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Privacy

Template to be completed. Replace every part in [square brackets], check that each sentence matches how your copy of the app really works, and have a lawyer review the text before opening it to clients. The Italian version is the reference text.

Last updated: [date] · Italiano

In short

• Almost everything stays on your device: diary, measurements, goals, plan, appointments, documents, questionnaire, conversation.
• Only these leave your phone: messages to Luce (to the AI provider, with your consent), the text read by the natural voice (if you choose it), YouTube videos (if you start them) and the sheet you send to Fabrizia yourself.
• We ask for your consent when it is needed, separately for each use, and you can withdraw it from the Menu, under Privacy and consents.

Who runs the app

The app is run by Dott.ssa Fabrizia Lellero, nutrition biologist, Italian VAT no. 07320641215, registered with the Italian National Order of Biologists under no. AA067533. [Professional address.] Contact: dott.lellero@gmail.com.

What it is

A healthy lifestyle and coaching path for adults, with an AI assistant called Luce. It is not therapy, it does not diagnose and it is not an emergency service.

What happens to what you write

• On your device. Exercise answers, diary, ticks, optional Home notes and photos, the pre-visit questionnaire, the conversation with Luce and settings are saved in this device’s browser. The same applies to the Patient area (goals, action plan, habits diary, documents), Monitoring (measurements and charts) and Video consultations (appointments, links, questions). You can delete everything at any time from the Menu, under Privacy and consents, with Delete everything.
• To write a reply. When you send a message to Luce, your latest messages pass through our server to the AI provider, [Anthropic], which writes the reply. We do not keep messages on our server. [Keep this sentence only while it is true.]
• Technical data. Like any website, the hosting provider, [Netlify], processes your IP address and technical request data to run the app and limit abuse. [Add retention periods.]

The consents we ask for

• Notice and terms, the first time: you confirm you are at least 18, that you understand Luce is an AI, and that you have read this notice.
• Health data on this device, the first time you open the Patient area, Monitoring or Video consultations. Without it, those areas stay closed.
• Messages to Luce, the first time you write to her: your latest messages are sent to the AI provider to write the reply.
• Natural voice and YouTube videos, only if you choose them.
• Sending your sheet to Fabrizia, every time: you choose what to include and confirm. You send the file yourself, with the app you prefer.

The app records the date and version of each consent on the device. You can withdraw it at any time from the Menu, under Privacy and consents; withdrawal does not make earlier processing unlawful.

How long data are kept

• Habits diary, measurements, intentions and wins diary: 24 months, then the app deletes them by itself.
• Conversation with Luce: the last 200 messages, only if you choose to remember it.
• Goals, action plan, appointments, documents, questionnaire, Home photos: until you delete them.
• Sheets sent to Fabrizia: she keeps them in the professional area, encrypted, for [10 years after the end of the path: period to be confirmed with the lawyer under professional rules], then deletes them.
• On our server: no messages. [The hosting provider keeps technical logs for: state.]

The professional area

The professional area is used only by Dott.ssa Fabrizia Lellero. Client files, notes, plans, instalments and history stay on her device, encrypted (AES-256) with a passphrase only she knows; the area locks itself after 10 minutes of inactivity. They do not pass through any server. Backups are files encrypted with the same passphrase. [The lawyer states the legal basis and record-keeping obligations here.]

Payments

[When active.] Payments take place on Stripe’s secure page (Stripe Payments Europe Ltd.). The app neither sees nor stores payment details. [State which data Fabrizia receives from Stripe and how long she keeps them for accounting purposes.]

Video consultations

The appointments and links you save stay on your device. The video call takes place on the service chosen by Fabrizia ([service name]), under its own privacy rules. Reminders are files for your phone’s calendar: the app sends no notifications from its servers.

Sign-in with an account

Today the app has no accounts and does not ask you to sign in with Google, Apple or email. [If this is introduced, state the provider, the data transferred, where they are processed and the safeguards.]

YouTube and Spotify

In Listening, videos come from YouTube (Google) and audio opens in Spotify. A video loads only after you choose «Play the video»: from then on YouTube receives your IP address and device data, may use cookies and may show ads. You can withdraw permission in the Menu, under Settings. [Add links to Google’s and Spotify’s privacy notices and transfer safeguards.]

The voice

If you ask Luce to read a reply aloud, your device’s voice reads it: nothing leaves your phone. [Only if the natural voice is active.] If you choose the natural voice, the text of Luce’s replies you listen to is sent to [ElevenLabs or Microsoft Azure, and where it processes data], which turns it into audio. Your own messages are not sent.

Security

The app works only over HTTPS, with security rules that prevent code being loaded from other sites. Data on the device are protected by your phone or computer lock: on a shared device, whoever uses it can see them. Protect your device with a code and do not save the conversation on shared devices.

Sensitive data

What you write may concern your health, your eating habits or your private life. You decide what to share. [The lawyer states the legal basis here, for example explicit consent, under the GDPR and, where applicable, the Swiss Federal Act on Data Protection.]

Your choices and rights

• Turn off «Remember it on this device» to not keep the conversation.
• Use Delete everything to remove what is saved on this device.
• With «Download a copy of my data» (Menu, Privacy and consents) you get a file with everything the app keeps about you: this is your right to data portability.
• You can ask which data we process, have them corrected or deleted, and complain to the supervisory authority. Write to [email].

Age

The app is for people aged 18 and over.