Privacy Policy
Doomscroll.FM · Creative Mayhem UG (haftungsbeschränkt) i.G. · GDPR / BDSG · Last updated: April 2026
This policy explains how Creative Mayhem UG (haftungsbeschränkt) i.G. (“we”, “Creative Mayhem”) processes personal data in connection with Doomscroll.FM, an automated satirical AI broadcast channel. It covers (i) the Doomscroll.FM production pipeline and (ii) the doomscroll.fm website itself.
1. Controller
The controller within the meaning of Art. 4(7) GDPR is:
Creative Mayhem UG (haftungsbeschränkt) i.G.
Alte Jakobstraße 92
10179 Berlin, Deutschland
Managing director: Christopher Karl Neitzert
E-mail: privacy@doomscroll.fm (also: privacy@creativemayhem.com, info@creativemayhem.com)
2. What Doomscroll.FM processes
Doomscroll.FM produces satirical monologues and music from publicly available news. The pipeline processes two categories of personal data:
- Named individuals mentioned in public news reporting. RSS feeds of news outlets routinely contain the names, roles, statements, and (sometimes) images of identifiable persons (politicians, executives, public figures, and — in crime, accident, and human-interest reporting — private individuals). This material is processed when the pipeline summarises articles and generates satirical commentary referencing them.
- Nothing from you as a listener or visitor on this website beyond the technical server-log data described in Section 7. Doomscroll.FM does not operate user accounts, does not collect behavioural telemetry, does not run analytics or advertising, and does not receive personal data back from the distribution platforms we publish on.
3. Lawful bases
Processing of personal data relating to named individuals in news content is carried out on the following bases:
- Art. 6(1)(f) GDPR — legitimate interests. Our legitimate interest is the production of satirical, artistic, and commentary-oriented media works of evident public character, weighed against the limited intrusion represented by referencing already-public information about already-public matters.
- Art. 85 GDPR — processing for journalistic, academic, artistic, and literary purposes. Germany has given effect to this provision through § 23 BDSG. Doomscroll.FM’s satirical-artistic purpose falls squarely within the derogation; the broadcast is a creative work, not an advertising or profiling instrument.
Processing of server-log data for operating the website rests on Art. 6(1)(f) GDPR (legitimate interest in secure, reliable operation). Processing of e-mail correspondence with us rests on Art. 6(1)(b) or (f) GDPR.
4. Retention
Doomscroll.FM has two distinct retention regimes, and the distinction matters:
- Raw ingested content (the “story database” / SpiderCat crawler): deleted within 96 hours of ingestion. This is the raw source material gathered from RSS feeds; once it has either been used as input to a published artefact or has passed the 96-hour window, it is removed from the story database.
- Published artefacts (monologue audio, video, accompanying metadata): retained indefinitely and distributed to YouTube, Spotify, SoundCloud, Apple Podcasts, RSS.com, Telegram, Instagram, X, and occasionally Facebook. Once published, an artefact persists on each platform for as long as the platform preserves it, subject to takedown (see Section 8).
- Server log files (this website): retained only as long as necessary for operational and security purposes; in the absence of a concrete security incident, this does not exceed what is needed to operate the service day-to-day.
- E-mail correspondence: retained for the duration necessary to handle the inquiry and to comply with any applicable statutory retention obligations.
5. Sub-processors and recipients
Personal data processed by Doomscroll.FM may be handled by the following third parties:
- Hetzner Online GmbH (Industriestraße 25, 91710 Gunzenhausen, Germany) — hosts Creative Mayhem UG’s infrastructure, including the doomscroll.fm website and the local inference servers that run the Doomscroll.FM pipeline. Processor under an Art. 28 GDPR data-processing agreement. All processing occurs within the European Union.
- Cloudflare, Inc. (101 Townsend Street, San Francisco, CA 94107, USA) — authoritative DNS for doomscroll.fm. No content is routed through Cloudflare’s reverse-proxy network (DNS-only).
- OpenAI, L.L.C. (USA) — acts as an occasional processor for the text-generation stage of the pipeline when local inference capacity is saturated. Input consists of news-article summaries submitted to the GPT-3.5 API. Governed by OpenAI’s Data Processing Addendum and Standard Contractual Clauses for transfers of personal data to the United States. The primary text-generation path (Qwen3 8B Instruct) runs locally; the OpenAI path is used as an overflow fallback only.
Published artefacts are distributed on YouTube (Google Ireland Ltd.), Spotify (Spotify AB), SoundCloud (SoundCloud Global Ltd. & Co. KG), Apple Podcasts (Apple Distribution International Ltd.), RSS.com, Telegram (Telegram FZ-LLC), Instagram (Meta Platforms Ireland Ltd.), X (X Corp.), and Facebook (Meta Platforms Ireland Ltd.). These platforms are independent controllers in respect of data they collect from their own users (viewers, listeners, subscribers). Their handling of that data is governed by each platform’s own privacy policy, not this one.
6. International transfers
Primary pipeline operations (local LLM, local model inference, local storage) occur entirely within the European Union. When the OpenAI overflow path is used, content summaries are transferred to the United States under the Standard Contractual Clauses referred to above. Where distribution platforms process data outside the EEA, they rely on their own adequacy decisions or equivalent transfer mechanisms.
7. The doomscroll.fm website specifically
The website you are reading does not set cookies, does not run analytics or tracking tools, does not embed third-party content (no social-media plugins, no external fonts, no video embeds, no chat widgets), and does not maintain user accounts. Server-log data (IP address, request URL and status, timestamp, bytes transferred, referrer, user agent) is processed for the purposes described in Section 4 on the lawful basis described in Section 3. All connections are served over TLS.
8. Rights, correction, and takedown of AI-generated content
Under the GDPR you have:
- the right of access (Art. 15);
- the right to rectification (Art. 16);
- the right to erasure (Art. 17);
- the right to restriction of processing (Art. 18);
- the right to data portability (Art. 20), where applicable;
- the right to object to processing based on legitimate interests (Art. 21);
- the right to withdraw previously granted consent (Art. 7(3)), where applicable.
Requests should be sent to privacy@doomscroll.fm. We will respond without undue delay and in any event within the one-month period prescribed by Art. 12(3) GDPR. In practice we typically respond and act substantially faster.
If you appear (by name, likeness, or other identifier) in a Doomscroll.FM broadcast and want the broadcast removed or altered, the same contact applies. Because Art. 85 GDPR / § 23 BDSG balance data-protection rights against freedom of expression and the journalistic-artistic derogation, we assess each request on its facts and respond with the outcome and reasoning.
Please note that once an artefact has been syndicated to third-party platforms (YouTube, Spotify, etc.) we can only remove it from accounts under our direct control; downstream re-uploads are outside our technical reach.
9. Automated decision-making
We do not engage in automated decision-making producing legal or similarly significant effects concerning any natural person within the meaning of Art. 22 GDPR. The pipeline generates satirical creative output; it does not rate, screen, profile, or make decisions about individuals.
10. Security
Technical and organisational measures include TLS for transport security, encryption at rest for the story database during its retention window, and restricted administrative access to production infrastructure.
11. Supervisory authority
You have the right to lodge a complaint with a data-protection supervisory authority (Art. 77 GDPR). For Creative Mayhem UG the competent authority is:
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59–61, 10555 Berlin, Germany
www.datenschutz-berlin.de
12. Changes to this policy
This policy is current as of the date shown below. As the Doomscroll.FM pipeline, the legal environment, or our processing activities evolve, we may update this policy. The current version is always published at this URL.
This policy is published in English because Doomscroll.FM is an English-language service. Under Art. 12(1) GDPR we may communicate with data subjects in a language they understand; for our audience that language is English.