Last Updated: June 2026
This Privacy Policy applies to your use of the SolvyKit platform (hub.solvykit.com). It supplements the corporate Privacy Policy of PsyKotiki UG, available at psykotiki.com. Where this addendum conflicts with the corporate policy, this addendum takes precedence regarding the SolvyKit product.
PsyKotiki UG Corporate Privacy Policy
PsyKotiki UG (haftungsbeschränkt), Lilly-Reich Str. 8, 80807 Munich, Germany.
Managing Director: Cristian Pastramagiu
Email: admin [at] psykotiki [dot] com
SolvyKit processes Special Category Data — data concerning mental health, including cognitive patterns and emotional states — to provide its coaching services.
Legal Basis: We process this data based on your explicit consent (Art. 9(2)(a) GDPR), which you provide by accepting our consent notice when you first use the platform. You may withdraw this consent at any time by deleting your account.
Data collected includes: the text of your coaching sessions; cognitive profiles derived from sessions (identified patterns, strength themes, assessment results); and emotional and safety-related data (sentiment, mood scores, AI-assessed risk classifications used to provide crisis resources when needed).
To deliver its coaching frameworks, SolvyKit uses Large Language Models (LLMs) provided by third-party sub-processors: OpenAI (USA) and Anthropic (USA).
We maintain Data Processing Agreements (DPAs) with these providers. They operate under zero-retention API policies, meaning your conversational data is not stored by them beyond the duration of request processing and is not used to train their models.
International Transfers: These providers are based in the United States. We ensure compliance with GDPR international transfer requirements via the EU-US Data Privacy Framework and Standard Contractual Clauses (Art. 46 GDPR).
If you use SolvyKit through a coaching practice, your coach has access to: which coaching modules you use, your session dates and total count, key thinking patterns detected in your sessions, and session summaries.
You provide separate, explicit consent for coach data sharing when you accept a coach invitation. You can see exactly what your coach can access in the consent notice.
Platform-level safety protocols run independently of your coach's configuration. In cases of identified safety risk, the platform may provide you with localized crisis resources regardless of coach settings.
In addition to the AI providers listed above, SolvyKit uses the following sub-processors:
Hetzner Online GmbH (Germany) — hosting and infrastructure. Brevo (Sendinblue, France) — transactional email. Stripe (USA) — payment processing. PostHog (EU) — product analytics.
All sub-processors operate under Data Processing Agreements and process data only as necessary to provide their respective services.
Data Export (Art. 20 GDPR): You can export your complete data — including session history, cognitive profiles, and assessment results — at any time through the Account Settings page. The export is provided as a machine-readable JSON file.
Right to Erasure (Art. 17 GDPR): You can permanently delete your account and all associated data at any time via the 'Delete Account' button in Account Settings. This irreversibly removes your session data, assessments, cognitive profiles, and coaching records from our servers. Anonymized, non-identifiable aggregate data may be retained for service improvement.
Right of Access (Art. 15 GDPR): You may request confirmation of whether we process your personal data, and if so, access to that data, by contacting us at the address above.
Right to Restriction (Art. 18 GDPR): You may request restriction of processing under certain circumstances.
Right to Object (Art. 21 GDPR): You may object to processing based on legitimate interest (Art. 6(1)(f) GDPR).
Right to Withdraw Consent (Art. 7(3) GDPR): You may withdraw your consent at any time by deleting your account. Withdrawal does not affect the lawfulness of processing before withdrawal.
Right to Lodge a Complaint: You may lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence.
Active accounts: Your session data, cognitive profiles, and coaching records are retained for as long as your account is active.
Deleted accounts: Upon account deletion, all personal data and special category data is permanently removed. Anonymized aggregate data (e.g., total session counts, feature usage statistics) may be retained.
Billing records: Payment and invoice data is retained as required by German tax law (typically 10 years) even after account deletion.
SolvyKit is an AI-powered tool. All conversations are with an AI assistant, not a human. Users are informed of this at the start of every session.
SolvyKit is not a replacement for medical or psychological treatment. It is a structured thinking tool that uses evidence-based therapeutic frameworks.
We use technical and organizational measures to protect your data, including encrypted connections (TLS), access controls, and multi-layer safety systems. However, no internet transmission is entirely secure.
We may update this policy from time to time. Material changes will be communicated via the platform (e.g., a new consent notice). The 'Last Updated' date at the top reflects the most recent revision.
For questions regarding your data in SolvyKit, contact: PsyKotiki UG, Lilly-Reich Str. 8, 80807 Munich, Germany. Email: admin [at] psykotiki [dot] com.
For general company-level privacy matters (website logs, marketing, analytics), please refer to our corporate Privacy Policy.