How we treat your data.

• Profile you provide during onboarding: first name, age range, gender, industry, role, language and avatar.
• Personality questionnaire answers used only to personalize your scenarios.
• Your scenario attempts, choices, and audit history, so you can track your own growth.
• Optional photo if you choose AI avatar stylization. The original photo is not retained after stylization.
• Standard technical logs (errors, latency) needed to keep the app running.

We do not sell personal data. We do not use your private practice content to advertise to you.

User data is stored in our managed backend with encryption in transit (TLS) and at rest. AI requests (scenario generation, coaching feedback, narration, translation) are sent to enterprise AI providers under data-processing agreements; prompts and completions are not used to train third-party foundation models.

For EU customers we operate under EU data-residency for the primary user database. India-based customers can request a documented sub-processor map listing where their data physically sits.

• Lawful basis: contract performance for the core app, and your consent for optional features like AI avatar stylization.
• You can request access, correction, export or deletion of your data at any time via the contact below.
• Data Processing Agreement (DPA) available on request for B2B customers.
• Sub-processors listed and updated in our public sub-processor register, sent on request.

Win-Win uses generative AI to author practice scenarios, coaching feedback and narration. We classify these features as limited-risk with transparency duties: outputs are labelled as AI-generated in the app, and the system makes no consequential decisions about people.

• No emotion recognition. Emotions are self-reported by the user and never inferred from face, voice or biometric signals, so the prohibited practice does not apply.
• No employment decisions. Individual results stay private to the person practising and are never used for hiring, promotion, ranking or discipline.
• Generated text, audio and avatar images are marked as generated where they appear.
• A human on our team reviews complaints about AI output and can correct the system.
• AI literacy material is published in the app so users understand its limits before they rely on it.

Win-Win is explicitly not a therapy, medical, legal or financial tool. The app surfaces a redirect to local resources if a user types crisis-flag content.

We know that introducing a learning tool with behavioural feedback triggers § 87 Abs. 1 Nr. 6 BetrVG. To make co-determination easy we provide, on request:

• A German-language Betriebsvereinbarung template.
• A Datenschutz-Folgenabschätzung (DPIA) skeleton scoped to Win-Win.
• Confirmation that individual scenario choices are never shared with the employer; only anonymized, aggregated usage is.
• Opt-out: any employee can use the app without their data feeding any aggregate dashboard.

• Notice and consent are presented in clear language at onboarding and before any optional AI feature.
• Users can withdraw consent and request erasure via the contact below.
• For team deployments we sign a Data Processing Addendum naming the employer as Data Fiduciary and Win-Win as Data Processor.
• We do not knowingly process data of children under 18 without verifiable parental consent.

• Active accounts: data retained while the account is in use.
• Inactive accounts: anonymized after 24 months unless you request earlier deletion.
• On deletion request: personal identifiers are removed within 30 days; backups roll off within 90 days.

Security and privacy questions, DPA / DPDP / Betriebsrat document requests, vulnerability reports: write to our team via the request form on the team access page.

The list below is a plain-English summary of the sub-processors Win-Win relies on. A signed, versioned register with legal entity names and locations is available on request under DPA / DPDP.