Privacy policy
As of 12 November 2026. This is a translation; the German version is binding.
1. Who is responsible
VRtual X GmbH
Hegestraße 40
20251 Hamburg, Germany
Managing directors: Tim B. Frank, Matthias Wolk
Email: hello@talkypage.com
Questions about data protection: datenschutz@talkypage.com
2. The essentials first
- This website sets no cookies and uses no analytics or advertising services.
- Fonts, images and scripts come from our own servers in Germany, not from third parties.
- The voice assistant in the bottom right corner connects only when you click it. Before that, no microphone is switched on and no connection to an AI provider is made.
3. Visiting this website
Our servers are located in data centres of Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, in Germany. Hetzner processes the data on our behalf (Art. 28 GDPR).
When you open a page, the server processes what your browser sends for it: IP address, date and time, the address requested, the amount of data transferred, the status code, the page visited before and the identifier of your browser. We write the IP address to the log only in shortened form (for IPv4 the last two blocks removed), so that it can no longer be linked to a person. The logs serve secure operation and troubleshooting; they are overwritten continuously and not analysed.
The legal basis is our legitimate interest in a secure and working website (Art. 6 (1) (f) GDPR).
4. Contact and booking an appointment
Preview for your website. When you enter the address of your website, we fetch its start page once and take a picture of it for a computer and a phone, so you can try your Talky on it. We keep the picture for one day. If you then send it with your email address, we set up a provisional account with your website and your Talky, read up to 100 pages of your website and send you link and password of your preview, and one single reminder three days before it ends. We store your email address encrypted with the key of this account, do not use it for advertising and delete the account after 14 days together with the preview, the pages read and your email address; the key is destroyed in the process. For our statistics, the date, the domain of your website and whether a contract resulted remain, after 12 months only counts. To prevent abuse, your browser solves a small computing task before the picture and before sending, without a cookie and without any third-party service; how many previews come from one IP address we count in memory only, for one day. The legal basis is Art. 6(1)(b) GDPR (your request before a contract).
Preview for your website (request by form). If you send us the address of your website, your email address and, optionally, your name via “Preview for your website”, we store these details together with the language and the page you sent them from, in order to set up a preview for you and reply to you. We do not store your IP address for this. To prevent abuse, your browser solves a small computing task before sending, without a cookie and without any third-party service. If no contract results from the request, we delete the address, email and name after 12 months, and obvious abuse after 30 days.
Requesting the accessibility check. If you send the address of your website and your email address on the page "Accessibility check", we keep these details like a request by form (previous paragraph), with the language and the page you sent from, to send you the payment link and set up the check. Payment is by card with Stripe (Stripe Payments Europe, Ltd., Dublin, Ireland), which processes your payment details itself; we only receive the name or company, billing address, email address, where applicable the VAT ID, and whether payment was made. After payment we set up an account with your website for you, for which section 6 applies; the check only reads what is public on your website. We keep invoices as long as the law requires. The legal basis is Art. 6(1)(b) GDPR (your request and the contract) and, for keeping invoices, Art. 6(1)(c) GDPR.
Applying as a partner (partner.talkypage.com). If you apply on our partner site, we keep your name, your email address and, if you give them, your phone number, your company, the address of your website or profile, what you do and your message, with the language and the page you sent it from, to answer you and possibly take you on as a partner. We do not keep your IP address for this; before sending, your browser solves a small computing task, without a cookie and without any third party. The partner site loads the number of free places of the founding offer from live.talkypage.com, without any data about you. If no partnership follows, we delete your data after 12 months, obvious abuse after 30 days. The legal basis is Art. 6(1)(b) GDPR (steps prior to a contract).
You book an appointment through our booking calendar anpacken (book.anpacken.app), developed in-house by VRtual X GmbH. The calendar is loaded only when you click "Book an appointment"; before that, this website makes no connection to it. For the booking we process your name, e-mail address, the chosen time and anything you write to us, in order to hold the meeting. If you e-mail us instead, we process your details to answer your enquiry and, where appropriate, to prepare an offer or a contract.
The legal basis is the preparation of a contract (Art. 6 (1) (b) GDPR), otherwise our legitimate interest in answering enquiries (Art. 6 (1) (f) GDPR). We delete your enquiry once it is settled, unless commercial or tax law requires us to keep it longer (up to six or ten years).
5. The voice assistant on this website
On this website you can talk to our own AI assistant. It answers questions about TalkyPage from the content of this website and, if you wish, shows you the right place.
Before you start the conversation: When the page loads, your IP address is sent to our servers so that the assistant's button can be shown. Nothing is stored in your browser, no microphone is switched on and no connection to an AI provider is made.
When you start the conversation: Before that, you see a notice that you are talking to an AI and where your voice is sent. Your voice is streamed to our servers and from there to the AI provider, where it is recognised and answered:
- for the 3D figures to OpenAI (OpenAI, L.L.C., USA). The transfer to the USA is based on the EU-US Data Privacy Framework (adequacy decision, Art. 45 GDPR)
- for video figures to Google Cloud (Google Cloud EMEA Ltd.), processed in data centres in the EU
Your voice and the wording of the conversation are not stored. We only store the start, duration and entry page of the conversation and a pseudonymous identifier that changes daily; these are deleted after 13 months. The AI providers do not use the data for training.
Storage in your browser: Only after you have started the conversation does the assistant store the identifier of the conversation in the sessionStorage of this tab, so that it continues when you move to another page. It is deleted when you close the tab. This is strictly necessary for the service you asked for (§ 25 (2) no. 2 TDDDG). The assistant sets no cookies.
Legal basis: our legitimate interest in answering your questions about TalkyPage in conversation too and in showing the product on itself (Art. 6 (1) (f) GDPR). You decide whether to start a conversation and can end it at any time.
6. Customer area
Anyone using TalkyPage signs in at app.talkypage.com. There we process the account details (name, email address, password as a hash, a second factor if chosen), the details of the business and its settings in order to perform the contract (Art. 6 (1) (b) GDPR), and an audit log of important changes for security (Art. 6 (1) (f) GDPR). For signing in we set a session cookie that is strictly necessary for the service (§ 25 (2) no. 2 TDDDG).
What our customers process with TalkyPage on their websites, we process on their behalf under the data processing agreement. The respective customer is responsible there; their privacy policy provides information.
Elio, the helper Talky in the customer area: In the customer area you can talk or write to Elio, our AI helper that explains the customer area. Only when you start a conversation do your voice or your text go as a stream to our servers and from there to OpenAI (OpenAI, L.L.C., USA; EU-US Data Privacy Framework, Art. 45 GDPR). Elio sees the fields of the page you are on, never passwords or similar secrets. What you and Elio say or write is stored as text, encrypted and readable only for you, for 60 days, so that Elio goes on the same day where you stopped and can look back on earlier conversations; then it is deleted. Your voice is turned into text for this; no recording is stored. When you ask, Elio looks at your business's data in the customer area as far as you may see it, protocols of your website's conversations too; what it reads for this also goes to OpenAI and is not stored there. We also store when the conversation began, how long it lasted, what it cost and who held it, to limit and bill the minutes, and, without reference to a person, how often a piece of our help knowledge was looked up. If you ask Elio to report something to us, we store the report with your business, read it to improve TalkyPage and delete it after 24 months. The legal basis is the contract (Art. 6(1)(b) GDPR) and our legitimate interest in making the customer area understandable and improving it (Art. 6(1)(f) GDPR). You decide yourself whether to talk to Elio.
7. Recipients
Your data is received only by the service providers named in this policy who work for us. The complete, always current list is at Subprocessors. We do not sell data and do not pass it on for advertising.
8. Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and the right to object to processing based on our legitimate interest on grounds relating to your particular situation (Art. 21 GDPR). Write to us at datenschutz@talkypage.com.
You may also lodge a complaint with a supervisory authority. The authority responsible for us is the Hamburg Commissioner for Data Protection and Freedom of Information, Ludwig-Erhard-Straße 22, 20459 Hamburg, Germany.
9. Changes
If our offer or the law changes, we adapt this policy. The version published here applies.