Privacy policy on the Use of Comosio
This notice informs you about how we at Somana use the software Comosio from Jetfi Systems GmbH to document treatment appointments in our practice — and what rights you have in this regard. It supplements our general privacy policy (somana.com/de/datenschutz) as well as the privacy information you receive as an attachment to your intake form.
Important upfront: The use of Comosio in your treatment appointments is entirely optional. If you do not consent, this will not change anything about your treatment — you will receive the same therapy, the same appointments, the same service.
What is Comosio?
Comosio is software that supports our therapists in documenting treatment appointments. With your consent, the system records your treatment conversation and automatically creates a transcript and an initial documentation draft from it. The speech recognition for this works with the help of artificial intelligence; Comosio merely creates a suggestion from the conversation, which your therapist then reviews, corrects, and incorporates into our treatment documentation.
Comosio does not make diagnoses, give therapy recommendations, or decide anything about your treatment. The professional assessment is always the responsibility of your therapist.
What We Need Your Consent For
The use of Comosio is only permitted if you expressly consent. This consent is not obtained via the website or at our reception — but in a personal conversation with your therapist during the initial consultation. There you will receive a separate form and can clarify all questions directly before deciding.
What Data Is Processed?
If you consent, the following data is processed:
Audio recordings of your treatment appointments (voice, conversation content)
Transcripts generated from the recordings
Structured treatment documentation created from the transcripts in our practice system (THEORG)
This data may contain special categories of personal data within the meaning of Art. 9 (1) GDPR — in particular health data.
Who Has Access
Recordings and transcripts are accessible exclusively to your treating therapist. No one else has access — neither other patients, nor the reception team, nor the management. All employees are bound by confidentiality (§ 203 of the German Criminal Code / StGB).
Legal Basis
The legal basis for processing within the scope of Comosio is your voluntary consent pursuant to Art. 6 (1) lit. a in conjunction with Art. 9 (2) lit. a GDPR. Insofar as the recordings or transcripts contain information about your ethnic origin, religious beliefs, or your health, your consent — if granted — also applies to this information.
Who Technically Processes the Data (Data Processors)
We use the following service providers as data processors pursuant to Art. 28 GDPR:
Jetfi Systems GmbH, Spinnereistraße 7, Halle 14, 04179 Leipzig — provider of the Comosio software and technical operations
Hetzner Online GmbH — hosting of recordings and transcripts in data centers in Germany
Google Cloud Vertex AI — processing for structuring texts, region eu-west3 Frankfurt, Germany
Contracts pursuant to Art. 28 GDPR exist with all data processors; insofar as professional secrets are affected, the requirements of § 203 (3) StGB are met and the participating persons are bound to confidentiality pursuant to § 203 (4) sentence 2 no. 1 StGB.
Jetfi Systems GmbH is contractually obligated never to use your data — even in pseudonymized form — for training, fine-tuning, or improving models or products.
Storage Location and Third-Country Transfer
Recordings and transcripts are stored exclusively in data centers in Germany. Processing takes place within the European Economic Area (EEA). For individual services used or their subcontractors, third-country access cannot be completely ruled out in every case; insofar as such access is conceivable, we ensure that appropriate safeguards exist pursuant to Art. 44 et seq. GDPR — in particular standard contractual clauses of the EU Commission and supplementary technical and organizational measures.
How Long We Store the Data
Recordings, transcripts, and the final treatment documentation are processed as three separate data objects with different retention periods:
Audio recordings: deletion after validation of the treatment documentation, at the latest after seven days if no validation occurs
Transcripts: deletion at the latest after twelve months in accordance with our internal deletion concept
Treatment documentation: retention pursuant to § 630f (3) BGB (German Civil Code) for ten years after completion of treatment
Relationship to the Patient File
Audio recordings and raw transcripts do not replace the treatment documentation. Medically relevant content is transferred from the raw data into the structured treatment documentation in THEORG; the raw data itself is then deleted in accordance with the above-mentioned periods.
You Retain Control at All Times
Microphone stop in every appointment. You can object to the recording in each individual appointment — even without justification and even if you have generally consented. Simply tell your therapist; the microphone will be deactivated immediately.
Withdrawal possible at any time. You can withdraw your consent at any time with effect for the future, informally in text form (by email to info@somana.com). Existing recordings and transcripts will then be deleted without delay. The lawfulness of processing carried out up to the withdrawal remains unaffected (Art. 7 (3) sentence 2 GDPR).
No disadvantages in case of refusal. If you do not consent or withdraw your consent, nothing will change about your treatment.
No Automated Decision-Making
There is no exclusively automated decision-making within the meaning of Art. 22 GDPR. With Comosio, only suggestions and drafts are created; the professional review and decision are made exclusively by your treating therapist.
Your Rights
Under the GDPR, you have in particular the following rights:
Right to information about the data processed about you (Art. 15 GDPR)
Right to rectification of incorrect or incomplete data (Art. 16 GDPR)
Right to erasure, insofar as no statutory retention obligations preclude this (Art. 17 GDPR)
Right to restriction of processing (Art. 18 GDPR)
Right to data portability in a structured, common format (Art. 20 GDPR)
Right to object to processing based on legitimate interests (Art. 21 GDPR)
Right to withdraw consent given with effect for the future (Art. 7 (3) GDPR)
Right to lodge a complaint: You also have the right to lodge a complaint with a supervisory authority — for Berlin with the Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59–61, 10555 Berlin (datenschutz-berlin.de). However, we kindly ask you to contact us directly in advance — many issues can be resolved quickly in a personal conversation.
Controller and Data Protection Officer
Controller: Somana Health GmbH, Französische Straße 24, 10117 Berlin, info@somana.com, +49 30 754 394 470
Data Protection Officer: Proliance GmbH (Dominik Fünkner), Leopoldstraße 21, 80802 München, datenschutzbeauftragter@datenschutzexperte.de
When making an inquiry to the data protection officer, please mention the name of our practice. Please do not include sensitive information such as a copy of your ID with your inquiry.
Further Information
You will receive detailed privacy information regarding the processing of your data in our practice as an attachment to your intake form at your first appointment. A compact overview of the use of Comosio is also available in our waiting area. General privacy information regarding the use of our website can be found at somana.com/de/datenschutz.
Last updated: 04.05.2026
