01
Who is responsible?
LessWord UG (haftungsbeschränkt)Managing Director: Philipp Gühlholtz
Adelheidstraße 32
80796 Munich, Germany
Email: lesswordug@gmail.com
This notice covers the LessWord website and its Avyron and Color.Cee pages. The privacy rules of Apple, Google and other destinations apply after you use their services or follow a link to them.
02
Website delivery, hosting and aggregated analytics
When you open the website, the hosting infrastructure necessarily processes access data. This can include your IP address, the requested page or file, date and time, request result, referrer URL, browser, operating system, device type and language settings. We use this processing to deliver the site, maintain security, diagnose faults and prevent misuse.
The legal basis is Article 6(1)(f) GDPR. Our legitimate interests are the reliable, secure and understandable provision of this website and the protection of our systems.
The website is hosted through ChatGPT Sites, a service provided by OpenAI. OpenAI and its listed subprocessors may provide hosting, infrastructure, content-moderation and support services for Sites. OpenAI identifies Cloudflare, Ltd. as a content-delivery and web-hosting provider. More information is available in the OpenAI subprocessor list and OpenAI privacy policy.
Sites records traffic automatically and makes aggregated statistics available to us, including visitors and page views as well as breakdowns by page, source, device and country and metrics such as session duration and bounce rate. LessWord does not receive names, email addresses or individual visitor profiles through this analytics view, and we do not add a separate analytics SDK, advertising pixel or profiling tool.
LessWord does not independently retain raw hosting logs. Their retention is governed by the hosting provider’s service and privacy terms. We use the aggregated Sites statistics only to understand whether the website is useful and functioning as intended.
04
Email contact and Avyron team applications
The site uses email links rather than a contact form. If you email us, we process your address, message, technical email metadata and any attachments to answer your request and take the steps you ask us to take. Providing this information is voluntary; without a return address or sufficient context, we may be unable to respond.
For general enquiries, the legal basis is Article 6(1)(f) GDPR (our legitimate interest in communicating with interested people and business contacts). If your message concerns a contract or steps requested before a contract, Article 6(1)(b) GDPR also applies.
Messages are received in Gmail. Google therefore processes email data as the email service provider. Depending on the processing location, data may also be processed outside the EEA. Google describes its processing and international-transfer safeguards in the Google privacy policy and data-transfer framework information.
We delete ordinary correspondence when the matter is completed and no legitimate reason for further retention remains. Where a message is a legally relevant business or tax record, we retain it for the applicable statutory period.
If you contact us about joining the Avyron team, we process your application information to assess and conduct the application process under Article 6(1)(b) GDPR together with Section 26 BDSG. If no collaboration or employment results, we normally delete application data no later than six months after the process ends, unless you consent to longer retention or the data is required to establish, exercise or defend legal claims.
05
Apple, Google Play and other external links
The Color.Cee page displays official store-badge artwork from Apple and Google servers. Loading that page therefore creates a technical request to those providers. They may receive information such as your IP address, browser and device data, the time of the request and the requested resource. We suppress the referrer header on these badge requests where the browser supports it.
The legal basis for displaying the current official download paths and unmodified store artwork is Article 6(1)(f) GDPR. Our legitimate interest is to give visitors a clear, trustworthy route to the released app. Apple and Google process data under their own responsibility; see the Apple privacy policy and the Google privacy policy.
Other external links transfer you to the destination only when you select them. The destination provider then processes the access under its own terms. We use noreferrer on external store links to reduce the information sent from this website.
06
Recipients and international transfers
Personal data is disclosed only where needed to operate the website, handle your communication, comply with law or protect legal rights. Relevant recipients can include OpenAI and its hosting subprocessors, Google as email provider, Apple and Google for the remotely loaded store badges and external destinations you choose to visit.
ChatGPT Sites does not currently offer data residency. Processing may therefore take place outside the EEA. Where data is transferred to a country without an EU adequacy decision, providers state that they use appropriate safeguards such as the European Commission’s Standard Contractual Clauses. Further details are available in the provider policies linked above.
07
Your rights
Subject to the legal conditions, you can request access, correction, deletion, restriction of processing and data portability. You can withdraw consent at any time for the future. Where processing is based on Article 6(1)(f) GDPR, you can object for reasons arising from your particular situation. Contact lesswordug@gmail.com to exercise these rights.
You also have the right to complain to a data-protection authority. The supervisory authority responsible for private companies in Bavaria is the Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 18, 91522 Ansbach, Germany.
08
No automated decisions
LessWord does not use personal data collected through this website for automated decision-making or profiling within the meaning of Article 22 GDPR.
We update this notice when the website, providers or legal requirements change. The version published here is the current version.