Extended GDPR Notice

Legal reference: Regulation (EU) 2016/679 (GDPR).

1. Data Controller

Fabrizio Fiammenghi, contact: grisu7002@gmail.com.

2. Data minimization principle

The app author does not automatically collect personal or usage data. Data is primarily handled on the user's device.

3. Categories of data processed in the app

Data voluntarily entered by users: notes, encounter records, tags, functional metadata, media attachments, and app settings.

4. Processing purposes

App usage, personal data organization, backup/restore, optional cloud sync, access security, and technical support when requested.

5. Legal basis

Performance of a service requested by the data subject (Art. 6(1)(b) GDPR). For log sharing: explicit user consent/voluntary action.

6. Processing methods

Local processing on device. If enabled, cloud features use the user's iCloud account under Apple's terms.

7. Disclosure and recipients

No data selling. No third-party data sharing for marketing. Logs are received only if users voluntarily share them for debugging.

8. Retention

Data remains until deleted by the user. Backup and cloud copies depend on user settings and Apple service policies.

9. Security

Available local measures include PIN/Face ID (if enabled), backup controls, and in-app security options. Users remain responsible for device/account security.

10. Data subject rights

Access, rectification, erasure, restriction, objection, portability, and complaint to the competent supervisory authority.

11. Extra-EU transfers and third-party providers

Any international transfer depends only on services linked to the user's own cloud account (iCloud/Apple). See Apple's privacy documentation for details.

12. Automated decision-making

No profiling or automated decision-making under Art. 22 GDPR is performed.