Privacy Policy

Last updated: 25 March 2026  ·  Effective: 25 March 2026  ·  Version 1.0

This Privacy Policy explains how THC Projects SRL ("Soemel", "we", "us", "our") collects, uses, and protects your personal data when you use our services. We are committed to full compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and Romanian data-protection law.

1. Data Controller

The data controller responsible for your personal data is:

If you have any questions or concerns about how we handle your personal data, please contact us at the address above. We will respond within 30 days.

2. What Data We Collect

2.1 Account Information

When you register, we collect:

2.2 Conversation Metadata

We log metadata about your sessions for operational purposes, including:

We do NOT store the content of your conversations. Your prompts and the AI's responses are processed in real time to generate a reply and are then discarded. We do not use conversation content for training AI models, and we do not retain message text on our servers after a session ends.

2.3 Payment Information

Payments are handled by Stripe, Inc. We receive from Stripe only tokenised references to your payment method (e.g. last 4 digits, card type, expiry). We never see or store your full card number or CVV.

2.4 Technical Data

2.5 Cookies & Tracking

We use minimal, strictly necessary cookies for session authentication. We do not use third-party advertising cookies or tracking pixels. See Section 7 for details.

3. How We Use Your Data

PurposeLegal Basis (GDPR)
Providing the Soemel service (account management, AI responses)Article 6(1)(b) — performance of contract
Processing payments and managing subscriptionsArticle 6(1)(b) — performance of contract
Sending transactional emails (receipts, security alerts)Article 6(1)(b) — performance of contract
Improving platform reliability and fixing bugsArticle 6(1)(f) — legitimate interests
Complying with legal obligations (tax records, GDPR requests)Article 6(1)(c) — legal obligation
Sending product updates and marketing emails (optional)Article 6(1)(a) — consent (opt-in)

We do not sell your personal data to third parties. We do not use your data for automated decision-making that produces legal or similarly significant effects without human review.

4. Data Retention

5. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights:

To exercise any of these rights, email support@soemel.com with subject line "GDPR Request – [right]". We will verify your identity and respond within 30 days.

You also have the right to lodge a complaint with the Romanian supervisory authority: Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)www.dataprotection.ro.

6. International Transfers

We are an EU-based company (Romania) and process data primarily within the EU/EEA. However, some of our third-party service providers (Anthropic, Google, Stripe) may process data outside the EU. In such cases, we ensure adequate safeguards are in place, such as:

7. Cookies

We use the following cookies:

CookieTypePurposeDuration
session_tokenStrictly NecessaryAuthenticates your logged-in sessionSession / 30 days
csrf_tokenStrictly NecessaryPrevents cross-site request forgerySession

We do not use advertising, analytics, or social-media tracking cookies. No third-party cookies are set on soemel.com.

8. Third-Party Service Providers

We share limited personal data with the following trusted sub-processors to operate the service:

ProviderRoleData SharedLocation
Anthropic, Inc.AI model (Claude)Conversation content (real-time, not stored)USA (SCCs apply)
Google LLCAI model (Gemini)Conversation content (real-time, not stored)USA/EU (SCCs apply)
Stripe, Inc.Payment processingEmail, billing infoUSA/EU (SCCs apply)
Hetzner Online GmbHServer hostingAll data (hosting provider)Germany (EU)

We do not sell, rent, or share your personal data with advertisers or data brokers.

9. Data Security

We implement industry-standard technical and organisational measures to protect your personal data, including:

In the event of a personal data breach that poses a risk to your rights, we will notify you and the relevant supervisory authority within 72 hours as required by GDPR Article 33.

10. Children's Privacy

Soemel is not directed at children under 16. We do not knowingly collect personal data from children under 16. If you become aware that a child has provided us with personal data, please contact us at support@soemel.com and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top and notify you by email or in-app notification at least 14 days before the changes take effect. Continued use of Soemel after that date constitutes acceptance of the updated policy.

12. Contact & DPO

For any privacy-related questions, data subject requests, or to contact our Data Protection Officer: