Privacy Policy

The controller responsible for the processing of personal data within the meaning of the General Data Protection Regulation (GDPR) is:

A data protection officer has not been appointed, as there is currently no legal obligation to do so.

We process the personal data of our users exclusively in accordance with applicable data protection laws, in particular the GDPR, the Austrian Data Protection Act (DSG), and relevant telecommunications law provisions.

Personal data is processed only insofar as this is:

• necessary for the provision and performance of our contractual services,
• based on a voluntary consent, or
• based on a legal obligation.

When registering a user account, the following data is processed:

• E-mail address
• Name (optional)
• Password (stored encrypted)
• Device and system information (e.g. operating system, app version)

Purpose of processing: Creation and administration of the user account, provision of app functionalities.

Legal basis: Art. 6 (1) (b) GDPR (performance of a contract).

Netly is a personal CRM (Customer Relationship Management) for managing personal contacts, tasks, appointments and notes.

Depending on usage, the app processes in particular:

• Contact data from the local phone book (only with explicit user authorization)
• Calendar data from connected services (Google Calendar, Apple Calendar, Microsoft Calendar)
• Tasks, reminders and notes
• User-defined fields (custom fields)

External calendar or contact services are only connected after active user authorization via the respective interfaces.

Use of Google user data: When Netly accesses data from Google APIs (in particular Google Calendar and Google Contacts), its use, storage and sharing of that data adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

• We use Google user data solely to provide and improve the user-facing features of Netly.
• We do not sell Google user data.
• We do not use Google user data for advertising.
• Humans do not read your Google data - except with your explicit consent, to resolve security or abuse incidents, where required by law, or in aggregated/anonymized form to maintain internal operations.

Legal basis: Art. 6 (1) (b) GDPR (performance of a contract).

The app allows users to voluntarily store special categories of personal data within the meaning of Art. 9 GDPR (e.g. religious beliefs, dietary preferences or other sensitive information).

This data is:

• processed exclusively at the user's initiative,
• used only for the features chosen by the user,
• not used for other purposes without explicit user action.

Legal basis: Art. 9 (2) (a) GDPR (explicit consent by active input or conscious use of the corresponding functions).

Netly uses integrated AI-powered functions to support users, in particular for:

• Analysis of entered content,
• Generation of suggestions (e.g. contact prioritization, task recommendations),
• Summarization and structuring of information.

AI is an integral part of the app and is used automatically within the provided functions.

The AI processes only data:

• that the user themselves enters into the app, or
• whose processing the user explicitly triggers.

This may also include sensitive data, provided the user stores it themselves or consciously includes it in an AI function.

To provide certain AI functions, we use external AI service providers (currently in particular OpenAI). In doing so, content may be transmitted for processing to servers outside the European Union.

AI-generated suggestions are intended to support the user and do not replace independent decisions by the user.

Legal basis: Art. 6 (1) (b) GDPR (performance of a contract); for sensitive data additionally Art. 9 (2) (a) GDPR.

To ensure the functionality, quality and further development of the AI functions, we process:

• Content of AI requests
• Generated AI results

This processing takes place exclusively in connection with the use of the AI functions and not for general marketing or tracking purposes.

Legal basis: Art. 6 (1) (b) GDPR (performance of a contract).

If users activate push notifications, we process corresponding device identifiers in order to deliver reminders, tasks or relevant app information.

Push notifications can be deactivated at any time via the app settings or the respective operating system.

Legal basis: Art. 6 (1) (a) GDPR (consent).

If users expressly consent, we use the e-mail address for:

• Product news
• Newsletter
• Information about updates, offers and waitlists

Delivery is performed via the service provider Mailchimp (Intuit Inc.). Personal data may be transferred to the USA or other third countries.

Consent can be withdrawn at any time.

Legal basis: Art. 6 (1) (a) GDPR (consent).

The app is operated on servers of Amazon Web Services (AWS) within the European Union. No external backups are made outside the EU.

We use appropriate technical and organizational measures to protect personal data from loss, misuse or unauthorized access.

Recipients of personal data may include:

• IT service providers and hosting providers (AWS)
• E-mail service providers (Mailchimp)
• Providers of AI services (e.g. OpenAI)

All service providers are contractually obligated to comply with data protection regulations.

Personal data is stored only for as long as is necessary for the respective purposes or for as long as legal retention obligations exist.

After termination of the user account, the data will be deleted within reasonable timeframes, unless legal obligations prevent this.

Users have the right at any time to:

• Access
• Rectification
• Erasure
• Restriction of processing
• Data portability
• Object to certain processing

Requests can be sent at any time to office@netly-crm.com.

Consents can be withdrawn at any time with effect for the future, without affecting the lawfulness of processing carried out until then.

Users have the right to lodge a complaint with the competent supervisory authority:

We reserve the right to adapt this privacy policy as needed in order to reflect legal or technical changes.