Legal
Privacy.Information pursuant to Art. 13 and 14 GDPR
This English version is provided for convenience. The German version is authoritative.
1. Controller
The controller within the meaning of the General Data Protection Regulation (GDPR) and other data protection provisions is:
Creativate Technologies GmbH
Lahnstraße 65
60326 Frankfurt am Main, Germany
Represented by its Managing Director Leonardo Bornhäußer
Email: contact@creativate.tech
Zulano is a service of Creativate Technologies GmbH.
Data protection officer: You can reach our data protection officer at privacy@creativate.tech. You can contact them with any questions about data protection and about exercising your rights.
2. Scope
This notice applies to the website www.zulano.io and also describes the processing on the related services api.zulano.io (catalogue), app.zulano.io, zfu.zulano.io and bau.zulano.io, insofar as you reach them from this website.
3. Hosting and server logs
The website is hosted by Amazon Web Services EMEA SARL in the Frankfurt am Main region (eu-central-1) and delivered via the Amazon CloudFront content delivery network. When the site is accessed, technically necessary access data are logged: IP address, date and time, requested address, HTTP status, amount of data transferred, referring page and browser and operating system identifiers.
- Purpose
- Delivering the site, operational security, defending against attacks and analysing errors
- Legal basis
- Art. 6(1)(f) GDPR — legitimate interest in secure and trouble-free operation
- Retention
- Deleted as soon as the data are no longer required for these purposes; no fixed period has been set at present
- Recipients
- Amazon Web Services EMEA SARL as processor
4. Cookies and local storage on this website
This website sets no analytics, advertising or tracking cookies and does not embed any third-party services for analytics purposes. Details are in the Cookie Policy.
4.1 Language choice (cookie zulano_lang)
When you open a page and when you switch the language, a cookie zulano_lang with the value “de” or “en” is set. It contains only this information and no identifier that makes a person recognisable. Validity: twelve months; on zulano.io it applies to all subdomains.
- Purpose
- Keeping your language choice for your next visit
- Legal basis
- Section 25(2) no. 2 TDDDG — strictly necessary for the service you have expressly requested; additionally Art. 6(1)(f) GDPR
- Retention
- 12 months from being set; can be deleted in the browser at any time
- Recipients
- not disclosed
4.2 Notice about local storage
The notice at the bottom of the page records in your browser’s local storage (zulano_cookie_consent) that you have read it, so that it does not reappear on every visit. It does not set a cookie itself. As this website uses no services that require consent, it is not a consent banner: there is nothing to allow or refuse, so it only has one button to close it. You can show it again at any time via “Cookie settings” in the footer.
- Purpose
- Not showing the notice again after you have closed it
- Legal basis
- Section 25(2) no. 2 TDDDG — strictly necessary; additionally Art. 6(1)(f) GDPR
- Retention
- until you clear your browser data; no expiry date
- Recipients
- not disclosed — the value does not leave your browser
4.3 Fonts
The fonts used are bundled when the site is built and delivered from our own server. Visiting this website establishes no connection to Google or any other font provider; your IP address is not transmitted to them. This does not apply to the catalogue — see section 7.
5. Contact and appointment requests
Using the form at /kontaktyou can write to us or suggest a call. The following are transmitted: name, email address, optionally company and telephone number, your request, the “urgent” flag and — in appointment mode — the time slots you have chosen. The request is sent to a server at zfu.zulano.io and from there delivered by Amazon Simple Email Service (SES) to a mailbox of Creativate Technologies GmbH.
- Purpose
- Answering your request and arranging a call
- Legal basis
- Art. 6(1)(b) GDPR where the request concerns a contract or its initiation; otherwise Art. 6(1)(f) GDPR — legitimate interest in answering enquiries
- Retention
- until your request has been dealt with conclusively and no statutory retention obligations apply; no fixed period has been set at present
- Recipients
- Amazon Web Services EMEA SARL (hosting, SES) as processor
The form contains a field that is invisible to people, to fend off automated submissions. It is not evaluated if — as is usual for human input — it stays empty.
6. Trying the assistants for free (chat at /app)
On the page /app you can try the assistants without signing up. Your question and the conversation so far are sent to a server at app.zulano.io and passed on from there to AI providers to generate the answer.
Please do not enter personal data in the chat.
What you enter there is transmitted to service providers in the United States to generate the answer (see section 9). Please therefore avoid names, addresses, case numbers, health information and other details that make you or others identifiable. Describe your concern in general terms.
6.1 Content of the conversation
Only Groq, Inc. and OpenRouter, Inc., both based in the United States, are used to generate the answers. Google LLC, additionally named in section 8.4, is not used here.
- Purpose
- Answering your question and finding suitable services in the catalogue
- Legal basis
- Art. 6(1)(b) GDPR — performing the function you have requested; additionally Art. 6(1)(f) GDPR
- Retention
- Processing takes place to generate the answer; retention by the operator and the AI providers follows their terms and is not conclusively documented here
- Recipients
- Groq, Inc. and OpenRouter, Inc. (both US); Amazon Web Services EMEA SARL
6.2 Identifier and limit on questions
So that the free allowance is not used without limit, your browser stores a randomly generated identifier in local storage (zulano_sandbox_id). It consists of a random sequence, contains no information about you and is only sent to this service. In addition, your IP address is kept on the server for 24 hours in order to limit the number of requests.
- Purpose
- Preventing misuse and assigning the free allowance
- Legal basis
- Art. 6(1)(f) GDPR — legitimate interest in protection against excessive use
- Retention
- Identifier: until you clear your browser data · IP address: 24 hours plus one hour until automatic deletion
- Recipients
- Amazon Web Services EMEA SARL as processor
7. Catalogue (api.zulano.io)
The catalogue loads its fonts directly from fonts.googleapis.com. In doing so, your IP address is transmitted to Google Ireland Limited and possibly to Google LLC in the United States. This transmission happens automatically when the catalogue is opened, before you can influence it.
- Purpose
- Displaying the page in the intended fonts
- Legal basis
- Art. 6(1)(f) GDPR — legitimate interest in a consistent display. Note: switching this to local delivery is planned.
- Retention
- no storage by us; Google's terms apply to processing at Google
- Recipients
- Google Ireland Limited, Ireland; Google LLC, US
This embedding does not exist on this website (www.zulano.io) — the fonts are delivered from our own server here (section 4.3).
8. Applications at zfu.zulano.io and bau.zulano.io
8.1 User account
An account is required for the application assistants. Sign-in runs via Amazon Cognito; email address and password are collected, and confirmation takes place via a code sent by email. Passwords are stored only as hash values.
- Purpose
- Creating the account, signing in, assigning your applications
- Legal basis
- Art. 6(1)(b) GDPR — performance of the user agreement
- Retention
- for the lifetime of the account; after its deletion the data are removed unless statutory retention obligations apply
- Recipients
- Amazon Web Services EMEA SARL as processor
8.2 Application data
The information you enter into an application is stored in a database (Amazon DynamoDB) in the Frankfurt am Main region.
- Purpose
- Creating, saving and outputting the application as a document
- Legal basis
- Art. 6(1)(b) GDPR
- Retention
- for the lifetime of the account; after its deletion the data are removed unless statutory retention obligations apply
- Recipients
- Amazon Web Services EMEA SARL as processor
8.3 Intermediate state in the building assistant
The building assistant keeps your intermediate state exclusively in your browser’s local storage. This information is not transmitted to a server; it stays on your device until you clear your browser data.
8.4 AI support in the assistant
To suggest and fill in application fields, to check your information for completeness and to analyse web addresses you provide, your input is transmitted to AI providers: Groq, Inc., OpenRouter, Inc. and Google LLC (Gemini model). All three are based in the United States; this is therefore a transfer to a third country (see section 9). Here, too, please only enter the information required for the application.
- Purpose
- Suggesting and filling in application fields, checking information for completeness, analysing web addresses provided
- Legal basis
- Art. 6(1)(b) GDPR — performing the function you have requested
- Retention
- Processing to generate the answer; retention by the providers follows their terms
- Recipients
- Groq, Inc., OpenRouter, Inc. and Google LLC (all US)
8.5 Payment processing
Where a paid service is offered and booked by you, payment is processed by Stripe Payments Europe, Limited, Ireland. Your payment details — such as card number or bank details — are entered directly at Stripe and not transmitted to us; we only receive the information whether the payment was successful. As long as no paid service is booked, this processing does not take place.
- Purpose
- Processing a payment you have instructed
- Legal basis
- Art. 6(1)(b) GDPR
- Retention
- in accordance with the retention periods under commercial and tax law
- Recipients
- Stripe Payments Europe, Limited, Ireland
9. Transfers to third countries
The AI providers used are based in the United States. With every request, the content you enter is transmitted there:
- Groq, Inc. and OpenRouter, Inc. — when trying the service at /app (section 6) and in the application assistants (section 8.4)
- Google LLC (Gemini model) — only in the application assistants (section 8.4), not when trying the service at /app
For the United States, an adequacy decision of the European Commission exists only for companies certified under the EU-US Data Privacy Framework. Where a provider is not certified, the transfer is based on the European Commission’s standard contractual clauses under Art. 46(2)(c) GDPR.
Despite these safeguards, it cannot be ruled out that US authorities access the transmitted data and that you have no legal remedies comparable to those in the European Union. Please therefore do not enter personal data into the AI-supported functions.
Embedding the fonts in the catalogue (section 7) can also trigger a transfer to Google LLC in the United States.
10. Overview of recipients
10.1 Used by Zulano
| Recipient | Purpose | Location |
|---|---|---|
| Amazon Web Services EMEA SARL | Hosting, delivery (CloudFront), database (DynamoDB), accounts (Cognito), email (SES) | EU — Frankfurt am Main |
| Groq, Inc. | AI requests at /app and in the application assistants | US |
| OpenRouter, Inc. | AI requests at /app and in the application assistants | US |
| Google LLC | AI requests in the application assistants (Gemini) | US |
| Google Ireland Limited / Google LLC | Fonts in the catalogue (api.zulano.io) | Ireland / US |
| Stripe Payments Europe, Limited | Payment processing, if booked | Ireland |
10.2 Other sub-processors of Creativate Technologies GmbH
The following service providers are part of the shared infrastructure of Creativate Technologies GmbH and are listed in its data processing agreement. At Zulano they currently receive no data. If that changes, this notice will be updated beforehand.
| Recipient | Purpose | Location |
|---|---|---|
| Anthropic | AI language model (Claude) | US |
| OpenAI | AI language model (GPT) | US |
| HuggingFace | ML model hosting and inference | EU / US |
| HubSpot | CRM and marketing automation | EU — Germany |
11. Your rights
You have the right to:
- access the data processed about you (Art. 15 GDPR)
- rectification of inaccurate data (Art. 16 GDPR)
- erasure (Art. 17 GDPR)
- restriction of processing (Art. 18 GDPR)
- data portability (Art. 20 GDPR)
- object to processing based on a legitimate interest (Art. 21 GDPR)
- withdraw consent given, with effect for the future (Art. 7(3) GDPR)
An informal message to our data protection officer at privacy@creativate.tech is sufficient to exercise these rights.
12. Right to lodge a complaint with a supervisory authority
Irrespective of this, you can lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement. The authority responsible for Creativate Technologies GmbH is:
Der Hessische Beauftragte für Datenschutz und Informationsfreiheit
Gustav-Stresemann-Ring 1
65189 Wiesbaden, Germany
13. Data security
Transmission between your browser and our servers is encrypted with TLS throughout. Passwords are stored only as hash values. Access to stored application data is restricted to signed-in users.
14. No automated decision-making
No automated decision-making, including profiling, within the meaning of Art. 22 GDPR takes place. The AI-supported functions produce suggestions and draft texts; you decide yourself how to use them.
Last updated: 20 October 2026 · This notice is updated when the services or the legal situation change.