Funpilot Privacy Policy
Onyx Blue Digital GmbH ("Funpilot", "we", "us") operates the Funpilot service (the "Service"). This Privacy Policy explains what personal data we process when you use the Service, why, on what legal basis, with whom we share it, and the choices and rights you have. If you reside in Austria, the German-language Privacy Policy is the binding version for you.
We do not run advertising trackers or ad-network SDKs, and we do not sell, rent, or share your personal data with advertisers or data brokers.
1. Controller and contact
The controller is Onyx Blue Digital GmbH, Tuchlauben 7A, 1010 Wien, Austria (FN 677713 m, UID ATU83267019). You can reach us at support@funpilot.ai.
2. What we process, why, and on what legal basis
Where the table refers to Art. 6(1)(b) GDPR, processing is necessary to provide the Service or the relevant feature you request. Where the table refers to Art. 6(1)(c) GDPR, processing is necessary to comply with legal obligations, including tax, accounting, age-related or regulatory obligations where applicable. Where the table refers to Art. 6(1)(f) GDPR, we rely on our legitimate interests in operating, improving and securing the Service, preventing misuse, providing useful personalization, enabling social features, responding to support requests and establishing, exercising or defending legal claims.
Where we process special-category data within the meaning of Art. 9 GDPR, such as health, fitness, weight, mental wellbeing or similar sensitive goals, we do so only where a separate Art. 9 legal basis applies, in particular your explicit consent under Art. 9(2)(a) GDPR, unless another legal basis applies in a specific case.
| Data | Examples | Purpose | Legal basis (GDPR Art. 6 (1)) |
|---|---|---|---|
| Account data | email, nickname, language, account status | Create and run your account; sign you in | (b) contract |
| Authentication | session cookie, sign-in events | Keep you signed in; protect your account | (b) contract; (f) security |
| Age verification | result + timestamp + method (not your date of birth) | Confirm you are 18+ | (b) contract; (f) legitimate interest in enforcing age restrictions and preventing misuse; (c) where age checks are legally required |
| Preferences | transport, intensity, interests, budget, etc. | Personalise suggestions | (a) consent where the preference is optional and consent-based; Art. 9(2)(a) explicit consent where the preference reveals special-category data; (b) contract |
| Location | homebase, and (if you use it) device location | Suggest activities near you | (b) contract for homebase and location-based features; (a) consent for device location and live beacon sharing |
| Activity data | saved/visited activities, adventures, to-dos | Provide the features you use | (b) contract |
| Conversations | messages with buddies and people you chat with | Provide chat and recommendations | (b) contract |
| Learned facts | facts inferred from your conversations | Personalise and keep suggestions relevant | (f) legitimate interest in providing a useful, personalised service; see §4; Art. 9(2)(a) explicit consent where learned facts include special-category data and are used for sensitive goals |
| Contacts & invitations | your contacts; invitee email + name | Let you connect and plan with people | (b) contract; (f) running a social feature |
| Payment data | billing identifiers held by our payment processor; invoices | Process Premium and name-your-price; tax duties | (b) contract; (c) tax/accounting |
| Support | the content of your messages to us | Answer your questions | (b) contract; (f) legitimate interest |
| Operational telemetry | error reports, performance traces, logs | Diagnose problems; keep the Service secure and running | (f) operation and security |
Age: we use your date of birth only to compute the 18+ result and then discard it; we do not store it.
3. AI features and AI vendors
The Service uses AI to power buddies, recommendations, chat, conversation titles, parts of the activity catalogue, and AI-generated images (such as buddy portraits and illustrative activity images). To provide these features, we send the necessary inputs (such as your messages and preferences) to specialist AI vendors acting as our processors (the current vendors are named in our sub-processor list). We have data-processing terms with these vendors and configure their services to disable training on our data where the vendor supports it.
AI outputs can be inaccurate, incomplete or not suitable for your specific situation. Buddy messages and recommendations are not professional advice and should not be relied on as medical, psychological, legal, financial or other professional advice.
In line with our transparency duties under the EU AI Act, we tell you when you are interacting with AI, and AI-generated images are visibly labelled and carry a machine-readable marker identifying them as AI-generated.
4. Learned facts and personalisation
Your buddies learn facts about you from your conversations to make suggestions more useful and relevant. For example, they may remember activity preferences, places you like, budget ranges, transport preferences or things you have said you do or do not enjoy. You can see and delete learned facts in your account. Deleting a fact does not stop it being learned again if you mention it later. We rely on our legitimate interest in providing a useful, personalised service; you can object to this processing at any time (see §10). Where a learned fact includes special-category data, such as health, fitness, weight, mental wellbeing or similar sensitive goals, we use it only where a valid Art. 9 GDPR legal basis applies, in particular your explicit consent where required.
4a. Proactive engagement and sensitive goals
Proactive engagement is a Premium feature: buddies may contact you on their own initiative based on your settings, history, and learned facts. It is on by default for Premium users and can be turned off at any time in your settings. Where a proactive message would draw on goals about your health or wellbeing (for example fitness or weight goals), that information may be special-category data under Article 9 GDPR; we process it only where you have actively provided the relevant information for this purpose and where we have a valid legal basis, including your explicit consent, where required. You can withdraw that consent or turn the feature off at any time. This profiling is used to time and shape supportive suggestions; it does not produce legal or similarly significant effects, and the messages are not professional advice. The withdrawal of consent does not affect the lawfulness of processing before withdrawal.
We do not use proactive engagement to make automated decisions about eligibility, creditworthiness, employment, insurance, access to essential services or similar matters.
5. Connecting with people, and invitations
When you invite someone by email, we process that person's email and name to send the invitation on your instruction.
- If they are not a Funpilot user, we send them an invitation email and keep a pending invitation record.
- We apply sending limits to reduce misuse.
If you receive an invitation from a Funpilot user and you are not yet a Funpilot user, we received your name and email address from that user. We use this data only to send and manage the invitation, prevent misuse, and maintain security. If you do not accept the invitation, we delete or anonymise the pending invitation record according to our invitation-retention rules.
You should invite people only where you are allowed to do so and where the invitation is not unwanted or unlawful.
6. Location and live sharing
We use your homebase, and - only if you choose to use device location - your device's location, to suggest activities nearby. You can disable device location through your device or browser settings. If you switch on a live "beacon", your real-time location is shared with your contacts while it is active; this is based on your consent, you can stop it at any time, and it expires automatically. We do not use device location or live beacon data for advertising.
7. Payments
Premium subscriptions (and any voluntary "name your price" payments) are processed through Stripe. Onyx Blue Digital GmbH is the seller of record; because we use Stripe's managed payments, Sold Through Link, LLC acts as the merchant of record for the transaction. We receive billing identifiers and transaction records (not your full card number) and keep invoices and related records to meet tax and accounting obligations. Stripe may process your payment data as a separate controller for certain payment-related purposes, as described in Stripe's own privacy information.
8. Cookies and similar storage
Funpilot's own code sets a small number of essential cookies: a session cookie that keeps you signed in, a CSRF-protection cookie that guards against cross-site request forgery, and a language-preference cookie that remembers the language you use. We do not set advertising, analytics, or marketing cookies, and we do not show a cookie-consent banner. We also use a small amount of temporary local storage needed to complete sign-in, which is cleared afterwards. Third-party pages (such as Stripe's checkout) set their own cookies on their own domains. See our Cookie Policy for the full list.
9. Recipients and international transfers
We share personal data only with processors acting on our behalf - hosting and cloud infrastructure, payment processing (Stripe), email delivery, maps and places, sign-in, error tracking, and the AI vendors described above - and with authorities where the law requires it. The current, named list of our sub-processors is in our sub-processor list.
Some processors operate outside the European Economic Area. Where they do, we rely on appropriate safeguards under the GDPR - typically the European Commission's Standard Contractual Clauses - and check the processor's transfer safeguards.
Some processors may process personal data in countries for which the European Commission has not adopted an adequacy decision. Where required, we also apply additional technical and organisational safeguards. If required by law, you can request further information and, where applicable, a copy of the relevant safeguards by contacting us at support@funpilot.ai.
We may also share data with courts, authorities, legal advisers or other recipients where this is required by law or necessary to establish, exercise or defend legal claims.
10. How long we keep data, and your rights
Retention. We keep account data while your account exists. When you ask to delete your account, it is scheduled for deletion after a grace period; after that we delete your data, except records we must keep by law - in particular invoices and tax records, and a de-identified record that you accepted a given version of our legal documents (the policy version and the time of acceptance), kept for the applicable limitation period.
Conversations, activity data, preferences and learned facts are kept while your account exists, unless you delete them earlier where the Service allows this. Device location is processed only while needed to provide the location-based feature. Live beacon data is shared only while the beacon is active and expires automatically. Pending invitation records are kept until the invitation is accepted, withdrawn, expires or is deleted according to our invitation-retention rules.
Authentication logs, security logs, error reports and operational telemetry are kept for a limited period necessary for security, fraud prevention, troubleshooting and operation of the Service. Support communications are kept for as long as needed to handle your request and, where necessary, for applicable limitation periods to document the communication.
Where we need data to establish, exercise or defend legal claims, we keep it for as long as necessary for that purpose.
Your rights. Under the GDPR you can access, rectify, erase, restrict, object to processing, and receive your data in a portable format. Where we rely on consent, you can withdraw it at any time (Art. 7(3)) without affecting prior processing. You can also lodge a complaint with a supervisory authority - for users in Austria, the Datenschutzbehörde (https://www.dsb.gv.at). To exercise your rights, contact support@funpilot.ai.
11. Children
The Service is for users 18 and over. We do not knowingly process data of people under 18; where age verification fails, related data is removed. Where necessary, we may keep limited records for security, fraud prevention or legal compliance.
12. Changes
We may update this Policy. We will make material changes visible before they apply. The current version is always available on our website.