Terms of service and software licence

Contractual version: alpha-2026-10-12-proattivita, dated 12 October 2026.

These Terms of Service and Software Licence (“Terms”) govern access to mindset: and its use during the closed, invitation-only alpha test. This document is a draft requiring legal review before the service opens to the public. Fields marked [TO BE COMPLETED] must be completed before that opening.

This version replaces version alpha-2026-10-11-profili and the Terms of Service and EULA of version alpha-2026-10-08. The application’s licence conditions are incorporated into these Terms, in the section License.

The processing of personal data is described in thePrivacy Policy, which constitutes an information document distinct from these Terms and is not subject to contractual acceptance. Optional consents to the processing of data are collected separately.

Main provisions

• The Service is intended for the training of thoughts and habits in the context of personal well-being. It does not provide health, diagnostic or therapeutic services.
• Access is reserved for adults with invitations.
• Artificial intelligence capabilities are optional; their results may contain errors.
• The alpha phase shall contain the limitations specifically described in section
• You can export your data, delete your account and exercise your withdrawal in the following ways.
• The substantial changes and termination of the Service shall be communicated with the prior notice provided for in these Terms.
• The rights of the User, the applicable legal guarantees and the liability of the Manager shall be without prejudice to the limits set out in the section "Responsibilities" .

Manager identification and definitions

The service mindset: is provided by [To BE COMPLETED: name or business name of the holder, legal form, location, registration number or VAT number] ("Gestore" ()).

For the purposes of these Terms, "User" means the natural person who accesses mindset: through his or her account; "Application" means the web app, the Telegram Mini App and native applications, when made available; "Service" means all the functionality provided by the Application.

Notifications relating to the contract, complaints and requests for the exercise of rights must be addressed to [To BE COMPLETED: e-mail address, postal address]. Representative in the European Union and the United Kingdom, if requested: [To BE COMPLETED: name and address].

Subject matter and purpose of the Service

The Service includes guided exercises, a diary of tests, reminders, a map of the objectives and optional functions of analysis using artificial intelligence models. During the alpha phase, Users participate in the product test and may send observations to the founder or the subject who invited them.

The Service is intended for personal well-being purposes. It does not constitute a health service, does not make diagnosis, does not prescribe therapies and does not guarantee the prevention or treatment of pathologies. It does not replace medical or psychological assistance or emergency services.

The Manager does not guarantee the achievement of individual results. The studies referred to in the sheets "Why?" and their explanations are general informational and do not constitute personalized advice.

In case of immediate danger or intention to harm themselves, you must contact the emergency number of the country where you are in; in Italy and in other countries of the European Union is available the 112. The SOS section of the Application has verified assistance numbers for some countries and an international list of listening lines. The Service is not able to activate rescue interventions. The suggested country for SOS contacts derives from the connection and may be incorrect, even in the presence of a VPN. The User can manually select the Country; the language of the interface does not determine the territorial availability of a number.

If enabled by the User, some analyses search for relevant trouble indicators in the texts. A clear difficulty classification, or other signals identified according to the rules of the Application, can determine the display of an SOS reminder in the Today screen. Such reminder does not constitute a diagnosis and does not involve notifications to emergency services or third parties.

Features of artificial intelligence

The Service currently uses the Gemma model 4, provided through Cloudflare Workers AI, for the suggestion of exercises, the routing of the messages sent in the Application or to the Telegram bot, the rewording of the messages for you, the optional composition of the morning/evening calls and the analysis of the dream and the strong words. For voices enabled with dedicated consent, the Whisper large-v3-turbo model, provided through the same service, produces the transcription used by the selector. The User can enable and disable them. The guided exercises and other features follow rules prepared by the Manager.

The Application identifies the proposals and texts produced by the model by means of indications such as "Proposed by an automatic model" and "rewritten by an automatic model" .

The results of the model are automatic elaborations that may be incorrect, incomplete or not relevant. The User is invited to verify the adequacy. These results must not constitute the sole basis of relevant decisions in the field of health, financial or legal, for which it is appropriate to address a qualified professional.

There is no real-time human text reading service. When an artificial intelligence functionality is enabled, the texts are processed by the template. The relevant classifications are not used to modify the User's rights or to determine its access to the Service.

The categories of data transmitted to the model, recipients, processing sites and retention criteria are described in the Privacy Policy.

The messages to the bot determine a tool proposal or a link to a function of the Application; they do not activate a service of conversation, personal assistance or surveillance of the conditions of the User. The transcription of a voice may contain errors and in the Application can be corrected before continuing. The limit of the vowels is one minute and 2 MiB; text and voice share a limit of five attempts per day per account. In addition, a total daily roof is applied to automatic processing. Guided exercises and the SOS remain available when the limits are reached.

The acoustic measurements describe the characteristics of the signal received and do not determine the emotion of the User. With the specific consent of the user . With the specific consent of the voice "Il tono della voce" , an experimental classifier can formulate a hypothesis on the emotional expression of the voice. The classifier is trained on spoken German recited, is not validated in Italian or in daily use and can produce incorrect results; the scores do not represent calibrated probabilities of the real emotional state. Vocal hypotheses remain distinct from the clues derived from the content and the state optionally declared by the User. They do not modify the tool's proposal on their own or the security functions. No validated emotional comparison is available between tone and content or specific detectors of tremor, wheezing or hiccups. The Manager does not keep the audio file or transcription on its server; Telegram's original message storage remains regulated by the conditions of that provider. The purposes of analysis, separate consents and the effects of revocation are described in the Privacy Policy.

Access requirements

Access to the Service is only permitted to persons of at least 18 years in possession of an invitation. The User declares that the age requirement is fulfilled by means of the box 1 described in the next section. If it appears that the account is used by an underage person, the Manager shall close and delete the data.

The account is personal, limited to one account per person and cannot be transferred or made available to third parties. Each invitation allows only one registration, is intended for one person and expires after 14 days. The sale, exchange and assignment of the invitation is prohibited.

Conclusion of the contract and registration of acceptances

The contract between the Manager and the User ends with the creation of the account and the confirmation of the two boxes on the first screen. Both boxes are mandatory and are not pre-selected. The texts displayed in the Application are as follows:

Box 1. I have at least 18 years and I accept the Terms of Service and the license of use.

Box 2. «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 1 box expresses the acceptance of these Terms, including the licensing conditions. The 2 box expresses the specific and separate acceptance of the deviations described in the

Before confirmation, the User may consult, save and print the Terms. For each box, the displayed text, the chosen text, the date and time, the version of the Terms and the version of the Application are recorded. The receipt of the registrations can be exported from the Application in text format.

In case of cancellation of the account or withdrawal, proof of acceptances and of any withdrawal is kept associated with the account code only, without the other data of the User, for the period necessary for the determination, exercise or defence of a right in court [TO BE COMPLETED: duration]. The relative processing is governed by the Privacy Policy.

Optional consents for health data, called "The Dream" , "The Strong Words" , "The Tips" , "The Use of the App" , "The Voices" and "The Tone of Voice" , "The Custom Messages" are distinct from the contractual acceptance. They are not a requirement to access the Service, they are collected separately for each purpose and can be modified according to the Privacy Policy.

Alpha phase

The Service is offered in alpha version, as part of a test phase. By box 2, the User specifically and separately accepts, after receiving information, the following deviations from the characteristics normally expected by a digital service, pursuant to Article 135-undecies, subparagraph 4, of the Consumer Code and Article 8, paragraph 5, of Directive (EU) 2019/770:

• Variability of functionality. Functionality, content and interface are subject to frequent changes, including additions, replacements, displacements, suspensions and removals of features already used.
• Discontinuity of Service. Continuous availability, maximum duration of interruptions, which may last for hours or days, or minimum service times, are not guaranteed.
• Possible malfunctions. Screenshots, calculations, reminders and contents may present errors or incompatibility with certain browsers and devices.
• Possible loss of data on the server. Account data, synchronization copies, day catalog and recorded interactions can be lost, even in full.
• Automatic updates. The Application is automatically updated and previous versions may cease to work.

You can export your data at any time by using Settings, Your Data and Your Account. Regular export of the data you intend to store is recommended.

The separate acceptance only concerns the functional features, the continuity of the Service and the retention of data on the server. It does not constitute a derogation from the personal data protection obligations, does not limit the rights of the User and does not modify the liability regime provided for by these Terms.

The conclusion of the alpha phase and the changes that have a significant impact on the use of the Service are subject to the provisions of the sections "Modifications of Service and Terms " and "Duration, suspension and termination of the relationship " including the faculties of export and termination of the relationship free of charge.

License

Concession and scope. The Manager grants the User a personal, non-exclusive, non-transferable and revocable license exclusively in the cases provided for in these Terms, to use the Application on its devices for personal and non-commercial purposes, for the period of activity of the account. The license includes the web app, the Telegram Mini App and native applications for iOS, Android and HarmonyOS, when published. The Application is licensed; neither the ownership of the software nor the source code are transferred.

Distribution via store. If an application is downloaded from the App Store, Google Play, AppGallery or other store, the conditions of the respective distributor also apply. These conditions prevail over this license insofar as this is required for the use of the application. The contract remains concluded between the Manager and the User. [TO BE CHECKED: minimum mandatory conditions of Apple, Google and Huawei for the apps distributed in their stores, before publishing each app.]

Limitations of use. Without prejudice to the mandatory rights recognised by law, including those relating to software, the User is not authorized to:

• copy, modify, adapt or decompile the Application;
• extract exercises, texts or cards, manually or by automated means, to republish them, to perform similar services or to train models;
• resell, lease, sublicense or make the Application available to third parties;
• circumventing security measures, controls against automation or limits of use.

Intellectual property. Rights relating to mindset:'s exercises, texts, cards, design, code, denomination and logo belong to the Manager or their licensors. All rights not expressly granted by these Terms are reserved.

Third party components. Third-party components remain subject to their respective licenses, which prevail over this license as regards these components. Atkinson Hyperlegible Next and Figtree characters are distributed under the SIL Open Font License 1.1. [TO BE COMPLETED: page with the list of components and their licenses.]

Cease. The licence shall cease at the end of the contract, in accordance with the provisions of the sections "Duration, suspension and termination of the relationship" and "Recess" respectively.

User Content

The User retains the rights to content included in the Service, including diary, answers, evidence, traps, letters, information about people and map.

For the sole purpose of providing the functions enabled, the User grants to the Manager a free authorisation, not exclusive and limited to the duration of the use of the Service, to preserve, reproduce and transmit such content to the extent necessary to provide such functionality. In this context, the encrypted synchronization between devices and, where enabled, the analysis by model. No further rights are acquired on the content.

The authorisation shall cease with the deletion of the content or account. The security copies shall be deleted in accordance with the terms set out in the Privacy Policy. The processing of personal data shall remain subject to this Information and to the User's choices.

The inclusion of information relating to third parties, including in the section "Your persons" must be limited to what is necessary for the exercises. It is forbidden to use the Service to collect or publish information about third parties for surveillance or harassment purposes.

Prohibited obligations and uses

The Service is intended for personal use. It is prohibited:

• accessing someone else's accounts or allowing third parties access to their account;
• compromise or overload the Service, circumvent the limits of use, including the daily limits of suggestions, or circumvent controls against automation;
• sell, exchange or generate serial invitations;
• use the Service for illegal content or purposes.

The breach of these obligations may result in the suspension or closure of the account in accordance with the conditions laid down in the ...Duration, suspension and termination of the account.

Account management and security

Authentication takes place through passkey or through an external provider connected to the account, such as Telegram. The User's name or email address is not used to manage the account.

Upon creating the account, the recovery code is shown only once. The User is required to keep it securely, since it allows the recovery of access in case of loss of passkey or Telegram access. In Settings, your account is possible to generate a new code, with contextual impairment of the previous one. The activation of the synchronization also involves the release of a data code for accessing the archive from a new device.

The joint loss of access credentials and recovery code may prevent the recovery of the account. The loss of the data code can make the encrypted copy not accessible.

The sessions of the connected devices have a maximum duration of 180 days. The list of sessions can be consulted in your account, from which the User can revoke them.

The User is required to keep the codes confidential. In case of suspected unauthorized access, it is appropriate to generate a new recovery code, revoke the other sessions and contact the Manager.

The Manager shall take appropriate technical and organisational measures to meet the risk. The synchronization copy shall be encrypted on the device prior to transmission to the server. The measurements shall be described in the Privacy Policy.

Availability, technical requirements and assistance

The Manager works for the operation of the Service, stopping the limitations of the alpha phase and the absence of a guaranteed minimum level of availability. The interruptions may also depend on the hosting providers, artificial intelligence or Telegram services.

Use requires a recent browser or Telegram and an internet connection for account, sync, reminder, and artificial intelligence features. [To BE COMPLETED: list of browsers, systems and supported versions.]

The assistance is available in Italian and English through the address indicated in the section "Contacts" . [TO BE COMPLETED: response time.]

Fees

In the current phase, the Service is provided without any monetary consideration. Any costs of Internet connection remain the responsibility of the User. The introduction of fees is subject to prior communication and new confirmation by the User for the continuation of the relationship. The processing of the data provided is described in the Privacy Policy.

Changes to the Service and Terms

The Manager may modify functionality, content, interface, suppliers and these Terms exclusively for the following reasons:

• adaptation to legal provisions or measures of the authorities;
• safety requirements;
• modification or termination of a supplier's services;
• product development, particularly frequent during alpha phase;
• events outside the reasonable control of the Manager.

The changes are effective for the future and do not entail costs for the User. Continuing use does not constitute acceptance of new Terms. Each new contractual version is presented in the Application at first opening and requires confirmation of the two boxes. In case of non-acceptance, the User can export the data and withdraw also from the confirmation screen.

Changes that do not adversely affect the use of the Service and do not modify the processing of data may be introduced without further acceptance requirements, as provided for in the new contractual versions.

Changes that adversely affect the use of the Service, or modify the Terms to the disadvantage of the User, are communicated in the Application with reasonable notice and indication of the effective date. The User may withdraw at no cost within 30 days of communication or modification, if later, pursuant to article 135-vicies-semel of the Consumer Code. The right to terminate the relationship at any time, without cost and after export of the data remains unchanged.

The modification of the purposes of the processing of health data requires a new consent, if necessary. In the absence of such consent, the new purpose is not applied to the User.

Urgent changes, necessary for security reasons or imposed by law, can have immediate effect and are communicated as soon as possible.

Duration, suspension and termination of the report

Duration and termination at the User's initiative. The contract is for an indefinite period. The User may terminate the relationship at any time, without cost or without notice, by deleting the account in Settings, or by exercising the withdrawal. Before termination, you can export the data.

Suspension and closure of the account. The Manager may suspend or close an account only if there is a serious reason, according to non-arbitrary criteria, in the following cases:

• serious or repeated breach of these Terms, including prohibited uses;
• legal obligation or provision of an authority;
• serious risk to the security of the Service or of third parties;
• creation of the account with an invitation obtained in violation of the Terms;
• established use of the account by a minor.

If possible, the order is communicated in the Application with at least 7 days of notice and indication of the reason. The User may submit observations to the address indicated in

Cease alpha, Service or a feature. The Manager shall notify the termination of the Application with at least 30 days of notice. Except for circumstances outside his control, such as the termination or change without prior notice of the service of a supplier, an authority's order or a serious security problem; in such cases, the communication shall be made as soon as possible. Prior to termination, the export of the data is permitted.

Effects of termination. The termination of the relationship involves the termination of the license and the cancellation of the account and the data on the server according to the Privacy Policy. The provisions intended, by their nature, to survive the termination, including those relating to liability, applicable law and the forum, remain effective.

Withdrawal

End. The User has the right to withdraw within 14 days from the conclusion of the contract, without obligation to justify and without costs, pursuant to articles 52 and following of the Consumer Code. The term starts from the creation of the account and the confirmation of the two boxes.

Mode. You may withdraw from the contract in the Application through Settings, “Your account”, “Withdraw from the contract here” and “Confirm withdrawal”. A receipt showing the date, time and account code is immediately available and can be exported as text using “Save the receipt”. The receipt confirms the withdrawal. Alternatively, you may send an explicit statement of withdrawal to the address listed under “Contact”, including your account code. [TO BE COMPLETED: standard withdrawal form, if required by legal counsel.]

Effects. The withdrawal determines the termination of the contract, the cancellation of the account and the data on the server and the deletion of the archive on the device used. Before the confirmation it is possible to export the data; in the absence, the deleted data are not recoverable. It is not due any cost. Only the proofs of the acceptances and the withdrawal are kept, as indicated in the section on the conclusion of the contract.

Due to the 14 days period, the User retains the option to cancel the account and terminate the relationship, with the same operational effects.

Liability

The Service Manager shall provide the Service with the competence and diligence reasonably required for a service of the same nature.

The Manager shall be liable for damages arising from the violation of these Terms or from non-compliance with normal due diligence, within the limits of predictability at the time of the commencement of use of the Service, in accordance with article 1225 of the Civil Code. He shall not be liable for any unpredictable damage or damage arising from events outside his reasonable control, such as network or supplier failures.

No limitation or exclusion of liability applies to malicious or gross negligence, death or damage to the person, or to rights that the law does not allow to limit or exclude. These Terms do not provide for a maximum limit of compensation.

Legal guarantee of compliance

Users benefit from the legal guarantee of conformity of digital services pursuant to articles 135-octies et seq. of the Consumer Code and the corresponding provisions applicable in other countries. The Service must possess the characteristics described in these Terms and those normally expected by a service of the same nature, without prejudice to the deviations of the alpha phase specifically accepted by means of the box 2.

In the event of lack of compliance, legal remedies remain available, without any limitation arising from these Terms. Users resident outside Italy shall be protected from the mandatory rights provided for in the applicable law.

Complaints and dispute resolution

Complaints may be sent to the contact details indicated in the "Contacts" section. The reply time is [To BE COMPLETED: Time to reply to complaints, proposal 30 days].

The use of the judicial authority is not subject to a mandatory attempt to reconcile. The User may apply to an alternative dispute resolution body or to the competent authority for the protection of consumers in his country, including the Competition and Market Authority in Italy. For disputes relating to personal data, the User may lodge a complaint with the competent authority in accordance with the procedures indicated in the Privacy Policy.

Applicable law and forum

Consumer users. For Users who use the Service for personal purposes:

• the Terms are governed by the law of the country of habitual residence of the User, including the Italian law for Italian residents;
• the User may act before the judge of the place of residence, without prejudice to any further legal holes;
• the Manager may act against the User only before the judge of the place of residence of the User;
• no binding arbitration or exclusive forum is provided for the benefit of the Manager.

In any case, the mandatory provisions of the User's country remain applicable.

Non-consumer users. For use in the context of a professional activity: [TO BE DECIDED WITH THE LAW: law and forum. Proposal: law and forum of the place where the owner is established, not exclusive forum.]

Users resident in the United States. [TO BE DECIDED WITH THE LAW: clause with individual arbitration with a consolidated entity, waiver of collective actions, right to refuse it within 30 days and court of small claims. Not applicable to residents of the European Union, Switzerland, the United Kingdom and Brazil.]

Partial disability. The invalidity or ineffectiveness of a provision shall be without prejudice to the validity of the remaining provisions.

Language and interpretation

The Terms are written in Italian. For Users resident in Italy the Italian version prevails. In case of differences between translations, the most favourable meaning prevails to the User. The interpretative doubts, in any language, are resolved according to the interpretation more favorable to the consumer.

Contacts

[To BE COMPLETED: name of owner, postal address, e-mail address, any representatives.]

How to exercise your personal data rights, including access, rectification and deletion, are indicated in thePrivacy Policy.