ChatiTec — Legally Compliant & Data-Protection-Compliant AI from Augsburg

Supplementary Agreement on the Protection of Professional Secrets

Convenience translation. This English version is provided for information purposes only. The legally binding version is the German original (/legal/geheimnisschutz-203stgb.html). In the event of any discrepancy, the German version shall prevail. German statutory references have been retained.

(§ 203 StGB (German Criminal Code) in conjunction with § 43e BRAO (Federal Lawyers' Act) or medical confidentiality)

As of: 23 October 2026

between

the professional secrecy holder – hereinafter the "Client" –

being the professional secrecy holder designated in the customer account or in the order

and

Sat-iTec – hereinafter the "Contributing Person" within the meaning of § 203 Abs. 3 StGB –

Sat-iTec Systemhaus GmbH Heisinger Straße 21, 87437 Kempten (Allgäu) represented by Günther Löb (Managing Director)


Preamble

As a professional secrecy holder, the Client is subject to a statutory duty of confidentiality (§ 203 StGB), in particular

In the context of the use of the "ChatiTec" platform, Sat-iTec contributes to the professional activity of the Client and may thereby obtain knowledge of protected secrets. In doing so, Sat-iTec acts as an other contributing person within the meaning of § 203 Abs. 3 Satz 2 StGB. This Agreement ensures the involvement and commitment required under criminal law and professional law. It supplements the Data Processing Agreement (Art. 28 GDPR) and does not replace it.


§ 1 Subject Matter

This Agreement governs the obligation of Sat-iTec and of the further persons engaged by Sat-iTec to safeguard the professional secrets incumbent upon the Client in connection with the provision of services via the ChatiTec platform.


§ 2 Status as Contributing Person

(1) Sat-iTec is a contributing person within the meaning of § 203 Abs. 3 Satz 2 StGB. The contribution is limited to what is necessary for the use of the contributing activity.

(2) Insofar as protected secrets are disclosed to Sat-iTec in the course of the activity, such disclosure is justified under § 203 Abs. 3 Satz 2 StGB, as it is necessary for the use of the contributing activity. Sat-iTec shall take note of the secrets that have become accessible to it only to the extent necessary.


§ 3 Obligation of Confidentiality

(1) Sat-iTec undertakes to maintain secrecy about all third-party secrets that have become known to it in the course of the activity – in particular client or patient secrets as well as secrets belonging to the sphere of personal life and trade or business secrets – and neither to disclose nor to exploit them without authorisation.

(2) The obligation of confidentiality is unlimited in time and shall continue to apply after termination of the contractual relationship.

(3) Disclosure to third parties shall only take place insofar as this is required by law or the Client has given prior written consent.


§ 4 Obligation of Further Persons Engaged (§ 203 Abs. 4 StGB)

(1) Sat-iTec shall ensure that all further persons employed by it or engaged by it in the course of the activity (employees, subcontractors, other contributing persons) are bound to confidentiality to the extent set out above before commencing their activity and are instructed about the criminal consequences of a breach.

(2) Where further contributing persons (sub-processors) are engaged, Sat-iTec shall bind them in a corresponding manner; § 203 Abs. 4 Satz 2 StGB must be observed. The engagement shall take place in accordance with § 5 of the Data Processing Agreement.

(3) Sat-iTec shall provide evidence that the obligations under paragraphs 1 and 2 have been imposed, insofar as the Client so requests.


§ 5 Anonymisation as a Technical Protective Measure

(1) Insofar as external AI providers are used for the provision of services, protected secrets are automatically anonymised before transmission (PII tokenisation). This anonymisation is enforced by default (PII_FORCE_FOR_EXTERNAL=true). External providers therefore do not receive any identifying plain-text content; re-identification is only possible locally (Fernet-encrypted) on the infrastructure operated in Germany.

(2) For particularly sensitive processing, purely local operation (Ollama/vLLM) without any external data transfer is available.

(3) These measures serve to avoid disclosure to external third parties as far as possible or to limit it to non-identifying content. The Client remains obliged to examine in each individual case whether the respective processing is compatible with its duty of confidentiality.


§ 6 Instruction on Criminal Liability

Sat-iTec and the persons working for Sat-iTec have been instructed that


§ 7 Relationship to Other Agreements, Final Provisions

(1) This Agreement supplements the Data Processing Agreement (Art. 28 GDPR) and the main contract. In the event of conflicts relating to the protection of professional secrets, this Agreement shall take precedence.

(2) Amendments and supplements require text form.

(3) Should any provision be invalid, the validity of the remaining provisions shall remain unaffected.

(4) The law of the Federal Republic of Germany shall apply.


Conclusion of the Agreement: This Agreement is concluded in electronic format by the Client accepting it upon registration or ordering; the time and version of acceptance are logged. A separate signature is not required. Upon request, Sat-iTec will provide a version signed by both parties.


As of: 23 October 2026 – The professional law obligations of the Client (e.g. BRAO/BORA, medical professional law) remain unaffected.

Sat-iTec Systemhaus GmbH · ChatiTec — Supplementary Agreement on the Protection of Professional Secrets (§ 203 StGB) · As of 23 October 2026