Privacy Policy for the Research Chatbot "EzBot"

This website hosts "EzBot", an experimental chatbot that is used in the context of a university research project in the field of digital governance. The chatbot relies on external service providers, in particular OpenAI and Amazon Web Services (AWS), in order to enable the technical provision of the service and the generation of responses. The protection of your personal data is a top priority for us.

The following information explains how your data are processed when you use the chatbot, in accordance with Article 13 of the General Data Protection Regulation (GDPR).

1. Controller

The controller within the meaning of the GDPR is

Freie Universität Berlin
represented by the President
Kaiserswerther Straße 16–18
14195 Berlin
Germany

Person responsible for the research project "EzBot"

Prof. Dr. Genia Kostka
Institute of Chinese Studies
Freie Universität Berlin
Fabeckstr. 23/25
14195 Berlin
Germany
Email: vw.privacy@chinastudien.fu-berlin.de

2. Data Protection Officer

The official Data Protection Officer of Freie Universität Berlin can be contacted at

Freie Universität Berlin
Official Data Protection Officer
Kaiserswerther Straße 16–18
14195 Berlin
Germany
Email: datenschutz@fu-berlin.de

You may also send confidential data protection related inquiries to this email address. The university does not have access to this communication.

3. Categories of data processed

When you use EzBot, the following categories of personal data in particular may be processed

We design the system in such a way that no additional personal data are collected which are not required for the research purpose. In particular

Please note that we cannot control which content you voluntarily enter in the chat. It is therefore possible that you disclose personal data or particularly sensitive information in your text entries, for example concerning health, political opinions or other protected areas. We ask you to enter such information only if it is necessary for participation in the research project and if you are aware of the associated risks.

4. Purposes of processing

Your data are processed for the following purposes

Your data are not processed for advertising purposes or for profiling for commercial purposes.

5. Legal bases of processing

The processing of your personal data is based on the following legal grounds

Because we cannot fully control the content of your text entries, it cannot be ruled out that special categories of personal data within the meaning of Article 9 paragraph 1 GDPR are processed, for example data concerning health or political opinions. Insofar as such data are processed, we rely on

The provision of your personal data is voluntary. If you choose not to provide data, you will not be able to participate in the study, but you will not suffer any other disadvantages.

You may withdraw your consent at any time with effect for the future. Processing carried out before the withdrawal remains lawful.

6. Storage of data and location of processing

The technical infrastructure for EzBot is operated exclusively in data centres within the European Union.

We store

Pseudonymised raw data are deleted as soon as they are no longer required for the research purpose. This also includes backups, insofar as they contain personal content. Specific retention periods follow from the research plan and the relevant retention rules of Freie Universität Berlin.

7. Recipients and processors

Within Freie Universität Berlin, only those persons have access to your data who necessarily require it in order to conduct the research project, in particular members of the research group of Prof. Dr. Kostka.

We use the following processors within the meaning of Article 28 GDPR

Data processing agreements have been concluded with both service providers that comply with the requirements of Article 28 GDPR. AWS and OpenAI process the data exclusively on our instructions and not for their own purposes.

Research partners outside Freie Universität Berlin are granted access, where necessary, only to anonymised or aggregated datasets which do not allow any conclusions about individual participants.

Your personal data are not passed on for commercial purposes or for advertising.

8. Transfers to third countries and Standard Contractual Clauses

Your data are stored exclusively in data centres within the European Union. Nevertheless, both AWS and OpenAI are corporate groups with their head offices in the United States. This means that, in theory, access from a third country may be possible, for example due to administrative activities or legal disclosure obligations in the United States.

For this situation, we rely on the following for any data transfers and access possibilities

Despite these safeguards, a residual risk cannot be completely ruled out that authorities in the United States may access data stored in the EU. This structural risk cannot currently be completely eliminated when using US based providers. We take this into account in our risk assessment and limit the scope and sensitivity of the data processed as far as possible.

9. Automated decision making and profiling

The chatbot uses an AI language model to generate its responses. However, there is no automated decision making within the meaning of Article 22 GDPR that produces legal effects concerning you or similarly significantly affects you.

There is no profiling aimed at evaluating or classifying you for decisions outside this research project.

10. Your rights

Subject to the statutory conditions, you have the following rights vis à vis Freie Universität Berlin

To exercise these rights, you can contact us using the contact details set out in section 1 or contact the Data Protection Officer of Freie Universität Berlin directly.

You also have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data violates the GDPR. The competent supervisory authority is usually

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt Moabit 59–61
10555 Berlin
Germany

11. Updates to this privacy policy

This privacy policy may be amended from time to time, for example if the research design, the service providers used or the legal requirements change. The current version is available at the URL indicated on this website.

Effective date: December 19, 2025