PRIVACY POLICY (Selv-a)

Effective date: 2026-03-19 Last updated: 2026-04-04

Chapter 1: Purpose, scope, and who we are

1.1 Purpose

This Privacy Policy explains how Luminibus S.r.l.s. socio unico (“Selv-a”, “we”, “us”) collects, uses, discloses, and protects Personal Data when you access or use our self-awareness and AI-powered wellbeing and self-discovery services (the “Service”).

1.2 Scope

This Policy applies to processing of Personal Data in connection with:

the Selv-a mobile application and any associated websites or landing pages
AI-powered features, personalization features, and safety systems
customer support communications
marketing communications
sharing features (including link sharing and group comparisons)
analytics, security, fraud prevention, and core service quality activities.

1.3 Definitions

Personal Data: information relating to an identified or identifiable natural person.

User Content: content you submit to the Service, including prompts, journal entries, answers, mood check-ins, and any files you upload.

Outputs: content returned by the Service, including AI-generated responses, summaries, insights, and suggestions.

Controller: the entity that determines the purposes and means of processing Personal Data.

Processor: a third party that processes Personal Data on behalf of the Controller.

AI Providers: OpenAI and Anthropic, the third-party AI model or API providers currently used to generate Outputs or support safety features.

1.4 Roles and responsibilities

Selv-a is the Controller for the processing described in this Policy, unless we explicitly state otherwise.

We select Processors and AI Providers, define processing instructions, and implement safeguards proportionate to the risks of the processing.

Certain third parties you interact with directly outside Selv-a act as separate controllers for their services under their own privacy policies.

1.5 Contact

Company legal name: Luminibus S.r.l.s. socio unico

Registered office: Via Papa Giovanni XXIII, 8, 27052 Godiasco Salice Terme (PV), Italia

Codice fiscale / P. IVA: 03034600183

PEC: luminibus@legalmail.it

Support email: support@selv-a.com

Privacy email (rights requests): privacy@selv-a.com

DPO: We will appoint and publish a Data Protection Officer contact if required by law or if we choose to do so. If appointed, DPO contact details will appear here.

Chapter 2: Key points summary

This summary does not replace the full Policy.

We process your inputs to provide the Service and generate Outputs.

We use vendors for hosting, analytics, security, communications, and AI processing.

Under our current commercial setup with OpenAI and Anthropic, inputs and outputs sent to AI Providers are not used to improve provider models unless we explicitly enable separate feedback or sharing controls. Selv-a does not currently use User Content for non-essential internal AI or service-improvement activities. We explain this in Chapter 6.

You can access, export, and delete your data, control marketing preferences, and submit restriction requests and residual objections to privacy@selv-a.com.

Personal Data may be processed outside the EEA/UK depending on vendor location, with safeguards where required.

Chapter 3: What data we collect

3.1 Data you provide

A. Account and profile data

email address and login identifiers (including sign-in tokens from Apple or Google)
account settings and preferences
age and age-gate responses.

B. User Content

messages, prompts, and conversation inputs
journal entries and reflections
answers to questions (multiple choice, scales, open text)
mood check-ins and self-reporting fields
content you choose to share (link content and group comparison content).

C. Support and communications

messages you send to support
survey responses, feedback, bug reports, and related metadata.

3.2 Data collected automatically

A. Device and technical data

device type or model, operating system version, app version, language, time zone
crash logs, diagnostics, and performance data. We use Sentry (Functional Software, Inc.) for crash reporting and performance monitoring. Sentry receives crash logs, stack traces, device information, and user identifiers to help us diagnose and fix issues.

B. Usage and event analytics

feature usage, screens viewed, clicks, session metadata
performance metrics and error telemetry.

On our dedicated /download landing page, we use Vercel Analytics (provided by Vercel Inc.) to collect cookieless page-view counts, navigation performance (Core Web Vitals), approximate location derived from IP address, and device and browser information. Vercel Analytics does not use cookies and does not track individual users across sites. IP addresses are anonymised by Vercel before storage. See vercel.com/docs/analytics/privacy-policy.

On the dedicated /download landing page, we do not set cookies or local storage identifiers for analytics. If anonymous measurement is enabled for that page, we limit it to cookie-free page views and first-party app-store badge clicks, and we suppress that measurement when the page-level opt-out is present or when the browser sends a supported privacy signal such as Do Not Track or Global Privacy Control.

In the Selv-a mobile application, Google Analytics for Firebase (provided by Google LLC) is disabled by default and is activated only if you opt in through the app's separate mobile analytics control. Where active, Firebase Analytics collects app usage events, screen views, session metadata, device information, and may receive a pseudonymous user identifier and user properties (such as subscription tier) to help us understand feature usage patterns. Firebase Analytics does not receive your name, email address, or the content of your reflections. At launch, this measurement does not use the Apple IDFA or Android advertising ID (AAID). See policies.google.com/privacy.

C. Network data

IP address, approximate region derived from IP, timestamps, and log files.

D. Advertising identifiers and App Tracking Transparency

At launch, Selv-a does not access the Apple IDFA or Android advertising ID (AAID), and the app does not currently prompt for App Tracking Transparency. The separate mobile analytics control described above governs Firebase Analytics collection without enabling advertising-identifier access.

If we later introduce a feature that requires access to IDFA or AAID, we will request any required device permission first, update this Policy before activation, and describe that feature and its legal basis separately.

3.3 Data from third parties

Apple or Google authentication claims (for example stable account identifier and email relay where provided).

B. App stores and payment platforms

subscription status, purchase confirmations, renewal status, refunds, chargeback or fraud flags. We generally do not receive your full payment card number when you pay through Apple or Google.

C. Analytics or attribution providers

campaign source information and aggregated measurement data, where used.

3.4 Notes on Face ID and biometrics

If you use Face ID (or a similar device feature), the biometric authentication is performed on your device by the operating system provider. Selv-a does not receive your Face ID biometric template. We receive only an authentication result (for example a success token) through the relevant device authentication flow.

Chapter 4: How we use your data

We use Personal Data for the following purposes:

4.1 Provide the Service

create and manage accounts
store your preferences and history
generate Outputs and provide self-discovery features
enable sharing features that you initiate.

4.2 Security and integrity

prevent abuse, fraud, and unauthorized access
enforce Terms and content restrictions
monitor, investigate, and protect system security.

4.3 Safety features

run automated safety checks on User Content and Outputs
detect signals that may indicate self-harm risk and provide safety resources (see Chapter 9).

4.4 Service quality, troubleshooting, and safety assurance

product development, troubleshooting, and quality assurance using aggregated usage, diagnostics, and operational records
maintaining core routing and service reliability
maintaining and testing safety systems.

4.5 Communications

send transactional messages (service notices and security alerts)
respond to support requests.

4.6 Marketing and promotions

send newsletters and promotional messages where permitted
tailor marketing content and communications
measure campaign effectiveness.

4.7 Legal and corporate

comply with legal obligations and defend legal claims
respond to lawful requests
support financing, acquisition, merger, or reorganization activities consistent with Chapter 7.

4.8 Your responsibilities

You are responsible for the content you submit and for ensuring it does not violate laws or third-party rights.

Where the GDPR applies, we rely on the following legal bases:

5.1 Contract (Art. 6(1)(b))

Processing necessary to provide the Service and core functionality, including account management and generating Outputs.

5.2 Legitimate interests (Art. 6(1)(f))

Processing for security, fraud prevention, core quality assurance, and service reliability using aggregated operational records, subject to balancing tests. Residual objections to legitimate-interest processing can be submitted to privacy@selv-a.com.

Processing where we present you with a consent choice, such as:

certain marketing communications where consent is required
certain optional personalization or measurement settings
optional mobile app analytics through Firebase Analytics, which remains off until you opt in through the app
any future access to your device's advertising identifier (IDFA/AAID), if we introduce a feature that requires it and ask separately through App Tracking Transparency or equivalent mechanisms
processing of special category data as described below.

5.4 Legal obligation (Art. 6(1)(c))

Processing necessary to comply with legal obligations (for example accounting, tax, and responding to lawful requests).

Some User Content may include special category data (for example, information that reveals health-related or mental wellbeing information). We collect explicit consent (Art. 9(2)(a)) for each of the following specific processing purposes through separate, clearly identified consent actions:

(a) Personality profiling — processing your responses to personality assessments to generate personality trait scores and insights, including storing your trait scores, comparing them across time, and using them to personalize AI-generated reflections.

(b) Mood tracking — processing your mood check-ins, self-reported emotional states, and related notes to track patterns over time, generate mood summaries, and provide wellbeing-related insights.

(c) AI-powered wellbeing insights — processing your reflections, journal entries, and other User Content through AI Providers (OpenAI and Anthropic) to generate personalized insights, reframes, guided reflections, and self-discovery content, as described in Chapter 6.

You may grant or withhold consent for each category independently. Withholding consent for a specific category will disable features that require that processing but will not affect other Service features.

You may withdraw consent for any category at any time. Withdrawal does not affect the lawfulness of processing performed before withdrawal and may limit certain features that require that data.

If you do not want us to process special category data, do not submit it through the Service.

Chapter 6: AI processing, training, and human review

6.1 AI transparency

Selv-a includes AI-powered features. We inform users when they are interacting with AI systems and when content is generated by AI, where required or appropriate.

6.2 Data sent to AI Providers

To generate Outputs and operate safety checks, we may send to AI Providers:

the minimum necessary parts of your User Content and relevant context
structured metadata needed for routing and safety (for example language, feature type, tier routing)
safety classifier signals where applicable.

Important: User Content may include Personal Data if you enter it. Do not include sensitive information you do not want processed.

6.3 De-identification and minimization approach

Where feasible, we reduce direct identifiers in data sent to AI Providers (for example removing an email address or account ID from payload fields). However:

free-text content may still contain Personal Data if you include it; and

“de-identified” does not necessarily mean “anonymous” under applicable laws, especially for rich text.

We treat such data as potentially personal and apply safeguards accordingly.

6.4 Internal AI and service improvement (Selv-a)

Selv-a does not currently use User Content or interaction data for non-essential internal AI or service-improvement activities such as prompt tuning, model evaluation, provider benchmarking, or optional QA sampling.

We may still process User Content where necessary to provide the requested feature, maintain safety and security, investigate abuse or incidents, troubleshoot technical problems, or comply with law. If we later introduce non-essential internal improvement processing, we will update this Policy and provide any required notice or choice before that change takes effect.

6.5 AI Provider training and retention (third-party)

Selv-a currently uses OpenAI and Anthropic as AI Providers under commercial terms and data-processing clauses. Under the current commercial setup, inputs and outputs sent to those AI Providers are not used to improve provider models unless Selv-a explicitly enables a separate feedback or sharing setting.

If we enable provider-side sharing, add a provider with materially different model-improvement terms, or otherwise change this posture, we will update this Policy and any required notices before or when the change takes effect.

Even when provider-side model improvement is disabled, AI Providers may still retain certain API data for abuse monitoring, application state, or legal compliance according to the provider's platform settings and endpoint behavior. We use configurations intended to minimize unnecessary retention, but retention characteristics may vary by endpoint and provider. Selv-a does not currently claim OpenAI Zero Data Retention or Modified Abuse Monitoring.

We do not promise that third parties cannot attempt re-identification unless and until we have strong, specific contractual and technical guarantees supporting that claim.

6.6 Human review

We may review User Content and Outputs:

for safety escalations
to investigate abuse, misuse, security incidents, or technical faults
when required by law or to protect users, the Service, or our rights.

Human review is limited to trained personnel and vendors bound by confidentiality, with logged access and least-privilege controls.

We may share Personal Data with:

7.1 Processors and vendors

hosting, databases, logging, and content delivery networks (including Supabase Inc. for database hosting and authentication; Render Services, Inc. for backend API hosting; Vercel Inc. for website hosting and CDN; Cloudflare Inc. for DNS, CDN, and SSL/TLS; and Upstash, Inc. for serverless Redis caching and rate limiting, with data stored in the EU — Ireland)
analytics, advertising measurement, and crash reporting providers (including Google Analytics and Google Tag Manager by Google LLC for website analytics and tag management — see policies.google.com/privacy; Meta Pixel by Meta Platforms, Inc. for advertising measurement and conversion tracking — see facebook.com/privacy/policy; Sentry by Functional Software, Inc. for error tracking, crash reports, and performance monitoring — see sentry.io/privacy; Vercel Analytics by Vercel Inc. for cookieless /download landing-page performance and visitor measurement — see vercel.com/docs/analytics/privacy-policy; Vercel Speed Insights by Vercel Inc. for Core Web Vitals and navigation performance measurement across the website — see vercel.com/docs/speed-insights; and Microsoft Clarity by Microsoft Corporation for website session replay and heatmap analytics where activated — see privacy.microsoft.com/privacystatement; and Google Analytics for Firebase by Google LLC for opt-in mobile app usage analytics and event measurement — see policies.google.com/privacy)
email delivery and communications systems (including Postmark by ActiveCampaign LLC for transactional and marketing email delivery)
push notification services (including Expo Push Service by 650 Industries Inc. for mobile push notification delivery)
internal safety and operations tooling (including Slack by Salesforce Inc. for internal safety alert routing, which may receive limited user identifiers in the context of safety escalations)
customer support tools.

7.2 AI Providers

OpenAI and Anthropic, to generate Outputs and perform safety processing as described in Chapter 6.

Apple and Google for authentication.

7.4 App stores and payment providers

Apple (App Store) and Google (Play Store) process in-app purchases and subscriptions as independent controllers under their own privacy policies. We share transaction identifiers and subscription status with them to confirm purchases, renewals, and related billing events.

7.5 Professional advisors

Lawyers, auditors, insurers, and consultants, where necessary.

7.6 Authorities and legal recipients

Where required by law, court order, or where necessary to protect rights, safety, and security.

7.7 Corporate transactions

Potential investors, acquirers, merger partners, and their advisors under confidentiality and with appropriate safeguards.

7.8 Vendor requirements

We require vendors to process Personal Data under written agreements and implement appropriate technical and organizational safeguards.

Chapter 8: International data transfers

Because we use global vendors and AI Providers, Personal Data may be processed outside the EEA or UK. Where required, we use appropriate safeguards (such as Standard Contractual Clauses) and, where necessary, supplementary measures. Transfer locations may vary depending on the vendor or AI Provider used.

9.1 Not an emergency service

Selv-a is not an emergency service and is not a suicide prevention hotline.

9.2 What we do if safety signals are detected

If our safety systems detect content that may indicate distress or concerning patterns, we may:

present support resources and guidance
encourage contacting emergency services
encourage contacting qualified professionals.

9.3 No guarantee of detection or intervention

We do not guarantee that we will detect any particular risk or that any intervention will occur.

9.4 Disclosures to third parties

We generally do not contact third-party hotlines or authorities as part of the Service. If we ever implement a feature that contacts third parties in limited scenarios, we will do so only where lawful, proportionate, and operationally reliable, and we will update this Policy before or when that feature is introduced.

Chapter 10: Data retention

We retain Personal Data only as long as necessary for providing the Service, maintaining security, complying with legal obligations, resolving disputes, and enforcing agreements.

10.1 Standard retention periods (unless law requires longer)

Account data: retained for the life of the account. After account deletion, the account enters a soft-deletion state and is deleted or anonymized within 30 days, unless longer retention is required for legal claims, fraud prevention, or compliance.

User Content and stored history: retained until you delete it or delete your account. After account deletion, the related data is deleted or anonymized within 30 days, subject to the limitations below.

Backups: may retain data for up to 90 days after deletion due to backup cycles.

Security logs and access logs: retained for 12 months (up to 24 months for high-risk security events).

Crash logs and diagnostics: retained for 6 months.

Support tickets and customer communications: retained for 24 months after closure.

Accounting and tax records (payments, invoices, subscription records): retained for 10 years where required by applicable law.

Marketing suppression lists (unsubscribe records): retained as necessary to honor your opt-out, typically 5 years, unless law requires otherwise.

10.2 Deletion limitations

If data has been incorporated into aggregated analytics, security records, or other operational records, complete removal may not be technically feasible.

Where deletion cannot be fully applied, we will apply reasonable measures to remove direct identifiers and restrict further use.

Chapter 11: Security

We use technical and organizational measures appropriate to risk, including:

access controls and least privilege
encryption in transit
encryption at rest where feasible
monitoring, logging, and incident response processes.

Limitations: Full end-to-end encryption is not compatible with typical AI processing workflows for all features, because content must be processed to generate Outputs.

Chapter 12: Your rights and choices

Depending on your jurisdiction, you may have rights to:

access, correct, or delete Personal Data
export your data (portability)
object to certain processing (including processing based on legitimate interests)
restrict processing in certain cases under Article 18 GDPR
withdraw consent where processing is based on consent
lodge a complaint with a data protection authority.

12.1 Controls

Export: you can export stored data where the feature is available.

Deletion: you can delete your profile and request account deletion.

Marketing preferences: unsubscribe links in newsletters and in-app controls where available.

Restriction requests (Art. 18 GDPR): submit them to privacy@selv-a.com. We assess requests case by case and apply temporary restriction where accuracy is contested, processing is alleged to be unlawful, data must be preserved for legal claims, or an Article 21 balancing test is pending.

Objections to legitimate-interest processing (Art. 21 GDPR): direct marketing objections are honored through unsubscribe controls. Any other objection to legitimate-interest processing can be submitted to privacy@selv-a.com and will be assessed case by case.

12.2 How to exercise rights

Submit requests to: Privacy Email: privacy@selv-a.com. We may request additional information to verify your identity and protect your account. Restriction requests and residual objections are handled through this manual privacy workflow; Selv-a does not currently provide a self-service in-app control for those rights.

Chapter 13: Children and age requirements

The Service is intended for users aged 17 and older. We do not knowingly allow users under 17 to create accounts.

Chapter 14: Changes to this Policy

We may update this Policy from time to time. If changes are material, we will provide notice (for example by email or in-app notice) before they take effect where required.

Chapter 15: Contact and complaints

Support: support@selv-a.com

Privacy: privacy@selv-a.com

If you are in the EEA or UK, you may lodge a complaint with your local data protection authority. In Italy, you may lodge a complaint with the Garante per la protezione dei dati personali.

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