Privacy Policy Scavenger App

Last updated May 1st 2026

1. Introduction

In the following, we provide information about the collection of personal data when using:

  • our platform app.scavenger

  • our profiles in social media.

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1 Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Scavenger AI GmbH, Thurn-und-Taxis-Platz 6, 60313 Frankfurt am Main, Germany, email: support@scavenger-ai.com. We are legally represented by Felix Beissel, Maximilian Hahnenkamp.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

Please note that if we are acting as a data processor, this privacy policy does not apply. In that case, our customer will be the controller.

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:


  • Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.

  • Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.

  • Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.

  • Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).


In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.


In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access,

  • Right to correction or deletion,

  • Right to limit processing,

  • Right to object to the processing,

  • Right to data transferability,

  • Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

  1. Newsletter

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

We send newsletters with the tool HubSpot of the provider HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy: https://legal.hubspot.com/privacy-policy). The provider processes content, usage, meta/communication data and contact data in the process in the EU.

  1. Data processing on our website


3.1. Notice for website visitors from Germany

Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections.

This storage and access is based on the following provisions:

  • Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g., to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 para. 2 no. 2 of the German Telecommunications Digital Services Data Protection Law (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz), "TDDDG").

  • Otherwise, this storage or access takes place on the basis of the website visitor's consent (Section 25 para. 1 TDDDG).

The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

  • IP address

  • Date and time of the request

  • Time zone difference to Greenwich Mean Time (GMT)

  • Content of the request (specific page)

  • Access status/HTTP status code

  • Amount of data transferred in each case

  • Website from which the request comes

  • Browser

  • Operating system and its interface

  • Language and version of the browser software.

3.3. Web hosting and provision of the website

Our website is hosted by Vercel. The provider is Vercel Inc., 340 S Lemon Ave Unit 4133 Walnut, CA, USA. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy at https://vercel.com/legal/privacy-policy.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

The legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We use the content delivery network Vercel for our website. The provider is Vercel Inc., 340 S Lemon Ave Unit 4133 Walnut, CA, USA. The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy at https://vercel.com/legal/privacy-policy.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

Legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

3.4. Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

3.5. Vacant positions

We publish positions that are vacant in our company on our website, on pages linked to the website or on third-party websites.


The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act (Bundesdatenschutzgesetz). We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.


Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 s. 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR.


We pass on the applicants' data to the responsible employees in the HR department, to our data processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receiving the application.

3.7. Customer account

Site visitors can open a customer account on our website. We process the data requested in this context based on a contract with the user. Legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR.

Beyond the data entered during registration, we process login/out-dates, session times, user interaction data, device, location.

3.8. Single-sign on

Users can log in to our website using one or more single sign-on methods. In doing so, they use the login data already created for a provider. The prerequisite is that the user is already registered with the respective provider. When a user logs in using a single sign-on procedure, we receive information from the provider that the user is logged in to the provider and the provider receives information that the user is using the single sign-on procedure on our website. Depending on the user's settings in his account on the provider's site, additional information may be provided to us by the provider. The legal basis for this processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing users with a simple log-in option. At the same time, the interests of the users are safeguarded, as use is only voluntary.


Providers of the offered method(s) are:


3.9. Technically necessary cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.


Specifically, we set technically necessary cookies for the following purpose or purposes:

  • Cookies that adopt language settings,

  • Cookies that store log-in data

3.10. Data analysis

Users can insert or upload data in order to perform analyses on this data. User data may be processed in order to deliver the analysis. We use service providers in order to offer these services. These include data hosting services. The legal basis for processing data is the contractual relationship with the user.


3.10a. Google User Data

Our Application allows users to connect their Google account in order to import data from Google services into the Application for data analysis purposes. This section describes how we handle Google user data in compliance with the Google API Services User Data Policy.


Data Accessed. When a user connects their Google account, the Application may access data from the following Google services, depending on the connectors the user configures: Google Drive (file metadata and file content, e.g., CSV files), Google Sheets (spreadsheet content), BigQuery (query results), Spanner (database records), and Firestore (document data). The Application accesses only the data that the user explicitly selects or configures for import. Additionally, the user's Google email address is collected from the Google identity token for display purposes within the Application. We do not access any Google user data beyond what is described above.

Data Usage. The imported data is used solely to provide our data analysis service. Users can query their imported data through the Application's interface, which uses large language model (LLM) technology to process queries and return results. Google user data is not used for advertising, market research, or any purpose unrelated to the functionality of the Application. Google user data is not used to train, improve, or fine-tune any artificial intelligence or machine learning models.


Data Sharing. To process user queries against imported data, portions of the imported data may be sent to LLM services hosted within the European Union, specifically OpenAI models via Microsoft Azure (EU Central region) and Anthropic Claude models via AWS Bedrock (EU Central region). These services process the data solely to generate query responses and do not retain user data beyond the duration of the request. The data is not used by these providers to train or improve their models. We do not sell Google user data or share it with any other third parties, except as required by law.


Data Storage and Protection. Imported Google user data is stored persistently on secure servers within the European Union. We implement industry-standard technical and organizational security measures to protect user data, including encryption in transit (TLS) and access controls. Only authorized personnel have access to stored data, and access is limited to what is necessary for the provision and maintenance of the service.


Data Retention and Deletion. Imported Google user data is retained for as long as the user maintains an active account and the data remains in the user's workspace within the Application. Users can delete imported data sets at any time through the Application interface. In accordance with the EU General Data Protection Regulation (GDPR), users have the right to request deletion of their personal data, including any data imported from Google services, by contacting us at support@scavenger-ai.com. Upon receiving a valid deletion request, we will permanently delete the relevant data without undue delay and in any event within 20 days, unless a legal obligation requires further retention. Upon account deletion, all associated Google user data is also permanently deleted and any Google OAuth tokens are revoked.


Revoking Access. Users can disconnect their Google account from the Application at any time through the Application interface, or revoke access through their Google Account permissions page (https://myaccount.google.com/permissions). When a user disconnects via the Application, the stored OAuth tokens are revoked with Google and deleted from our systems. Upon revocation, the Application will no longer be able to access or import new data from Google services. Previously imported data will remain in the Application until the user deletes it or requests its deletion.


Limited Use Disclosure. Scavenger AI's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

3.11. Third-parties

3.11.1 Google Analytics

We use Google Analytics for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for processing is Art. 6 para. 1 s. 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA is an adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided in an adequacy decision pursuant to Art. 45 (3) GDPR that the third country offers an adequate level of protection.

The data will be deleted when the purpose of its collection no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy.



3.11.2. Auth0 by Okta

We use Auth0 to manage authentication. The provider is Okta, Inc, 100 First Street, San Francisco, California 94105, USA. The provider processes contact data (e.g. email addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses) and master data (e.g. names, addresses) in the EU.

The legal basis for processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.

We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://www.okta.com/privacy-policy/.


3.11.3. PostHog

We use PostHog for analytics and to understand how users interact with our 

Application. We host PostHog on our own infrastructure within the EU.

PostHog processes usage data (e.g. pages visited, features used, clicks, 

session duration), technical data (e.g. browser type, device information, 

operating system), and meta/communication data (e.g. IP addresses, which may 

be anonymized).


The legal basis for processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a 

legitimate interest in analyzing user behavior to improve our Application's 

functionality and user experience.


Users can opt out of analytics tracking through their account settings or by 

adjusting their browser settings to block tracking cookies.

The data will be deleted when the purpose of its collection no longer applies 

and there is no obligation to retain it. Further information about PostHog can 

be found at https://posthog.com/privacy.



3.12 Payment processing with Stripe


For processing payments in our Application, we use the external payment service provider Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland ("Stripe"). When a user makes a payment, the required payment and billing data are transmitted to Stripe in order to process the transaction.


Stripe may process data such as name, address, email address, payment method information (e.g. credit card details), transaction data, and fraud prevention data. Scavenger AI does not store full credit card details.


The legal basis for the data processing is Art. 6 para. 1 s. 1 lit. b GDPR (performance of a contract) and Art. 6 para. 1 s. 1 lit. f GDPR (our legitimate interest in secure and efficient payment processing).


Data may be transferred outside the European Economic Area (EEA), in particular to the USA. Stripe ensures compliance with GDPR requirements for international data transfers through the use of Standard Contractual Clauses (SCCs) approved by the European Commission.


Further information on data processing by Stripe can be found in Stripe’s privacy policy: https://stripe.com/privacy.

4. Data processing on social media platforms

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.


If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

4.1. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy?_l=de_DE.

One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

  1. Questions and comments

f you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.