Privacy policy

This policy covers the website comsemble.com and the Comsemble service at app.comsemble.com, including the messages the service sends and receives on WhatsApp, RCS, SMS and email.

1. Controller

DesignCore
Zur Schockenkammer 1
31535 Neustadt
Germany
Email: [email protected]

The full provider details are in the imprint.

2. This website

comsemble.com is a set of static pages. It sets no cookies, uses no analytics or tracking, embeds no third-party content and loads its fonts from this site, not from a font service. It has no forms and does not ask for any personal data.

The pages are delivered by a hosting provider: Amazon Web Services (Amazon S3 and Amazon CloudFront). The files are stored in Amazon S3 in the Frankfurt region (eu-central-1) and served through Amazon CloudFront, a content delivery network; a request is answered by a CloudFront location near you in Europe, North America or Israel. To deliver a page, CloudFront processes technical access data (IP address, time of the request, requested page, browser information). We have not enabled CloudFront access logs, so the site stores no access logs. The legal basis is our legitimate interest in delivering the website securely (Art. 6(1)(f) GDPR).

3. The Comsemble service

Comsemble coordinates changes to shared operational plans, such as events, jobs, shoot days and site phases. Organizers work in the web app; suppliers, clients, staff and attendees (“contacts”) are reached on WhatsApp, RCS, SMS or email.

Data we process

• Organizer accounts: name, email address, workspace and agency name, sign-in sessions including IP address and browser user agent.
• Contacts: name, phone number, email address, and for each channel the consent record: which consent wording was agreed to, how consent was given, and when a channel was verified or revoked.
• Messages: the content of messages exchanged with the service, including voice notes and their transcripts, images and documents and the text read from them, shared locations, and the WhatsApp profile name of a person who joins with a code.
• Plan data: tasks, assignments, decisions, confirmations and an audit history of who did what and when.
• Contact memory: statements a contact made in a message (for example a constraint such as a latest serving time), kept with the date and the source message. Organizers can see and delete these entries.

Purposes and legal bases

• Providing the service to organizers and their workspaces (Art. 6(1)(b) GDPR).
• Coordinating the work with contacts, sending plan updates, decision requests and confirmation requests (Art. 6(1)(f) GDPR, the legitimate interest of the organizer and the parties in a coordinated plan), on channels the contact has confirmed (Art. 6(1)(a) GDPR, see section 4).
• Security, abuse prevention and audit (Art. 6(1)(f) GDPR).

4. Consent and opting out of messages

• Double opt-in. When an organizer adds a phone number or email address, it receives nothing but a verification message until the person confirms it. Verification codes expire after 48 hours.
• Joining yourself. A person who writes JOIN with a join code starts the conversation; that channel is verified because the person initiated it.
• Consent from another system. When an organizer’s own system (for example a CRM) supplies consent through the API, the record says which integration supplied it.
• SMS and RCS: reply STOP to stop messages, START to resume and HELP for help. Opt-outs are honoured and recorded: depending on the configuration, on the opt-out list of AWS End User Messaging or on the service’s own list.
• WhatsApp and email: to stop messages, tell the organizer who added you or write to us at the address in section 1.

5. Artificial intelligence

Voice notes are transcribed with Amazon Transcribe and documents read with Amazon Textract. Incoming messages and photos are interpreted with Amazon Bedrock: to recognise a reported change, to answer a contact’s question from the parts of the plan meant for them, and to help organizers draft plans. AI only suggests and explains. Money, schedules and permissions are calculated by deterministic code, and nothing is approved, committed or sent to a supplier without a person’s decision. A Bedrock guardrail screens the interpretation and masks phone numbers and email addresses in its output.

Bedrock is called in the AWS region Frankfurt (eu-central-1) through EU cross-region inference profiles, which may route a request to a foundation model in another AWS region within the EU. Conversation memory uses Amazon Bedrock AgentCore Memory in the same region.

There is no decision based solely on automated processing that produces legal or similarly significant effects (Art. 22 GDPR).

6. Recipients and processors

• Amazon Web Services (AWS), region Frankfurt (eu-central-1): hosting (Amazon ECS on Fargate, Amazon RDS for PostgreSQL, Amazon S3, Amazon SQS and SNS, AWS Lambda, Amazon CloudWatch Logs), messaging (AWS End User Messaging for SMS and RCS, AWS End User Messaging Social for WhatsApp, Amazon SES for email), media processing (Amazon Transcribe, Amazon Textract) and AI (Amazon Bedrock, Amazon Bedrock AgentCore). The website comsemble.com is hosted on Amazon S3 and delivered through Amazon CloudFront (section 2).
• Meta (WhatsApp): WhatsApp messages are carried by WhatsApp; Meta’s own privacy terms apply to your use of WhatsApp.
• Mobile network operators deliver SMS and RCS messages.
• Cloudflare provides DNS for comsemble.com. Traffic to comsemble.com and app.comsemble.com is not proxied through Cloudflare.
• OpenStreetMap: location maps in the web app load map tiles from tile.openstreetmap.org, which receives the viewer’s IP address.
• Systems an organizer connects through the API or signed webhooks receive the project events that organizer configured.

Several of these providers belong to groups outside the EU or EEA. Safeguards for any transfer outside the EU or EEA: To be completed by the owner: transfer safeguards per provider

7. Cookies in the web app

Signing in to app.comsemble.com sets a session cookie that is strictly necessary to keep you signed in. The web app uses no analytics or advertising cookies.

8. Retention

• Voice notes, images and documents in media storage: deleted after 30 days.
• Raw incoming emails: deleted after 30 days.
• Conversation memory events (AgentCore Memory): 30 days.
• Application logs: one month.
• Database backups: 7 days.
• Sign-in links: valid for 15 minutes.
• Response links in messages: valid until the request is answered, at most 7 days.
• Accounts, contacts, messages, plans and audit history: no automatic deletion period is configured yet. Deletion period: To be completed by the owner: retention period for workspace data

9. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). Where processing is based on consent, you can withdraw it at any time with effect for the future (Art. 7(3)). Write to the address in section 1.

You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), for example the authority of Lower Saxony, where the controller has its seat.

10. Changes

We update this policy when the website or the service changes. The date at the top shows the current version. For the hackathon demo, all names, organizations and messages in the demo workspace of app.comsemble.com are synthetic.