PsyClinicAIApplication Copilot
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Privacy and security

Courtesy translation. The German version is legally binding: German version.

The Application Copilot processes your patients’ health data. This page sets out where that data is stored, who processes it and what a language model gets to see. Anything not yet in place is marked “planned”.

As of 9 October 2026 · Version 5 · Change log

The Application Copilot is not yet in live operation. This page describes the state at launch.

  • GermanyStored content data at Hetzner, Nuremberg/Falkenstein
  • Chiffre onlyA case code, no patient names in the system
  • AI processing in GermanyC5-attested provider, no storage, no training
  • Encrypted per practiceAES-256-GCM, key not in the database

1Where your data is stored

Case records, session notes, questionnaire scores and reports are stored exclusively in Germany, on servers of Hetzner Online GmbH in Nuremberg/Falkenstein. There is no secondary location outside Germany, not even for backups. The only exception is the pseudonymised excerpts that are processed briefly, also in Germany, to produce report drafts (section 3). You remain the controller within the meaning of the GDPR; we are your processor (Auftragsverarbeiter).

Hetzner holds an ISO/IEC 27001:2022 certificate and a BSI C5:2020 Type 2 attestation (Testat) for the cloud services we use. This applies to the infrastructure, not to our application. For the Application Copilot itself we have no C5 attestation and no ISO 27001 certificate. Preparation for a C5 audit (comparison against all basic criteria, action plan) is under way Planned.

Who the Application Copilot is for today. At launch it is open only to practices without a statutory-insurance licence (Kassenzulassung): private practices with self-paying clients, privately insured clients, civil-servant (Beihilfe) clients and statutorily insured clients via reimbursement (Kostenerstattung, § 13(3) SGB V). The reason is § 393 SGB V: practices with a statutory-insurance licence or authorisation may only have health data processed in the cloud if the provider holds a C5 attestation. We do not have that yet. At registration we therefore ask about a statutory-insurance licence. Practices with a statutory-insurance seat (KV-Sitz) can be added to a waitlist on request, and we notify them once, as soon as the attestation is available. If you obtain a licence later, please tell us (Terms § 1(2c)).

Operating environment during the introductory phase. The application runs on a Hetzner cloud server in Germany that we share with other web projects of ours. It is separated by its own containers, its own internal networks, its own database, its own keys and secrets; only the shared proxy is exposed. Physical separation and full-disk encryption are not in place; instead, content and backups are encrypted at application level. Before we serve a larger customer base, we will move to a dedicated server.

Data flow of the Application Copilot The practice's browser or app connects over TLS to Caddy at Hetzner in Germany. Caddy forwards to the API. The API stores data encrypted in PostgreSQL, a worker enforces deletion periods, and backups and exports sit encrypted in object storage at the same location. Pseudonymised excerpts are sent over TLS to the language model at STACKIT (Schwarz Digits Cloud GmbH & Co. KG) in Germany, a C5-attested provider that neither stores nor trains on them. Creem receives only payment data, the email service only account emails without case content, Sentry only technical errors without content. Hetzner Online GmbH, Germany Data centres Nuremberg and Falkenstein · infrastructure: ISO/IEC 27001:2022, BSI C5:2020 type 2 Practice Browser or app Code and name only in your record Patient Questionnaire by link or QR, no names Caddy TLS 1.2 und 1.3 API Login + 2nd factor Permissions, scrubbing Audit log PostgreSQL Row-level security per practice AES-256-GCM per practice Worker Deletion periods Object storage Backups encrypted (WAL-G) Exports 24 h at most STACKIT, Germany Language model (eu01) C5-attested provider pseudonymised excerpts no storage, no training Creem Payment and invoice no case content Email service account emails only Sentry (EU) Errors without content 1 3 4 WAL-G, encrypted Payment: you switch to Creem, feedback via signed webhook (plan status only) 5 without case content Practice data without health data 1 TLS · 2 login, permissions, audit · 3 encrypted storage · 4 pseudonymised excerpts · 5 account and error data only
Data flow. Solid arrows: practice data. Dashed: services without health data.
  1. Connection. Your browser or the app connects over TLS to our proxy at Hetzner.
  2. Checks. Our API checks login with a second factor, practice membership and permissions, and logs every event.
  3. Storage. PostgreSQL stores content, additionally encrypted per practice. A background process enforces deletion periods.
  4. Draft. For report drafts, pseudonymised excerpts go to the language model. It runs at Schwarz Digits Cloud GmbH & Co. KG (STACKIT AI Model Serving) in data centres in Germany (region eu01). The provider holds a BSI C5 Type 2 attestation, is listed as a sub-processor and is bound to confidentiality under § 203 StGB. It neither stores requests or responses nor uses them for training. We do not run a model server of our own.
  5. Ancillary services. Payment runs through Creem, account emails through an email service, technical errors through Sentry. None of them receives case content.

2Who processes data

The same list as in Annex 3 of our data processing agreement (AVV, Auftragsverarbeitungsvertrag). It names only providers that are actually used.

ProviderPurposeLocationBasisData categories
Hetzner Online GmbHGunzenhausenServers, database, object storage, backups, websiteGermanyProcessing on our behalf, Art. 28 GDPRAll content data (encrypted), account data, logs
Language modelmodel to be confirmed, Schwarz Digits Cloud GmbH & Co. KG (STACKIT)Drafts for report sections and formal review notes. Dictation is not active at launchGermanySub-processor, contract under Art. 28 GDPR; confidentiality undertaking under § 203 StGBPseudonymised excerpts, draft text
Resend, Inc.Account, invitation and security emailsUSAProcessing on our behalf; EU-US Data Privacy Framework, standard contractual clausesEmail address, name, text of the system email. No patient emails, no case content
Apple (push service APNs)Push notifications to the iOS appUSA/IrelandData Privacy Framework or standard contractual clausesDevice token and fixed, generic texts. No code, no health data
Functional Software, Inc. (Sentry)only if enabledTechnical error reportsEU region (Frankfurt)Processing on our behalf; standard contractual clausesError data without content, without user identifier
CreemArmitage Labs OÜ, TallinnPayment and invoicing (merchant of record)EstoniaOwn controller, not a sub-processorBilling and payment data of the practice. No card data with us, no health data

No website statistics. Not used: Google Cloud, Firebase, Anthropic or OpenAI interfaces, Groq, Cohere, Azure OpenAI, PostHog, SendGrid.

3The language model

The Application Copilot creates a draft from your records. You write and are responsible for the report. Every sentence points to its source, and unsupported sentences are marked. The software makes no diagnosis, prognosis or treatment recommendation.

Model
to be confirmed before launch
Where it runs
At Schwarz Digits Cloud GmbH & Co. KG (STACKIT AI Model Serving) in data centres in Germany (region eu01). The provider holds a BSI C5 Type 2 attestation, is listed as a sub-processor and is bound to confidentiality under § 203 StGB. It neither stores requests or responses nor uses them for training. We do not run a model server of our own.
What it receives
Pseudonymised excerpts from the sources of the respective section: session notes, questionnaire scores, your own entries.
What it does not receive
Names, addresses, contact details, insurance numbers. The case record carries only a code; names, places, employers and contact details in free text are removed before the call.
What is stored
The result in your case and a log without content: model, time, number of tokens, duration. The provider stores and logs no requests or responses (contractually assured, verified before launch).
Training
Your data is not used for training, neither by us nor by the provider.

Traceable in the app. For every generation we record which model processed where and from how many sources excerpts were sent, without content. In the version view of the report you read: “Created with [model], processed in Germany (STACKIT AI Model Serving, region eu01), sent: pseudonymised excerpts from 26 sources”. Model and operator are defined in exactly one place in our configuration; this page and the app both read from it. If the model provider changes, we announce it 30 days in advance.

4Encryption and access

  • TransportTLS 1.2 and higher with HSTS.
    Implemented
  • StorageContent encrypted at application level with AES-256-GCM, one key per practice. The keys are wrapped with master keys that are not in the database.
    Implemented
  • BackupsEncrypted before they leave the server (WAL-G).
    Implemented
  • Separate backup storageStorage in Hetzner object storage in Germany with object lock, separate from the server.
    Planned
  • Disk encryptionIn addition to the encryption of the content.
    Planned
  • LoginPassword and mandatory second factor (TOTP) for every access to content. The login service runs on our servers.
    Implemented
  • Separation of practicesThe database enforces that each practice sees only its own rows, including for our own database roles.
    Implemented
  • Roles under § 203 StGB (German Criminal Code, professional secrecy)Case content is seen only by the treating therapist, by substitutes for a limited time and, in group practices, by colleagues with read access. The practice owner and practice administration see only master data without approval; practice administration never reads content.
    Implemented
  • Access by our teamNone in regular operation. Exception only with your approval, four-eyes principle, time-limited and logged. Everyone with technical access is bound in writing under § 203 StGB.
    Planned for launch
  • LogCreating, changing, deleting, exporting and logging in are recorded in an audit log with a hash chain. Tampering is detectable. As owner you can see your practice's log. Signed report versions are immutable.
    Implemented
  • External penetration testBefore live operation. Not yet carried out.
    Planned
  • C5 attestation for the applicationNot yet available, and no ISO 27001 certificate either. Preparation is under way: comparison against all 121 C5 basic criteria and a 12-month action plan. Only with the attestation will we open the Application Copilot to practices with a statutory-insurance licence (§ 393 SGB V). Status in the AVV, Annex 3.
    Planned

5Retention and deletion

You keep the treatment record (§ 630f BGB, 10 years). We are not a retention service. Before anything is deleted, the app reminds you to transfer content into your record.

DataPeriod
Case record, notes, questionnaires, reportsYou can delete at any time. Deleted items can be restored for 7 days; after that, deletion is final.
After the contract ends30 days read-only for export, then deletion of all data of the practice.
BackupsExpire after 35 days, no selective deletion.
Export files (PDF, DOCX)Not stored permanently, 24 hours at most.
Questionnaire linksUsually valid for 72 hours; link data deleted after 30 days.
Unsubmitted life-history questionnaires30 days after the link expires.
Supervision: copy and comments30 days after the share ends (expiry or revocation). The record of who saw which version when stays with the case.
Proof of training (PiA plan)After the follow-up proof is checked, 13 months after upload at the latest, and 30 days after the contract ends.
Waitlist for practices with a statutory-insurance licenceAfter the notification, 12 months after sign-up at the latest. Only email, time and, optionally, location.
Audit log3 years.
Error reports, server logs90 days; IP addresses in logs truncated after 7 days, logs deleted after 30 days.
Billing records10 years (§ 147 AO, German Fiscal Code), no health data.
At the AI providerNo storage beyond the request.

Every deletion is logged without content. We issue a deletion confirmation on request.

6Your documents to download

All documents carry a version and a checksum. This gives your data protection adviser what they need for the record of processing activities and the impact assessment. The documents are in our application and available from launch. The documents are in German, and the German versions are legally binding.

7Changes

We announce new sub-processors at least 30 days in advance, by email to the practice owner and on this page. Within 14 days you can object for an important data-protection reason. If no agreement is reached, either side can terminate as of the date of the change; we refund prepaid fees pro rata.

DateChange
09.10.2026No GPU server of our own: AI processing takes place in Germany at Schwarz Digits Cloud GmbH & Co. KG (STACKIT AI Model Serving), a C5-attested provider, with no storage and no training; listed as a sub-processor and bound under § 203 StGB. Dictation not active at launch. New versions of the AVV, privacy policy, deletion concept, patient information, confidentiality undertaking and DPIA template; deletion job for the waitlist implemented.
08.10.2026At launch only for practices without a statutory-insurance licence (§ 393 SGB V), waitlist for practices with a statutory-insurance seat; status of the C5 preparation disclosed (no attestation, no ISO certificate); deletion periods added for supervision, proof of training and waitlist; new versions of the Terms, AVV, privacy policy and deletion concept.
06.10.2026Language model and speech recognition run on our own GPU dedicated server at Hetzner in Germany (private tunnel), no external provider; operating environment of the application in the introductory phase disclosed; backup storage listed as “planned”.
04.10.2026First version of this page (language model then on our own server in Germany).

8Privacy contact

Privacy questions
kontakt@psyclinicai.com, subject “Datenschutz”
Report a vulnerability
kontakt@psyclinicai.com, subject “Sicherheit”. Please do not send patient data.
Controller
See imprint

Data subjects should contact the treating practice for access, rectification or deletion; we support the practice in doing so.