Privacy policy

Last updated: October 15, 2026

1. Who is responsible

The controller for the processing of personal data on this website and in connection with our services is:

Further details are in our legal notice.

2. Visiting this website

This website is hosted by dogado GmbH, Antonio-Segni-Straße 11, 44263 Dortmund, Germany. When you visit the site, the server automatically records technical information that your browser transmits: IP address, date and time of the request, the page requested, the referring page, and browser and operating system details.

We use this information only to deliver the website and to keep it secure and stable. The legal basis is our legitimate interest in operating a secure website (Art. 6(1)(f) GDPR). The log data is not combined with other data and is deleted or anonymised once it is no longer needed for these purposes. dogado processes this data on our behalf under a data processing agreement (Art. 28 GDPR).

3. No cookies, no tracking

This website does not use cookies, analytics, advertising or tracking tools. Fonts and videos are served from our own server, so no data is sent to third-party font providers or video platforms.

This website links to websites of other organisations. When you follow such a link, their privacy policies apply.

4. Contacting us

If you email us, we process your email address, your name and the content of your message to answer your request. The legal basis is the preparation or performance of a contract (Art. 6(1)(b) GDPR) or our legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR). We delete this correspondence when it is no longer needed, unless statutory retention periods apply (for example, for business letters and invoices under German commercial and tax law).

Our email is hosted by dogado GmbH (see section 2), which processes it on our behalf under the same data processing agreement.

5. Images and materials you send us

To deliver our services, you may send us product photos, listing links, scripts, documents or other materials. We use them solely to produce the work you have ordered, for example on-model images or short-form videos.

Please only send material you are entitled to share. If your material shows identifiable people, make sure you have their permission.

The legal basis is the performance of our contract with you (Art. 6(1)(b) GDPR). Where we process personal data contained in your material on your behalf, we act as your processor and will conclude a data processing agreement with you on request.

We delete your source material and the finished files 30 days after delivery, unless we agree on a different period with you or statutory retention obligations apply.

6. AI processing with Google Gemini

We create images and video with the help of the Gemini API, a paid service provided by Google. For this purpose, your material is transmitted to Google. Under Google’s terms for paid Gemini API services, your inputs and the generated results are not used to improve Google’s products. The data may be stored temporarily or cached in countries where Google or its agents operate facilities, including the United States.

Transfers to the United States are based on the EU–U.S. Data Privacy Framework, under which Google is certified, and on the EU standard contractual clauses included in Google’s data processing terms (Art. 45 and 46 GDPR).

Images generated with Gemini may carry an invisible digital watermark (SynthID) that identifies them as AI-generated. In addition, we label all AI-generated images and videos as such.

7. Business contacts

We may contact businesses whose contact details are publicly available, for example on their website, to introduce our services. We process the company name, the contact person’s name, the business email or postal address, and notes on our correspondence. The legal basis is our legitimate interest in direct marketing to businesses (Art. 6(1)(f) GDPR).

You can object to this at any time, without giving reasons, by replying to our message or emailing us. We will then stop contacting you and keep only the information needed to make sure we do not contact you again.

8. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you (Art. 15),
• have inaccurate data corrected (Art. 16),
• have your data deleted (Art. 17),
• restrict processing (Art. 18),
• receive your data in a portable format (Art. 20),
• object to processing based on legitimate interests, including direct marketing (Art. 21),
• withdraw any consent you have given, with effect for the future (Art. 7(3)).

To exercise these rights, email info@universal-vocabulary.com.

You also have the right to lodge a complaint with a data protection supervisory authority, for example the authority responsible for us: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW), Düsseldorf, Germany.

9. No automated decisions

We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.

10. Changes

We update this policy when our services or the law change. The current version is always available on this page.