Legitimate interests of PAISTRY
Last updated: 3 November 2026
PAISTRY TECHNOLOGIES GmbH, Bretonischer Ring 8, 85630 Grasbrunn, Germany (“PAISTRY”) operates AI agents – such as the shopping advisor Stroodl – that answer questions in a conversation, on our own pages and on partner websites.
For some processing we rely on legitimate interest (Art. 6(1)(f) GDPR) instead of consent. For each of these purposes we describe below what we do, why we need it, how we weighed it against your interests, what protects you and what your objection does. The purposes are named as in the IAB Transparency & Consent Framework (TCF).
What applies to all purposes below
- We do not know who you are. We do not ask for a name, email address or account. Data is linked to a random session number; a visitor number that recognises you across visits exists only if you consented (on our page: “Ja, merk dir mich” – “yes, remember me”; on a partner website: the partner’s consent banner).
- Legitimate interest never covers storing or reading anything on your device beyond what is strictly necessary to run the agent. That always needs your consent (§ 25 TDDDG; TCF purpose 1).
- Today we build no profiles for advertising or content; a memory across visits exists only with your consent (privacy policy, section 6). We do not sell data.
- Improving our agents from your conversations (TCF purpose 10) does not rest on legitimate interest: we do it only with your consent (privacy policy, section 6).
- IP addresses, full and shortened, are deleted with the session record 426 days after the visit began. All retention periods are in the privacy policy, section 8.
- We use one TCF feature: match and combine data from other data sources (feature 1). When an affiliate network (for example Awin) reports a sale that followed a click in the agent, we match it to the visit the click came from, to measure whether our recommendations lead to purchases (purposes 7 and 9). The report carries no name and no contact details. We use no other features.
How to object
You can object to any purpose below at any time (Art. 21 GDPR):
- With a consent banner: if the agent runs on a website with a consent banner, object there (usually under “Legitimate interest” or “Vendors”).
- Without a banner – for example on our own pages or on partner websites without a banner: by email to privacy@paistry.tech.
We then stop the processing for you unless we have compelling legitimate grounds; for the special purposes see there. For purposes 7 and 9 we also delete the conversation text of the visit in the next nightly deletion run after it ended; the session record and counts stay until their period ends. What your objection does is stated for each purpose. You can keep using the agent.
Use limited data to select advertising (TCF purpose 2)
- What we do
- Some suggestions in an agent are sponsored and labelled as an ad. We choose which sponsored suggestion, campaign or ad to show from the current visit: the page you are on, the product category of your question, your language, your type of device and the country derived from your IP address. When an agent shows ads from an advertising partner, the partner receives the address of the page and, only where this is switched on for the agent, the context of the conversation, so it can choose a fitting ad.
- Our interest
- Sponsored suggestions that fit the topic finance the free service; a suggestion that fits is also less intrusive for you than a random one.
- Why it is necessary
- Without the current context we could only show sponsored suggestions at random.
- Balancing
- Only data from the current visit is used: no profile, no history from earlier visits, no data from other companies about you. Sponsored suggestions are always labelled as ads.
- Safeguards
- As for purpose 8; sponsored suggestions are labelled “Anzeige” / “Ad”. We call an advertising partner only once your consent choice covers the purposes it needs for this.
- If you object
- We no longer choose sponsored suggestions or ads from the page or your conversation.
Measure advertising performance (TCF purpose 7)
- What we do
- When you reach an agent through a campaign link (for example an advertisement for a product), we record which campaign, creative and website the link came from, and what happened in the visit: questions, products shown, sponsored suggestions and ads shown and clicked, clicks to shops. When an affiliate network reports a sale that followed such a click, we match it to that visit (TCF feature 1). To make that possible, the link to the shop carries the random session number of your visit as a click reference, and the network returns it with the sale report.
- Our interest
- To report to the advertiser whether the campaign reached people and was useful to them, and to be paid for it.
- Why it is necessary
- Campaign reports are how advertisers decide whether to fund the free service. The campaign parameters are in the link you clicked; we read them, nothing else.
- Balancing
- Reports are aggregated per campaign, creative and website. We never pass on who you are, never send your data back to the advertiser’s systems, and use no tracking pixels of third parties.
- Safeguards
- Aggregated reports only; no click IDs of advertising platforms are stored or returned to them; the only reference handed to the affiliate network is the random session number of your visit, which means nothing outside PAISTRY; the sale reports we receive carry no name or contact details; retention as for purpose 8.
- If you object
- Your visit is no longer included individually in campaign reports; it is only counted anonymously. We delete the conversation text of that visit in the next nightly deletion run after it ended.
Measure content performance (TCF purpose 8)
- What we do
- We count how the agent is used: that it was opened, which questions were asked, which suggestions and products were shown and clicked, whether an answer was rated helpful. If you consented to being recognised, we also measure across visits, for example whether readers come back.
- Our interest
- To know whether the agent gives useful answers, and to report its reach to the partners whose websites it runs on.
- Why it is necessary
- Without counting, we cannot tell a helpful answer from a useless one, and partners cannot see whether the agent works on their website. Aggregated counts alone are not enough, because we need to see which question led to which click within one visit.
- Balancing
- You would reasonably expect a service you are using to count whether it works. The data is limited to what happens inside the agent, linked to a random session number, and is not combined across visits unless you consented.
- Safeguards
- No visitor number without consent; usage events are kept for 426 days from the start of the visit, then deleted (see the privacy policy, section 8); partners see counts and the questions asked, never who asked them.
- If you object
- Your visits are no longer measured individually; they are only counted anonymously.
Understand audiences through statistics or combinations of data from different sources (TCF purpose 9)
- What we do
- We analyse conversations and produce statistics across many visits: which topics are asked about, which product categories are in demand and how that demand develops over time. Purchase intent and topics are classified per visit and only ever counted in totals.
- Our interest
- To understand what readers need, improve the agent’s knowledge and give partners insight into demand on their websites.
- Why it is necessary
- Single visits do not show trends; only analyses across many visits do.
- Balancing
- The output is always aggregated; no statistic describes an individual, and a classification stays within the visit it comes from. The only outside data we combine is a sale reported by an affiliate network, matched to the visit it came from (feature 1); we receive no other data about you from other companies.
- Safeguards
- Statistics that refer to no visit and no person have no personal reference; the conversation text, classifications and events they are built from are kept for 426 days from the start of the visit.
- If you object
- Your conversation is not analysed for insights. We delete the conversation text of that visit in the next nightly deletion run after it ended.
Use limited data to select content (TCF purpose 11)
- What we do
- Before you ask anything, the agent suggests questions that fit the article you are reading; for this it receives the article. In the conversation it chooses suggestions, articles and products based on what you asked, the page you are on, your language and your type of device.
- Our interest
- Relevant answers and suggestions.
- Why it is necessary
- An answer that does not consider your question and the page is not an answer.
- Balancing
- Only data from the current visit is used; no profile, no history from earlier visits unless you consented.
- Safeguards
- As for purpose 8.
- If you object
- The agent no longer suggests questions from the article you are reading, no longer receives the article as context, and no longer orders suggestions and products by page and device. It still answers what you type.
Special purposes (no objection in the consent banner)
The TCF defines three purposes that are necessary to run a service at all; they cannot be switched off in a consent banner. You can still object by email to privacy@paistry.tech; we will check your case individually.
- Ensure security, prevent and detect fraud, and fix errors (special purpose 1). We check messages and requests for abuse, bots, attacks and content that is illegal or harmful, and we analyse errors. Interest: protect you, our partners and the service, and meet our legal obligations. Safeguards: the IP address (full and shortened) and error logs are deleted 426 days after the visit began.
- Deliver and present advertising and content (special purpose 2). Technical delivery of the agent, its answers and its pages to your browser (IP address, device and browser type), and the memory the agent answers from in the conversation (on our servers, at most 395 days after your last visit).
- Save and communicate privacy choices (special purpose 3). We store your consent decision so we do not ask again, and keep a record of it as proof.
Questions or objections: privacy@paistry.tech. Supervisory authority: Bavarian State Office for Data Protection Supervision (BayLDA), Ansbach. Full privacy policy: paistry.tech/privacy.