link and Stripe determine their own purposes, legal bases, and retention for their Consumer Services, merchant-of-record, payment, tax, fraud, security, support, and legal functions under the Link Privacy Policy and Stripe Privacy Center.

Link may share Order and Transaction Data with Doli so that Doli can provide the plan, support the customer, reconcile entitlements, and meet its accounting and evidence duties. Stripe and Link may also share data with affiliated entities, banks, card networks, payment providers, Financial Partners, fraud and security providers, other processors, and competent authorities where required for the transaction, their services, or legal obligations.

Stripe operates globally and states that data may be transferred to countries including the United States and India. According to the Link Privacy Policy, the mechanisms used depending on applicability include adequacy decisions, EU Standard Contractual Clauses, the UK Addendum, and other lawful mechanisms; Stripe also relies on the applicable EU-US, UK-US, and Swiss-US Data Privacy Frameworks.

Stripe does not state one fixed retention period for all Transaction Data. Its Privacy Policy states that data is retained to provide the Services and beyond that where needed for legal and regulatory duties, fraud prevention, and tax, accounting, and financial records. Stripe's or Link's own retention and rights requests are governed by their notices and contact channels.

10. Distribution rule against duplicate subscriptions

Doli processes existing plan, provider, and entitlement status, open purchase references, and service periods to block a new web or app purchase where an existing active paid Doli entitlement or unresolved purchase is detected. The purpose is to prevent unintended duplicate subscriptions and inconsistent entitlements; the bases are Article 6(1)(b) and (f) GDPR.

This check is not a promise to detect every purchase status from an external Store completely or immediately. It neither cancels nor refunds a subscription. The purchaser must also check existing subscriptions with the relevant payment or Store provider.

11. Roles and contracts for business customers

For Customer Data that a business customer directs Doli to process, Doli acts as processor or subprocessor. This includes audio, text, subtitles, images, PDFs and document content, response requests, generated translations or explanations, and routing data strictly required for that processing. The DPA and its Annexes provide the details.

Doli acts as independent controller for the Doli account, authentication, business profile, representative and role selection, contract acceptance and evidence, web or Store purchase, entitlement, allowance, reconciliation, accounting, and Doli's own support, security, fraud, abuse, and legal records. A customer may be a controller or processor for an upstream controller; no industry questionnaire is required.

Before a B2B web purchase, Doli processes business, representative, and role details and the version, hash, and time of provisional acceptance. The provisional acceptance is bound to the user, business, role and documents; it alone is not a paid order. Following a confirmed order, Doli verifies initial Stripe evidence and creates the technical contract and entitlement record once. Doli then creates an immutable personalised contract copy, stores it privately, makes it available in the authorised account, and sends it through STRATO to the verified contract email address. Unpurchased provisional B2B data is removed after 30 days except for strictly required coarse security records. Renewal creates no new DPA acceptance.

For a pay-as-you-go business account, Doli additionally processes the shared account assignment, authorized pairings, seconds-based usage, one-time starter minutes, billing periods, payment status and any self-selected net limit. These metadata support access, billing and cost management and contain no conversation content. With a positive limit, enabled 80 and 100 percent notices are sent through the email provider to the contract address; delivery status is recorded for reliable delivery. Without a configured limit, no such threshold notices are created. The legal bases are Article 6(1)(b) GDPR, point (c) for statutory accounting evidence and point (f) for technical security and delivery records. The retention and deletion criteria below apply. Successful setup is verified against the matching payment-provider evidence and does not require purchasing a fixed minute package.

Device management additionally processes device labels, installation identifiers, pairing assignments, per-device usage and limit values, revision records and email notification preferences. Authorized account administrators see these metadata for paired employee devices; conversation content is not displayed. Employees use separate accounts without receiving the billing account's credentials. Both email thresholds can be disabled separately; limit enforcement and usage blocks remain independent. Unpairing removes further access, not billing records that must be retained. The legal bases and retention criteria above apply accordingly.

12. Spoken translation, captions, and Google processing

Audio transfer starts only when a user expressly starts the feature and grants microphone permission. Since 25 September 2026, Doli processes all content through Google Cloud Vertex AI: spoken translation and the language request at start with Gemini 3.8 Live, chat, captions and letter and image explanations with Google's Gemini Flash models. The model location is set to the Google Cloud EU multi-region for all of these features; in normal operation they all use the EU endpoint of the Vertex API. Content travels through Doli's relay hosted by Hetzner in Nuremberg. The same route serves personal and business accounts. Doli no longer uses the Gemini Developer API of Google LLC. Doli keeps no conversation history.

For captions, Doli's relay splits the microphone signal by loudness into speech segments and sends each segment as a short audio file to a Gemini Flash model for translation. The relay only detects pauses in speech; it identifies no persons and creates no voice profiles. The segments stay only in memory until the translation returns (at most 12 seconds) and are not stored. As a fallback, captions can temporarily run on Gemini 3.5 Live Translate. The relay then streams the microphone signal continuously through the global Vertex endpoint, because Google does not offer this model on the EU endpoint; the model location remains the EU multi-region.

The EU statement concerns the Vertex processing of content, not all account, authentication, payment, support or technical service data of every provider. It is not an assurance of suitability for professional secrecy under section 203 of the German Criminal Code; that review has been commissioned.

Doli does not retain audio recordings, transcripts or translations as conversation history on its servers, in logs or in backups. Content is processed transiently for the current request or session; technically necessary temporary recordings on the device are deleted after processing or cancellation.

Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland, processes Vertex Customer Data under the Google Cloud Data Processing Addendum. The applicable Google privacy notices govern separate account, billing and technical service/usage data.

From Doli 1.1.4, Doli no longer uses Microsoft Azure Speech for spoken output; the interpreter's voice is produced by the Gemini model itself. Doli 1.1.3 has not been served since 21 September 2026; older versions must update to 1.1.4.

Zero data retention applies to Google Cloud project 674711097607 as defined by Google: Google approved the requested exception from abuse-monitoring prompt logging, the project's data cache is disabled, and Doli uses no feature under which Google stores content. Google therefore processes conversation content only for the respective request and stores it neither for abuse review nor in a cache. Automated safety checks during processing remain in place. If any of these conditions changes, Doli updates this notice.

Google does not use Vertex Customer Data to train or fine-tune AI models without prior permission or instruction. Doli gives no such permission for conversation content. Doli does not sell content or use it for advertising or profiling.

Doli does not use session resumption, search or maps grounding, stored interactions or explicit context caching. Google's in-memory cache is disabled for the Doli project.

Further information: Google abuse monitoring and Google retention and zero data retention.

13. Camera, image, and document explanation

In camera mode, a document can be scanned, a photo taken, or an image or PDF selected from the device. The file travels encrypted through the Doli server to Google Cloud Vertex AI described in Section 12 and is processed with a Gemini Flash model to return an explanation or reply draft in the selected language. A short voice request is also transmitted for a reply draft. The provider rules in Section 12 also apply here.

Doli does not create a persistent content history. In-memory content is discarded after completion or cancellation. Technically necessary temporary device recordings are then deleted; files selected or expressly saved by the user remain under the user's control. The Doli server logs no content and records only seconds-based allowance usage. Sharing or saving a reply draft happens solely on the user's own device. The legal basis is Article 6(1)(b) GDPR.

On Android, Doli uses the Google ML Kit Barcode Scanning SDK to scan a device's QR code during pairing. The camera image and detected QR result are processed on the device and are not sent to Google by ML Kit. Doli then sends the pairing invitation and, where applicable, proof read from the QR code to the Doli server.

Separately, the ML Kit SDK sends technical metrics to Google encrypted in transit using HTTPS: device and app information, per-installation identifiers, performance data, API configuration including image format and resolution, input and output sizes, feature versions, event types, and error codes. According to Google's documentation, Google uses these data for diagnostics, usage analytics, API maintenance and improvement, and misuse detection. The Google Privacy Policy and ML Kit privacy information apply; these metrics are separate from documents sent to Gemini and their retention rules.

14. Feedback and ratings

Through "Send feedback" in the profile, a short message can be sent to Doli voluntarily. Doli stores the text with the app language, app version, and platform (iOS or Android). The link to the account is kept for 24 hours only, to allow at most five messages a day; after that, the message is no longer linked to any account. It is deleted after 180 days. The app asks users not to include conversation content or health data. The legal basis is Article 6(1)(f) GDPR; the legitimate interest is improving Doli and limiting abuse of the form.

For ratings, Doli asks the operating system to show Apple's or Google's own rating dialog. Doli learns nothing about whether or how a rating was given. When the app asks depends on the interpreting time so far, which is stored only on the device and not sent to Doli.

15. Supported countries and local device data

New business purchases are available only for countries enabled in the versioned server-side country catalog after provider and distribution availability, sanctions, transfer, and legal checks. Doli adds neither automatic location inference nor an industry questionnaire for that purpose. Enabling a country is not a promise that every use or tax treatment is lawful in every jurisdiction.

The signed-in session, selected app language, and required technical settings are stored in protected device storage or the session storage required for the website. They remain there until removed through sign-out, account deletion, app deletion, browser functions, or operating-system functions.

16. Retention, account deletion, and subscription

Account, profile, entitlement, and allowance data are processed for the duration of the account and associated service. Purchase, contract, invoice, and event references are processed as long as needed for contract performance, subscription and entitlement attribution, accounting, legal retention duties, or bringing and defending open claims. They are then deleted or, where further retention is required, restricted and purpose-limited.

Separate periods apply to the free start (Section 6, also beyond account deletion) and to feedback (Section 14).

After confirmed account deletion, other Doli account data is deleted unless legal retention duties, open claims, or mandatory security reasons prevent it. Deleting the account does not automatically end a web or Store subscription; it must also be managed or cancelled with the relevant payment or Store provider. Stripe/Link data remains independently subject to their retention and deletion rules described in Section 9. For a request to Link to delete Managed Payments data and the associated Link account, Stripe also describes cancellation of subscriptions sold through that service. This process is separate from deleting the Doli account.

17. Data-subject rights

Subject to the GDPR, data subjects have in particular rights of access, rectification, erasure, restriction, portability, and objection. Consent can be withdrawn with future effect. Requests concerning Doli processing can be sent to info@doliapp.de. An identity check may be required to prevent unauthorised disclosure.

For processing for which Stripe or Link is an independent controller, rights must be exercised through the Stripe Privacy Center or the contact routes in the Link/Stripe privacy notices. Doli assists with attribution where possible but cannot replace an independent Stripe decision.

Data subjects may also lodge a complaint with a data protection supervisory authority, in particular the authority where they reside or the supervisory authority responsible for Doli in Baden-Württemberg.

18. Updates

Doli updates this Notice when functions, recipients, or legal requirements change. Changes to direct content subprocessors are notified to business customers under the DPA. Before a new web purchase, the controlling version is displayed and bound server-side by version and hash. Changes do not operate retroactively and do not affect statutory rights already accrued.