Privacy Notice

Last Updated: 15.09.2025

1. Who We Are (Controller)
GENEREX SYSTEMS Computervertriebsgesellschaft mbH, Brunnenkoppel 3, 22041 Hamburg, Germany, is the controller for processing related to our customer support via GENEREX Zendesk.
Email: privacy@generex.de.

2. Data Protection Contact
For all privacy inquiries, please contact privacy@generex.de.

3. Scope
This notice covers all interactions with our support via GENEREX Zendesk (tickets, web forms, emails to support, phone calls via our support hotlines, chat/messaging, and the Help Center).

4. What Data We Process (Categories)

• Identification/Contact Data: name, email, phone, company, role.
• Ticket Content: messages, attachments, screenshots, system exports/logs you send.
• Technical Data: IP address, device/browser information, timestamps, request IDs, security logs.
• Telephony: call metadata (time/duration/number) and—if you consent—audio recordings and transcripts.
• Automation/AI Metadata: topic classifications, priorities, summaries, suggested replies.

5. Where We Get the Data (Sources)
Primarily from you. We may also receive data from your colleagues/admins, from our products/services (enabled diagnostic logs), or from publicly available sources relevant to troubleshooting.

6. Why We Process the Data & Legal Bases (Art. 6 GDPR)

• Provide support, answer requests, fulfill product obligations → Art. 6(1)(b) (contract) or Art. 6(1)(f) (legitimate interest) if no contract exists.
• Improve support quality, prevent abuse/spam, ensure security, analyze ticket flows → Art. 6(1)(f).
• Call recording & transcription → Art. 6(1)(a) (consent). Withdrawal possible anytime (see §12).
• AI-assisted ticket handling and drafting (no solely automated decisions with legal effect) → Art. 6(1)(f).
• Legal/compliance obligations → Art. 6(1)(c).

We do not process special categories of personal data (Art. 9 GDPR). Please do not send them.

7. Do You Have to Provide Data?
Voluntary – but without sufficient details, we may not be able to handle your request. Never send passwords, API keys, private certificates, full payment data, or other secrets.

8. Recipients & Processors
We use vetted service providers under data processing agreements for ticketing/help center (Zendesk), telephony, hosting/security, and AI-assisted support services (classification/summarization/suggested replies).
We instruct our providers not to use your identifiable content to train publicly available models.
A current overview of processor categories is included in this notice; a detailed list is available on request.

9. International Data Transfers
Your data may be processed outside the EU/EEA (e.g., USA). We use EU Standard Contractual Clauses and apply safeguards (encryption, access controls).

10. Retention

• Tickets & correspondence: 3 years after last activity (regular limitation period in Germany), unless longer retention is needed for legal claims.
• Call recordings/transcripts (with consent): 180 days or until withdrawal; longer only for disputes/compliance.
• Security logs/telemetry: 90–180 days.
• Statutory retention obligations (if applicable within support): 6–10 years.

After expiration, data is deleted or anonymized.

11. AI-Assisted Support (Transparency)
We use automated systems to prioritize tickets, flag risks, classify topics, and suggest replies. A human remains responsible for the final decision. No solely automated decisions with legal effect or similarly significant impact are made (Art. 22 GDPR). If you object, we will route your ticket to manual handling where feasible.

12. Call Recording & Transcription
We may record support calls and create transcripts—but only with your prior consent. Without consent, no recording takes place. You may withdraw consent at any time; this has no retroactive effect.

13. Cookies & Consent (TTDSG/GDPR)
The Help Center uses cookies and similar technologies.

• Strictly necessary cookies: without consent (Art. 6(1)(f)).
• Other cookies (e.g., analytics, preferences, marketing): only with your consent (Art. 6(1)(a), §25 TTDSG).

You may change/withdraw your consent anytime via the “Cookie Settings” link in the footer. The cookie panel shows categories, purposes, providers, storage periods, and recipients.

14. Security
We apply technical and organizational measures: access controls, encryption in transit, least-privilege roles, malware scanning of attachments, logging, and regular audits of providers.

15. Your Rights
You have the right to access, rectify, erase, restrict, data portability, and object to processing based on legitimate interests. Where we rely on consent (e.g., call recording), you may withdraw it at any time.

16. Children
Support is not intended for children under 16. We do not knowingly process their data without appropriate consent.

18. Changes to This Notice
We will publish updates here and adjust the “Last Updated” date. For material changes, we will provide additional notice where appropriate.

19. Contact
GENEREX SYSTEMS Computervertriebsgesellschaft mbH
Brunnenkoppel 3, 22041 Hamburg, Germany
Telephone: +49 (0) 40 2269 291 - 0 | Fax: +49 (0) 40 2269 291 - 10
Email: privacy@generex.de