Raimund Schlotmann, trading as “Leadership and Soul”
Lindenstrasse 12
40822 Mettmann
Germany
E-mail: info@leadershipandsoul.de
Phone: +49 2104 1774745
No data protection officer has been appointed. Please direct all data protection matters to the address above.
Your personal content in DeepAnchor — anchors, journal entries, check-ins, letters to your future self and media you store yourself — is encrypted on your device (AES-256) and kept on the server only as unreadable ciphertext. Neither the provider nor your coach nor the hosting company can read it; the key stays with you.
There is one exception, and it is deliberate: the moment you start a conversation with your coach or with the AI coach, exactly what you release for it leaves that protected area. It is stored unencrypted, because otherwise the other side could not read it. Only what is shown to you verbatim before you send it is transmitted — nothing is attached automatically, and none of this happens unless you start a conversation.
To register you, we process your first and last name and your e-mail address (Art. 6(1)(b) GDPR). The e-mail address is used for confirmation and for signing in again on a new device. We also assign your account a 24-character identifier that bears no relation to your name, as well as an identifier for your device with which the app authenticates to the server.
By registering you confirm that you are at least 18 years old. We record two items with your account for this purpose: the time of that confirmation and the version of the terms of use and the privacy notice shown to you at the time. Both serve solely as evidence that the confirmation was given and which text applied at that point; we do not use them for any other purpose. The legal basis is our legitimate interest in being able to demonstrate compliance with our own accountability obligations (Art. 6(1)(f) GDPR; cf. Art. 5(2) GDPR). Both items are deleted together with your account.
Your encrypted content is backed up on the server so that you can restore it on a new device. The key is derived from your personal recovery code, which only you hold.
If you enable reminders, your device's push registration is stored — a device token from Apple or Google. We also transmit the times of your anchors, your time zone and the due dates of your letters so that the reminder is triggered at the right moment.
The notification itself contains none of your content. It names only the occasion — for example “A moment for you” or “Your coach has replied”. For technical reasons this title and short text are passed to Apple's or Google's push service in the clear and are readable there until delivery; with a notification on the lock screen this cannot be avoided. That is why it names the occasion and never the content. If you do not want this, turn reminders off in the settings.
If you use DeepAnchor through a coach, we assign your account to that coach via the activation code. Your coach sees your name, your e-mail address, the organisation you entered, the time of your last activity and your course assignment. Your coach does not see your encrypted content. Your coach only sees the conversations you start yourself — see the next section.
When you start a conversation, we process the passage you release (a journal entry, an insight or an anchor), your contributions to the exchange, the sentence you are working on together, the label of the state you want to strengthen (your Deep Anchor), and — only if you explicitly tick it — a set of figures about your progress so far (the number of entries, insights and anchors per Deep Anchor, active anchors, check-ins met, longest streak). No content is included, and the exact wording is shown to you before you send it.
The legal basis is your consent (Art. 6(1)(a) GDPR). A channel only opens once both sides have agreed; you can withdraw your consent at any time with future effect in the settings.
Where you make statements about your health — such as exhaustion, anxiety, sleep or strain — these are health data within the meaning of Art. 9 GDPR. Your consent expressly extends to such data (Art. 9(2)(a) GDPR). You decide anew in every conversation what you write.
If you do not have a human coach, you may use the AI coach instead. It is not a human being but an AI system; every one of its contributions is marked as such. Before anything is transmitted for the first time, we inform you in the app and obtain your express consent. Without that consent nothing is transmitted.
What is transmitted: the passage you release, your contributions to this conversation, the sentence you are working on, your Deep Anchor, the figures you ticked, the language you have set, and the identifier of your account, which the service provider needs to detect misuse. Your name and your e-mail address are not transmitted. Your journal, your anchors and your check-ins do not leave the encrypted area.
So that the AI coach does not start from scratch in every conversation, it receives two kinds of context.
If you continue a conversation, the previous course of that concern is transmitted with it — the earlier conversations in the same chain verbatim, that is your contributions and the AI coach's, each shortened to 700 characters per contribution. At most the conversations of the last three months, at most 120 conversations and at most 24,000 characters in total are transmitted; anything older is cut off. This history belongs to the very conversation you chose to continue, so it is always transmitted when you choose that continuation. If you do not want it, start a new conversation instead of a continuation.
For your other concerns it receives a short recap: up to twelve conversations from the last fourteen days, each with only the date, the Deep Anchor and the outcome — or, where none emerged, your last sentence in shortened form. You can switch this recap off in the settings.
For both: conversations with a human coach never feed into this, and conversations you have deleted are not included.
The legal basis is your express consent under Art. 6(1)(a) GDPR and, where health data are concerned, under Art. 9(2)(a) GDPR. You can withdraw it at any time with future effect in the settings. This does not affect the lawfulness of processing carried out until then; conversations already held remain readable for you until you delete them.
The AI coach asks questions. It does not make decisions about you, does not assess you and does not give advice — in particular no medical, therapeutic, legal or financial advice. No automated individual decision-making within the meaning of Art. 22 GDPR takes place.
If you buy access or a question pack, payment runs through the App Store's purchasing system. The store handles payment, invoicing and refunds; we never receive or see your payment details.
The store issues your device a signed purchase receipt, which the app passes on to us. We verify its signature on our own server — no enquiry to Apple or to a payment provider is needed, and no one outside learns who bought what and when. From the receipt we store the transaction number, the product identifier purchased, whether it was a test or a real purchase, and the time it was booked. The receipt itself is not stored. The legal basis is performance of the contract (Art. 6(1)(b) GDPR); we additionally need the transaction number to prevent the same receipt being redeemed twice (Art. 6(1)(f) GDPR).
When you sign in on a new device, we send a six-digit code to the e-mail address on file. The code is stored with us only as a checksum, is valid for fifteen minutes and allows three attempts; the process is then deleted. The legal basis is performance of the contract (Art. 6(1)(b) GDPR).
If you send us feedback or report an error, we process your details in order to deal with the matter (Art. 6(1)(f) GDPR). Our legitimate interest lies in improving the application and keeping it free of errors.
When the server is accessed, technical data arise (time, resource requested, IP address). The log files are held in our webspace. The addresses in them are stored in truncated form: for IPv4 the final number is dropped, for IPv6 everything from the fourth block onwards. The webspace provider rotates the files continuously and removes them after about eight weeks. We do not analyse these logs to learn anything about individual visitors, and we do not combine them with other data. The legal basis is our legitimate interest in secure and functioning operation (Art. 6(1)(f) GDPR).
The servers and e-mail delivery are operated by a service provider in Germany (united-domains AG). A data processing agreement under Art. 28 GDPR is in place with this provider.
For the AI coach's replies we use Anthropic Ireland Limited, Dublin, Ireland, as a processor; that entity provides the service to customers in the European Economic Area. A data processing agreement under Art. 28 GDPR is in place with Anthropic.
Anthropic Ireland Limited in turn engages Anthropic, PBC, 548 Market St, PMB 90375, San Francisco, CA 94104, USA, as a sub-processor. The transfer to the USA takes place at that level. It is based on the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/914); in addition, we have assessed and documented the risks of the transfer. You may request a copy of the safeguards at the address given above.
Anthropic does not use the transmitted content to train AI models. According to the provider's published practice, inputs and outputs are deleted there within 30 days as a rule. Where there is a suspicion of a breach of the provider's usage policy, it may retain the content for up to two years and the results of its misuse review for up to seven years.
If you use DeepAnchor through a coach, that coach is independently responsible for your support. We process the resulting data on their behalf. The AI coach is not offered to a coach's participants; their data are not transmitted to the AI service provider.
DeepAnchor uses no cookies for advertising or tracking purposes and embeds no third-party analytics services. For the app to work, data are stored locally on your device.
We keep your account and the associated data for as long as your account exists.
Conversations with your coach and with the AI coach are kept for as long as your account exists. You can delete any conversation yourself at any time; you can also request the deletion of your data held by a coach through the app.
If your access is suspended — for example when your plan runs out — your data are kept for a further six months so that you can return without losing anything. After that we delete your account and all associated data. Fourteen days beforehand we notify you by e-mail at the address you registered with.
After you delete your account, we remove your data, your encrypted backups and your conversations. Three things remain for a limited time, for these reasons: the bare usage volume of the AI coach for cost control (time and extent, without content and without a link to your account); the record of your consent for as long as we need it to defend against claims (Art. 17(3)(e) GDPR) — it is deleted three years after the end of the calendar year in which the account was deleted; and the transaction numbers of your purchases, so that the same receipt cannot be redeemed more than once — their link to your account ends at the latest three years after the end of the calendar year in which your access ended (Art. 17(3)(e) GDPR), after which no personal data remains in this respect. These data are used solely for the respective purpose and deleted on schedule.
Retention at the AI service provider is governed by the section "AI service provider".
DeepAnchor is intended for people aged 18 and over; younger persons may not use the app. If we learn that an account is held by a younger person, we delete it.
You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21). You may withdraw consent at any time with future effect (Art. 7(3)).
Because of the end-to-end encryption we cannot decrypt your encrypted content and therefore cannot provide information about it. We can provide information about your conversations, because these are held unencrypted.
Please contact info@leadershipandsoul.de. You also have the right to lodge a complaint with a data protection supervisory authority; the authority responsible for us is the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia.
Last updated: August 2026 (version to be released together with the new AI coach disclosure)