This policy explains what data we collect, why we collect it, where it goes, and what rights you have. We keep it short and concrete — no dark patterns, no buried clauses.
Last updated: 16 May 2026
Foth Group GmbH operates spicyemilia.com and is the controller of personal data processed through this service within the meaning of Art. 4(7) GDPR.
We deliberately collect only what we need to run the service:
We do not use any third-party analytics, social-media trackers, advertising pixels, or fingerprinting. No data is shared with advertisers or data brokers. Ever.
| Purpose | Legal basis |
|---|---|
| Creating and securing your account, delivering chat replies, generating images you request, sending magic-link sign-in emails | Performance of contract — Art. 6(1)(b) GDPR |
| Processing intimate or sexual content within your chats (Art. 9 special category) | Your explicit consent given at sign-up — Art. 9(2)(a) GDPR. You can withdraw consent at any time by deleting your account |
| Security monitoring, rate-limiting, fraud and abuse prevention | Our legitimate interest — Art. 6(1)(f) GDPR |
| Complying with statutory obligations (tax, recordkeeping, lawful requests) | Legal obligation — Art. 6(1)(c) GDPR |
We use a small number of carefully selected providers. All have signed data-processing agreements (Art. 28 GDPR) with us:
| Provider | Role | Location |
|---|---|---|
| Hetzner Online GmbH | Hosting, database, file storage | Falkenstein, Germany (EU) |
| BytePlus Pte. Ltd. | AI inference for chat replies and image generation | Singapore (third country) |
| Resend, Inc. | Transactional email (magic links, account notifications) | United States (third country) |
BytePlus (Singapore) and Resend (United States) process data outside the EU/EEA. Singapore has been recognised by the European Commission as offering an adequate level of protection for the categories of data we transmit (no special category data is transmitted to Resend; chat content sent to BytePlus is processed transiently for inference and not retained by BytePlus per their data-processing terms). For the US transfer to Resend we rely on the EU-US Data Privacy Framework and, as a fallback, the EU Standard Contractual Clauses (Module 2) plus supplementary technical and organisational measures.
Your chat messages are transmitted to BytePlus only as needed to generate a reply. We do not allow BytePlus to retain, train on, or otherwise reuse the content of your conversations.
Under the GDPR you have the following rights, exercisable free of charge:
To exercise any of these rights, email kontakt@fothgroup.de. We respond within one month as required by Art. 12(3) GDPR.
You can delete your account at any time from within the app, which triggers irreversible deletion of your messages, generated media, persona state and account record. Backups containing prior states cycle out within 30 days.
This service is strictly for adults. You must be at least 18 years old (or the higher age of majority in your jurisdiction) to sign up. We do not knowingly collect data from minors. If you believe a minor has accessed the service, please contact us immediately at kontakt@fothgroup.de.
All content on spicyemilia is generated by AI. Our generation pipeline and policy explicitly exclude content depicting minors, non-consensual scenarios, real-person deepfakes, violence against persons, and any content prohibited under §§ 130, 184a–c German Criminal Code or § 4 of the German Interstate Treaty on the Protection of Minors (JMStV). User prompts targeting such content are filtered server-side and may result in immediate account termination.
If you encounter content on this site that you believe violates these standards or applicable law, please report it to kontakt@fothgroup.de. Include a URL or screenshot, the reason for your report, your contact details for follow-up, and whether you are reporting as a private individual, an EU trusted flagger within the meaning of Art. 22 DSA, or a public authority. We acknowledge receipt within 24 hours and issue a reasoned decision within 72 hours, together with information on remedies and internal complaint mechanisms pursuant to Art. 16, 17 and 20 of the EU Digital Services Act.
Conversations on spicyemilia are conducted with an artificial-intelligence character. The persona's replies, generated images and adaptive intensity setting are produced by AI models, not by a human writing in real time. We do not use the data we hold about you to make decisions that produce legal effects or similarly significantly affect you within the meaning of Art. 22 GDPR.
We use TLS for all connections, encrypted storage at rest, hashed and salted credentials, and strict access controls. No system is perfectly secure, but we apply industry-standard safeguards proportionate to the sensitivity of the data we hold.
We may update this policy from time to time. Material changes will be communicated by email to your registered address and announced in the app at least 14 days before they take effect. Continued use of the service after that period constitutes acceptance of the updated policy.
Privacy questions, rights requests, complaints:
kontakt@fothgroup.de
Foth Group GmbH, Seehofstraße 137, 14167 Berlin, Germany