Privacy Policy

Effective Date: February 09. 2026
‍Version: 1.0
This Privacy Policy explains how Aulino (“we,” “us,” “our”) collects, uses, discloses, and protects personal data when you visit https://www.aulino.ai and related pages (the “Website”), including when you sign up for our waitlist (the “Waitlist”).

Important: Aulino is currently pre-launch. This Privacy Policy covers the Website and Waitlist only. If we later launch a device/app or child-facing features, we will provide a separate product privacy notice describing those data flows.

1) Controller / Contact

Controller (data controller / responsible entity):
Dr. Anja Koetzsch
Service Address: Prenzlauer Allee 43, 10405 Berlin, Germany
Email: support@aulino.ai

If you have questions about privacy, you can contact us at support@aulino.ai.

‍Data Protection Officer (DPO): We have not appointed a Data Protection Officer at this time. If that changes, we will update this Policy.

2) What Personal Data We Collect

2.1 Data you provide to us (Waitlist and messages)

We may collect the following categories of personal data:
  1. Email address (required for the Waitlist)
  2. Any additional information you choose to provide (e.g., name, country, message content), if the Website asks for it
  3. Any information you send us by email

2.2 Data collected automatically (Website usage & logs)

When you visit the Website, certain information may be collected automatically:
  1. IP address (often stored in server logs)
  2. Device and browser information (e.g., browser type, operating system)
  3. Pages viewed, date/time of access, referring URL
  4. Approximate location (inferred from IP, typically city/region-level)

2.3 Cookies and similar technologies

We may use technically necessary cookies to operate the Website (e.g., security, load balancing, basic functionality).If we add analytics, marketing pixels, or non-essential cookies, we will implement an appropriate cookie consent mechanism where required (especially for Germany/EU users).

3) How We Use Personal Data

We use personal data to:
  1. Operate and secure the Website (including troubleshooting, preventing abuse, and ensuring availability)
  2. Manage the Waitlist and send Waitlist updates (e.g., confirmations, invitations, product updates)
  3. Respond to inquiries and communicate with you
  4. Improve the Website (e.g., understanding which pages are most useful) — only if/when we implement analytics, and where required, only with consent
  5. Comply with legal obligations and enforce our Terms

4) Legal Bases (GDPR – for Germany/EU/EEA users)

If you are located in Germany or the European Economic Area (EEA), we process your personal data under the following legal bases:
  1. Consent (Art. 6(1)(a) GDPR)
    For sending Waitlist updates and marketing-style emails (where applicable), especially if we use a double opt-in confirmation process.
  2. Legitimate interests (Art. 6(1)(f) GDPR)
    For operating, securing, and improving the Website (e.g., server logs, preventing fraud/abuse, ensuring performance). Our legitimate interests include maintaining a reliable and secure Website.
  3. Legal obligation (Art. 6(1)(c) GDPR)
    Where we must process data to comply with law (e.g., responding to lawful requests, record-keeping obligations).
Where consent is the legal basis, you may withdraw consent at any time (see Section 9).

5) Sharing and Disclosure

We do not sell your personal data. We may share personal data with:
  1. Service providers (processors) who help us operate the Website and manage communications (e.g., hosting provider, email delivery, security tools). They may process data only on our instructions and for the purposes described here.
  2. Authorities / legal recipients if required by law or to protect rights, safety, and security.
  3. Business transfers: if we undergo a merger, acquisition, or asset sale, personal data may be transferred as part of that transaction (subject to applicable law).

6) International Data Transfers (Germany/EU/EEA)

If you are in Germany/EU/EEA, your personal data may be transferred to and processed in countries outside the EEA (including the United States) where data protection laws may differ.
When we transfer data internationally, we use appropriate safeguards, such as:
  1. Transfers to providers certified under an EU adequacy framework (where applicable), or
  2. Standard Contractual Clauses (SCCs) and, when needed, additional safeguards.
You can contact us to request information about the safeguards used for specific transfers.

7) Data Retention

We keep personal data only as long as necessary for the purposes described above:
  1. Waitlist email data: until you unsubscribe, request deletion, or until we determine the Waitlist is inactive
  2. Inquiry emails: as long as needed to resolve your request, then retained as required for legitimate business or legal reasons
  3. Server logs: typically retained for 365 days (security and troubleshooting), unless a longer retention is needed to investigate abuse or comply with law

8) Security

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or destruction. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

9) Your Rights (Germany/EU/EEA)

If you are in Germany/EU/EEA, you may have the following rights under the GDPR (subject to legal requirements and exceptions):

  1. Right of access (Art. 15)
  2. Right to rectification (Art. 16)
  3. Right to erasure (“right to be forgotten”, Art. 17)
  4. Right to restriction of processing (Art. 18)
  5. Right to data portability (Art. 20)
  6. Right to object (Art. 21), especially where we rely on legitimate interests
  7. Right to withdraw consent at any time (Art. 7(3)) if processing is based on consent
To exercise rights, contact us at support@aulino.ai. We may request information to verify your identity.

Complaints
You also have the right to lodge a complaint with a supervisory authority in the EU/EEA, in particular in your country of residence, place of work, or place of the alleged infringement.

10) U.S. Privacy Rights

Depending on where you live in the United States, you may have certain privacy rights under state laws (e.g., California and other states). These may include the right to access, delete, or correct personal information, and to opt out of certain processing.
‍We do not sell personal information and do not engage in targeted advertising based on sensitive child data through the Website.

To make a request, contact us at support@aulino.ai with the subject line “Privacy Request.” We may verify your request before responding.

11) Children’s Privacy

The Website and Waitlist are intended for adults (e.g., parents/guardians). We do not knowingly collect personal information from children under 13 through the Website.

If you believe a child has provided personal data through the Website, please contact us at support@aulino.ai and we will take steps to delete it.

Product note: If we later introduce child-facing product features, we will publish a dedicated product privacy notice and implement appropriate parental controls and legal safeguards.

12) Third-Party Links and Embedded Content

The Website may contain links to third-party websites. We are not responsible for their privacy practices.If we embed third-party content (e.g., videos), those providers may collect data when the content is loaded. Where required, we will use consent-based loading mechanisms.

13) Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and update the “Effective Date.”If changes are material, we will take reasonable steps to provide notice on the Website.

19) Contact

If any provision of these Terms is found unenforceable, the remaining provisions will remain in full force and effect.Questions about these Terms?

Contact: support@aulino.ai