Privacy Policy

1. Data controller

The data controller is:

ICS Industrial S.r.l.
Via Santa Sofia 27
20122 Milan, Italy
Email: support@italianicity.com

This Privacy Policy covers Italianicity and its consumer surfaces, including account, Chat, Chapters, Journal, Library, Memory, research, Discovery, export and deletion features and, where activated, Premium features.

2. Principles

Italianicity is designed around data minimization, purpose separation, server-side authorization, user control and restricted access to private data.

Personal data is not treated as a general-purpose marketing warehouse. Sponsors and partners do not receive access to individual conversations, uploaded documents, Memory, Journal, Library or personal profiles.

Italianicity does not sell personal data.

3. Data we may process

Depending on the features you use, we may process:

• account and authentication data, including account identifiers, settings and technical session data;
• conversation content, including user messages and generated responses;
• user-provided files and media, such as documents, images, audio and links explicitly selected by you;
• Memory and continuity data, when the feature is enabled;
• Chapters, Journal and Library data, including content and relationships saved or generated in those surfaces;
• technical and usage data, needed for reliability, security, performance, cost, quality and product measurement;
• plan and purchase data, when paid features are available, including entitlement state and normalized Store transaction status;
• support and security data, when you contact us or when needed to investigate a technical or security issue.

Italianicity does not require precise GPS location collection for ordinary V1 analytics and does not use background location as a standard feature.

4. Purposes and legal bases

We process data only for defined purposes.

Performance of a contract or pre-contractual steps

• creating and managing your account;
• providing Chat and other requested features;
• storing and synchronizing content you choose to keep;
• handling export, deletion and service-related support;
• operating Premium features and entitlements when available.

Legitimate interests

• protecting accounts, users and infrastructure;
• preventing abuse and fraudulent use;
• diagnosing errors and maintaining reliability, security and performance;
• measuring product quality and operation using minimized or pseudonymized data.

Where we rely on legitimate interests, we assess whether the processing is proportionate to users’ rights and reasonable expectations.

Legal obligations

• complying with tax, accounting, regulatory or lawful authority requirements;
• retaining data where required by law.

Consent Where an optional feature or processing requires consent under applicable law, we will ask before activating it. Consent may be withdrawn where applicable without affecting prior lawful processing.

5. Artificial intelligence and providers

Italianicity may use external providers for technical capabilities such as authentication, hosting, database/storage, AI inference, research/retrieval, notifications, observability, technical evaluation and App Store distribution.

Providers receive only the data needed for the requested capability and do not become the owners of Italianicity’s canonical product state merely because they provide a technical service.

Private production conversations are not automatically transferred to evaluation systems as a general dataset. Any materially different use requires specific privacy, minimization and retention review.

6. Telemetry and internal Console

Italianicity uses controlled technical and product events.

Ordinary telemetry should not contain by default:

• full private conversation text;
• full prompts or responses;
• Journal;
• Memory;
• Library content;
• uploaded documents;
• audio transcripts;
• images;
• passwords, tokens, cookies or credentials;
• email, name or phone as ordinary analytics attributes;
• IP addresses stored as persistent analytics identifiers.

The internal Console is a private administrative surface. It is not designed for ordinary browsing of users’ conversations, Memory, Journal or Library.

7. Sponsors, partners and advertising

Commercial relationships do not alter Italianicity Judgment.

Sponsors and advertisers do not receive access to individual conversations, uploaded documents, Memory, Journal, Library or personal profile data. Identity or personal data is not transferred to an advertiser before an explicit user action makes such transfer necessary and lawful.

Any future persistent commercial personalization requires a separate decision, an appropriate legal basis and explicit user controls.

8. Retention

We retain data only as long as necessary for the purposes for which it is processed, taking into account account duration, requested features, legal/accounting obligations, security, dispute handling and technical backup cycles.

For the currently approved V1 telemetry:

• high-granularity technical diagnostics: up to 30 days;
• pseudonymized product/funnel analytics: up to 12 months;
• pseudonymized cost attribution: up to 12 months;
• versioned quality/evaluation results: up to 12 months;
• commercial/billing telemetry: up to 24 months;
• privileged/security audit events: up to 24 months;
• corpus/provider operations: up to 90 days.

These periods apply to telemetry and do not automatically define retention for account data, user content, documents, tax records or backups.

Account content is retained to provide the service while the account or relevant content remains active, unless deleted by the user or limited further retention is required for lawful or legitimate purposes.

9. Export and deletion

Italianicity supports account-data export and account deletion.

Sensitive actions may require recent identity verification. Export may be prepared through an asynchronous job and delivered through a temporary download.

Deletion is a controlled process and is not presented as instantaneous where technical completion, backups or legal obligations must be handled.

Downgrading from a paid plan does not automatically delete existing user content.

10. Recipients

Where necessary, data may be processed by:

• authentication providers;
• hosting, database and storage providers;
• AI and research/retrieval providers;
• notification and mobile infrastructure providers;
• reliability, security, observability and evaluation services;
• Apple and Google for distribution, purchases and Store management;
• professional advisers and authorities where necessary or legally required.

Providers are selected and governed according to the capability they perform and must respect applicable minimization and security boundaries.

11. International transfers

Some providers may process data outside the European Economic Area. Where required, transfers are managed under applicable legal mechanisms, including adequacy decisions or appropriate safeguards such as Standard Contractual Clauses where relevant.

You may request information about applicable safeguards at support@italianicity.com.

12. Security

Italianicity uses technical and organizational measures appropriate to risk, including encryption in transit, data-at-rest protection according to the applicable architecture, server-side authorization, secret separation, access controls and audit of privileged actions.

No system can be guaranteed to be absolutely secure.

13. Your rights

Where provided by the GDPR, you may request:

• access;
• rectification;
• erasure;
• restriction of processing;
• objection;
• data portability;
• withdrawal of consent where processing is based on consent.

You may also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or another competent supervisory authority.

You can use controls available in the app or email support@italianicity.com. We may ask you to verify your identity to protect your account and data.

14. Automated decisions

Italianicity uses artificial intelligence systems to generate responses and user-requested features. V1 is not designed to make solely automated decisions about a user that produce legal or similarly significant effects under the GDPR.

15. Children

Italianicity is intended only for users aged 18 or older.

16. Changes to this Policy

We may update this Privacy Policy to reflect changes in the product, providers, law or our practices. Material changes will be communicated appropriately.

17. Contact

For privacy, personal-data or support requests:

support@italianicity.com

ICS Industrial S.r.l.
Via Santa Sofia 27
20122 Milan, Italy