TribeNest

Privacy Policy

Last updated: November 2025

This Privacy Policy explains how Couplements UG (haftungsbeschränkt) operating as TribeNest collects, uses, and protects personal data when you use our website (https://tribenest.co) and the TribeNest creator dashboard (together the "Service"). The Service includes an AI agent named Mira; how she processes your data is described in Section 10.

1. Data Controller

Couplements UG (haftungsbeschränkt) Kockhannstr 6, 10249 Berlin, Germany Email: hello@tribenest.co

2. Data We Collect

We collect the following categories of personal data when you use the Service:

3. How We Use Your Data

We process personal data to:

4. Legal Bases for Processing (GDPR)

Under the EU General Data Protection Regulation (GDPR), we rely on the following legal bases for processing personal data:

5. Data Sharing & Third Parties

We only share personal data with third parties when necessary, including:

Our full sub-processor list is available in Section 12. All third parties we engage are subject to data processing agreements that require appropriate safeguards.

6. International Transfers

Some of our sub-processors (including LLM providers, payment providers, and CDN providers) are located outside the EU/EEA, primarily in the United States. Where personal data is transferred outside the EU/EEA, we implement safeguards such as Standard Contractual Clauses (SCCs), supplementary technical measures, or other lawful transfer mechanisms (Art. 46 GDPR) to ensure continued protection.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes set out in this Policy, or as required by law. Specific retention periods: - Account data: retained for the duration of your account plus 30 days after deletion request. - Transaction and order records: retained for 10 years as required by German fiscal law (Abgabenordnung, § 147). - Session and login data: up to 90 days. - Audit logs and security logs: up to 3 years. - AI prompt/response logs (Mira): up to 30 days for debugging and abuse prevention; outputs Mira saves into your account (briefings, drafts, proposals) follow the account-data retention rule above. - Marketing and analytics data: as set by the relevant cookie / consent (see Cookie Policy). When you delete your account, we will remove or anonymize your personal data within the applicable retention period.

8. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

To exercise any of these rights, please use our Data Rights Request form at https://tribenest.co/data-rights or email us at hello@tribenest.co. We will respond to your request within 30 days.

9. Cookies

For detailed information about how we use cookies and similar technologies (on both the marketing site and inside the creator dashboard), please refer to our Cookie Policy at https://tribenest.co/cookie-policy.

10. AI Processing & Profiling (Mira)

Mira is an AI agent included with paid TribeNest plans. She reads data from your TribeNest account (and any integrations you have connected) to generate a daily business briefing, draft emails and posts, surface anomalies, and propose actions for you to approve or reject. This section explains how this works in plain terms. What data Mira reads: your orders, customers, subscribers, email list, posts and post performance, comments and DMs (where you have connected social channels), course completion and lesson drop-off data, membership events, ad campaign metrics, and your direct questions to her. Mira does not read your card numbers, passwords, or the body of private end-customer support chats unless you explicitly route them to her. How Mira processes data: we use Anthropic (Claude models) as the underlying LLM provider. When Mira generates a briefing or a proposal, the relevant data is sent to the LLM provider over an encrypted connection together with a system prompt. The LLM returns text which we save into your account. No training on your data: under our agreement with the LLM provider, your inputs and outputs are not used to train their underlying models. We also do not train any TribeNest model on your business data without your explicit opt-in. Proposals vs. autonomous actions: Mira's default behavior is to propose. You see the suggestion in your dashboard and either approve, edit, or reject it. Nothing is sent to your customers, posted to your channels, or charged to your account by Mira unless (a) you explicitly approve it, or (b) you have enabled auto-approval for a specific, narrow category of action (for example, abandoned-cart recovery emails). You can disable auto-approval at any time. Disabling Mira: you can turn Mira off in your account settings. When Mira is disabled, no business data is sent to the LLM provider for AI processing. Legal basis: contract performance (Art. 6(1)(b)) for accounts where Mira is part of the subscription, plus legitimate interest (Art. 6(1)(f)) for short-lived prompt/response logs used for debugging and abuse prevention. You may object to profiling at any time (Art. 21) by disabling Mira.

11. Automated Decision-Making (Art. 22 GDPR)

Mira's outputs are proposals, not automated decisions. A human (you) reviews each proposal and decides whether to approve, edit, or reject it. Therefore, Mira's normal operation does not constitute solely automated decision-making with legal or similarly significant effects under Article 22 GDPR. Where you enable auto-approval for a specific narrow category of action (for example, sending an abandoned-cart recovery email or replying to a frequently-asked DM), you remain in control: you set the rules, you receive a log of every action Mira takes, and you can disable auto-approval at any time. We do not use Mira to make decisions that have legal or similarly significant effects on you or on your customers (such as denying service, setting prices for individual customers based on profiling, or making credit decisions). If we ever introduce such a feature, we will notify you in advance and request explicit opt-in.

12. Sub-processors

We engage the following sub-processors to deliver the Service. All sub-processors are bound by data processing agreements (Art. 28 GDPR). - Stripe Payments Europe Ltd (Ireland) — payment processing. - PayPal (Europe) S.à r.l. (Luxembourg) — payment processing. - Paystack Payments Ltd (Nigeria, with Stripe parent) — African payment processing. - Amazon Web Services EMEA SARL (Luxembourg / Frankfurt region) — hosting, storage, and SES email delivery. - Cloudflare Inc. (USA) — CDN and DDoS protection. - Vercel Inc. (USA) — frontend hosting and analytics. - LiveKit Inc. (USA) — live streaming infrastructure. - Crisp IM SAS (France) — customer support chat. - Anthropic PBC (USA) — LLM provider powering the Mira AI agent. - Endorsely — testimonials/referrals widget on the marketing site. For international transfers we rely on Standard Contractual Clauses and other safeguards as described in Section 6. We will keep this list current; material additions of sub-processors will be reflected here. If you require an up-to-date list at any point, contact hello@tribenest.co.

13. Supervisory Authority

The competent supervisory authority for data protection matters is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Friedrichstr. 219, 10969 Berlin, Germany. Website: https://www.datenschutz-berlin.de.

14. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority, in particular in the EU/EEA member state of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR (Art. 77 GDPR).

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by posting a notice on the Service. The "Last updated" date at the top of this page indicates when this policy was last revised.