The data controller within the meaning of the General Data Protection Regulation (GDPR) is:
Marvin Rüßbüldt
c/o IP-Management #8928, Ludwig-Erhard-Straße 18, 20459 Hamburg, Germany
Email: info@goru.rocks
In the course of operating the goru.rocks platform, the controller processes the following categories of personal data:
(a) account data: email address, display name, and the identifier of the OAuth provider (provider user ID), obtained via the Google OAuth or Discord OAuth login;
(b) payment data: transaction data processed via Stripe;
(c) generated videos: the video files created by the user;
(d) activity logs: log data relating to video generations, renders, purchases, logins, and Live Chat activity; the details are described in Section 3;
(e) generated scripts: the full text of the generated video scripts;
(f) consent logs: evidence data on consents given during paid transactions and on the Join-Consent declaration when entering public Live Chat rooms;
(g) IP addresses: for securing operations and for abuse prevention;
(h) script drafts: drafts stored in the local storage of the browser (localStorage), which do not leave the user's browser;
(i) Live Chat messages: message content exchanged in public or private rooms;
(j) Live Chat username: the display name set by the user for the Live Chat;
(k) Live Chat character: the character (country with flag) selected per room;
(l) Reports: data on reported Live Chat messages including the reason for reporting and, where applicable, the surrounding message context.
For the secure provision of the Platform, for abuse detection, for error correction, and for quality improvement, the controller logs certain activities. The following data are recorded in detail:
(1) For each video generation and each render:
(a) IP address;
(b) user identifier (user ID) for logged-in users, or session identifier (session ID) for users who are not logged in;
(c) the topic or prompt entered;
(d) the generated script in its full wording;
(e) the characters used (names and type);
(f) the selected format (Chat or Quiz);
(g) the selected tab (Countries or Characters);
(h) the timestamp;
(i) the user's usage plan;
(j) the credits spent (number and purpose).
(2) For each purchase:
(a) IP address;
(b) user identifier (user ID);
(c) the product purchased (subscription plan or credit package);
(d) the amount;
(e) the payment method;
(f) the timestamp;
(g) the accepted version of the Terms;
(h) confirmation of the relevant controls (checkbox confirmations).
(3) For each login and each account action:
(a) IP address;
(b) timestamp;
(c) the OAuth provider used (Google or Discord).
(4) For each Live Chat activity:
(a) IP address;
(b) user identifier (user ID);
(c) Username;
(d) the selected character;
(e) room identifier and type of room (public or private);
(f) message content;
(g) timestamp;
(h) the action performed (in particular joining, leaving, sending a message, mute by the host, submission of a Report).
(5) Live Chat messages are stored on the server side and are encrypted at rest using AES-256 encryption. There is no end-to-end encryption in either public or private rooms. Server-side storage and the ability to decrypt messages are prerequisites for the moderation of reported messages (Section 4(3), Section 12(2)) and for the generation of highlight and session videos from the Live Chat.
Processing of the data referred to in Sections 2 and 3 is based on the following legal bases:
(1) Performance of a contract pursuant to Art. 6(1)(b) GDPR for: account data, payment data, generated videos, the purchase- and account-related log data (Section 3(2) and (3)), and the provision of the Live Chat including the processing of Live Chat messages, Username, character selection, and the Live Chat log data (Section 3(4)).
(2) Legal obligation pursuant to Art. 6(1)(c) GDPR for: payment data and consent logs within the scope of tax retention obligations.
(3) Legitimate interest pursuant to Art. 6(1)(f) GDPR for: the activity logs (Section 3(1)), IP addresses, generated scripts, the moderation of the Live Chat including the preliminary review of reported messages by an artificial intelligence service, and the retention of reported messages for evidentiary purposes. The legitimate interest consists in the secure provision of the Platform, abuse detection, error correction, quality improvement, and the protection of users from unlawful content in the Live Chat.
(4) Script drafts are stored exclusively in the user's local browser storage and are not transmitted to the controller.
The data categories referred to are retained for the following periods:
(a) activity logs relating to generations and renders: 12 months, followed by anonymisation;
(b) IP addresses: 30 days in the activity log, followed by deletion;
(c) generated scripts: 12 months with personal data, then anonymised (user ID, IP address, and session ID are removed); anonymised scripts are retained indefinitely for analytics and service improvement;
(d) purchase data and consent logs: 10 years pursuant to tax retention obligations;
(e) account data: until deletion of the user account;
(f) generated video files: 24 hours after creation, followed by deletion;
(g) script drafts: until deleted by the user in local browser storage;
(h) Live Chat messages in public rooms: stored permanently until deletion of the user account;
(i) Live Chat messages in private rooms: stored permanently until deletion of the user account;
(j) reported messages (Reports) including the surrounding message context: 90 days for evidentiary purposes, followed by deletion;
(k) Live Chat Username, character assignments, and other Live Chat master data: until deletion of the user account.
After expiry of the respective retention period, the personal components (in particular IP address and user identifier) are removed from the logs. Anonymised and aggregated data without personal reference, such as the number of videos generated per day, may be stored for an unlimited period.
(1) Backups are created regularly to secure the Platform. Backups may contain personal data. Backup data are overwritten and deleted in accordance with the regular backup rotation cycle.
(2) The backup rotation cycle is structured as follows:
(a) daily backups are retained for 30 days;
(b) weekly backups are retained for 90 days;
(c) after expiry of these periods, the backups are automatically overwritten or deleted.
(3) In addition, backup copies may be retained on external, offline storage media for the purpose of disaster recovery. These archival backups are not actively processed, not accessed, and are not subject to any rotation cycle. Personal data contained in such archival backups may therefore be stored indefinitely. In the event of an erasure request pursuant to Art. 17 GDPR, the data are deleted from the active system without undue delay; data contained in archival backups remain for technical reasons until the respective storage medium is eventually overwritten and are processed solely in the event of disaster recovery.
(1) The Platform is operated on the servers of an external hosting provider located within the European Union.
(2) Each access automatically records and stores information in server log files, which are automatically deleted after 30 days. Processing is based on the legitimate interest in the secure and efficient provision of the online service pursuant to Art. 6(1)(f) GDPR.
(1) The controller engages the following services:
(a) Stripe: payment processing;
(b) OpenAI: generation of video scripts and preliminary review of reported messages for moderation of the Live Chat;
(c) Google: OAuth login. The controller accesses solely the display name, the email address, and the Google account identifier;
(d) Discord: OAuth login. The controller accesses solely the display name, the email address, and the Discord user identifier;
(e) hosting provider located within the European Union: operation of the servers.
(2) For operational purposes, the controller sends internal notifications to itself, for example regarding purchases, errors, and registrations. Delivery takes place via a Discord webhook and by email via the controller's own mail server. The notifications contain the event type (for example "New purchase: Starter plan"), a timestamp, and, where applicable, the email address of the affected user account for internal identification. IP addresses and full scripts are not part of these notifications. Where delivery occurs via Discord, no user data beyond the aforementioned content is transmitted to Discord.
The use of Stripe, OpenAI, Google, and Discord may result in transfers of personal data to the United States of America. These providers ensure an adequate level of data protection through Standard Contractual Clauses pursuant to Art. 46 GDPR or a data processing agreement.
(1) The controller uses solely technically necessary means:
(a) a session cookie for maintaining the login;
(b) the local browser storage (localStorage) for saving script drafts.
(2) In the course of payment processing, Stripe may set its own cookies. Their necessity depends on the respective cookie type.
(3) No marketing or tracking cookies are used.
(1) For the generation of video scripts, the topics entered by the user are transmitted to OpenAI. No account data or other identifying characteristics of the user are transmitted in this context.
(2) For the moderation of reported Live Chat messages, the content of the reported message and, where applicable, the preceding message context are transmitted to OpenAI. Personal identifying characteristics of the user (in particular email address, Username, user ID) are not transmitted to OpenAI in this context. The final decision on the merit of a Report rests with the controller.
(1) The user has the following rights:
(a) access to the data stored about the user (Art. 15 GDPR);
(b) rectification of inaccurate data (Art. 16 GDPR);
(c) erasure of the user's data (Art. 17 GDPR);
(d) restriction of processing (Art. 18 GDPR);
(e) data portability (Art. 20 GDPR);
(f) objection to processing (Art. 21 GDPR);
(g) lodging a complaint with a supervisory authority (Art. 77 GDPR).
(2) The data export and the deletion of the user account can be carried out by the user directly in the account settings (profile) at any time. The remaining rights may be exercised via info@goru.rocks.
(3) The competent supervisory authority is the Hamburg Commissioner for Data Protection and Freedom of Information (Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit), Ludwig-Erhard-Straße 22, 20459 Hamburg, Germany.
(1) The user may delete their user account in full at any time directly in the account settings (profile).
(2) Upon deletion, the account data are deleted from the active system without undue delay. Any existing subscription is cancelled; the billing period already paid is not refunded. Unspent credits expire without substitute and without any claim to a refund. Payment and consent data continue to be stored for the duration of the statutory retention periods and are erased thereafter. Section 7 applies to data contained in backups.
The controller may amend this Privacy Policy. Registered users will be notified of material changes by email and prompted to review and accept the updated version upon their next login. The currently applicable version is made available at goru.rocks/privacy.
For data protection enquiries: Marvin Rüßbüldt, info@goru.rocks