1. General information
This is the Privacy Policy of ID37 Company GmbH (hereinafter: "ID37"), especially for the use of our AI coach Jay.
You can find our contact details as a controller under data protection law, information about your rights and further information on the use of our website in our general Privacy Policy at https://www.id37.io/en/privacy. All definitions in our general Privacy Policy also apply to the present Privacy Policy for AI Coach Jay.
After completing the personality test and providing your ID37 profile in the login area of our website, you can sign up to access and use an AI chatbot, which we have named Jay. Jay is a chatbot that is designed to answer your questions as an AI coach based on the ID37 personality model. This present Privacy Policy for AI Coach Jay informs you about the basic functionality and other aspects of data processing associated with the use of Jay.
2. Purposes of data processing and basic functionality of Jay
As explained in our general Privacy Policy, we store and process your personal data for the purpose of conducting the personality test with you, providing you with your personal personality profile and exchanging your test results or personality profile with other registered users of ID37, provided that you have selected the respective option in your ID37 profile (this data together with general information on the ID37 personality analysis hereinafter referred to as "ID37 knowledge database"). Your personal data will only be stored and processed in pseudonymized form. The ID37 knowledge database is stored in compliance with the EU GDPR in the ID37 environment on servers in the EU (Germany).
If you subscribe to the use of Jay, we will also process your data for the purpose of providing you with the Jay chatbot. Jay is a proprietary development of ID37. It is a proprietary large language model (hereinafter referred to as "LLM"), which we have trained with psychometric data, in particular with general background information on the ID37 method. Jay is therefore able to give you general information about the ID37 method and answer any questions you may have in this regard.
In the application, you have the option of entering text such as a question in an input window. You will then receive a suitable and inspirational answer. Thanks to the LLM's ability to render dialogs natural and fluid, you can enter into a dialogue that resembles a coaching conversation. This conversational behavior consisting of questions and answers can be repeated at will. The dialogues are saved in the user's account and can be accessed again.
As part of the ID37 knowledge database, Jay also accesses your personality profile. This enables Jay to provide you with individual answers based on your own personality profile and the motives that guide you. If you have shared your personality profile with other registered ID37 users or with your Master, they can also access your personality profile via Jay, just as you can ask Jay about the personality profiles of all those registered ID37 users who have shared their personality profiles with you. In this way, Jay can answer questions in the context of the ID37 personality analysis that also relate to the people in your ID37 network.
3. Cooperation with third parties and possible transfer of data
In order to be able to offer AI coach Jay in a user-friendly, precise and professional language, we use the software ChatGPT by OpenAI LLC, 3180 18th St., San Francisco, CA 94110, USA (hereinafter "OpenAI"). We have concluded a contract with OpenAI that excludes access by OpenAI to your and all other test results, personality profiles and other personal data stored and processed by us. In case any data is transferred to OpenAI, the data is pseudonymized in our own server environment before that transfer occurs. In this process, the data is altered in such a way that it can no longer be used to identify a specific natural person without additional information. This additional information is stored separately and under strict security precautions. Through pseudonymization, the data loses its personal character. When using Jay, therefore, no personal data leaves our server environment and is transferred to OpenAI.
As soon as you enter text Jay's chat window (hereinafter: "prompt"), the chatbot searches the ID37 knowledge database for relevant information to answer your query. At the same time, the prompt is automatically transmitted to OpenAI via an application programming interface (hereinafter: "API") in order to linguistically prepare the information found for you. OpenAI then automatically transmits all information to ID37 via the API to provide Jay with an answer and to make it available to you in the chat. According to OpenAI, your prompt is never saved.
As your prompt may contain personal data, we have concluded a data processing agreement with OpenAI. Under this contract, OpenAI may only process your personal data on our instructions and for specific purposes. OpenAI is also committed to comprehensive data security measures.
The data processing agreement also contains the standard contractual clauses for the transfer of personal data to third countries, which the EU Commission published as Annex to Implementing Decision (EU) 2021/914 of June 4, 2021. The standard contractual clauses oblige OpenAI to comply with a level of data protection that is essentially comparable to that of the EU. In addition, the standard contractual clauses also provide appropriate safeguards for the transfer of personal data to the USA within the meaning of Art. 46 para. 2 lit. c GDPR. Further information on data protection at OpenAI in the context of API use can be found at https://openai.com/enterprise-privacy.
Apart from your prompt, no personal data is transmitted to OpenAI. The chats you save while using Jay remain on servers in the ID37 environment, as does the training data we used to train Jay.
4. Legal basis for the processing
The legal basis for all processing in the context of the use of Jay is Art. 6 para. 1 sentence 1 lit. b GDPR, as it is carried out at your request and is therefore necessary for the performance of the contract between ID37 and you for the use of Jay.
You can find all further information in our general privacy policy at https://www.id37.io/en/privacy. For all queries and to assert your data protection rights, please contact us at any time at hello@id37.io
