Privacy Notice for the e-mobilio AI Assistant

1. Go to Emma's privacy policy →

2. Go to Nina's privacy policy →

3. Go to Christian’s privacy policy →

 

 

 

Privacy Notice pursuant to Article 13 of the GDPR and Terms of Use

for the AI assistant Emma

This document consists of two parts. In Part A—Privacy Notice—we, e-mobilio GmbH (hereinafter also“e-mobilio,” “we,” or “us”), provide users of our chatbot—in the form of the AI assistant “Emma”—on the employee portal with information, pursuant to Article 13 of the GDPR, regarding the processing of their personal data and the rights to which they are entitled as data subjects. Part B—Terms of Use—governs the relationship between you and e-mobilio regarding your use of the AI assistant. Part A alone governs the processing of your personal data.

e-mobilio enables you to communicate with the AI assistant Emma via the AI chatbot product “DocsBot” provided by UglyRobot, LLC, 651 N Broad St., Suite 206, Middletown, DE 19709, United States of America. The AI assistant is provided for informational purposes only and offers general advice based on the information available to her. She can answer your questions about e-mobility and the e-mobilio employee portal and help you navigate the new world of electric mobility.

The answers provided are not intended as professional advice and do not replace the advice of a qualified e-mobilio expert. Please evaluate the answers critically and always exercise due diligence when making decisions. Contact our experts if necessary.

The individuals affected by the data processing activities described here and the intended audience of this privacy notice are, with regard to the processing of personal data, specifically the users of the employee portal. Use of the chatbot service is voluntary. To clarify the questions and topics addressed there, you may also contact an e-mobilio employee at any time using traditional methods (e.g., by mail, email, or phone).

This privacy notice applies exclusively to the processing of personal data in connection with the use of the AI assistant Emma, for whiche-mobilio itself determines the purposes and essential means of processing and is therefore the controller within the meaning of Article 4(7) of the GDPR. For other processing activities on the employee portal, the respective client company is generally responsible; its separate privacy policy applies in this regard.

Part A: Privacy Notice

1. Who is responsible for processing your personal data, and who can you contact?

Address: Medienbrücke, 7th Floor, Gisela-Stein-Str. 21, 81671 Munich

Phone: +49 89 2555556 0

Email: info@e-mobilio.de

Managing Directors: Ralph Missy, Denis Reichel

You can contact our external data protection officer at:

Name: Lutz Mönig, on behalf of Pohl Consulting Team GmbH

Address: Mengeringhäuser Str. 15, 34454 Bad Arolsen

Phone: +49 5691 8900 501

Email: datenschutz@e-mobilio.de

2. What data do we use, and how do we collect it?

• The content of your questions and the responses generated by Emma (chat logs),
• your voluntary feedback on the quality of the responses (feedback),
• technical connection and log data, in particular conversation and session identifiers, a hash value of the IP address, timestamps, error logs, and a pseudonymous alias generated by DocsBot,
• details about your portal session that the employee portal transmits to the chatbot when you access Emma, specifically your email address or user ID stored in the portal, as well as your company’s Internet domain,
• the information stored on your device regarding your consent to the Terms of Use.
• Responding to your inquiries: Our legitimate interest lies in receiving and processing the inquiry you actively submit and providing you with a response based on the stored sources. You decide for yourself whether to access Emma and what information to enter. The employee portal remains fully available to you regardless of this.
• Quality assurance and error correction: Our legitimate interest lies in reviewing the quality of Emma’s responses, identifying incorrect or incomplete answers, and correcting the sources used. To this end, we analyze the chat logs and your voluntary feedback within the timeframes specified in Section 5.1. The underlying language model is not trained using your input.
• Technical Operation, Security, and Administration of Emma: Our legitimate interest lies in the secure, stable, and functional operation of the AI assistant Emma as a feature of the employee portal provided by e-mobilio. This includes, in particular, technical provision, session control, processing of necessary log and protocol data, error analysis, protection against malfunctions and security-related incidents, backend administration, authorization management, and the implementation of deletion processes.
• Storage on your device: Our legitimate interest lies in technically managing your session and documenting your consent to the Terms of Use so that we do not have to present them to you again each time you access the site.
• Handling of voluntarily provided third-party data: If users voluntarily enter third-party personal data in free-text fields, our legitimate interest lies in being able to technically process the actively submitted inquiry and handle any unintentionally entered personal data in accordance with the established deletion and protection processes.
• e-mobilio’s own content, including a collection of frequently asked questions and answers, pre-formulated response templates, and contact information
• Individual information pages on our e-mobilio.de website covering the topics of technology, public charging, and the environment, as well as the “About Us” page
• Configuration and installation instructions from manufacturers of wallboxes and charging stations
• An overview from a service provider of the charging stations supported by our system
• the reference book “Electric Mobility—Fundamentals of an Advanced Technology,” edited by Achim Kampker and Heiner Hans Heimes, 3rd edition, Springer Vieweg, Berlin/Heidelberg 2024, licensed under Creative Commons Attribution 4.0 International (CC BY 4.0), https://creativecommons.org/licenses/by/4.0/
• Answer questions about electric mobility and the e-mobilio employee portal based on the provided sources,
• summarize information from the provided e-mobilio sources and present it in an understandable way,
• Translate content from these sources.

The user’s name or username is not displayed in the chat window. DocsBot assigns a technically generated pseudonymous alias to the conversation in the backend. Since the details of your portal session are stored along with the conversation, it is still possible to link it to your portal account.

The association with your portal account serves exclusively the purposes specified in Section 3, in particular to provide relevant links to portal sections and the contact address responsible for your company, as well as to process your data subject rights. The data is not used for performance or behavioral monitoring.

The data will not be disclosed to third parties unless there is a legal obligation to do so (Art. 6(1)(c) of the GDPR). Processors acting on our behalf and in accordance with our instructions are not considered third parties within the meaning of this policy; details can be found in the section “Who has access to your data and where is it transferred?”.

Apart from the transfer of session data described above, we do not combine this data with other data sources.

3. For what purposes and on what legal basis do we process your data using the AI assistant Emma?

We base the processing activities listed below on the protection of our legitimate interests pursuant to Article 6(1)(f) of the GDPR. Processing on this basis takes place only to the extent that it is necessary to safeguard these interests and is not opposed by any overriding interests or the fundamental rights and freedoms of the data subjects.

We base the following processing activities on the legitimate interests specified below:

b) To comply with legal obligations (Art. 6(1)(c) of the GDPR)

If you contact us to file an objection or exercise another data subject right, we will process the information you provide in order to review and respond to your request. The legal basis for this is our obligations under Articles 12 through 22 of the GDPR.

4. How does the AI assistant Emma work?

Emma supports you in various ways, for example:

Emma deliberately does not answer questions outside this subject area. We have also instructed Emma not to provide information on political, religious, medical, legal, or financial topics. If Emma cannot find an answer in the stored sources, she will direct you to contact us via email.

Below, we’ll briefly explain how Emma works from a technical standpoint:

 

1. Document Capture and Processing
2. Storage in a vector database
3. Responding to user inquiries
4. Generation of Responses
5. Outputting the response

First, all the documents on which Emma is based are converted into vectors. These vectors are mathematical representations of the documents’ content and allow us to store and search them efficiently.

The document vectors are stored in a vector database, which functions like a giant library of information.

When you enter a question, the system converts it into a vector and compares it with the vectors in the database. This allows it to find the information that best matches your query. Along with your question, the portal sends the history of your conversation so far, as well as details about your portal session, so that Emma can provide you with relevant links to portal sections and give you the contact information for the department responsible for your company.

The most relevant information is then used as context, along with the original question, to generate a response in Markdown format. Markdown is a simple markup language that allows us to format text and add links.

The answer is then converted to HTML and displayed to the user.

 

Emma combines two components: vector search in our own knowledge base and a language model from the OpenAI ChatGPT API, which formulates the wording of the response based on the content found. The content comes from the stored sources, while the wording is generated by the language model. Despite these guidelines, responses may be incomplete or contain errors. For definitive information, please contact our support team.

5. How does the AI assistant Emma store and secure data?

5.1 Retention Period

If data processing is carried out in our legitimate interest or that of a third party, the personal data will be deleted as soon as that interest no longer exists, provided that no retention or documentation obligations prevent this.

To improve the quality of the chatbot and the user experience, e-mobilio stores the chat logs and the data collected during your conversation with the AI assistant Emma for 90 days.

After 90 days, we delete the data from our active systems. Any remaining copies in backup systems are removed within 90 days. Conversations that we manually export for analysis are deleted no later than 30 days after the export.

5.2 Cookies and Local Storage

Session cookies are absolutely necessary for your intended use of the chatbot; their use is therefore permitted without consent under Section 25(2)(2) of the TDDDG. The same applies to the entry in local storage that documents your consent to the Terms of Use.

5.3 Security

6. Who has access to your data, and where is it transmitted?

6.1 Recipients / Disclosure of Data

Personal data processed in connection with the use of the chatbot or the AI assistant Emma is generally not disclosed to third parties.

Within our company, access to your data is generally limited to those individuals who program and manage the chatbot.

Otherwise, the chatbot provider will necessarily become aware of the data mentioned above, to the extent provided for in our data processing agreement with the chatbot provider.

6.2 Data Processing Outside the European Union

7. What are your rights?

If the processing of your personal data is based on your consent, you are entitled under Article 7 of the GDPR to withdraw your consent at any time and without providing a reason, with effect for the future. This does not affect processing that took place prior to the withdrawal.

To the extent that the processing of your personal data is based on Article 6(1), first sentence, subparagraph (f) of the GDPR to safeguard legitimate interests, you also have the right, pursuant to Article 21 of the GDPR, for reasons arising from your particular situation, to object at any time to the processing of this personal data. We will then no longer process this personal data unless there are compelling legitimate grounds for the processing. These grounds must override your interests, rights, and freedoms, or the processing must serve the purpose of asserting, exercising, or defending legal claims.

To exercise your rights or if you have any further questions regarding data processing, you may contact our Data Protection Officer using the contact information provided in Section 1 of this Privacy Notice.

8. Is there an obligation to provide data?

9. Does automated decision-making or profiling take place?

Part B Terms of Use

10. What terms and conditions apply to the use of the AI assistant Emma?

• Use of the chatbot is permitted only to individuals who are at least 16 years of age.
• You must use Emma responsibly and exclusively for lawful purposes.
• You must not enter any special categories of personal data, any personal data regarding criminal convictions or offenses, or any personal data belonging to other individuals.
• You will not use Emma to create illegal, harmful, or discriminatory content.
• You understand that Emma is an AI and not a human. She cannot understand and answer all questions, and she may make mistakes.
• You understand that Emma is continuously being developed and does not always work flawlessly.
• You will verify the accuracy of the responses before basing a decision on them.

e-mobilio bears unlimited liability for damages resulting from injury to life, limb, or health, as well as for damages caused by willful misconduct or gross negligence. In the event of a negligent breach of material contractual obligations, liability is limited to foreseeable damages typical for this type of contract. Otherwise, liability is excluded. The AI assistant’s responses are generated automatically and may be incomplete or inaccurate. Therefore, make decisions with due care and consult appropriate experts if necessary.

11. Changes

 

 

 

Privacy Notice pursuant to Article 13 of the GDPR and Terms of Use

for the AI assistant Nina

For the sake of readability only, we have omitted the simultaneous use of masculine, feminine, and diverse (m/f/d) forms. All references to persons apply equally to all genders.

Preliminary Note

This document consists of two parts. In Part A—Privacy Notice—we, e-mobilio GmbH (hereinafter also“e-mobilio,” “we,” or “us”), provide users of our chatbot—in the form of the AI assistant “Nina”—on our website e-mobilio.de with information, in accordance with Article 13 of the GDPR, regarding the processing of their personal data and the rights to which they are entitled as data subjects. Part B—Terms of Use—governs the relationship between you and e-mobilio regarding your use of the AI assistant. Part A alone governs the processing of your personal data.

e-mobilio enables you to communicate with the AI assistant Nina via the “DocsBot” AI chatbot product provided by UglyRobot, LLC, 651 N Broad St., Suite 206, Middletown, DE 19709, United States of America. The AI assistant is provided for informational purposes only and offers general advice based on the information available to her. She can answer your questions about electric mobility, fleet management, and charging infrastructure, as well as about e-mobilio, our products, and services, and help you navigate the world of electric mobility.

The answers provided are not intended as professional advice and do not replace the advice of a qualified e-mobilio expert. Please evaluate the answers critically and always exercise due diligence when making decisions. Contact our experts if necessary.

The individuals affected by the data processing activities described here and the intended recipients of this privacy notice are, with regard to the processing of personal data, specifically the visitors to our website e-mobilio.de. Use of the AI chatbot is voluntary and does not require registration or a user account. To clarify the questions and topics addressed there, you may also contact an e-mobilio employee at any time using traditional methods (e.g., by mail, email, or phone).

This privacy notice applies exclusively to the processing of personal data in connection with the use of the AI assistant Nina, for which e-mobilio itself determines the purposes and essential means of processing and is therefore the controller within the meaning of Article 4(7) of the GDPR. Our general privacy policy applies to all other processing activities on our website.

Part A: Privacy Notice

1. Who is responsible for processing your personal data, and who can you contact?

Address: Medienbrücke, 7th Floor, Gisela-Stein-Str. 21, 81671 Munich

Phone: +49 89 2555556 0

Email: info@e-mobilio.de

Managing Directors: Ralph Missy, Denis Reichel

You can contact our external data protection officer at:

Name: Lutz Mönig, on behalf of Pohl Consulting Team GmbH

Address: Mengeringhäuser Str. 15, 34454 Bad Arolsen

Phone: +49 5691 8900 501

Email: datenschutz@e-mobilio.de

2. What data do we use, and how do we collect it?

• The content of your questions and the responses generated by Nina (chat logs),
• Your voluntary feedback on the quality of the responses (feedback),
• technical connection and log data, in particular conversation and session identifiers, a hash value of the IP address, timestamps, error logs, and a pseudonymous alias generated by DocsBot,
• the information stored on your device regarding your consent to the Terms of Use,
• the contact information you voluntarily provide and the conversation content necessary for processing, provided that you wish to be contacted by an e-mobilio employee.

No user name or chat name is displayed in the chat window. DocsBot assigns a technically generated pseudonymous alias to the conversation in the backend. Since the service is used without registration, we do not associate the conversation with any user account. A link to your identity can only be established if you enter personally identifiable information yourself or initiate contact with e-mobilio.

Data is not disclosed to third parties unless there is a legal obligation to do so (Art. 6(1)(c) GDPR). Processors acting on our behalf and in accordance with our instructions are not considered third parties within the meaning of this provision; details can be found in the section “Who has access to your data and where is it transferred?”.

We do not combine this data with other data sources. The data is not used for advertising, tracking, or analyzing your usage behavior.

3. For what purposes and on what legal basis do we process your data through the AI assistant Nina?

1. In the context of balancing of interests (Art. 6(1)(f) of the GDPR)

We base the processing activities listed below on the protection of our legitimate interests pursuant to Article 6(1)(f) of the GDPR. Processing on this basis takes place only to the extent that it is necessary to safeguard these interests and is not opposed by any overriding interests or the fundamental rights and freedoms of the data subjects.

We base the following processing activities on the legitimate interests specified below:

• Responding to your inquiries: Our legitimate interest lies in receiving and processing the inquiry you have actively submitted and providing you with a response based on the sources on file. You decide for yourself whether to use Nina and what information to enter. Regardless of this, our website remains fully available to you.
• Quality assurance and error correction: Our legitimate interest lies in reviewing the quality of Nina’s responses, identifying incorrect or incomplete answers, and correcting the sources used. To this end, we primarily evaluate your voluntary feedback as well as chat logs selected on a case-by-case basis or at random within the timeframes specified in Section 5.1. We do not systematically evaluate all conversations. The underlying language model is not trained using your input.
• Technical Operation, Security, and Administration of Nina: Our legitimate interest lies in the secure, stable, and functional operation of the AI assistant Nina as a feature of our website. This includes, in particular, technical provision, session control, processing of necessary log and protocol data, error analysis, protection against malfunctions and security-related incidents, backend administration, authorization management, and the implementation of deletion processes.
• Storage on Your Device: Our legitimate interest lies in technically managing your session and documenting your consent to the Terms of Use so that we do not have to present them to you again each time you visit the site.
• Processing of contact and support requests: If you initiate contact with an e-mobilio employee, our legitimate interest is in receiving, forwarding, and processing your request. This applies unless the processing is already based on subparagraph (b).
• Handling of voluntarily provided third-party data: If users voluntarily enter third-party personal data in free-text fields, our legitimate interest lies in being able to technically process the actively submitted inquiry and to handle any unintentionally entered personal data in accordance with the established deletion and protection procedures.

1. To carry out pre-contractual measures (Art. 6(1)(b) GDPR)
2. To comply with legal obligations (Art. 6(1)(c) GDPR)

If your inquiry is aimed at entering into a contract with e-mobilio, we process the contact information you have voluntarily provided and the details of our communication necessary for handling your inquiry in order to take steps prior to entering into a contract.

If you contact us to exercise your right to object or any other data subject right, we will process the information you provide in order to review and respond to your request. The legal basis for this is our obligations under Articles 12 through 22 of the GDPR.

4. How does the AI assistant Nina work?

• e-mobilio’s own content, including collections of frequently asked questions and answers on fleet management as well as pre-formulated response templates
• our website e-mobilio.de, including the blog and magazine articles published there
• selected additional websites on the topics of electric mobility, charging infrastructure, and funding opportunities, including a press release from the Arnsberg District Government regarding funding for climate protection measures
• the reference book “Electric Mobility—Fundamentals of an Advanced Technology,” edited by Achim Kampker and Heiner Hans Heimes, 3rd edition, Springer Vieweg, Berlin/Heidelberg 2024, licensed under Creative Commons Attribution 4.0 International (CC BY 4.0), https://creativecommons.org/licenses/by/4.0/
• Answer questions regarding electric mobility, fleet management, and charging infrastructure, as well as e-mobilio, our products, and services based on the provided sources,
• summarize information from the provided e-mobilio sources and present it in an understandable way,
• Direct you to relevant content on our website and provide contact information.

Nina supports you in a variety of ways, for example:

Nina deliberately does not answer questions outside this subject area. If Nina cannot find sufficient information in the available sources to provide an answer, she will ask for clarification, point out the lack of information, or refer you to contact e-mobilio.

Below, we’ll briefly explain how Nina works from a technical standpoint:

 

1. Document Capture and Processing
2. Storage in a vector database
3. Responding to user inquiries
4. Generation of Responses
5. Outputting the response

First, all the documents on which Nina is based are converted into vectors. These vectors are mathematical representations of the documents’ content and allow us to store and search them efficiently.

The document vectors are stored in a vector database, which functions like a giant library of information.

When you enter a question, the system converts it into a vector and compares it with the vectors in the database. This allows it to find the information that best matches your query. Along with your question, the system also transmits the history of your conversation as well as technical connection and session data.

The most relevant information is then used as context, along with the original question, to generate a response in Markdown format. Markdown is a simple markup language that allows us to format text and add links.

The answer is then converted to HTML and displayed to the user.

 

Nina combines two components: vector search in our own knowledge base and a language model from the OpenAI ChatGPT API, which formulates the wording of the response based on the content found. The content comes from the stored sources, while the linguistic form is generated by the language model. Despite these guidelines, responses may be incomplete or contain errors. For definitive information, please contact our support team.

If you’d like to speak with an e-mobilio representative, Nina will forward your request. In doing so, the details of the conversation necessary for processing your request and the contact information you provide in the chat will be forwarded to the appropriate representative. This forwarding takes place exclusively at your request. If you explicitly ask for our contact information, Nina will provide you with the email address and phone number of our support team.

5. How is data stored and secured by the AI assistant Nina?

5.1 Retention Period

If data processing is carried out in our legitimate interest or that of a third party, the personal data will be deleted as soon as that interest no longer exists, provided that no retention or documentation obligations prevent this.

To improve the quality of the chatbot and the user experience, e-mobilio stores the chat logs and the data collected during your conversation with the AI assistant Nina for 90 days.

After 90 days, we delete the data from our active systems. Any remaining copies in backup systems are removed within 90 days. Conversations that we manually export for analysis are deleted no later than 30 days after export.

5.2 Cookies and Local Storage

Session cookies are absolutely necessary for your intended use of the chatbot; their use is therefore permitted without consent under Section 25(2)(2) of the TDDDG. The same applies to the entry in local storage that documents your consent to the Terms of Use.

5.3 Security

6.1 Recipients / Disclosure of Data

Personal data processed in connection with the use of the chatbot or the AI assistant Nina is generally not disclosed to third parties.

Within our company, access to your data is generally limited to those individuals who program and manage the chatbot. If you initiate contact, the employee responsible for your inquiry will also be granted access to the information necessary to address it.

Otherwise, the chatbot provider will necessarily become aware of the data mentioned above, to the extent provided for in our data processing agreement with the chatbot provider.

6.2 Data Processing Outside the European Union

7. What are your rights?

If the processing of your personal data is based on your consent, you are entitled under Article 7 of the GDPR to withdraw your consent at any time and without providing a reason, with effect for the future. This does not affect processing that took place prior to the withdrawal.

Since Nina is used without registration, we store conversations under a randomly assigned chat name or session ID. To help us match your inquiry to the correct conversation, please provide us with the necessary details, particularly the approximate time of use. We do not collect or store any additional personal data solely for the purpose of identifying you; if assignment is not possible, Article 11(2) of the GDPR applies. After the expiration of the time limits specified in Section 5.1, no data remains to which a request could pertain.

8. Is there an obligation to provide data?

9. Does automated decision-making or profiling take place?

Part B Terms of Use

10. What terms and conditions apply to the use of the AI assistant Nina?

• Use of the chatbot is permitted only to individuals who are at least 16 years of age.
• You must use Nina responsibly and exclusively for lawful purposes.
• You must not enter any special categories of personal data, any personal data regarding criminal convictions or offenses, or any personal data belonging to other individuals.
• You will not use Nina to create illegal, harmful, or discriminatory content.
• You understand that Nina is an AI and not a human. She cannot understand or answer all questions, and she may make mistakes.
• You understand that Nina is continuously being developed and does not always operate without errors.
• You will verify the accuracy of the answers before basing a decision on them.

e-mobilio bears unlimited liability for damages resulting from injury to life, body, or health, as well as for damages caused by willful misconduct or gross negligence. In the event of a negligent breach of material contractual obligations, liability is limited to foreseeable damages typical for this type of contract. Otherwise, liability is excluded. The AI assistant’s responses are generated automatically and may be incomplete or inaccurate. Therefore, please exercise due diligence when making decisions and consult appropriate experts as needed.

11. Changes

 

 

Privacy Notice pursuant to Article 13 of the GDPR and Terms of Use

for the AI assistant Christian

The answers and product recommendations provided are not intended as professional advice and do not replace the advice of a qualified e-mobilio expert. The product information, prices, and availability displayed in the online store and at checkout are authoritative. Please evaluate the answers critically and always make decisions with due care. If necessary, contact our experts.

The individuals affected by the data processing activities described here and the intended audience of this privacy notice are, with regard to the processing of personal data, specifically the visitors to our online store. Use of the AI chatbot is voluntary and does not require registration or a user account. To clarify the questions and topics addressed there, you may also contact an e-mobilio representative at any time using traditional methods (e.g., by mail, email, or phone).

This privacy notice applies exclusively to the processing of personal data in connection with the use of the AI assistant “Christian,” for which e-mobilio itself determines the purposes and essential means of processing and is therefore the data controller within the meaning of Article 4(7) of the GDPR. For all other processing activities in our online store—in particular regarding the shopping cart, the ordering process, and the cookies used therein—our general privacy policy in our online store applies.

Part A: Privacy Notice

1. Who is responsible for processing your personal data, and who can you contact?

Address: Medienbrücke, 7th Floor, Gisela-Stein-Str. 21, 81671 Munich

Phone: +49 89 2555556 0

Email: info@e-mobilio.de

Managing Directors: Ralph Missy, Denis Reichel

You can contact our external data protection officer at:

Name: Lutz Mönig, on behalf of Pohl Consulting Team GmbH

Address: Mengeringhäuser Str. 15, 34454 Bad Arolsen

Phone: +49 5691 8900 501

Email: datenschutz@e-mobilio.de

2. What data do we use, and how do we collect it?

• The content of your questions and the responses generated by Christian (chat logs),
• the information you provide regarding your requirements and preferences, such as charging power, connection type, cable length, vehicle compatibility, installation situation, or budget,
• the product recommendations generated by Christian based on this information, as well as the shopping cart links created at your request,
• your voluntary feedback on the quality of the responses (feedback),
• technical connection and log data, in particular conversation and session identifiers, a hash value of the IP address, timestamps, error logs, and a pseudonymous alias generated by DocsBot,
• the information stored on your device regarding your consent to the Terms of Use,
• the contact information you voluntarily provide and the conversation content necessary for processing, provided that you wish to be contacted by an e-mobilio employee.

No user name or chat name is displayed in the chat window. DocsBot assigns a technically generated pseudonymous alias to the conversation in the backend. Since the service is used without registration, we do not associate the conversation with any user account. A link to your identity can only be established if you enter personally identifiable information yourself or initiate contact with e-mobilio.

If you open a shopping cart link generated by Christian, our online store’s systems will process the data required for the shopping cart, the order, and payment. Christian does not transmit any information from the chat to the shopping cart. The link contains only the identifier of the product or product variant you selected and the quantity. The general privacy policy of our online store applies to processing in the shopping cart and during the rest of the ordering process.

Data is not disclosed to third parties unless there is a legal obligation to do so (Art. 6(1)(c) GDPR). Processors acting on our behalf and in accordance with our instructions are not considered third parties within the meaning of this provision; details can be found in the section “Who has access to your data and where is it transferred?”.

We do not combine this data with other data sources, in particular not with customer or order data from the online store. Product recommendations are based exclusively on the information you provide during the chat. The data is not used for tracking, analyzing your usage behavior beyond the conversation, or for advertising purposes outside of the chat.

 

3. For what purposes and on what legal basis do we process your data through the AI assistant Christian?

1. As part of the balancing of interests (Art. 6(1)(f) of the GDPR)

We base the processing activities listed below on the protection of our legitimate interests pursuant to Article 6(1)(f) of the GDPR. Processing on this basis takes place only to the extent that it is necessary to safeguard these interests and is not opposed by any overriding interests or the fundamental rights and freedoms of the data subjects.

We base the following processing activities on the respective legitimate interests specified:

• Responding to your inquiries: Our legitimate interest lies in receiving and processing the inquiry you have actively submitted and providing you with a response based on the available sources. You decide for yourself whether to contact Christian and what information to provide. Regardless of this, our online store is fully available to you.
• Product advice and sales promotion for our own product range: Our legitimate interest lies in recommending suitable products from our range in response to your inquiry, matching the requirements you specify with the stored product information, and informing you about suitable accessories as well as our consulting and installation services. The recommendations relate exclusively to our own product range or to products we have approved and do not constitute a neutral comparison of the entire market. Data processing takes place solely within the chat you have actively initiated. We do not link your information to a user account, order history, or your other usage behavior in the online store, and we do not use it for subsequent or cross-channel advertising.
• Quality Assurance and Error Correction: Our legitimate interest lies in verifying the quality of Christian’s responses and recommendations, identifying incorrect or incomplete information and recommendations, and correcting the cited sources and system specifications. To this end, we primarily evaluate your voluntary feedback as well as chat logs selected on a case-by-case basis or at random within the timeframes specified in Section 5.1. We do not systematically evaluate all conversations. The underlying language model is not trained using your input.
• Technical Operation, Security, and Administration of Christian: Our legitimate interest lies in the secure, stable, and functional operation of Christian as a feature of our online store. This includes, in particular, technical provision, session management, processing of necessary log and protocol data, error analysis, protection against malfunctions, misuse, and security-related incidents, backend administration, authorization management, and the implementation of deletion processes.
• Storage on your device: Our legitimate interest lies in technically managing your session and storing your acceptance of the Terms of Use so that we do not have to present them to you again each time you visit the site. The access to your device’s storage required for this purpose is based on Section 25(2)(2) of the TDDDG.
• Processing of contact and support requests: If you contact an e-mobilio employee, our legitimate interest is to receive, forward, and process your request. This applies unless the processing is already based on Article 6(1)(b) of the GDPR.
• Processing of Information from Publicly Available Sources: To the extent that the sources provided or made available by e-mobilio contain publicly accessible business contact information, our legitimate interest is to provide you with accurate information and the appropriate contact persons. Processing is limited to current information from a professional context that is necessary for providing a specific response.
• Handling of voluntarily provided third-party data: If users voluntarily enter third-party personal data in free-text questions, our legitimate interest lies in being able to technically process the actively submitted inquiry and to handle any unintentionally entered personal data within the framework of the established deletion and protection processes. Special categories of personal data under Article 9 of the GDPR and data under Article 10 of the GDPR are not legitimized by this legal basis.

1. To carry out pre-contractual measures (Art. 6(1)(b) GDPR)
2. To comply with legal obligations (Art. 6(1)(c) GDPR)

If your inquiry specifically concerns the selection or purchase of a product, a product variant, or a service; the creation of a shopping cart link; or any other pre-contractual steps, we will process your information and the content of our communications necessary for handling your request in order to carry out pre-contractual measures. This includes, in particular, clarifying your requirements for a specific product, answering your questions regarding ordering, delivery, and installation, and creating a shopping cart link at your express request.

If you contact us to exercise your right to object or any other data subject right, we will process the information you provide in order to review and respond to your request. The legal basis for this is our obligations under Articles 12 through 22 of the GDPR.

4. How does the AI assistant Christian work?

• the offerings in our online store, shop.e-mobilio.de, including product descriptions as well as selected product range and bestseller overviews
• compiled lists of websites related to our products, accessories, charging infrastructure, and our consulting and installation services
• a product and variant mapping that Christian uses to generate a link to a pre-filled shopping cart
• a collection of frequently asked questions and answers
• the reference book “Electric Mobility—Fundamentals of an Emerging Technology,” edited by Achim Kampker and Heiner Hans Heimes, 3rd edition, Springer Vieweg, Berlin/Heidelberg 2024, licensed under Creative Commons Attribution 4.0 International (CC BY 4.0), https://creativecommons.org/licenses/by/4.0/
• Answer questions about our products, their features, the charging infrastructure, installation, and the ordering process based on the provided sources,
• recommend suitable products from our lineup based on the requirements you have specified,
• point out related accessories as well as our consulting and installation services,
• and, upon request, provide you with a link to a pre-filled shopping cart.

Christian supports you in various ways, for example:

If you specify technical requirements—such as charging power, connection type, cable length, or vehicle compatibility—Christian will compare them with the stored product information. A recommendation will only be made if all the requirements you’ve identified as mandatory can be confirmed using these sources. If required information is missing, Christian will ask for clarification, point out the lack of information, or direct you to contact e-mobilio. If you do not specify any selection criteria, Christian can suggest products that are in high demand and those that are part of e-mobilio’s key product categories. The recommendations apply exclusively to e-mobilio’s product range and do not constitute a neutral comparison of the entire market. Christian deliberately does not answer questions outside this subject area.

Below, we’ll briefly explain how Christian works from a technical standpoint:

 

1. Document Capture and Processing
2. Storage in a vector database
3. Responding to user inquiries
4. Generation of Responses
5. Outputting the response

First, all the documents on which Christian is based are converted into vectors. These vectors are mathematical representations of the documents’ content and allow us to store and search them efficiently.

The document vectors are stored in a vector database, which functions like a giant library of information.

When you enter a question, the system converts it into a vector and compares it with the vectors in the database. This allows it to find the information that best matches your query. Along with your question, the system also transmits the history of your conversation as well as technical connection and session data.

The most relevant information is then used as context, along with the original question, to generate a response in Markdown format. Markdown is a simple markup language that allows us to format text and add links.

The answer is then converted to HTML and displayed to the user.

 

Christian combines two components: vector search in our own knowledge base and a language model from the OpenAI ChatGPT API, which formulates the wording of the response based on the content found. The content comes from the stored sources, while the linguistic form is generated by the language model. Despite these specifications, answers and product recommendations may be incomplete or incorrect. The product information, prices, and availability displayed in the online store and at checkout are authoritative. For binding information, please contact our support team.

If you express an intention to purchase a single product, Christian can generate a link to a pre-filled shopping cart based on the stored product and variant assignments. Christian will provide you with this link but will not place an order himself. Only when you open the link, review the product selection and price in the shopping cart, and continue the ordering process yourself will our online store’s systems process the necessary data.

If you’d like to speak with an e-mobilio employee, Christian will forward your request. In doing so, the details of the conversation needed to process your request and the contact information you provide in the chat will be forwarded to the appropriate employee. This forwarding takes place exclusively at your request. If you explicitly ask for our contact information, Christian will provide you with the email address and phone number of our support team.

5. How is data stored and secured by the AI assistant Christian?

5.1 Retention Period

If data processing is carried out in the legitimate interest of us or a third party, the personal data will be deleted as soon as that interest no longer exists, provided that no retention or documentation obligations prevent this.

To improve the quality of the chatbot and the user experience, e-mobilio stores the chat logs and the data collected during your conversation with the AI assistant Christian for 90 days.

After 90 days, we delete the data from our active systems. Any remaining copies in backup systems are removed within 90 days. Conversations that we manually export for analysis are deleted no later than 30 days after the export.

5.2 Cookies and Local Storage

Session cookies are absolutely necessary for your intended use of the chatbot; their use is therefore permitted without consent under Section 25(2)(2) of the TDDDG. The same applies to the entry in local storage that documents your consent to the Terms of Use.

This information does not affect the cookies used by our online store independently of the chatbot.

5.3 Security

6.1 Recipients / Disclosure of Data

Personal data processed in connection with the use of the chatbot or the AI assistant Christian is generally not disclosed to third parties.

Within our company, access to your data is generally limited to those individuals who program and manage the chatbot. If you initiate contact, the employee responsible for your inquiry will also be granted access to the information necessary to handle it.

Otherwise, the chatbot provider will necessarily become aware of the data mentioned above, to the extent provided for in our data processing agreement with the chatbot provider.

6.2 Data Processing Outside the European Union

7. What are your rights?

Every data subject has the right of access under Article 15 of the GDPR, the right to rectification under Article 16 of the GDPR, the right to erasure under Article 17 of the GDPR, the right to restriction of processing under Article 18 of the GDPR, the right to notification under Article 19 of the GDPR, and the right to data portability under Article 20 of the GDPR.

In addition, you have the right to lodge a complaint with a data protection supervisory authority under Article 77 of the GDPR if you believe that the processing of your personal data is not lawful. This right to lodge a complaint is without prejudice to any other administrative or judicial remedy. The data protection supervisory authority responsible for us is: Bavarian State Office for Data Protection Supervision (BayLDA), P.O. Box 1349, 91504 Ansbach, Phone +49 (0) 981 180093-0.

If the processing of your personal data is based on your consent, you are entitled under Article 7 of the GDPR to withdraw your consent at any time and without providing a reason, with effect for the future. This does not affect processing that took place prior to the withdrawal.

To the extent that the processing of your personal data is carried out pursuant to Article 6(1), first sentence, subparagraph (f) of the GDPR to safeguard legitimate interests, you also have the right, pursuant to Article 21 of the GDPR, for reasons arising from your particular situation, to object at any time to the processing of this personal data. We will then no longer process this personal data unless there are compelling legitimate grounds for the processing. These grounds must override your interests, rights, and freedoms, or the processing must serve the purpose of asserting, exercising, or defending legal claims.

To the extent that we process your personal data for the purpose of direct marketing, you may object to this processing at any time and without providing a reason.

To exercise your rights or if you have any further questions regarding data processing, you may contact our Data Protection Officer using the contact information provided in Section 1 of this Privacy Policy.

Since Christian is used without registration, we store conversations under a randomly assigned chat name or session ID. To help us match your inquiry to the correct conversation, please provide us with the necessary details, particularly the approximate time of use. We do not collect or store any additional personal data solely for the purpose of identifying you; if assignment is not possible, Article 11(2) of the GDPR applies. After the expiration of the time limits specified in Section 5.1, no data remains to which a request could pertain.

8. Is there an obligation to provide data?

9. Does automated decision-making or profiling take place?

10. What terms and conditions apply to the use of the AI assistant Christian?

• Use of the chatbot is permitted only to individuals who are at least 16 years of age.
• You must use Christian responsibly and exclusively for lawful purposes.
• You must not enter any special categories of personal data, any personal data regarding criminal convictions or offenses, or any personal data belonging to other individuals.
• You will not use Christian to create illegal, harmful, or discriminatory content.
• You understand that Christian is an AI and not a human. He cannot understand or answer all questions, and he may make mistakes.
• You understand that Christian is continuously being developed and does not always operate error-free.
• You will review the answers, product recommendations, prices, and product features before making a purchase decision. The product information, prices, and availability displayed in the online store and at checkout are authoritative.
• You understand that the recommendations refer exclusively to the e-mobilio product range and do not constitute a neutral comparison of the entire market.

e-mobilio bears unlimited liability for damages resulting from injury to life, limb, or health, as well as for damages caused by willful misconduct or gross negligence. In the event of a negligent breach of material contractual obligations, liability is limited to foreseeable damages typical for this type of contract. Otherwise, liability is excluded. The AI assistant’s responses are generated automatically and may be incomplete or inaccurate. Therefore, please exercise due diligence when making decisions and consult appropriate experts as needed.

11. Changes