1. Controller and Contact

The controller responsible for the processing of personal data in connection with Elena is:

Die Plan.Net Studios GmbH & Co. KG
Friedenstraße 24, 81671 München
agentic@house-of-communication.com

You can contact our data protection officer at:

Dr. Georg F. Schröder, LL.M.
Serviceplan Group SE & Co. KG
Friedenstr. 24
81671 München
Deutschland
datenschutz@serviceplan.com

 

2. General Information on Data Processing

This privacy notice applies to the processing of personal data in connection with the use of Elena.

Elena is an Account and Project Management Partner that supports account management, project coordination, task management, scheduling, and internal communication. In order to provide this functionality, personal data of users and, where applicable, third parties are processed using the following third-party services:

Microsoft 365 (email, documents, calendar access)

Anthropic Claude (AI model for analysis and content generation)

 

3. Categories of Personal Data

The following categories of personal data are processed by Elena:

User master data (e.g. name, account details, contact details)

Content data (e.g. text entries, uploaded files, prompts, outputs)

Usage data (e.g. logs of interactions, timestamps, frequency of use)

 

4. Purposes, Legal Bases, Recipients and Retention Periods

The following table provides an overview of the processing operations. To the extent, we process personal data in connection with your use of Elena, we process such data solely based on our instructions in our capacity as a processor. For further information, please see section 5 below:

Category of data	Purpose of processing	Legal basis	Recipients	Retention period
User master data	Provision and administration of user account, fulfilment of contractual obligations	Art. 6(1)(b) GDPR	Internal departments, hosting providers	For the duration of the contractual relationship and statutory retention periods
Content data	Execution of Agent functionalities (processing of user input, generation of outputs)	Art. 6(1)(b) GDPR	Internal systems, subcontracted processors	Deleted after 6 months or upon user request
Usage data	Ensuring IT security, prevention of misuse, service optimisation	Art. 6(1)(f) GDPR	Internal IT, security service providers	6 months, unless longer storage is required for security incidents

5. Use of AI Agent

To the extent you (whether as a registered or unregistered user) provide personal data to us when you use our AI Agents (e.g. task assignment), we process such data – including your instructions, task parameters, and interaction metadata – solely as per your instructions as a processor based on a data processing agreement (“DPA”).

To the extent you opt to use a third-party AI Agent, please note that:

If the Agent is provided by another third party, that third-party AI Agent provider is independently responsible for the data processing activities that occur in connection with the agent. In such cases, additional information about the processing may be made available by the third-party AI Agent provider.

 

6. Source of Data

Where personal data are not collected directly from the end user, they originate from:

Publicly accessible sources (e.g. websites, social media)

Third parties who provide information for the use of the AI Agent

 

7. Recipients and Third-Country Transfers

Personal data are disclosed to processors and service providers who support the provision and operation of Elena (for example hosting providers, IT service providers, customer support). These recipients process personal data only on the basis of contractual agreements and in accordance with instructions.

7.1 Variant B2 – Transfer based on Standard Contractual Clauses (SCC)

Personal data are transferred to recipients located in the United States. There is no adequacy decision by the European Commission for this country. To ensure an appropriate level of data protection, the transfer is carried out on the basis of Standard Contractual Clauses adopted by the European Commission pursuant to Art. 46 GDPR. A copy of these clauses can be obtained from us at any time.

 

8. Retention Period

Personal data are retained only for as long as necessary to achieve the purposes described in this privacy notice or as long as statutory retention obligations require. Where possible, the specific retention periods are set out in section 4 above. If exact periods cannot be specified, the criteria used to determine the retention period are applied, such as:

Expiry of statutory limitation periods (typically three years)

Statutory tax and accounting retention obligations (up to ten years)

Termination of the contractual relationship

 

9. Automated Decision-Making and Profiling

Elena does not carry out automated decision-making within the meaning of Art. 22 GDPR.

 

10. Rights of Data Subjects

You have the following rights under the GDPR:

Right of access (Art. 15 GDPR)

Right to rectification (Art. 16 GDPR)

Right to erasure (Art. 17 GDPR)

Right to restriction of processing (Art. 18 GDPR)

Right to object (Art. 21 GDPR)

Right to data portability (Art. 20 GDPR)

To exercise these rights, please contact us using the contact details provided above.

In addition, you have the right to lodge a complaint with a supervisory authority under Art. 77 GDPR.

 

11. Obligation to Provide Data

The provision of certain personal data is necessary for the use of the AI Agent. Without these data, the service cannot be provided.

 

12. Amendments to this Privacy Notice

This privacy notice is updated whenever changes in the processing of personal data occur. The current version is always available within the Agent interface.