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Privacy Policy

This policy explains how Erfüllen handles account data, AI system metadata, compliance evidence, generated documents, and integration events for the EU AI Act compliance platform.

Last updated: 12 August 2026

Tenant data

Workspace, organization, and AI system records.

Evidence

Uploaded files, comments, approvals, and generated documents.

AI assistance

The Erfüllen Engine may use Claude and Gemini for drafting and reasoning.

Controls

Access controls, audit logs, and tenant-aware processing.

1. Who We Are

Erfüllen provides a compliance workflow platform for AI governance, EU AI Act readiness, evidence tracking, document generation, MLOps monitoring, and related compliance operations. References to "Erfüllen", "we", "our", or "us" mean the provider of this platform.

2. Data We Process

We process account and workspace information, organization membership data, AI system metadata, risk classification inputs, evidence records, uploaded files, generated document drafts, audit logs, billing and plan information, integration settings, webhook events, and support/contact requests.

3. Erfüllen Engine, Claude, and Gemini

The Erfüllen Engine powers risk reasoning, compliance document drafting, and workflow assistance. Depending on configuration, the Erfüllen Engine may use Claude by Anthropic and Gemini by Google as underlying model providers. Information submitted for classification or document generation may be sent to these providers to produce AI-assisted output. These providers operate outside Erfüllen's primary EU vault when their features are used. Generated content is a draft and must be reviewed by your responsible human reviewer, legal team, DPO, or compliance officer before regulatory filing or external submission. See our Sub-processors Disclosure.

4. Why We Use Data

We use data to provide the service, authenticate users, enforce tenant access controls, classify AI systems, generate and manage compliance documentation, calculate compliance readiness, process evidence approvals, monitor MLOps events, send alerts, provide support, maintain security, and improve reliability.

5. Integrations and Webhooks

If you connect MLflow, Weights & Biases, SageMaker, or another MLOps source, Erfüllen receives event payloads needed to identify model versions, stage or alias changes, metrics, and monitoring signals. We use this data to create monitoring events, trigger reassessment workflows, and help maintain compliance records.

6. EU Data Residency and Primary Hosting

Erfüllen's primary compliance data plane is hosted in the European Union (Frankfurt, eu-central-1). This includes workspace records, AI system metadata, evidence files, generated documents, audit logs, and private storage for compliance exports.
ComponentProviderRegionRole
App + APIVercelfra1 (Frankfurt)Next.js, middleware, tRPC, auth routes, workers
Database + Auth + StorageSupabaseeu-central-1 (Frankfurt)Postgres, sessions, evidence files
Rate limitingUpstash RedisEU-CENTRAL-1Auth and contact rate limits

7. Sharing, Processors, and Sub-processors

We share data with service providers only as needed to operate the platform. Primary EU vault processors include Supabase (database, authentication, storage), Vercel (application hosting), and Upstash (rate limiting). Additional processors — including AI model providers, email delivery, and billing — may process limited data outside the primary EU vault when their features are used. We do not sell customer data.

See the Sub-processors Disclosure and DPA & Processor Agreements pages for vendor details and GDPR Article 28 guidance.

8. Security and Tenant Controls

Erfüllen is designed for tenant-separated access using organization-scoped authorization, audit logs, role checks, private storage with signed URLs, and server-side data access. Customers remain responsible for choosing appropriate user roles, reviewing generated content, and avoiding uploads of unnecessary sensitive data.

Read the Data Residency Overview for production verification details.

9. Disclosure Documents

The following human-readable disclosure pages support this Privacy Policy:
DocumentDescriptionLink
Data Residency OverviewEU Frankfurt hosting for the primary compliance data plane.Open disclosure
Sub-processors DisclosureThird-party providers and what may leave the primary EU vault.Open disclosure
DPA & Processor AgreementsGDPR Article 28 data processing agreements and verification guidance.Open disclosure

10. Retention

We retain records for as long as needed to provide the service, satisfy audit and compliance needs, resolve disputes, enforce agreements, and meet legal obligations. You may request deletion or export subject to applicable contractual and legal limits.

11. Your Responsibilities

You are responsible for the accuracy of AI system metadata, the legality of uploaded evidence, obtaining required consents, performing human review, and deciding whether generated documentation is suitable for a regulator, notified body, customer, or internal audit.

12. Third-Party Visual Assets

The decorative world map used in Erfüllen demo and product visuals is based on a World SVG map from Fla-shop.com, used under the Creative Commons Attribution 4.0 International license.

13. Contact

For privacy questions, contact us through the in-app Contact us form or email hallo@erfuellen.com.