Privacy Policy

1. Data Controller

The data controller within the meaning of applicable data protection laws, in particular the EU General Data Protection Regulation (GDPR), is:

desapalencao Institute for Human Transformation UG (limited liability)
represented by the managing directors

Angel Candeaux
and Olaf Buntemeyer
Skalitzer Str. 28
10999 Berlin
Germany

Email: hallo@angel-candeaux.com
Website: www.angel-candeaux.com

2. Scope of this Privacy Policy

This Privacy Policy applies to:

the use of the website www.angel-candeaux.com,
the initiation, performance and administration of consulting and therapy services (in particular couple therapy and psychological counseling),
the processing of personal data within contractual relationships,
the use of technical systems, cloud infrastructures and AI-based applications as part of service delivery.

This Privacy Policy forms part of the contractual documentation and is made available to clients prior to entering into a contract.

3. Legal Bases for Data Processing

Personal data is processed on the basis of the following legal grounds:

Art. 6(1)(b) GDPR – performance of a contract and pre-contractual measures
Art. 6(1)(a) GDPR – consent
Art. 6(1)(f) GDPR – legitimate interest in a secure and efficient organization
Art. 9(2)(a) GDPR – explicit consent for the processing of special categories of personal data

4. Processing of Personal Data in the Context of Consulting and Therapy

4.1 Categories of Data

In the course of cooperation, the following data may in particular be processed:

master data (name, contact details),
contractual and billing data,
appointment and communication data,
content from sessions,
audio recordings of sessions,
therapeutic notes, analyses and summaries,
AI-generated text or audio evaluations.

This may include special categories of personal data within the meaning of Art. 9 GDPR.

5. Client Management (Zoho CRM)

We use Zoho CRM to manage clients, contracts, appointments and internal documentation.

Provider:
Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT Utrecht, Netherlands

Processing is carried out exclusively on behalf of the Institute (Art. 28 GDPR)
Data is stored exclusively on servers within the European Union
A data processing agreement (DPA) has been concluded

Zoho Privacy Policy:
https://www.zoho.com/privacy.html

6. Audio Recordings

As part of certain services offered by the Institute (e.g. consultations, therapy formats, programs or digital services), conversations or working sessions may be processed as audio recordings, subject to explicit consent.

Audio recordings are used in particular for:

internal documentation,
quality assurance,
professional review and follow-up,
the creation of summaries or audio reflections.

Principles of processing:

confidential handling of recordings,
no disclosure to third parties without additional consent or legal obligation,
storage exclusively on servers located within the European Union.

Providing consent is voluntary.

Consent may be withdrawn at any time with effect for the future. It is noted that certain services of the Institute – in particular those based on documentation, review or AI-supported evaluation – cannot be meaningfully provided without audio recordings. In such cases, withdrawal may result in an adjustment or termination of the cooperation.

7. AI-Based Data Processing

AI-based systems may be used within the Institute to support service delivery, internal analysis, structuring, quality assurance and the creation of accompanying materials.

AI systems do not make independent therapeutic, advisory or diagnostic decisions. Professional responsibility always remains entirely with the involved professionals or the Institute.

7.1 Types of Data Processed

Depending on the respective service, AI-based processing may include in particular:

text data from conversations, notes or working materials,
audio recordings or derived transcripts,
summaries, reflections or structured evaluations.

This may involve special categories of personal data pursuant to Art. 9 GDPR.

7.2 AI Service Providers

Claude AI (Anthropic)

Function: analysis, structuring and summarization of text and audio data
Provider: Anthropic PBC

purpose-limited processing on behalf of the Institute,
no use of data for training public AI models,
processing exclusively based on explicit consent.

ElevenLabs

Function: generation of audio material (e.g. audio reflections) based on provided text content.

7.3 Legal Basis and Consent

AI-based processing is carried out exclusively on the basis of:

the contractual relationship (Art. 6(1)(b) GDPR), and
explicit consent of the data subject (Art. 6(1)(a) GDPR in conjunction with Art. 9(2)(a) GDPR).

Providing consent is voluntary.

7.4 Withdrawal and Consequences

Consent for AI-based processing may be withdrawn at any time with effect for the future.

It is noted that certain services, workflows or service components of the Institute are based on or require AI-based processing. In such cases, withdrawal may lead to an adjustment, limitation or discontinuation of the respective service.

8. Cloud Storage (AWS – EU)

Sensitive working data (audio recordings, notes, summaries, audio reflections) is stored using Amazon Web Services (AWS).

storage exclusively in data centers within the European Union,
use based on a data processing agreement.

AWS Privacy Policy:
https://aws.amazon.com/privacy/

9. Website Use and Analytics Tools

9.1 Server Log Files

When visiting the website, technical access data (e.g. IP address, browser type, time of access) is processed automatically. This data is used to ensure technical security and stability.

9.2 Cookies and Cookie Settings

The website uses technically necessary cookies. Additional cookies (e.g. analytics or marketing cookies) are only set with consent.

Cookie settings:
Website visitors may adjust or withdraw their cookie settings at any time. Cookie settings are permanently accessible via a link in the footer of the website and are also offered via a cookie banner on the first visit.

In the contractual context, cookie settings are not relevant and do not constitute contractual obligations.

9.3 Zoho PageSense

We use Zoho PageSense to analyze website usage in an anonymized manner.

9.4 Zoho SalesIQ

We use Zoho SalesIQ to provide a website chat. Anonymous use is possible. If contact details are provided voluntarily, they are stored for communication purposes.

9.5 Google Analytics

This website uses Google Analytics to analyze website usage. Processing takes place exclusively on the basis of consent.

Google Privacy Policy:
https://policies.google.com/privacy

9.6 Google Maps

We use Google Maps to display interactive maps. When accessing the map, personal data may be transmitted to Google.

Google Privacy Policy:
https://policies.google.com/privacy

10. Data Retention

Personal data is stored only for as long as necessary for the respective purposes or as required by statutory retention obligations.

11. Rights of Data Subjects

Data subjects have the right to access, rectification, erasure, restriction of processing, data portability and objection at any time.

Requests may be addressed to:
hallo@angel-candeaux.com

12. Withdrawal of Consent

Consent may be withdrawn at any time with effect for the future. Certain processing activities (audio, AI) are a prerequisite for service delivery and may lead to termination of the cooperation if consent is withdrawn.

13. Supervisory Authority

A list of competent data protection supervisory authorities is available at:
https://www.bfdi.bund.de/EN/Infothek/Addresses_Links/addresses_links-node.html

14. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy. The current version shall apply.

Berlin, December 13, 2025