ANGD demo access privacy notice
How access, navigation and conversations are handled in this restricted demo.
Controller and contact
The controller is Domenico Ciarcelluti, VAT IT 18441131002, Italian tax code (codice fiscale) CRCDNC96C21G482K, Via Arturo Calza 29, Sc. A, Int. 11, 00157 Rome (RM), Italy. For any request about personal data, including exercising your rights: ciarcellutidomenico@gmail.com.
Data processed
Email address, approval status, request and access times, the pseudonymous watermark tag, and non-reversible HMAC fingerprints of IP address and browser. We log screens, sections and actions viewed, with time and session; chat questions and answers, language and model. When chat is used, the message, recent conversation and fictional data visible in the open app go to the AI service. Do not enter real personal or health data. We do not keep the audio of voice messages, nor the name or content of files and images uploaded in the apps. A photo chosen in “Customize Dom” is turned into a drawing directly in the browser: the photo is not sent or stored; the drawing stays only in this browser until “Delete the photo” is chosen or you sign out. OTPs and session tokens are never logged in plaintext. With Google sign-in we receive a verified email and basic profile data to identify the visitor; we retain the email, not the Google profile.
Purpose and legal basis
To manage and protect access, prevent abuse, and check and improve the demo, including manual review of paths and conversations. Legal basis: the controller’s legitimate interest in the security and quality of the restricted demo under Article 6(1)(f) GDPR. We do not use these data for marketing, automated profiling or automated commercial decisions.
Service improvement
Service improvement. General lessons (errors, recurring questions, answers to be corrected) are drawn from conversations and paths in the demo to improve the service. Lessons are written without names, without conversation content and without health data, using invented examples. Legal basis: the controller's legitimate interest in improving the service, Art. 6(1)(f) GDPR. You may object at any time by writing to the controller. Conversations in the demo are not used to train models.
Retention
Paths in our log: 30 days. General and app conversations, feedback and change requests: 12 months. Through Digital Dom, in a restricted area that only he can access, the controller Dom reviews each visitor’s access dates and times, paths and conversations, linked to the visitor’s email address. OTP records: up to 24 hours. Sessions: up to 12 hours and deleted within 7 days after expiry or revocation. Remembered devices: up to 30 days from the last visit, then deleted within 7 days; they can be revoked earlier. Security audit: 90 days. Inactive pending requests: 30 days. Encrypted backup copies: copies of the server disk for up to 7 days in Turin, copies of the data for up to 30 days in Milan, then deleted automatically. List of requested deletions, holding only non-reversible HMAC fingerprints, used to repeat them if a backup is restored: 31 days. Allowlist data remains while access is needed or until revoked/deleted on request. At the providers: Anthropic keeps prompts and answers for up to 30 days (up to 2 years only for content flagged by its automated systems as violating its usage policy); Microsoft Azure does not store the text read in real-time speech synthesis; other providers apply their own technical and contractual retention periods.
Recipients and transfers
Oracle Cloud Infrastructure (OCI), with servers in Italy (eu-turin-1 region, Turin) and encrypted backup copies also in the eu-milan-1 region (Milan, Italy), to host the demo and send access codes by email (Email Delivery service); authorised administrators; Google for Google sign-in (openid, email, profile) and for the contact mailbox (Gmail); Anthropic to generate chat answers (Claude model via the paid API): the contracting party is Anthropic Ireland, Limited (Ireland) and processing also takes place in the United States through Anthropic, PBC, under the European Commission standard contractual clauses included in the provider’s data processing addendum; Anthropic does not use prompts and answers to train its models. Microsoft Azure AI Speech, with its resource in the European Union (Italy North region, Italy), to read answers aloud when voice is enabled; if that service is unavailable, reading aloud is paused. Groq, Inc. (United States) to transcribe voice messages when the microphone is used, with processing outside the EEA under the provider’s contractual safeguards. This page loads no third-party analytics or fonts; the browser contacts Google only after the sign-in button is chosen.
Project chat
Only for clients and external collaborators invited to a custom project. Messages from the client and from the controller form a single project history, stored on our server and visible to project members and to the controller. Client messages are answered by an automated assistant generated with the Anthropic service listed above; the controller receives automated replies when writing through “View as” in the person’s project. Those messages and the relevant history are sent to the AI service; controller messages outside that view do not trigger automated replies. Automated replies pass through filters before they are saved; in the history shown, email addresses, phone numbers, IBANs and tax codes are masked. Those who develop the application, including with Anthropic artificial intelligence tools through the paid API under the terms listed above, receive a client message only after the controller has approved it; for each approval we log the date, the author and a fingerprint of the approved text. Purpose and legal basis: developing the application or project the person takes part in, Art. 6(1)(b) GDPR (pre-contractual steps or contract). Retention: messages and the approval log for up to 12 months after the last message in the project, unless deleted earlier on request. Only write information useful for the project; do not enter health data or unnecessary data about other people.
Essential cookies
The CSRF cookie lasts up to 2 hours and protects forms. The session cookie lasts up to 12 hours. The signed remembered-device cookie lasts 30 days and renews on each visit so you can return without another code; signing out revokes it. The temporary OAuth cookie lasts up to 10 minutes. All are Secure, HttpOnly and necessary for the requested functions; none is used for advertising or tracking.
Your rights
You may request access, correction, erasure, restriction, or object by using the controller’s contact details. You may also lodge a complaint with the competent supervisory authority.