Privacy policy

1. Controller

Taipan Consulting GmbH, Neue Mainzer Str. 66, 60311 Frankfurt am Main, Germany — represented by Frank Welsch-Lehmann.
Privacy enquiries: privacy@gardensofzen.com
General contact: zee@gardensofzen.com

2. What data we process

Gardens of Zen is deliberately built to be data-minimal. For the service itself we only process what it needs (for ad measurement, see section 8):

• Email address (required to deliver the program emails)
• First name (optional, for personal salutation)
• Program choice, language, timezone and preferred delivery time
• Program progress (current day) and replies you send to Zee by email
• Delivery and bounce information from our email service provider

3. Double opt-in

Sending only starts after you confirm your signup via a confirmation link sent by email (double opt-in). Unconfirmed signups are deleted automatically. The legal basis for processing is your consent (Art. 6(1)(a) GDPR); you can withdraw it at any time with effect for the future.

4. Unsubscribing and deletion (30-day erasure)

You can unsubscribe at any time — via the link in every email or via the settings page. Sending stops immediately upon unsubscribing. 30 days after unsubscribing we delete your personal data completely. On request we delete immediately (settings → unsubscribe, or an informal email to us).

While you are subscribed we store your program emails and your replies so Zee can build on earlier conversations. When we delete your data, these contents go with it.

5. Processors

We use the following service providers as processors:

• Postmark (ActiveCampaign, LLC) — sending and receiving the program emails
• Anthropic (Anthropic, PBC) — AI processing: creation of the daily routine texts, and processing of your reply emails so Zee can understand and answer them. This transfers the content of your message along with your first name, language, chosen program and current program day.
• Railway (Railway Corp.) — hosting of the website and platform
• Hindsight (Vectorize) — conversational memory: storage of content from your replies so Zee can refer back to it in later emails. These memories are deleted together with the rest of your data.

Data processing agreements pursuant to Art. 28 GDPR are in place with all providers. Where data is transferred to third countries, this is based on EU standard contractual clauses or the EU-US Data Privacy Framework.

6. Automated safety screening

Zee is not a therapy service and not an emergency service. So that we can respond when you are doing badly, every incoming reply is screened automatically for crisis signals — using a fixed keyword list and the AI evaluation of your message. If the system detects such a signal, you automatically receive an email pointing to professional support services, and our operations team is notified. That internal notification contains only a technical identifier for your account, not the text of your message. We record that a signal was detected, with a timestamp.

This screening may allow conclusions about your health (Art. 9 GDPR). The legal basis is your explicit consent, given at sign-up (Art. 9(2)(a) GDPR). You can withdraw it at any time; since the screening cannot be switched off separately, withdrawal means unsubscribing from the service.

7. Web analytics (Umami)

We use self-hosted web analytics (Umami) to measure reach. Umami sets no cookies, builds no cross-device profiles and stores no personal data; IP addresses are not retained here. The legal basis is our legitimate interest in privacy-preserving analytics (Art. 6(1)(f) GDPR). This applies to analytics only: ad measurement (section 8) does set cookies.

8. Ad measurement with OpenAI (ChatGPT Ads)

We advertise Gardens of Zen with ads in ChatGPT. To measure how many confirmed signups result from them, we use OpenAI's measurement pixel and Conversions API. For users in the EEA, the recipient of the data is OpenAI Ireland Limited, 1st Floor, The Liffey Trust Centre, 117–126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland.

OpenAI is not our processor here; under OpenAI's contract terms, we and OpenAI are each independent controllers. According to those terms, the data serves not only our own reporting but also OpenAI's own purposes, such as producing reports and audiences and measuring and improving its own services. For details, seeOpenAI's privacy policy.

Measurement pixel on the website

When you open our pages, your browser loads a script from OpenAI (frombzrcdn.openai.com). The settings pages are excluded, as is the confirmation page while its address contains a confirmation link. The script stores up to two cookies under our domain:

• __obref: a randomly generated identifier for your browser. It is set on every visit, even if you did not arrive via an ad. Stored for 365 days.
• __oppref: the click identifier OpenAI appends to the address when you click one of our ads. It is only set if you arrive via such an ad. Stored for 30 days, renewed with each further ad click.

On every page view the script sends these identifiers to OpenAI (bzr.openai.com), together with the address of the page without URL parameters, a timestamp and technical details about the script. As with any request over the internet, OpenAI also receives your IP address and your browser's identifier (user agent). What you enter in our forms, such as your email address, is not sent to OpenAI through the pixel.

Reporting confirmed signups (Conversions API)

When you sign up, our server reads the two cookies and stores them only together with your confirmation link. Only once you confirm your signup does our server report the event "registration completed" to OpenAI, regardless of whether you arrived via an ad. It transmits only these identifiers, the time of confirmation, the address of our confirmation page and a technical event ID that is formed from our internal participant number and the timestamp and prevents duplicate reports. We do not transmit your email address, your name or your IP address, not even as a hash.

After confirmation we delete the identifiers on our side. If you do not confirm, we delete them when the confirmation link expires after 48 hours. Unconfirmed signups are never reported to OpenAI.

Legal basis and transfers outside the EU

We do not ask for consent for the measurement pixel. We base the processing on our legitimate interest in measuring the success of our advertising (Art. 6(1)(f) GDPR). The data may also be processed in the USA, for example by OpenAI's affiliates. According to OpenAI, OpenAI Ireland Limited uses a recognised transfer mechanism within the meaning of Art. 44 et seq. GDPR for such transfers.

Objection and deletion

You can object to this processing at any time (Art. 21 GDPR). To prevent it technically, delete the cookies __obref and __oppref in your browser and block scripts from bzrcdn.openai.com, for example with a content blocker. Deleting alone is not enough, because the script sets a new identifier on your next visit. If you write to us before confirming, we promptly delete the stored identifiers and do not report your signup to OpenAI. We have no access to data already held by OpenAI; you can exercise your rights regarding that data directly with OpenAI.

9. Your rights

You have the right to access, rectification, erasure, restriction of processing, data portability and objection (Art. 15–21 GDPR), as well as the right to lodge a complaint with a data protection supervisory authority. Just write to us:zee@gardensofzen.com.

10. Version

This privacy policy is dated September 2026.