Privacy Notice

Last updated: 23.04.26

This privacy notice provides information, pursuant to Article 13 of the General Data Protection Regulation (GDPR), on the processing of personal data in connection with the use of the website www.routinelabs.ai (hereinafter "Website") by Routine Labs GmbH as the controller.

Routine Labs GmbH processes personal data strictly to the extent necessary for the provision, security, and operation of the Website and its services, adhering to the principle of data minimization. "Personal data" within the meaning of Article 4(1) GDPR refers to any information relating to an identified or identifiable natural person (data subject), such as name, address, telephone number, date of birth, email address, or IP address. Information that cannot be linked to a specific individual, for example as a result of anonymization, is not considered personal data.

1. Controller

The controller for the processing of personal data on the website within the meaning of the General Data Protection Regulation (GDPR) is:

Routine Labs GmbH Schönhauser Allee 52a 10437 Berlin, Germany

For data protection inquiries or to exercise your data subject rights, please contact hello@routinelabs.ai.

2. Data Protection Officer

The following person has been appointed as Data Protection Officer:

Kertos GmbH Brienner Straße 41 80333 Munich, Germany Email: dsb(at)kertos.io

3. Data Processing on Our Website

3.1 Provision of the Website

Purpose of processing: We process your data in order to

ensure the reliable operation of the website
provide user-friendly access to our website
and maintain IT security

Recipients: Amazon Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98109-5210, USA

Data processed:

IP address of the requesting device
Method (e.g., GET, POST), date and time of the request
Address of the accessed website and path of the requested file
if applicable, previously accessed or requested website/file (HTTP referer)
Information regarding the browser and operating system used
Version of the HTTP protocol, HTTP status code, size of the delivered file
Request information such as language, content type, content encoding, character encodings

Legal basis: Article 6(1)(f) GDPR. The processing of the specified data is necessary to provide the website and to ensure secure and user-friendly operation.

Retention period: The collected data will be deleted as soon as it is no longer required for the operation of the website, but no later than 30 days, unless a statutory retention obligation applies.

Third-country transfer: Data transfer to the USA based on the EU-U.S. Data Privacy Framework (Art. 45 GDPR). Amazon is certified under this framework. In addition, Standard Contractual Clauses (SCCs) are in place.

Further information: https://aws.amazon.com/privacy/

3.2 Applications

Purpose: Selection of candidates for the potential establishment of an employment relationship.

Recipients: JOIN Solutions AG, Landsgemeindeplatz 6, 9043 Trogen, Switzerland

Data processed:

Name
Email address
Telephone number
Curriculum vitae (CV)
Cover letter
Other application documents provided by you
IP address
Browser type and version
Operating system
Date and time of access

Legal basis: Article 6(1)(b) GDPR (performance of pre-contractual measures); Article 6(1)(f) GDPR, where we have a legitimate interest in the efficient conduct of the application process.

Retention period: We store your personal data until the conclusion of the application process. In the event of a rejection, your data will be retained for up to six months following notification of the decision. In the case of legal disputes, retention may be extended until final resolution. If you are hired, your application documents will be stored in your personnel file for the duration of your employment relationship. You may withdraw your application or object to the processing at any time; in this case, your data will be deleted and your application will no longer be considered.

International data transfer: Data may be transferred to Switzerland. An adequacy decision of the European Commission exists for Switzerland, so transfers are based on Article 45 GDPR. Where further transfers to other third countries occur, JOIN ensures an adequate level of data protection through appropriate safeguards in accordance with GDPR requirements.

Further information: https://join.com/de/dpa

3.3 Analytics and Tracking

Cookies are small text files stored by your browser on your device. Cookies do not execute programs or install malware. Comparable technologies include web storage (local/session storage), fingerprinting, tags, and pixels. Most browsers accept these technologies by default; however, you can adjust your settings to block their use or to require consent. Please note that blocking cookies or similar technologies may restrict certain functionalities of the website.

Purpose: We use tracking and analytics tools to continually optimize our website and adapt it to your needs. For this purpose, information is collected using these technologies or device information is combined (device fingerprinting).

Legal basis: Technically necessary tools required for the operation of the website are used on the basis of our legitimate interests in accordance with Art. 6(1)(f) GDPR, or for the performance of a contract or pre-contractual measures pursuant to Art. 6(1)(b) GDPR. The storage of or access to information on your device is strictly necessary in these cases and is based on Section 25(2) TDDDG. Optional tools are used exclusively with your consent pursuant to Art. 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG. Below, we outline the tracking and analytics tools used, their respective purposes, and the data processed.

Recipients: Google Tag Manager, Google Analytics 4

4. Google Tag Manager

Purpose: Management and triggering of website tags via a unified interface

Recipients: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland and Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Data processed:

Access data (e.g. time of page request, referrer URL)
Device data (e.g. IP address, device type)
Browser data (e.g. browser used, language settings)
Event data (e.g. tag triggering, interactions with embedded scripts)
Location data (e.g. country, city – based on IP address)

Legal basis: Consent pursuant to Article 6(1)(a) GDPR and Section 25(1) TDDDG

Retention period: Cookies are stored for up to 90 days.

Third-country transfer: Data transfer to the USA based on the EU-U.S. Data Privacy Framework (Art. 45 GDPR) as well as additional Standard Contractual Clauses (SCCs).

Further information: https://policies.google.com/privacy

5. Google Analytics 4

Purpose: Web analytics for measuring and evaluating website usage

Recipients: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland and Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Data processed:

Device data (e.g. IP address, device type, screen resolution)
Browser data (e.g. browser used, language, installed plug-ins)
Usage data (e.g. pages visited, time spent per page, click paths, scroll depth, entry and exit pages)
Event data (e.g. clicks on buttons/links, forms submitted)
Location data (e.g. country, city)
Source and traffic data (e.g. referrer URL, access source)
Conversion and goal data (e.g. completed conversions, goals reached on the website)

Legal basis: Consent pursuant to Article 6(1)(a) GDPR and Section 25(1) TDDDG

Retention period: Data are typically stored for 14 months.

Third-country transfer: Data transfer to the USA based on the EU-U.S. Data Privacy Framework (Art. 45 GDPR). Google is certified under this framework. In addition, Standard Contractual Clauses (SCCs) are in place.

Further information: https://policies.google.com/privacy

| Name | Provider | Purpose | Category | Retention | | ---------------- | ---------------- | -------------------------------------------------------- | ------------------ | --------- | | _ga | Google Analytics | Distinguishes unique users for reach measurement | Statistics cookies | 1 yr 1 mo | | _ga_H64ESZXF8T | Google Analytics | Stores session state for the Google Analytics 4 property | Statistics cookies | 1 yr 1 mo |

6. Book a Demo

Purpose: Scheduling of demo and introductory meetings via an online calendar

Recipients: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland and Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Data processed:

Name
Email address
Date and time preference
Time zone
Additional information provided (e.g. company, role, message)

Legal basis: Article 6(1)(b) GDPR for the performance of pre-contractual measures regarding the scheduling of a meeting; consent pursuant to Article 6(1)(a) GDPR and Section 25(1) TDDDG for setting technically non-essential cookies.

Retention period: Data are stored for as long as necessary to schedule and conduct the meeting.

Further information: https://policies.google.com/privacy

7. Contact via email or contact form

Purpose: To process and respond to your inquiry.

Data processed:

Name
Email address
Content of your message

Legal basis: Article 6(1)(f) GDPR (legitimate interest in communicating with you). If your inquiry is aimed at concluding or performing a contract, processing is carried out on the basis of Article 6(1)(b) GDPR.

Retention period: Your data will only be stored for as long as necessary to fully process your inquiry.

8. Social Media Online Presence

Purpose: Communication with interested parties, providing information about products and services, and analysing the use of our online social media presences.

Recipients:

LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland
Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland („YouTube")

Joint Controllership with LinkedIn: In relation to the processing of statistical usage data for our LinkedIn page (so-called "Page Insights"), we and LinkedIn Ireland Unlimited Company act as joint controllers within the meaning of Article 26 GDPR. This joint controllership covers in particular the collection and aggregation of usage data for the purpose of generating Page Insights. The essential information about the allocation of responsibilities between us and LinkedIn, especially with regard to the exercise of data subject rights and compliance with security obligations, can be found in LinkedIn's Joint Controller Addendum (see link below).

Categories of Data Processed:

Demographic information (e.g. age, gender)
Professional information (e.g. industry, professional experience)
Interaction data (e.g. likes, shares)
Usage statistics (e.g. page views, video views)
Content preferences (e.g. popular topics, interests)

Legal Basis:

Article 6(1)(b) GDPR (performance of a contract and pre-contractual measures)
Article 6(1)(f) GDPR (legitimate interest in effective information and communication)

Retention Period: In accordance with the privacy policies of the respective platforms.

International Data Transfer: Data may be transferred to the USA and other third countries, depending on the respective platform.

Further Information:

LinkedIn:
- https://legal.linkedin.com/pages-joint-controller-addendum
- https://www.linkedin.com/legal/privacy-policy

Note: We have no influence over the independent data processing by the platform providers. When visiting our online presences, usage data may be transferred to these providers, who may use this data for their own purposes. Data subject rights can be exercised directly with the respective platform providers.

9. International Data Transfers

Personal data is primarily processed within the EU/EEA. Transfers to so-called "third countries" only occur in compliance with the requirements of the GDPR and where suitable safeguards are in place. Before data is transferred to a service provider in a third country, the level of data protection is assessed. A transfer only takes place if sufficient protection mechanisms exist. All service providers must enter into a data processing agreement. For providers outside the EEA, additional measures are required. Pursuant to Articles 44 et seq. GDPR, a transfer is only permitted if at least one of the following requirements is met:

The European Commission has determined that an adequate level of data protection exists.
Standard Contractual Clauses have been concluded with the recipient.
Other appropriate safeguards pursuant to Article 46 GDPR are in place.
In certain exceptional cases as set out in Article 49 GDPR.

10. Recipients

Personal data collected by us will only be disclosed if:

you have given us your explicit consent pursuant to Article 6(1)(a) GDPR;
the disclosure is necessary to safeguard our legitimate interests or for the establishment, exercise, or defence of legal claims, and there is no reason to assume that your interests or fundamental rights and freedoms which require the protection of personal data override those interests (Article 6(1)(f) GDPR);
we are legally obliged to disclose the data (Article 6(1)(c) GDPR); or
such disclosure is lawful and necessary for the performance of a contract with you or for the implementation of pre-contractual measures at your request (Article 6(1)(b) GDPR).

Possible recipients include:

Processors: Group companies or external service providers (e.g., for technical infrastructure and processing, maintenance, payment processing) that are carefully selected and monitored. Processors may only process data in accordance with our instructions.
Public authorities: Government agencies and public institutions (e.g., tax authorities, public prosecutors, courts) to whom we are required to transfer personal data, for example to comply with legal obligations or to protect legitimate interests.

11. Data Security and Safeguards

We implement appropriate technical and organizational measures to ensure the security and confidentiality of your personal data. These measures are designed to protect against unauthorized access, manipulation, loss, or misuse. Our security measures are regularly reviewed and adapted to reflect technological advancements and current industry standards.

Please note that despite extensive protective measures, data transmission over the internet may involve security vulnerabilities. In particular, unencrypted communication (e.g., standard email) carries the risk that data may be accessed by third parties. We have no influence over the actions of external parties. We therefore recommend that you use encryption or other protective measures when transmitting sensitive information electronically to minimize potential risks.

12. Retention and Erasure/Blocking of Data

Personal data will be deleted or blocked as soon as the purpose of storage no longer applies. Further storage will only take place if required by European Union or national legal provisions to which the controller is subject. Data will also be deleted or blocked once a statutory retention period expires, unless continued storage is necessary for the performance of a contractual relationship.

13. Data Subject Rights

You have the following rights with regard to your personal data:

a. Right of access (Article 15 GDPR, Section 34 BDSG): You may request information as to whether and which personal data we process, for what purpose, to whom or to which categories of recipients the data is disclosed, and how long it is stored.

b. Right to rectification (Article 16 GDPR): You may request the immediate rectification of inaccurate personal data or the completion of incomplete personal data.

c. Right to erasure (Article 17 GDPR): You may request the erasure of your personal data, in particular if it is no longer necessary, you withdraw your consent, or the data has been unlawfully processed.

d. Right to restriction of processing (Article 18 GDPR): You may request the restriction of the processing of your data, for example if the accuracy of the data is contested.

e. Right to data portability (Article 20 GDPR): You have the right to receive your personal data that you have provided to us in a structured, commonly used, and machine-readable format, or to request the transfer of this data to another controller, where technically feasible.

f. Right to withdraw consent (Article 7(3) GDPR): You may withdraw any consent given at any time with effect for the future. The lawfulness of processing up to the point of withdrawal remains unaffected.

Right to object (Article 21 GDPR): You may object at any time to the processing of your personal data for reasons relating to your particular situation, especially in the context of direct marketing or any related profiling.

Right to lodge a complaint with a supervisory authority (Article 77 GDPR): You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes data protection regulations.

Change history

| Date | Version | Reason | | -------- | ------- | -------------------------------------------------------------- | | 23.04.26 | 1.0 | First version of the revised privacy notice in the new format. |