Information on the processing of personal data

Version: alpha-2026-10-12-proattivita, dated 12 October 2026.

This privacy notice (the “Notice”) describes the processing of personal data within mindset: during its closed, invitation-only alpha test. It replaces version alpha-2026-10-11-profili. This document is provisional and must undergo legal and data protection review before the service opens to the public. Fields marked [TO BE COMPLETED: …] must be completed before that opening.

The information is distinct from Terms of service and software licence, which govern the contractual relationship.

Summary of processing activities

Holder. [To BE COMPLETED: name or name, legal form and registered office of the holder]. Contact for data requests: [TO BE COMPLETED: email address or form for data requests].
Purpose of the service. mindset: is an application for the training of thoughts and habits in the context of personal well-being. It does not provide health, diagnostic or therapeutic services and does not replace medical assistance or emergency services. In case of immediate danger you must contact the local emergency number, including 112 in Italy.
Health data. Emotional indications, texts related to moments of difficulty and derived analyses may reveal health information. For further treatments compared to the basic functioning, explicit and separate consents are required for purposes.
Optional consensus. The choices relate to "The Dream" , "The Strong Words" , "The Tips" , "The Custom Messages" , "The Use of the App" , "The Voices" and "The Tone of Voices" , distinct for purposes. "The Voices" and "The Tone of Voices" are initially disabled and enabled separately in the Settings. In the current log interface, the other five boxes are pre-selected and can be unselected, or changed later in Settings. Failure to consent does not prevent the use of exercises, diary, SOS and local rules based on the security word list.
Artificial intelligence. With consent, the Gemma model, provided through Cloudflare Workers AI, processes the texts indicated in the following sections. The results can be inaccurate. No real-time human reading service is provided.
Local conservation. Journals, replies, tests, traps, letters and information about people are stored on the device in a separate encrypted account archive.
Storage on the server. Account data, without name or email, encrypted synchronization copies if enabled, Telegram messages if activated and the consent log are stored. Interactions and the day catalog are recorded, in pseudonymized form and associated with the account, only with the consent of the use of the app.
Access and recipients. The administrator accesses the structured data of interactions and catalog within the limits of consent, without access to the texts of the exercises or the encrypted copy. The texts of the daily messages Telegram are instead stored on the server without encryption applied by the owner. Cloudflare hosts the service and Telegram delivers the activated messages.
International transfers. Cloudflare is based in the United States. Processing through AI Workers can take place outside the European Economic Area; the place of inference is not indicated by Cloudflare. Telegram is located outside the European Economic Area.
Alpha phase. Features may vary, the service may be interrupted and the data on the server may be lost. Data export is available.
Rights. Access, export, rectification, cancellation, limitation, opposition, withdrawal of consent and complaint are available in the manner described below. The cancellation of the account and withdrawal do not result in the immediate elimination of acceptance and consent tests, which are subject to separate storage.

Cessation of report. In Settings, your account will be deleted and a receipt will be made available. You can also delete the account from the contract here. The consents are retained for [PROPOSE: 5 years].

Scope, definitions and status of the document

The Policy is a function of communication of the processing and is not subject to contractual acceptance. The two mandatory boxes concern the Terms, including the license, and the limitations of the alpha phase. The six optional choices relating to the data are distinct from these acceptances.

For the purposes of this Notice, the user shall mean the person he uses. mindset:; "Application" means areas of access to the service; "Titolare" means the person identified in the next section. Health data include information on physical or mental health, even of uncertain accuracy: emotional state, moments of difficulty, personal content and results of automatic analysis.

The indications [to BE COMPLETED: ...] identify missing information; [PROPOSED: ...] identifies a choice that has not yet been confirmed; [TO BE CHECKED: ...] identifies an element that is still subject to verification. Such indications do not constitute evidence of compliance already carried out.

The reference text is Italian. [To BE COMPLETED: English translation of the Information, because the app is also available in English]. The supplementary provisions applicable in the individual legal systems are contained in the section "Territorial provisions" . No provision of the Information limits the rights that cannot be waived by law.

Data controller and contact details

Data Controller: [TO BE COMPLETED: name or name, legal form, location and address]. The Data Controller determines the purposes and means of the processing described in the Information.
Address for rights, consents, complaints and requests: [TO BE COMPLETED: email address or form]. [PROPOSED: a dedicated box, for example privacy@mindset.xin, with reply within 30 days.] The person who sent the invitation has no access to the User's data and is not allowed to reply on behalf of the Owner.
Data Protection Officer: [TO BE COMPLETED: name and contact, or the reason why he is not appointed].
Representative in the European Union, pursuant to article 27 of the GDPR: [TO BE COMPLETED: name, address and contact of the representative].
Representatives and local leaders. For the United Kingdom, Switzerland, Brazil, Quebec, Korea, China, Japan and India, the information on the appointments requested is given in the section "Spatial provisions" with details still to be defined.
Roles in treatment. The Data Controller is responsible for the purposes and means of processing the data of the account, interactions, consent registers and Telegram messages. Cloudflare, Inc. acts as controller for the services provided on behalf of the Data Controller. Telegram operates as independent owner for its service. Cloudflare also works as holder for the signals used to improve Turnstyle.
Data protection impact assessment: [To BE COMPLETED: Date and Head of Evaluation, to be done before opening to people outside the alpha].

Categories of data, purposes and legal bases

The following entries indicate the categories of data, purposes, legal bases, recipients, terms of storage and the nature of the provision. The bases referred to are the performance of the contract, pursuant to Article 6, paragraph 1, point b of the GDPR; the consent, pursuant to Article 6, paragraph 1, point a, and, for health data, the explicit consent pursuant to Article 9, paragraph 2, point a; the fulfilment of legal obligations, pursuant to Article 6, paragraph 1, point c; the legitimate interest, pursuant to Article 6, paragraph 1, point f.

Account and authentication

They are processed: random identifier and account creation date; inviter identification; number of available invitations; public keys to passkeys; identifiers transmitted by Telegram, Google or Microsoft in case of use of the relevant access, including the Telegram numeric identifier; fingerprint of the recovery code; session data, including token imprint, dates and device type; versions of documents accepted. No name, email or password are retained for account management.

The purpose is the creation and management of the account and access. The legal basis is the execution of the contract. Cloudflare receives such data; authentication providers receive the necessary ones when chosen by the User. The retention extends to the duration of the account; the sessions have a maximum duration of 180 days. The conferment is necessary for access to the service.

Invitations

The code, the identity of the inviteer and the account that uses the invitation, the date of creation, the expiration and the date of use are treated to allow access to the closed test. The legal basis is the execution of the contract. The invitations are single-use and valid for 14 days. The cancellation of an account removes the links that concern it. The recipient is Cloudflare. The storage extends to the duration of the connected accounts, according to the terms indicated in the dedicated section. The transfer is necessary for registration.

Control against automation: Cloudflare Turnstyle

In the browser, the Turnstile control is loaded at the display of the access screen, prior to registration, access via passkey or recovery code, or the start of authentication with Telegram, Google or Microsoft. Cloudflare treats IP address, imprint of the TLS connection, header User-Agent, key of the site and site of origin, according to the Turnstile Privacy Attachment of 18 June 2025. The Owner transmits to Cloudflare the verification token and the IP address, without retaining the latter. The control is not used in the Mini App, in which the identity is verified by the signature of Telegram.

The purpose is the prevention of automated access. The legal basis indicated is the legitimate interest in the protection of the service; Cloudflare qualifies such signals as strictly necessary for the detection and blocking of bots. Cloudflare operates as holder for signals used in the improvement of Turnstyle, second its corollary. The Data Controller does not store the verification data; storage at Cloudflare is governed by the corollary.

The control is necessary for access from the browser. In case of opposition access is available via the Telegram bot. [TO BE CHECKED: compatibility of the loading of Turnstyle before the choices of the User with the provisions on data in the terminal.]

Contents stored on the device

The data are stored locally in the diary, answers, tests, traps, letters, information about the persons indicated by the User, including the name, number and desired frequency of the contacts, the person of trust, the type optionally indicated and settings. The data are encrypted in a separate archive per account. The Data Controller does not receive them, except the transmissions required by the functions enabled and described in the following entries.

The basis for local operation is the performance of the contract. The provision of individual content is optional; their absence limits the functionality that requires such information.

Encrypted synchronization

If enabled, the synchronization transmits an encrypted copy of the archive, encrypted envelopes that protect the key, date, size and version of the copy. Encryption takes place on the device; the server retains the encrypted content and the protected key. In the absence of the passkey or the user's data code, the server does not have the necessary elements to decipher the copy.

The legal basis indicated is the execution of the contract for the required functionality. [To be checked with the legal officer: if, because the copy contains health data, you also need explicit consent.] The recipient is Cloudflare. The copy is stored for the duration of the account. Disable synchronization on a device does not delete the copy on the server: the deletion is done through Settings,

Browser Notifications

If enabled, the delivery address of the browser, the selected times and the time zone are processed. The notification transmitted does not contain any text; the content is generated on the device. The basis indicated is the execution of the contract for the required functionality, accompanied by the browser notification permission. The recipients are Cloudflare and the browser notification service, provided by Google, Mozilla, Apple or Microsoft.

The data is stored until decommissioning; the address is deleted when the provider reports the expiry date. Registration is not associated with the account. [TO BE CHECKED: retention of the registration until the address expires in case of cancellation of the account without prior decommissioning of the reminders]. The provision is optional.

Telegram Daily Messages

The consent is dedicated and optional, proposed active in the initial configuration and editable in the Settings. The choices already expressed, including revocations, are not modified automatically. If lent, the Application selects a limited context, consisting of objective, step and, when relevant, situation declared in the same exercise, in addition to the chosen tone. The context is transmitted to the server and Gemma on Cloudflare Workers AI to compose the morning or evening call. The model may link the information received; the composition does not certify a cause, emotion or personal characteristic. On days recognised by the Application as difficult and in the absence of a sufficient context, prepared texts are used. The legal basis for the composition is explicit consent; the context may include health data.

The context and the personal texts can be used until the expiry date set on the device, however, within two days. After the expiration, a generic text is sent. Daily control removes from the server the context and the texts expired within the next day, for a maximum of three days from the update. A composite result with AI is recognizable in the message. The withdrawal of consent eliminates the context and the result AI preserved and keeps available the prepared texts; it does not delete the messages already present in the chat Telegram.

The use of the app is recorded for 30 days, the origin of the text, attempts, acceptance status or error of the Telegram service and openings, start/repairs and conclusions of the exercise attributed to the recall. The log, associated with the account, does not contain the text of the message or context. The administrator can consult this data; the withdrawal of consent deletes the registry. The acceptance of the message from Telegram does not show reading or displaying the notification; the conclusion of the exercise does not demonstrate the completion of the action in daily life.

If activated for the morning or evening, Telegram identification, chosen time, UTC deviation of the device, up to seven variants of the message composed on the device, text of the button, expiration, date of the last shipment and eventual refusal of delivery, are treated.Variants may include contents of the User: objective, intended action, a word of the plan and a personal test on the days of difficulty. The request to the service is repeated, within the expected window, in case of temporary errors; the block of the bot interrupts the sendings.

The texts are stored on the server without encryption applied by the Data Controller and are transmitted via Telegram. The server refuses text containing words from the security list. The basis indicated is the execution of the contract for the required functionality by choosing the time and permission of Telegram when sending messages. [TO BE CHECKED: need for explicit consent specific to Telegram messages containing health data; such consent is not currently included in the five choices.]

The recipients are Cloudflare and Telegram. The data is stored until the selection of "Spento" or the cancellation of the account. [PROPOSE: delete the text after sending and recompose it every day]. The conferment is optional.

Telegram Bot and Mini App

Telegram transmits signed data including identification, name and language. The Owner checks the signature and retains only the identifier; the name is used for the greeting and is not stored. The messages sent by the User to the bot are not retained by the Owner; with the consent of the User, the bot selects a tool and returns the link to open it. A free conversation or a historical chat is not built in the server of mindset:. The legal basis is the execution of the contract. The conferment is not necessary if the User does not use Telegram.

Tips and rewording of messages

With the consent of the user, the phrase inserted by the user, up to 4.000 characters in the bot and the routing service, and the list of the instruments allowed, are transmitted to the model. The previous field of the suggestions accepts up to 300 characters. For messages "For you" the elements used by the message are transmitted, such as objective, situation, word or test, along with reason, step, basic text and tone. The model proposes an exercise with a short motivation or reformulates the message. The phrases containing strong words are not sent to the template of the suggestions.

The Data Controller does not retain the sentences. With the consent of the "app" the routing service retains only the proposed tool, an emotional clue derived from the content, its uncertainty, the channel and the instant, separately from the emotions declared by the User. In addition, meters of use are kept, with limits of 5 suggestions and 3 rewordings per day. The legal basis indicated is the explicit consent. The recipient is Cloudflare Workers AI. The conferment is optional.

Voices and audio signal measurements

The consent is optional, dedicated and initially disabled. It is activated in the consents of the account prior to the processing of the first voice. You also need the consent to the consent of the vocals. The vowel, with a maximum duration of one minute and a maximum size of 2 MiB, is processed in memory by the computing services of Cloudflare: Whisper on Works AI transcribes it; Gemma selects a tool from the content. The application does not store the voice file in D1, in a bucket or cache. The file is released after processing. The transcription is returned to the User in the Application and is not stored by the Owner.

The duration is derived from the audio container and, by means of a separate calculation component (Cloudflare Durable Object), relative level and peak of the signal, variation of the level, share of low energy segments and clipping. The component does not use persistent storage. If the calculation fails, the duration, transcription and proposal of the instrument remain available. These measures are not used to identify the User and do not constitute a diagnosis or determination of his emotions.

With the distinct consent of the tone of the voice, optional and initially disabled, the same component obtains prosodic aggregates: median fundamental frequency, extension and variation, frequency and regularity of periodic segments, distribution and variation of energy, zero crossings and clipping. An experimental classifier proposes an emotional expression hypothesis between seven categories: anger, boredom, disgust, fear, joy, neutral and sadness, with uncalibrated numerical scores. In case of insufficient or unsupported signal it may not produce a hypothesis. The technical thresholds do not constitute a validation of emotional recognition.

The classifier is trained exclusively on recordings recited in German of the corpus EmoDB; it is not validated in Italian or in the daily use of the Users. The hypotheses may be incorrect, even when the score is high. Microphone, distance, noise, language and compression can alter the measurements. No specific detectors are implemented of tremolio, breath or hiccups. No biometric identification of the speaker or diagnosis is made. The vocal hypothesis remains distinct from the emotional clue derived from the content and state that the User can optionally indicate before sending. The instrument's proposal comes from the content; the vocal hypothesis alone does not modify the routing, the sos or the energy of the interface. The emotional comparison between words and tone and the longitudinal correlations between arguments and tone are not implemented.

For authorised analyses, acoustic aggregates may be compared with those of the previous vowels of the same account, separately by channel and version of the extractor. Median and descriptive variations from the past are calculated, without attributing to the deviation an emotion or a diagnosis. The comparison does not involve the preservation of audio or voice fingerprints.

With the distinct consent of the app, the measures, the prosodic aggregates and the authorized hypotheses, the optionally declared state, the model version, the channel and the instant are kept in pseudonymized form, associated with the account, for the analysis of the platform and visible to the administrator. The declared state is chosen by a list; it does not involve the preservation of the text of the message. Without such consent, the result is returned for the current request and is not included in the catalog. Texts, transcriptions, identification of the Telegram files, sound recordings, detailed prosodic contours or vocal fingerprints are not kept in the catalog.

The legal basis indicated is the explicit consent for each optional processing, including any health data. Recipients: Cloudflare for calculation and, for voices sent to the bot, Telegram for its service. Failure to store by mindset: does not remove voice from the chat or Telegram systems. The analysis catalogue is kept for 12 months, unless early revocation or cancellation of the account. The revocation of the "Il tono della voce" (Il tono della voce) deletes prosodic aggregates and vocal hypotheses from the catalog and prevents new elaborations; transcription and routing remain available with the relative consents. The revocation of "I vocali" (I vocali) deletes the vocal records; the revocation of "L" use of the "app" (I) deletes the entire catalog. The revocation does not modify the messages present in Telegram.

Country for SOS contacts

The Worker retrieves the country code of the connection from the information provided by Cloudflare, without saving the IP address. The code serves exclusively to suggest local SOS contacts and is returned to the device. The User can correct it; the manual choice is stored on the device per account. The interface language does not determine the Country. No GPS access or precise location are required. In the absence of a country or verified contacts, the international reference is shown. The legal basis indicated is the performance of the SOS functionality of the service.

Dream Analysis

With the consent of the Dream, the texts of the previous day are transmitted to the model, including answers to exercises, tests, traps and letters, up to 30 texts of maximum 600 characters each. Any names and contents with strong words inserted by the User are included.

The model draws themes, emotions with intensity from 1 to 3, quoted people, modes of thought, declared energy, level of difficulty (-no-one, -possible, -clear) and signals selected from a closed list: thoughts of death, self-harm, absence of hope, violence suffered and current danger. The result is returned to the device, validated and stored locally. The server does not keep the texts or analysis; it records only the number of requests, limited to 8 per day.

The legal basis indicated is explicit consent. The recipient is Cloudflare Workers AI. The conferment is optional.

Analysis of strong words

With the consent of "The strong words" the insertion of words that can indicate a moment of difficulty activates the analysis of the texts of the day, together with the history of the last four weeks. The story includes exclusively levels, signals and dates, without the texts of the previous days. The Application does not interrupt the insertion with a question.

The returned classification is automatic and may be incorrect. In the cases provided for by the rules of the Application is displayed in Today an SOS reminder, with the trusted person if indicated and the delivery of a listening line. The reminder is displayed even if the analysis fails. The legal basis indicated is explicit consent. The recipient is Cloudflare Workers AI. The conferment is optional.

Analysis of use and catalog of the days

The use of the app is subject to the consent of the user to record structured data associated with the account in pseudonymized form: opening of the application; starting and ending exercises; selected options and scale values, including emotional status and trust from 0 to 10; level and motivation of the interface energy; feedbacks of the party, the caress and the thrust of the scale; opening of the SOS, calling or message to the trusted person; response to the security question; levels attributed by the model and display of the SOS reminders; settings; reception phases; number of persons added, frequency of contacts and optional genre; optional genre of the User; randomly selected proposals; access area, version of the Application and minute of each event.

Only the short, medium or long, speechless, wordless, nameless, or textless length class of text is recorded for the inserted text. Events include a random installation identifier associated with the server to the account. From October 11 2026 also include a random event identifier, in order to avoid duplication in the event of re-sending, a session identifier for the operation and the UTC deviation of the device at the time of the event. The time difference is not a geographical location; historical data without such elements are not integrated retroactively.

The catalog contains a daily recording with exercise counts, outcomes, tests, traps, habits and contacts; state of the compass; last value of confidence; classes of text quantity; presence of a security check or words in the security list. If the dream is also enabled, it includes themes, emotions, mode of thought, declared energy, levels and signals of difficulty and codes of the persons mentioned, with role and tone. It does not include names, texts or genre of the people mentioned.

The purpose is to understand the usefulness of the functionality and improve the service. The legal basis indicated is explicit consent. The recipients are Cloudflare and the administrator. Storage: [PROPOSE: 12 months from registration, then deleted]. The conferment is optional.

Random change in proposals

Some proposals are randomly selected between options prepared for the User, such as an additional question in the Budget or the invitation to reread a content. Security features are not subject to random variation.

With the consent of the app, the use of the app is recorded the proposal made, the status of the day and the continuation of the use, without the inserted text. [TO BE CHECKED: current application of the random selection also to users without its consent.] [PROPOSED: a switch "Do not change the proposals" in Settings.]

Registration of acceptances and consensus

Each choice, positive or negative, is recorded by means of an uneditable entry including account identifier, exact text displayed, choice, date and time, document version, web channel or Telegram, application version and confirmation mode. The mode can be •Continue • with the optional boxes pre-selected in the first screen, or one of the collective commands in Settings, •I agree to the seven entries •I withdraw all optional consents • • The IP address is not registered.

The basis given is the obligation to demonstrate consent, pursuant to article 7, paragraph 1 of the GDPR, and the legitimate interest in the defence in court. The recipient is Cloudflare. Registrations are kept for the duration of the account. After cancellation or withdrawal they remain unconnected to the other data, for the period necessary to defend a right, pursuant to Article 17, paragraph 3, letter and: [PROPOSE: 5 years]. Registration is necessary for the two contractual acceptances.

Users' observations during the test

The observations on the functioning of the Application are discussed, communicated to the founder or the person who sent the invitation. The basis indicated is the execution of the contract in the context of the alpha test. The recipient is the founder. Storage: [PROPOSE: until the end of the alpha]. The conferment is optional.

Limits of use and protection of the service

Daily counters are treated for accounts, related to analysis, suggestions and rewording, daily consumption of the artificial intelligence service and limits of events per installation. The purpose is to prevent abuse and disproportionate costs; the basis is the legitimate interest in the protection of the service. For the messages of the bot are also kept the technical identifier of the update and the instant of receipt, to avoid duplicate processing; such recordings are eliminated after 7 days and do not contain any text, audio or user identification. The counters are stored for 30 days and subsequently deleted by night procedure; the counters associated with the account are also deleted on its cancellation. The treatment is necessary for the operation of the service.

Requests and communications

The content of the requests, the contact details used and the account code, if necessary to verify their ownership, are processed. The bases indicated are the fulfilment of the obligations related to the exercise of the rights and the legitimate interest in the management of communications. Storage: [PROPOSE: 24 months from the last reply]. The provision is optional, stops the need for information useful to manage the request.

Health data and consensus management

The two mandatory boxes express contractual acceptances and do not constitute consent to the processing of data:

Acceptance of the Terms. I have at least 18 years and I accept the Terms of Service and the license of use.
Separate acceptance of alpha phase. «mindset: is in alpha: I accept, separately, that the functions change, that the service can stop and that the data on the server can be lost. I can export them whenever I want.

The following five choices relate to optional treatments, distinguished for purposes, which may affect health data. In the current interface the boxes are pre-selected and can be unselected individually. None of them is a requirement for account creation or access to basic features. The texts displayed in the Application are provided in full:

The dream. I agree that at night an automatic model (Gemma on Cloudflare's Workers AI) rereads the texts of the day before, including mood, emotions and difficult moments, which are data on health, to return me what comes back in my days.[2] In the absence of consent, the texts are not transmitted for this purpose and the related observations are not generated.
Strong words. I agree that when I write words that may indicate a difficult moment, an automatic model will read them immediately with my history for the last four weeks, to remind me of the SOS and the trusted person when it is needed. In the absence of consensus, the strong words are not elaborated by the model. The SOS remains available.
The suggestions. I agree that an automatic template reads the phrase I write to propose an exercise, and rewrites the messages "For You" . In the absence of consent, the exercises remain available in the Tools and messages "For You" keep the default text.
Customized messages. I agree that Gemma on Cloudflare Workers AI uses my goal, step and context, including health data, to compose personal messages on Telegram. The context expires within two days and is deleted at the next daily checkup. I can turn off customization whenever I want.
Use of the app. I agree that mindset: records how I use the app and that on the server remains the catalog of my days without texts or names, including the mood that I infer and the difficult moments, connected to my account in pseudonymized form, to improve the service.In the absence of consent, the user's interactions are not recorded nor the catalog of days is kept.

Amendment and revocation. The consents can be modified or revoked by Settings, your account . Your consents may be changed by using the relevant switches. The revocation shall interrupt the functionality and subsequent processing for the purpose of the revocation, without prejudice to the lawfulness of the processing carried out previously. The revocation of the app will result in the simultaneous deletion from the server of the interactions associated with the account and the catalog of the days.

Documentation of choices. The choices are stored in the log described above. The receipt is exportable from Settings and is included in the export of the account.

There are two additional optional consents available in the Settings, initially disabled: - Voices: - Transcription and routing of audio, and - Tone of voice - experimental estimation of voice expression. - Purposes, data, limits and revocations are described in the section - Voices and measurements of audio signal - The corresponding consent text is shown next to each switch and recorded in full in the receipt.

Effects of non-consent. Refusal does not lead to denied advantages or further disadvantages compared to the lack of availability of the specific functionality. SOS, exercises and diary do not depend on optional consents.

Change in treatment. New purposes, categories of data or recipients are communicated in advance; if requested, the processing is subject to a new consent.

Exclusions of use. The data are not sold, used for advertising or communicated to employers or educational institutions. [PROPOSE: exclusion of the use of difficulty levels to determine access, availability of invitations or permanence of the account, and exclusion of their communication to third parties].

Artificial intelligence, profiling and automated decisions

This section describes the use of artificial intelligence for the purposes of transparency as provided for in Article 50 of the European Regulation on Artificial Intelligence and the Italian provisions on information on the use of AI.

Functionality and model. Suggestions, rewordings of the messages - For you - Dream and strong words use Gemma 4 26B A4B, hosted on Cloudflare Workers AI. The model does not handle a free conversation: select exercises from a list, reword short messages or attribute to the texts default categories.

Identification of results. The suggestions are accompanied by the indication "Proposed by an automatic model "; the messages reformulated by the indication "rewritten by an automatic model " . The analysis of dreams and strong words return categories drawn from closed lists, without generating free texts.

Data transmitted and training. The model receives the contents of the individual request, including any names present in the texts, but not the account identifier or the name of the User as separate data. The Owner does not retain the sent sentences. Cloudflare declares that it does not use the contents of the AI Workers customers to train models or improve its own or third-party services without explicit consent of the customer. The Owner does not use the User's data to train or modify models.

Limits of processing. Classifications are estimates and may attribute unequal emotions, omit signals of difficulty or overestimate severity. They do not constitute diagnosis or individual risk measures and do not replace human assistance or emergency services. The observations of the Application indicate the days and classifications from which they derive and may be challenged by

Human access. There is no real-time human monitoring of texts. For accounts with consent, the administrator accesses the structured results of the catalogue and interactions, without access to the texts of the exercises.

Descriptive analysis in administration. Permitted structured data are represented by period, source and context. Comparisons can be calculated between answers to the same question, differences before and after the exercises, cocorrencies and exploratory associations within the same account. The Mirror shows the answers to the individual sentences, without a psychometric personality score. Missing data remain such. Analysis does not constitute diagnosis, does not demonstrate causes and does not determine automated decisions with legal or similar significant effects. Administrative export includes the method, coverage and source of data.

Profiling by default rules. The Application determines by means of rules prepared by the Manager the energy of the interface, the state of the day, the selection and the time of the messages and the recurrences between days. For a recurrence are required at least three days, with at least one week between the first and the last. On days of difficulty are excluded the feedback of thrust. These treatments evaluate personal aspects and constitute profiling. They do not produce legal effects or similarly significant consequences: they do not determine the loss of services, rights or opportunities. They are therefore not used for automated decisions pursuant to article 22 of the GDPR.

User control. The User can withdraw consents in Settings, Your Account, Your Consents, or set a fixed level of energy in Settings. For requests related to local rules, you can contact the Owner.

Reports of difficulties. The SOS reminder has contact details that are already available, without notifying third parties or limiting the account. After a clear difficulty classification, the Application temporarily excludes any feedback from the party and push.

Origin of the data and nature of the transfer

The data comes from:

by the User, through texts, choices, settings and consents;
from the device and browser, by access area, version of the Application, time zone and random installation identifier;
from Telegram, Google or Microsoft, if used for access, through the transmitted identifiers; for Telegram are also received name and language, which are not retained;
by the caller, for the code and link of the invitation;
from the model, where authorised, for derived data such as themes, emotions, modes of thought and levels and signs of difficulty.

An invitation, passkey or external access supported by Telegram, Google or Microsoft and the two contractual acceptances are required to access the service. In the absence of such elements, the service cannot be used. The other contributions are optional and are required in relation to the activated features.

Data recipients

Cloudflare, Inc., San Francisco, United States. It provides hosting of the site and Application, database, execution of the server code and AI Workers. It acts as controller on behalf of the Data Controller. The data processing agreement is incorporated into the service contract [TO BE CHECKED: Cloudflare plan in use and acceptance of that contract]. For Turnstyle it also works as holder of the signals used to improve control.
Telegram, located outside the European Economic Area. In case of authentication, use of the Mini App or activation of the messages, it receives the data that transit through its service. its own information; no agreement has been concluded with Telegram as controller. This Policy also applies to the bot and Mini App. [TO BE COMPLETED: registration of this text in @BotFather].
Google and Microsoft. If used for authentication, they receive access information to mindset: and transmit an identifier. In the absence of active access, no exchange with the relevant supplier takes place. [TO BE CHECKED: which accesses are active in production].
Browser notification providers: Google, Mozilla, Apple or Microsoft. They receive the delivery address and notifications without text only if the User activates the reminders.
Administrator authorized by the Owner. It accesses the account ID and date of creation, inviting, availability of invitations, connected access types, last session, size and date of the encrypted copy. With the consent of the app, it also accesses the interactions and the catalog, including elaborations in the administrative browser such as the emotional path over time. It does not access the texts of the exercises or the contents of the encrypted copy. Access is reserved to the administrator's Telegram account, with permission of 12 hours, and to a confidential key used by the Owner's scripts. [TO BE COMPLETED: who, in addition to the owner, has this access.]
Authorities and judicial bodies. The data can be communicated in compliance with legal obligations or for the defence of rights.

No data is communicated to third parties for advertising or analysis. The Application does not integrate advertising or third-party analysis tools; the content security policy only allows scripts from the service domain and from challenges.cloudflare.com for Turnstyle. [TO BE CHECKED: native applications, before its publication.]

Places of treatment and international transfers

The recipients are those listed in the previous section. Information on transfers outside the European Union is given below. A copy of the guarantees may be requested from [TO BE COMPLETED: Contact].

Cloudflare, Inc. The application requests, including the IP address not retained by the Owner, the database data, the encrypted copies and, subject to consent, the texts and vowels intended for the models or the component of acoustic calculation. The purpose is to provide the service. The warranty indicated is the EU framework for data protection, approved by Implementing Decision (EU) 2023/1795, to which Cloudflare adheres; in the alternative, the standard contractual clauses provided for by Implementing Decision (EU) 2021/914 and the Cloudflare processing agreement. For Switzerland and the United Kingdom, the corresponding frameworks are recalled. [To be verified before publishing: status of the certification of Cloudflare in the framework register, that October 8 2026 was "Active " Re-certificate under Review" and the appeal pending against the decision.]
Database. The database is located in the EU jurisdiction of Cloudflare [TO BE CHECKED: Test from the Cloudflare panel]. This configuration does not extend to the execution of the server code or to Workers AI.
Workers AI is the place of inference not indicated. Cloudflare does not specify the country of processing and Workers AI is not part of the services subject to regional constraint. Processing may take place outside the European Economic Area, Switzerland and the United Kingdom. The guarantees indicated are those relating to Cloudflare, Inc. [TO BE COMPLETED: Country and sub-responsible for inference, if Cloudflare communicates them.]
Telegram outside the European Economic Area. According to the information of 21 August 2026, the group includes companies in the British Virgin Islands and in Dubai. The activated messages and data that transit through the Mini App within Telegram, for the functionality required by the User are transmitted. Guarantee: [TO BE COMPLETED: legal basis of the transfer, to be defined in the legal review, including any explicit consent subject to information on risks]. Telegram determines the processing of the messages autonomously; the authorities of the countries concerned may request access.
Browser Notification Services • United States or other countries. The delivery address and a notification without text are sent. [TO BE COMPLETED: Country and warranty for each service.]

The data processed abroad may be accessible to local authorities in accordance with the laws of their respective countries. The transfer to Cloudflare is based on the above-mentioned guarantees and not on the consent of the User.

Storage periods

Vowels. The file and transcription are not archived by the Owner. The structured descriptors shared for analysis follow the period of 12 months and the early cancellations described in the dedicated section.

Accounts, passkeys, linked identities, recovery code, key wrappings and encrypted copies. Retention for the duration of the account and deletion from the context database when it is deleted. [PROPOSED: Deletion of inactive accounts from 12 months, subject to communication in the "Application."]
Sessions. Up to 180 days or when disconnected from the device.
Access checks in progress. Up to 5 minutes or first use.
Invitation. Validity of 14 days; unused invitations are deleted 30 days after expiration. The calls used are retained as long as the linked accounts exist.
Interactions and catalog of the days. Storage for 12 months from registration, with cancellation by night procedure, or in advance in case of revocation of consent or cancellation of the account.
Telegram messages. Up to the selection of "Spento" or the deletion of the account. [PROPOSE: delete the text after sending.]
Browser notifications. Until such time as the delivery address is deactivated or expired.
Sensitivity log. For the duration of the account and thereafter [PROPOSE: 5 years after cancellation or withdrawal], for the defence of rights pursuant to Article 17, paragraph 3, letter and GDPR. After deletion, the registrations are not related to other data. The deadline must be confirmed in the context of legal review.
Requests and assistance. [PROPOSED: 24 months after last reply.]
Texts and vowels transmitted to the models. They are not stored by the Owner. According to Cloudflare for Workers AI, the content is stored only in case of joint use of storage services.
Security copies. The database recovery system may make recoverable deleted records for a limited period, up to 30 days [TO BE verified: 30 or 7 days, according to the Cloudflare plan in use]. At the end, deleted records are not recoverable.
Data on your device and browser. Up to the deletion by the User, to the disconnect from the account or to the deletion of all the data of the Application.

Security measures

The service uses the following technical and organisational measures:

Authentication without password. For passkeys only the public key is stored on the server. Session tokens and recovery codes are stored as fingerprints, not clear. Session cookie is not accessible to the page scripts and is transmitted only on secure connections.
Local archive encrypted separately by account. The key is derived from random material released by the server only after authentication in the account. When disconnected, the key is removed from the device. Another account in the same browser does not have access to the diary.
Encrypted synchronization on the device. The server does not have the passkey data code or secret. Encryption is performed in the browser using the Application code provided by the Owner.
Validate structured data. For interactions and catalogs, the server only accepts default types and categories and refuses free text. Only the length class is recorded for the content entered.
Aliase of persons mentioned. The catalog does not transmit names, but codes calculated using a secret stored on the User's device.
Control against automation and limits of use, to prevent abuse.
Reserved administrative access, through authorized Telegram account and authorisation of 12 hours. [TO BE COMPLETED: log of accesses to the dashboard and who else can have it.]

The security measures reduce the risks without eliminating them in full. The precautions requested by the User are indicated in the section "Precautions in use" .

The technologies used, their purpose and need are as follows:

Session cookie "mindset" It maintains web authentication, is necessary for the service and has a maximum duration of 180 days.
Temporary cookies “mindset_oidc_telegram”, “mindset_oidc_google” and “mindset_oidc_microsoft”. They are created when you start accessing with its provider and connect the return to the browser that started it. They contain a random value, are not accessible to the scripts of the page, are transmitted only on secure connections and expire after 10 minutes.
IndexedDB "mindset" Keep the encrypted archive and account keys; it is necessary for the Application to work.
localStorage for necessary functionality. It retains the status of access, the version of the documents accepted, the phase of reception and preparation, the preferences of the breath, the state and the proposal of synchronization and the last setting of the Telegram messages. In the Mini App the session token is stored in sessionStorage.
sessionStorage \"mindset.analysis.session \" It retains the random record of the session of the exercise only after the consent is given and is removed at revocation.
localStorage ...mindset.analysis... It retains the random installation identifier and the event queue, only after the consent of the app. It is not necessary for the basic features. The deletion of all application data determines the generation of a new identifier.
localStorage for consensus status. It retains the choices of the device and the indication of the days already transmitted to the catalog.
Turnstyle. Cloudflare loads a script from its domain into the web access screen. [TO BE CHECKED: Data stored by Turnstyle in the user's browser.]
Linguistic preference cookies "mindset_lingua" It is set when the User chooses a language and keeps the choice between site, Application and guide for up to 365 days. It contains only the language code; the choice is also stored in the localStorage of the browser.
Site mindset.xin. Keep your language and appearance preferences in the browser. The linguistic preference is shared with the Application and guide through the cookie described above.

The deletion of the browser data results in the loss of content stored exclusively locally. Before proceeding it is advisable to export.

Rights of data subjects and operating arrangements

The faculties described in this section are recognized to all Users, even in the laws that provide for more limited protections.

Access and copy. In Settings, your data is available for the export of local content. In your account is available the export of account data, including interactions, catalog, passkey, sessions, encrypted copy, key wrappings and receipt of consents. You can request the list of recipients to whom the data has been communicated. The answer is free.
Correction. The User can modify tests, traps and letters, update maps and people, or delete journal entries and repeat exercises with new answers. Model analyses can be challenged through
Cancellation. You can delete individual tests, traps, letters, diary entries and dream nights, or the entire dream, all application data or account. The deletion of the account deletes interactions, catalogs, copies, Telegram messages and user logs from the database; the consent log is kept separately according to the above terms.
Revocation of consent. It's available in Settings, your account is, your consents are available.
Limitation of treatment. In the event of a dispute about the accuracy of the data or opposition, the data subject may request the suspension of the processing during the verification, writing to [TO BE COMPLETED: contact].
Portability. The export is available in JSON format, readable by programs. For data related to and provided by the data subject, or recorded in the context of use, it is possible to request the reception or transmission to another holder.
Opposition. The modalities are indicated in the next section.
Delegate. The person concerned may appoint a representative and communicate his/her identity to [To BE COMPLETED: contact].
Submission of requests. Requests can be sent to [TO BE COMPLETED: Contact], indicating the account code available in Settings, .Your account will be returned to the Owner without delay and in any case within [PROPOSED: 30 days]. In the event of a refusal, please inform us of the reasons and how to request the review and contact the competent authority.
Cancellation to the persons in charge. The Data Controller requires its managers to delete the data processed on his behalf, without prejudice to the security copies and the terms described above.

Right of objection

The data subject may object at any time to processing based on legitimate interest: Turnstyle controls, limits of use and protection of the service, preservation of the evidence of consents for the defence of rights and management of communications. The request may be sent to [TO BE COMPLETED: contact]. The Data Controller shall communicate the existence of any prevailing reasons to continue the processing or arrange the termination.

For consent-based processing it is sufficient to revoke the relative choice in Settings, Your Account, Your Consents.

Complaints and supervisory authorities

The data subject may lodge a complaint with the Data Controller through [TO BE COMPLETED: contact or electronic form]. Reception is confirmed within 30 days. Remedies remain available from the competent authorities:

Italy. Personal Data Protection Supervisor: PEC protocollo@pec.gpdp.it; registered in Piazza Venezia 11, 00187 Rome. The complaint to the Guarantor and the recourse to the judicial authority are alternative.
Other countries of the European Union Authority of the place of habitual residence, employment or alleged infringement; the list is available on the website of the European Data Protection Board.
United Kingdom. Information Commission (ICO), ico.org.uk.
Switzerland. Federal Data Protection and Transparency Officer, edoeb.admin.ch.
United States. Prosecutor General of the competent State, including atg.wa.gov for Washington, and Federal Trade Commission, ftc.gov.
Brazil. ANPD, gov.br/anpd.
Canada and Quebec. Commissioner for privacy, priv.gc.ca; Commission d'accès à l'information del Québec, cai.gouv.qc.ca.
Australia. OAIC, oaic.gov.au.
Japan. Committee for the Protection of Personal Information, ppc.go.jp.
South Korea. PIPC, pipc.go.kr.
India. Data Protection Board.
China. [To be verified: competent authority].

Data relating to third parties entered by Users

Words processed by dream or strong words may contain references to persons other than the User. This section describes the processing of data of such data subjects.

The name and contents referred to the person mentioned are transmitted to the model for the analysis and are not retained by the Owner. If the User has also given consent to the use of the app, the catalog retains a derived code by means of a secret present only on the device, together with a role, such as family or work, and a positive, neutral or negative tone. The name is not included in the catalog.

The Data Controller is not able to identify the person from the code, nor to identify or update his/her registrations without further elements, in accordance with article 11, paragraph 2 of the GDPR. The person who believes he/she is quoted may contact [TO BE COMPLETED: contact] for information on the possibilities of access and opposition.

Users are invited to limit references to third parties to what is necessary to exercise and not to include data relating to their health.

Age and age requirements

The service is reserved for persons of at least 18 years. The requirement is stated in the first contractual box; the date of birth is not required. If it appears that the account belongs to a minor person, [PROPOSE: Closing of account and deletion of data, without prejudice to the consent register].

Minors are not allowed to use the Application. In case of need of help they can contact emergency services or the listening lines of their country.

Violations of personal data

In the event of a breach likely to pose a high risk to the data subject, the Data Controller shall notify the incident without delay through the Application or the access channel, indicating the nature of the incident, the precautions available and the reference address. [PROPOSE: notify the competent authority within 72 hours of the knowledge of the violation, where required by law.] [TO BE COMPLETED: accident management procedure.]

Precautions for use

Data recovery code and code must be stored securely. Their loss, in the absence of passkey, can prevent the recovery of your account or access to encrypted copy.
You should protect your Telegram device and account: Access to your device may also allow access to your account.
The dream features, strong words and suggestions transmit to the model the texts provided, including any names. To avoid the transmission you must not insert such contents or disable the relative functionality by revocation of consent.
Information on third parties should be limited to what is necessary; it is appropriate not to include data on their health.
The Application does not necessarily detect every situation of difficulty and does not require human monitoring. In case of immediate need you must contact the emergency number or use the contact details of the SOS section.
The contents inserted by the User are not subject to verification of truthfulness.

Information Updates

Only editorial corrections can be made without new collection of consents. The substantive changes, including new purposes, categories of data, recipients or countries of processing, replacement of the Owner or variation of the modalities of exercise of rights, are communicated in the Application with reasonable notice and indication of the changes, before their effectiveness.

New purposes based on consent require fresh consent; without it, the relevant processing is not enabled for the User. Continued use does not constitute consent. Earlier versions remain available [TO BE COMPLETED: address of the version archive]. Each version has a code, such as alpha-2026-10-09.2, recorded in the consent register.

Territorial provisions

The following provisions supplement the Information according to the applicable law. The other sections remain valid for all Users. In case of more stringent local protections, they are applied. [To BE COMPLETED: list of countries admitted to the test by invitation, to be defined in the context of legal review.]

Switzerland

Field. The following provisions apply in cases subject to the Swiss Data Protection Act. [TO BE CHECKED with the legal person: when applicable to a Swiss-based owner and users abroad].
Target states. United States for Cloudflare, Inc., adherent to the Swiss framework: USA; for Telegram [TO BE COMPLETED: State].
Consent expressed. The processing of health data and analyses assessing personality aspects require express and distinct consent for purposes.
Automated decisions. No decisions with legal effects or significant consequences are taken. In the case of introduction, the person concerned will receive information and may request a human review.
Access. Access is free of charge, normally within 30 days, including analyses of the person concerned and cannot be subject to prior waiver.
Representative in Switzerland. [TO BE COMPLETED: it only serves if the holder is established abroad and all legal conditions are fulfilled.]
Authority. Please refer to the Complaints section.

United Kingdom

Field. For those interested in the United Kingdom: [To BE COMPLETED: decision of the holder on the United Kingdom, and representative in the United Kingdom if needed].
Complaints to the Owner. They can be transmitted by [To BE COMPLETED: electronic form]. Reception is confirmed within 30 days and reply is provided without delay.
Authority. Information Commission, commonly referred to as ICO.
Transfers. The framework extended to the United Kingdom and, in the alternative, the clauses of the Cloudflare Agreement is recalled. [TO BE CHECKED].
Automated decisions. No significant decisions shall be made solely automated, nor decisions based on health data without explicit consent.

United States

Transparency. The data associated with the account is pseudonymized, not anonymous; the person who has the link information can bring them back to the account.
Encryption scope. The synchronization copy and the local archive are encrypted; the server retains encrypted content and protected key. The Owner does not apply encryption to Telegram messages, interactions or catalogs on the server. Texts intended for the model are available in clear form during processing.
Consensus. The health consent is distinct from the acceptance of the Terms and collected through specific texts. In the current interface the boxes are pre-selected, individually unselectable and can be revoked at any time.
Sales and advertising. The data are not sold or shared for advertising purposes. [TO BE CHECKED: on native applications, before its publication.]
Violations. In the event of unauthorised disclosure of health data, the data subject shall be informed without undue delay. [PROPOSE: Communication within a maximum of 60 days of discovery and notification to the Federal Trade Commission if requested].
Minors. The service is not intended for persons under the age of 18 years. In the case of an account referring to a minor, and in particular to a person under the age of 13 years, [PROPOSE: closure of the account and deletion of data].
California. [TO BE CHECKED: California's consumer privacy law thresholds are not reached. If it changes, we will add information to the collection and rights.] mindset: is not presented as a mental health service.
Washington, Nevada and Connecticut. The following section shall also apply.

U.S. Health Data

Consumer Health Data Privacy Policy for Washington, Nevada and Connecticut. [To be checked with the legal: in Washington this information must be a separate and visible link on the home page and in the app; here it contains only what the law requires. Link to this section is #dati-sanitaria-usa and should be added to the home page.]

Categories and purposes. They have been treated in the Compass and in the scales, emotions and difficulties described in the texts, classifications of the model, opening of the SOS and answers to the security question. The purposes are the provision of the required exercises, the identification of the recurrences, the SOS reminders and, subject to consent, the analysis and improvement of the service. The collection is limited to what is necessary for such purposes or authorized by the consent.
Sources. User, device and model, which derive default categories from the texts.
Categories communicated and recipients. Cloudflare, Inc. operates on behalf of the Owner according to an agreement binding its processing to the instructions; Telegram delivers the activated messages; the browser's notification provider receives only textless notifications. Health data are not shared with other subjects, except as necessary to the service requested or authorized by a separate sharing consent from that to the collection.
Third parties and related companies. Cloudflare, Inc., Telegram and the browser's notification provider. Related companies: [TO BE CHECKED: None]. The Application does not allow third parties to collect health data of the data subject over time and through different sites.
Sale and geolocation. No health data nor geographical fences around health facilities are sold.
Rights. The data subject may know the health data processed and the recipients, including third parties and related companies; withdraw the consent; request the deletion of the data, including the security copies. The reply is provided within 45 days; the security copies are deleted within a maximum of 6 months. The requests must be sent to [TO BE COMPLETED: contact]. In case of refusal the review is available from the Data Controller; if confirmed, the modalities of complaint to the Attorney General, including atg.wa.gov for Washington.
Consent. It does not result from the acceptance of the Terms or general disclosure and is not acquired through misleading interfaces. The texts displayed are shown in the section "Data relating to health and consent management."
Nevada and Connecticut. The same rights and guarantees are recognised. Consent must be yes, voluntary and separate for sharing.
Security. Access to health data shall be limited in accordance with the measures set out in section

Brazil

Information elements. Purposes, modalities, duration, identity and contact details of the Owner, recipients and purposes of sharing are indicated in the respective sections. Cloudflare operates on behalf of the Owner, while Telegram is independent owner. The rights of the article 18 are recognized, including the right to petition the ANPD.
Consent. For each purpose related to sensitive data, specific consent is required and evidenced through separate consents, including those dedicated to vowels and tone; no general authorisation is provided.
International transfers. Transfers to the United States and the place of inference are indicated, where available. [To BE COMPLETED: Specific and distinct consent for international transfer; Portuguese version of transfer information; encarregado (name and contact), before opening to people in Brazil.]
Authority. ANPD.

Canada and Quebec

Information elements and risks. Data collected, recipients, purposes and consequences are described: the model can produce incorrect results; texts may contain sensitive names and data and be processed by Cloudflare in the United States or elsewhere, according to its protection regime; analyses do not constitute diagnosis.
Treatment abroad. Data may be processed outside Canada and Quebec, the United States or the place of inference, and may be accessible to local authorities according to their respective laws.
Quebec. The profiling features, such as dreaming and analysis of account usage, are currently pre-selected and can be deactivated. [TO BE CHECKED with the legal person.] Consent is expressed and distinguished for purposes and other information. [TO BE COMPLETED: evaluation of private life factors and written agreement with Cloudflare before communicating outside Quebec; title and contact of the responsible person published on the site; version in French.]
Authority. Canada's Privacy Commissioner and Commission d'accès à l'information del Québec.

Australia

Information elements. The previous sections indicate identity and contact details of the Owner, purposes, consequences of non-contribution, usual recipients, methods of access, correction and complaint and countries of foreign recipients: United States for Cloudflare, Telegram Country and place of inference [TO BE COMPLETED: Countries].
Health data. The collection shall be subject to consent where it is not necessary for the required operation.
Transfers. The relationship with Cloudflare is governed by a data processing agreement.
Artificial intelligence. The calculation of the model is identified as such. Only automated decisions with significant effects on rights are not taken. [TO BE CHECKED: the new Australian rule on automated decisions since 10 December 2026].
Authority. OAIC.

China

Field. For those interested in China: [TO BE COMPLETED: decision on the perimeter; representative in mainland China if you accept people who are there].
Information elements. Identity and contact details of the Owner, purposes and modalities, categories of data, storage and rights are described in the previous sections.
Necessity and consequences of processing sensitive data. The data allow the selection of the exercises and, with prior consent, the identification of the recurrences and the improvement of the service. They can affect the proposals of the Application and the SOS reminders in case of classification of difficulties; they do not determine the rights of the User.
Separate consent. For health data and for each transfer abroad specific consent is required, separated from other processing and not cumulative. [To BE COMPLETED: text of consent to sending abroad with the name and contact of each recipient, purpose, mode, categories of data and how to exercise rights to him.]
Impact assessment. [To BE COMPLETED: evaluation made before treatment and stored for at least three years.]

Japan

Holder. Name, address and, for companies, name of representative: [To BE COMPLETED].
Purposes and procedures. Purposes, procedures for exercising rights and security measures are indicated in the respective sections. Address for complaints: [TO BE COMPLETED: where to submit them].
Sensitive data. The texts relating to diagnosis or treatment are transmitted to the model only by means of dream functionality or strong words authorized with prior and specific consent.
Transfers abroad. United States for Cloudflare and [TO BE COMPLETED: Country where model inference takes place]. Protection regime in the country and recipient's measures: [To BE COMPLETED: description of country protection system obtained in an appropriate and reasonable manner, and Cloudflare measures]. The maintenance of Cloudflare measures is checked annually [TO BE COMPLETED: frequency and responsible for control].
Authority. PPC.

South Korea

Consent. For sensitive data separate consent is required from other processing. For transfers abroad: [TO BE COMPLETED: separate consent with the five legal items: data transferred; country, date and manner; name and contact of the recipient; purpose and duration of preservation of the recipient; how to refuse and with what effects].
Responsible for privacy. [To BE COMPLETED: name and contact].
Prevalence in case of contrast. In the event of a discrepancy between information and contract, the provision most favourable to the person concerned shall prevail.
Artificial intelligence. The use of the generative model is stated and its results are identified as automatic elaborations.
Representative in Korea. [TO BE COMPLETED: it serves only above very high thresholds or at the request of the authority].
Authority. PIPC.

India

Information elements. Categories of data and purposes are described for each processing; methods of exercising rights and complaints to the Data Protection Board are indicated in the respective sections.
Consent. Free, specific, informed and limited consent is required to the data necessary for the purpose, which can be revoked with the same ease with which it is provided.
Language. [To BE COMPLETED: language or languages in which this Information is available, between English and the Eighth Table of the Indian Constitution].
Got it. Requests for the exercise of rights and complaints must be addressed to the contact indicated in the section on the Data Controller.
Minors. The service is reserved for adults.
Conservation. [To be verified: the Indian obligation to retain for at least one year certain data and data records of the processing, and how it fits with the cancellations described here.]

Privacy notice on the processing of personal data