AI processing consent

Valery Mironov, Behringstraße 20, 12437 Berlin, Germany, email: info@klarfold.com. Our Privacy Policy contains further information.

By giving your consent, you agree that

• we transmit the content that you use for an AI feature, for this purpose, via our server in Germany to the providers named in Sections 4 and 5, and that they process it; the legal basis for this is the contract with you (Art. 6(1)(b) GDPR);
• this also applies insofar as your content contains special categories of personal data, for example information about your health, about religious or political beliefs or about your sex life (Art. 9(2)(a) GDPR);
• providers also process your content outside the European Union, in particular in the USA, on the basis of the safeguards named in Section 6;
• your content is transmitted to a provider in a country without an adequate level of data protection and without appropriate safeguards (Art. 49(1)(a) GDPR). This currently concerns models from DeepSeek (People’s Republic of China) and, in My Ai, the image and video models Seedance (Malaysia, possibly also Ireland) and Kling (Singapore). We use these models only when you select them expressly: neither of our apps selects such a model on its own. In Ai Notes Studio, DeepSeek only receives content if you store your own DeepSeek key on the PRO API plan. We therefore only ask you for this consent at the moment when you select such a model or store such a key; if you do not give it, only that model remains unavailable. Section 7 explains the associated risks.

We only transmit the content that is required for the feature you are currently using. We do not transmit your email address or your account identifier.

Ai Notes Studio: audio recordings for transcription, together with entries in your dictation dictionary as a hint for spelling; transcripts and note texts for summaries, agents, titles and translations, together with the instructions of the agents, including your own; photos for text recognition; for “Ask AI”, your question, the last ten messages of the conversation and the notes in the scope you choose with title, folder, type, dates and content, as well as the name in your profile; for automatic filing, the beginning of the note text and your filing rules; for keyboard agents, the text you prepare and the instruction of the agent.

My Ai: your messages with attachments and the text of uploaded files; images and scanned PDFs that you add to a project, for text recognition; the last 20 messages of the chat; the instructions of the selected assistant and the sources of a project; insofar as you have provided them in your profile, your first and last name, your age and your gender; on the PRO plan with Memory switched on, the information saved to Memory and the names of your assistants and projects; the first message of a chat for its title; for Memory, the most recent messages of the chat; in voice conversations, your speech in real time together with the instructions of the assistant and the most recent messages; for reading aloud, the text of the message; for web search, the text of your message; for images and videos, the request, where applicable your photo, and the template image.

• Transcription: Groq, OpenAI or Google; if a provider fails, the next one takes over.
• Text features, text recognition, “Ask AI”, automatic filing and keyboard agents: OpenAI or Google; if one provider fails, the other takes over.
• Possible in future: models via OpenRouter and from NVIDIA. They will only be used once the necessary contracts are in place; the providers are named here already so that you know who may receive content.
• PRO API plan: exclusively the provider whose API key you store: OpenAI, Anthropic, Google, Groq, OpenRouter, xAI or DeepSeek. The processing then takes place on the basis of your own contract with this provider, whose terms govern storage and use for training. If you choose to use purchased PRO Minutes, the providers of the PRO plan apply. With OpenRouter, we only request providers that, according to OpenRouter, do not store inputs. If you use xAI, please enable processing without data retention (Zero Data Retention) in your xAI account; under xAI’s terms, personal data may only be transmitted in this way.

• Chat and image analysis: the model you select from OpenAI, Anthropic, Google or DeepSeek; with “Auto” and on the free plan, a model from OpenAI, Anthropic or Google. If a provider fails, the app may use a comparable model from OpenAI, Anthropic or Google and informs you of this.
• Chat titles, Memory and documents: low-cost models from OpenAI, Anthropic or Google that the app selects itself. We do not use models from DeepSeek for this.
• Images and videos: fal.ai with models from Google, OpenAI, xAI, ByteDance (Seedance) and Kuaishou (Kling).
• Voice conversations: Google and OpenAI; reading aloud: OpenAI or Google.
• Web search on the PRO plan: Google with Google Search and OpenAI with web search.
• Text recognition in project files: OpenAI, Anthropic or Google.
• Possible in future: models via OpenRouter and from NVIDIA, under the same conditions as in Section 4.

Whether a provider uses your content to train its models depends on the provider, the model and the type of access. We do not rule it out for any model – not even with paid access. We use models from several providers, switch between them depending on availability and partly use free quotas. Please assume that any content you give to an AI feature can be used for training. We do not train any models with your content ourselves. The information below states the seat, the transfer basis and the retention periods of each provider.

• OpenAI Ireland Ltd., 1st Floor, The Liffey Trust Centre, 117–126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland. Processing also in the USA on the basis of Standard Contractual Clauses. Stores inputs and outputs for up to 30 days for abuse detection, but not transcriptions.
• Anthropic Ireland, Limited, 6th Floor, South Bank House, Barrow Street, Dublin 4, D04 TR29, Ireland. Storage in the USA on the basis of Standard Contractual Clauses. Deletes inputs and outputs within 30 days, and in the event of violations of usage policies after up to two years; the results of the checks carried out for this purpose are kept for up to seven years.
• Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland. Processing possible worldwide, transfers to the USA on the basis of the EU-US Data Privacy Framework and Standard Contractual Clauses. Stores inputs and outputs for up to 55 days for abuse detection, and for 30 days for web search with Google Search, which Google may also use to troubleshoot and test this feature. Alongside the paid access we also use Google’s free quotas; for requests served under those quotas, Google may use the content to improve its products and therefore also for training.
• Groq UK Limited, 3 Hammersmith Grove, London W6 0ND, United Kingdom. Storage and processing in the USA on the basis of Standard Contractual Clauses. We use processing without data retention; Groq keeps logs for troubleshooting for no more than 30 days.
• OpenRouter, Inc., 169 Madison Avenue, New York, NY 10016, USA, on the basis of Standard Contractual Clauses. Does not store inputs and forwards requests to the provider of the selected model.
• NVIDIA Corporation, 2788 San Tomas Expressway, Santa Clara, CA 95051, USA. Processing in the USA. Under the terms of the NVIDIA API Catalog, inputs are stored for up to 30 days for security monitoring. Use only once a data processing agreement with Standard Contractual Clauses is in place.
• SpaceXAI LLC (xAI), USA, on the basis of Standard Contractual Clauses. Stores inputs and outputs for up to 30 days, but not in the case of processing without data retention; under xAI’s terms, personal data may only be transmitted in this way.
• Features & Labels, Inc. (fal.ai), 2261 Market Street, Suite 10467, San Francisco, CA 94114, USA, on the basis of Standard Contractual Clauses. Stores requests and results for up to 30 days; generated files can be retrieved via their link for at least seven days. May use anonymised or aggregated data to improve its services. May forward requests to the developers of the models or to their hosting partners: Google, OpenAI and xAI (USA), ByteDance (Malaysia, possibly also Ireland) and Kling AI Pte. Ltd. (Singapore).
• Hangzhou DeepSeek Artificial Intelligence Co., Ltd., People’s Republic of China. Stores data in China for as long as this is necessary for its purposes, and may use it for training. Neither an adequacy decision nor appropriate safeguards exist.

• USA: Under US law, authorities may access data under certain conditions. The EU-US Data Privacy Framework and the Standard Contractual Clauses are intended to ensure an adequate level of protection; an appeal against the adequacy decision is pending (Case C-703/25 P).
• People’s Republic of China, Malaysia and Singapore: The European Commission has not found an adequate level of data protection for these countries. Authorities may, under certain circumstances, access data without effective legal remedies being available to you, and it may not be possible to enforce your rights as a data subject there. In addition, DeepSeek may use your content for training.
• Storage and training by the providers: The providers store content temporarily and may use it to train their models. If a violation of their usage policies is suspected, employees of the providers may review content. Whatever has once gone into a model cannot be retrieved; please therefore do not give AI features any content that must under no circumstances leave your control.
• Results: AI results may be incomplete or incorrect.

Every consent is voluntary, and you can withdraw each of them at any time with effect for the future: in Ai Notes Studio under “Account” → “Plan and usage”, in My Ai in the app’s settings or by email to info@klarfold.com. Processing carried out until then remains lawful; the providers delete content already transmitted in accordance with the periods stated in Section 6. Your content in the app remains stored until you delete it or your account.

The consequences differ:

• Special categories of personal data (Section 2). We need this confirmation before you use the apps: your notes, recordings and chats may contain information about health, beliefs or similarly protected topics at any time, and we cannot separate it out. Without this confirmation, and after you withdraw it, we cannot provide the apps; the app then shows a notice with the options to give the confirmation again, to sign out or to delete the account.
• Transfers to countries without an adequate level of data protection (Section 2). We only ask for this consent when you select such a model. If you do not give it, or withdraw it, only that model remains unavailable; everything else continues to work.
• Usage analytics in My Ai. A separate, voluntary switch. Declining it has no consequences for using the app.

If your content contains information about other people, for example in recordings of meetings, you are responsible for ensuring that you are permitted to process this information and to use it for AI features. If you use Ai Notes Studio for business purposes, our Data processing agreement also applies. We do not conclude a data processing agreement for My Ai; My Ai is intended for personal use.

This consent bears version 2026-09-19.v5. If the providers or the scope of the transmission change materially, we will ask you for a new consent; until you agree to it, you cannot continue to use the app. Earlier versions, in particular version 2026-09-14.v2, no longer apply.

The apps display the following texts. The boxes are not pre-selected; the “Agree” button only becomes active once all items have been ticked. “Decline” is the same size and is not hidden. The text is displayed in German, English or Russian; for other interface languages, in English. The apps load the wording and the version number from our server; the copy shipped with the app is only used if it has the same version.

A. Before first use – both apps

This screen appears before the first start and again whenever the version of this consent changes. Heading: “Before you start”. Introduction in Ai Notes Studio: “Ai Notes Studio transcribes and processes your notes using AI models from other companies. Please read and confirm.” Introduction in My Ai: “My Ai works with AI models from other companies. Please read and confirm.”

• ☐ I agree that my content is transmitted to AI providers via the Klarfold server and that it may also contain special categories of personal data, for example information about health, beliefs or sex life. In Ai Notes Studio this is recordings, notes, photos, questions to the AI and the name from my profile; in My Ai it is messages, files, voice recordings and profile details. The providers are OpenAI, Anthropic, Google, Groq, xAI, fal.ai, OpenRouter and NVIDIA, including in the USA. They may store this data temporarily and use it to train their models; this cannot be ruled out for any model. Link “More about this”.
• ☐ I am at least 18 years old.
• ☐ I accept the Terms of Use and have taken note of the Privacy Policy. Links “Terms of Use” and “Privacy Policy”.

Buttons: “Agree” and “Decline”. After “Decline”, or after a withdrawal, the following appears: “Without these confirmations we cannot provide Ai Notes Studio.” or “Without these confirmations we cannot provide My Ai.” with the buttons “Back”, “Sign out” and “Delete account”.

B. When selecting a model from a country without an adequate level of data protection

This screen appears once per provider, at the moment you select such a model. If you decline, only that model remains unavailable; everything else continues to work.

• My Ai, a model from DeepSeek: ☐ I agree that my chat and the associated content are transmitted to DeepSeek in the People’s Republic of China. There is no adequate level of data protection there, authorities may under certain circumstances access the data, effective legal remedies may not be available to me, and DeepSeek may use the content for training. Link “More about the risks”.
• My Ai, the image or video models Seedance or Kling: ☐ I agree that my request and my photos are transmitted to ByteDance (Seedance) in Malaysia, possibly also in Ireland, or to Kuaishou (Kling) in Singapore. There is no adequate level of data protection for Malaysia and Singapore. Link “More about the risks”.
• Ai Notes Studio, your own DeepSeek key on the PRO API plan: ☐ I agree that my recordings and notes are transmitted with my own key to DeepSeek in the People’s Republic of China, where there is no adequate level of data protection and DeepSeek may use the content for training. Link “More about the risks”.

Buttons: “Agree” and “Cancel”. You can withdraw this consent where you select the model and in the settings.

C. Optional – My Ai only

On the same screen as A, clearly separated and switched off:

• ○ (optional) Send usage statistics: which steps I go through in the app. Can be turned off in the settings.

The “Agree” button does not depend on this switch.