Data Protection Declaration

Last updated: 1 September 2026

1) Information on the Collection of Personal Data and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Ömer Dertlioglu, SonicR1 · Ömer Dertlioglu, Kurfürstendamm 96, 10709 Berlin, Germany, Phone.: +4915678339307, e-mail: info@sonicr1.com. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) Data Collection When You Visit Our Website

2.1 When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:

  • Our visited website
  • Date and time at the moment of access
  • Amount of data sent in bytes
  • Source/reference from which you came to the page
  • Browser used
  • Operating system used
  • IP address used (if applicable: in anonymized form)

Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.

3) Hosting & Content Delivery Network

Vercel

For the hosting of our website and the display of the page content, we use the system of the following provider: Vercel Inc, 440 N Barranca Ave #4133, Covina, CA 91723, USA

All data collected on our website is processed on the provider's servers. We have concluded an order processing agreement with the provider, ensuring the protection of our site visitors' data and prohibiting unauthorised disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

4) Cookies

In order to make your visit to our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called "session cookies"), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called "persistent cookies"). In the latter case, you can find the duration of the storage in the overview of the cookie settings of your web browser.

If personal data is also processed by individual cookies set by us, the processing is carried out either in accordance with Art. 6 (1) point b GDPR for the performance of the contract, in accordance with Art. 6 (1) point a GDPR in the case of consent given or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.

You can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

Please note that the functionality of our website may be limited if cookies are not accepted.

5) Contacting Us

5.1 When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.

The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.

5.2 - Resend

We use the following provider to send transactional emails, i.e. event-driven messages triggered by a specific user interaction (such as the conclusion of a contract, registration or password reset): Plus Five Five, Inc., 2261 Market Street, #5039, San Francisco, CA 94114, USA

On the basis of our legitimate interest in effective and user-friendly email communication, we pass on the data you provide when carrying out such a user action to this provider in accordance with art. 6 (1) point f GDPR, so that they can handle the sending of emails on our behalf.

We have concluded an order processing agreement with the provider, which safeguards the data of our website visitors and prohibits a disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

6) Data Processing When Opening a Customer Account and for Contract Processing

Pursuant to Art. 6 (1) point b GDPR, personal data will continue to be collected and processed to the extent required in each case if you provide us with this data when opening a customer account. The data required for opening an account can be found in the input mask of the corresponding form on our website. Deletion of your customer account is possible at any time and can be done by sending a message to the above address of the person responsible. After deletion of your customer account, your data will be deleted, provided that all contracts concluded via it have been fully processed, no legal retention periods are opposed and no legitimate interest on our part in the continued storage exists.

7) Use of Client Data for Direct Advertising

Subscribe to our e-mail newsletter

If you register for our e-mail newsletter, we will regularly send you information about our offers. The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter once you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in future by clicking on an appropriate link.

By activating the confirmation link, you give us your consent for the use of your personal data pursuant to Art. 6 (1) point a GPPR. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration for the purpose of tracing any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the promotional purposes by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the responsible person named at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data, or we reserve the right to a more extensive use your data which is permitted by law and about which we inform you in this declaration.

8) Processing of Data for the Purpose of Order Handling

8.1 To fulfill the contract, we work with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transferred to these service providers in accordance with the following information.

8.2 Use of Payment Service Providers

- Stripe

Online payment methods from the following provider are available on this website: Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland

If you select a payment method of the provider, your payment data provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) point b GDPR. In this case, your data will only be passed on for the purpose of processing payment with the provider and only to the extent necessary for this purpose.

8.3 - Google Gemini

We use software incorporating artificial intelligence from the following provider to provide our services: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Information provided by you within the scope of a contractual relationship may be entered into the provider's software in order to organize, analyze, aggregate, modify, evaluate, or process it for the purpose of delivering our services.

Information may also be transmitted to: Google LLC, USA

The collection and further processing of this information are strictly limited to the purpose of contract fulfillment. Processing for the purpose of training or further developing the provider's AI language models is expressly prohibited.

Where the processing involves personal data, it is carried out based on our legitimate interest in structuring our services efficiently and making optimal use of available resources and technologies, in accordance with Art. 6(1)(f) of the GDPR. If the personal data belongs to third parties and you have entrusted us with its processing, such processing is secured through a data processing agreement concluded with us; this agreement specifies the measures taken to protect the data as well as your rights of control and access.

We have concluded an order processing agreement with the provider, that ensures the protection of personal data processed by the provider and prohibits unauthorized disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

You can find further legal information and Google's privacy policy at https://support.google.com/gemini/answer/13594961?hl=en

8.4 Electronic Withdrawal Function for Distance Contracts

Consumers who conclude contracts on this website for which a statutory right of withdrawal exists have the option to declare their withdrawal via an electronic withdrawal function, in accordance with the applicable withdrawal provisions.

When using the withdrawal function, in addition to details identifying the specific contract being withdrawn from, other personal information—such as the consumer's first name, last name, and email address—must be provided or confirmed.

The collection of this information and its transmission to us is carried out in accordance with Art. 6 (1) point b of the GDPR, and only to the extent necessary for the proper processing of the withdrawal request. Furthermore, and also based on Art. 6 (1) point b of the GDPR, the provided personal data is used to confirm receipt of the withdrawal declaration via email. An additional legal basis for this processing is Art. 6 (1) point c of the GDPR. We are legally obligated to provide an electronic cancellation function for remunerated distance contracts concluded with consumers.

9) Site Functionalities

9.1 Google Sign-In

On our website we provide a single sign-on function offered by the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 ESW5, Ireland

In addition to the transfer of data to the above-mentioned provider location, data may also be transferred to: Google LLC, USA

If you have an account with the provider, you can use this account data to create a user account or to register on our website.

When you visit this page, a direct connection between your browser and the provider's servers can be established via this login function, even if you do not have an account with the provider or are not logged in to one. The provider thereby receives the information that you have visited our site. The information collected in this respect (including your IP address, if applicable) is transmitted by your browser directly to a server of the provider and stored there. However, the information is not used to identify you personally and is not passed on to third parties.

These data processing operations are carried out in accordance with Art. 6 (1) point f GDPR based on our legitimate interest in a user-friendly and interactive design of our online presence.

If you click on the registration button to register with your account data by logging into the provider's website, the provider will transmit the general and publicly accessible information stored in your account (user ID, name, address, e-mail address, age, and gender) to us based on your express consent pursuant to Art. 6 (1) point a GDPR.

We store and use the data transmitted by the provider to set up a user account containing the necessary data (title, first name, surname, address data, country, email address, date of birth), if you have released that data to the provider. Conversely, data (e.g., information about your surfing or purchasing behavior) may be transferred from us to your account held with the provider based on your consent.

The consent given can be revoked at any time with effect for the future vis-à-vis us.

Further information on Google's privacy standards can be found here: https://business.safety.google/privacy/

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

9.2 - Cloudflare Turnstile

On this website, we use the CAPTCHA service of the following provider: Cloudflare, Inc., 101 Townsend St. San Francisco, CA 94107, USA

The service checks whether an input is made by a natural person or abusively by machine and automated processing with the aim of blocking spam, DDoS attacks and similar automated malicious attacks. To ensure whether an action is performed by a human being and not by an automated bot, Cloudflare Turnstile collects the IP address of the end device used, the recognition data of the browser, the operating system type and the date and duration of the visit and transmits these data to the provider's servers to be evaluated.

This process is based on our legitimate interest in determining individual responsibility when using the Internet and in preventing abuse and spam in accordance with Art. 6 Para. 1 lit. f GDPR.

We have concluded an order processing contract with the provider, ensuring the protection of our site visitors' data and prohibiting unauthorized disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

10) Tools and Miscellaneous

10.1 - Lexware Office

For the execution of the accounting, we use the service of the cloud-based accounting software of the following provider: Haufe-Lexware GmbH & Co. KG, Munzinger Straße 9, 79111 Freiburg, Germany

The provider processes incoming and outgoing invoices and, if applicable, also the bank transactions of our company in order to automatically record invoices, match them to the transactions and create the financial accounting from this in a semi-automated process.

Insofar as personal data is also processed in this context, the processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in the efficient organisation and documentation of our business transactions.

10.2 This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box.

Using the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted.

The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point f GDPR based on our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.
Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.
Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.

11) Rights of the Data Subject

11.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:

  • Right of access by the data subject pursuant to Art. 15 GDPR;
  • Right to rectification pursuant to Art. 16 GDPR;
  • Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
  • Right to restriction of processing pursuant to Art. 18 GDPR;
  • Right to be informed pursuant to Art. 19 GDPR;
  • Right to data portability pursuant to Art. 20 GDPR;
  • Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
  • Right to lodge a complaint pursuant to Art. 77 GDPR.

11.2 RIGHT TO OBJECT

IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.

12) Duration of Storage of Personal Data

The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).

If personal data is processed on the basis of express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.

If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.

When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

If personal data is processed for the purpose of direct marketing based on Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.

Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.

Supplementary Privacy Notes: the SonicR1 Platform

Last updated: 12 August 2026

The Data Protection Declaration above covers data processing that takes place when you visit this website. The following notes additionally describe the processing that takes place when you use the SonicR1 platform (after registration and sign-in).

1. Roles: controller and processor

For account data (e-mail address, name, company name), billing data and technical usage data of the platform, we act as the controller within the meaning of the GDPR.

For content our customers process through the platform (“Customer Content”) — in particular audio streams, transcripts, conversation analyses, uploaded recordings and data imported from connected CRM and calendar systems — we act as a processor under Art. 28 GDPR on the basis of our Data Processing Agreement (DPA). The DPA is part of every contract and available at sonicr1.com/dpa.

The legal bases for processing Customer Content, as well as any required information to and consent of call participants, are determined and owned by the customer as controller. If data subjects assert their rights towards us with respect to Customer Content, we forward the request to the responsible customer and support them in answering it.

2. Live calls and audio processing

In the default mode (“ephemeral”), call audio is transcribed in real time and is not stored as an audio recording.

Real-time transcription (speech-to-text) runs on EU endpoints of AssemblyAI, Inc.; use of the data for model training is disabled, and the provider deletes processing data within one day.

Where the selected plan includes AI notes and the user enables them, the transcript and AI summary are stored in the EU (Supabase, Frankfurt region); no audio from the live call is stored. A recording the user uploads is stored so it can be replayed and is deleted with the call. Before recordings are processed, the application requires an explicit confirmation that the necessary consents of the call participants have been obtained; the processing mode chosen for a call is technically locked for that call.

3. AI processing

Transcript analyses, coaching hints and summaries are generated with Google Cloud Vertex AI (Gemini models) in EU regions.

We do not use Customer Content to train shared or general-purpose AI models. We apply the model-improvement opt-outs and contractual restrictions the providers make available to us; the commitment is in section 6.4 of our DPA.

AI-generated assessments of individual conversations and persons are machine-generated hints. Person-related AI assessments are visible in the product only to the user concerned; team views for managers are limited to factual metrics.

4. Simulation and training calls

Practice calls with an AI counterpart use a synthetic voice and are labelled as AI in the application.

Runtime processing of simulation calls is transient (no permanent storage of the audio) on Fly.io infrastructure in the Frankfurt region.

5. Sub-processors of the platform

We use the following sub-processors to operate the platform. Transfers to third countries rely on the EU Standard Contractual Clauses (SCC) and — where the provider is certified — the EU-U.S. Data Privacy Framework (DPF):

  • Google Cloud EMEA Limited (Dublin, Ireland) — AI processing (Vertex AI/Gemini) and speech synthesis; EU endpoints; Google Cloud Data Processing Addendum incl. SCC (2021/914, Module 3)
  • AssemblyAI, Inc. (US) — speech-to-text; EU endpoints; provider DPA incl. SCC (2021/914, Module 3); training opt-out active
  • Supabase, Inc. (US) — database, storage, authentication; Frankfurt (Central EU); provider DPA incl. SCC (2021/914, Module 3)
  • Vercel, Inc. — application hosting; region fra1 (Frankfurt); SCC
  • Fly.io, Inc. — runtime for simulation calls (transient); Frankfurt; DPA with SCC
  • Upstash, Inc. (US) — rate limiting (technical keys only, no conversation content); Frankfurt; provider DPA incl. SCC (2021/914, Module 3)
  • Inngest, Inc. (US) — orchestration of background jobs; job identifiers, execution metadata and workflow step outputs, which include pseudonymised transcript text and generated CRM write payloads with tokens resolved, plus recipient address and message variables for transactional e-mail; no call audio; USA; provider DPA incl. SCC (2021/914, Module 3)
  • Plus Five Five, Inc. (Resend) — transactional e-mail; dispatched from the EU sending region; account data, message content, e-mail metadata, logs and API records stored in the USA regardless of that region; SCC and DPF

A current version of this list including transfer mechanisms is available on request at legal@sonicr1.com; it is published in full, with transfer mechanisms, in Annex 2 of our DPA at sonicr1.com/dpa.

6. Retention and deletion

Users can delete calls, transcripts and the associated analyses in the application at any time.

Retention periods for Customer Content depend on the selected plan; details are set out in the respective service description.

System and security logs are retained for a limited period. Please address deletion and access requests to legal@sonicr1.com.

7. CRM and calendar integrations

On the customer's instruction, third-party systems (e.g. Zoho CRM, monday.com, Close, HubSpot, Google and Outlook calendars, Calendly) can be connected via OAuth. We process imported data exclusively on behalf of the customer to provide the platform features.

The connection can be removed at any time in the settings; stored access tokens are deleted in the process.

8. Desktop application

The optional desktop application captures audio locally on the device and transmits it to the same EU processing paths as the web application; sections 2 and 3 apply accordingly.

9. Relationship to the Data Protection Declaration above

These notes supplement the Data Protection Declaration above with the platform-specific processing operations. The data-subject rights, contact channels and general information described there apply unchanged to the processing described here.