Privacy Policy

Applies to silverfriend.de and related online offerings of Silverfriend GmbH. The mobile app is also covered by the App-specific Privacy Policy. Phone calls (companion service) are also covered by the Pre-call notice. The German Datenschutzerklärung is the legally binding original; this English version is a courtesy translation.

As of: 13 April 2026
Version: 1.0

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1. Controller (Art. 4(7) GDPR)

Silverfriend GmbH
Döringstraße 6, 10245 Berlin, Germany
Email: datenschutz@silverfriend.de
Phone: to be announced

Managing Director: Feras Alsamawi — see Legal Notice.

2. Data Protection Officer

Until an external Data Protection Officer has been formally appointed by name, please reach us on any data-protection matter directly at:
Email: datenschutz@silverfriend.de
Postal: c/o Silverfriend GmbH, Döringstraße 6, 10245 Berlin, Germany

3. Scope and definitions

This policy explains:

• who we are and how to reach us,
• what personal data we process,
• why we process it and on what legal basis,
• who receives it,
• how long we store it,
• what rights you have and how to exercise them.

"Personal data" means any information relating to an identified or identifiable natural person (Art. 4(1) GDPR).

4. Two data-subject roles

Our service involves two distinct categories of people with different roles:

1. Subscriber / family caregiver — the person who signs up and uses the app.
2. Senior / called person — the person our phone companion calls.

Each has its own rights and its own consent path. The senior's consent for voice processing is captured directly on the call, not through the caregiver's app — see Pre-call notice.

5. What we process and why

5.1 When you visit the website

Category	Purpose	Legal basis	Retention
IP address, browser user-agent, request timestamp	Site delivery, security logging	Art. 6(1)(f) GDPR (legitimate interest: operations and security)	14 days in access logs, then deleted or pseudonymised
Pseudonymous session data (privacy-focused analytics, with consent)	Reach analytics	Art. 6(1)(a) GDPR + §25(1) TTDSG	13 months (anonymised)
Contact-form contents	Reply to enquiry	Art. 6(1)(b) GDPR (pre-contractual)	until resolved + 6 months
Newsletter sign-up	Sending requested content	Art. 6(1)(a) GDPR + §7(2)(3) UWG	until withdrawal

Cookies and similar device-storage technologies: see Cookie Policy.

5.2 When you create a subscriber account

Category	Purpose	Legal basis	Retention
Name, email, phone, postal code, living situation, interests	Contract performance; service personalisation	Art. 6(1)(b) GDPR	Subscription duration + 30 days
Authentication data (password hash, session tokens)	Account login	Art. 6(1)(b) GDPR	per auth lifecycle (refresh: 30d; access: 1h)
Payment data	Contract execution and bookkeeping	Art. 6(1)(b) and (c) GDPR (§147 AO)	10 years (tax law)
Consent records	Accountability	Art. 6(1)(c) GDPR (Art. 7(1) GDPR)	3 years after withdrawal or end of relationship

5.3 Phone companion (for the called senior)

Category	Purpose	Legal basis	Retention
Voice recording during call	Real-time processing by speech model (hosted in the EU)	Art. 6(1)(a) GDPR + Art. 9(2)(a) GDPR (for incidental health-related content)	7 days (audio); then deleted
Call transcript	Conversational continuity for follow-up calls	as above	180 days
Memory notes	Personalisation across calls	as above	730-day sliding window with relevance pruning
Life chronicle (anniversaries, events)	Long-term continuity	as above	Subscription duration + 30 days
Call metadata (timestamp, duration, status)	Service delivery, accountability	Art. 6(1)(b) and (f) GDPR	12 months
Safety events (see §6)	Emergency alert to caregiver	Art. 6(1)(d) + Art. 9(2)(c) GDPR (vital interests)	3 years

5.4 Push notifications (app)

Category	Purpose	Legal basis	Retention
Push token (device identifier)	Notification delivery	Art. 6(1)(a) GDPR + §25(1) TTDSG	until withdrawal, app uninstall, or 90-day inactivity
Notification type (no content in payload)	as above	as above	as above

6. Express clarifications about the voice service

Two important points we want to make explicit:

1. SilverFriend does not analyse the senior's mood or mental state. No such assessments are produced or shared with the caregiver.

2. Exception — emergency: on concrete signs of acute danger (e.g. suicidal ideation or imminent harm), we ask the caregiver to check on the senior in person — without disclosing the content of the call. Legal basis: Art. 6(1)(d) GDPR (vital interests) read with Art. 9(2)(c) GDPR.

The speech model runs on EU-hosted infrastructure. Under the applicable processing terms, inputs are not used to train the base model.

7. Recipients and processors

A complete, current list is published at silverfriend.de/datenschutz/subprocessors.

Key recipients:

Recipient	Role	Legal instrument	Location
Cloud hosting & data-processing provider	Processor (hosting, database, voice model)	Art. 28 GDPR + EU SCCs (Module 2)	EU; US sub-processor
Telephony provider	Processor (phone calls)	as above	EU; US sub-processor
Push-messaging provider	Processor (app notifications)	as above	EU; US parent
Marketing & CRM platform	Processor (website, CRM, marketing — caregiver data only)	as above	EU; US parent
Subscription-management platform (if shipped)	Processor (subscription management)	Art. 28 GDPR + SCCs	US
Tax adviser	Processor (bookkeeping)	Art. 28 GDPR	Germany

The named list of current subprocessors (company name, address, role) is maintained and published at silverfriend.de/en/datenschutz/subprocessors.

8. Transfers to third countries

Processing is in the EU by default (data centres in Germany and Sweden). Exceptions — control-plane access by certain US providers — are covered by EU Standard Contractual Clauses (Module 2) plus supplementary measures (encryption with customer-managed keys, TLS 1.2+, data residency, logging).

The Transfer Impact Assessment is available from the DPO. We monitor the validity of the EU-US Data Privacy Framework for the listed US providers, all of which are DPF-certified.

9. Retention — overview

For each data category we have set a specific retention period (see tables above). Our full deletion strategy follows DIN 66398 and is documented internally — see DATA_RETENTION_SCHEDULE.

10. Your rights

As subscriber or as senior you have the right to:

• Access the data we process about you (Art. 15 GDPR),
• Rectification of inaccurate data (Art. 16),
• Erasure ("right to be forgotten", Art. 17),
• Restriction of processing (Art. 18),
• Data portability (Art. 20),
• Object to processing based on legitimate interest (Art. 21),
• Withdraw consent at any time, with effect for the future (Art. 7(3)),
• Lodge a complaint with a supervisory authority (Art. 77).

Please contact: datenschutz@silverfriend.de.

We respond within 30 days. Where identity verification is required we will request a suitable proof (e.g. confirmation from the registered email account). Seniors may submit requests via the caregiver or during a call ("nicht mehr anrufen" / "do not call again" stops further calls immediately).

Supervisory authority: Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin — https://www.datenschutz-berlin.de.

11. Automated decision-making

There is no automated decision-making within the meaning of Art. 22 GDPR. Specifically:

• We do not create credit, personality, or health profiles.
• The only model-supported decision is the detection of acute-danger signals (see §6); this triggers a human-oriented request for the caregiver to check in person — no automatic consequence.

12. Security (Art. 32 GDPR)

Among the technical and organisational measures we apply:

• Encryption of stored data with customer-managed keys,
• TLS 1.2+ for all transit,
• Role-segregated database access,
• Credential management via a dedicated secrets-management system,
• Web Application Firewall,
• Logging of security-relevant events,
• Quarterly security reviews and annual external audits.

13. Changes to this policy

We update this policy on material processing changes. Active subscribers are informed at least 14 days before the change takes effect by email or in-app banner. A change history appears at the end of this page (once changes occur).

14. Change history

Date	Version	Material changes
2026-04-13	1.0	Initial publication (pre-launch)

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As of 13 April 2026 · Controller: Management of Silverfriend GmbH · DPO: appointment in progress