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We are committed to protecting your privacy.

This policy explains how Numena collects, uses, and protects your personal data, and the rights you have in relation to it.

## 1. Who we are

The data controller for Numena (the "Service") is [Legal entity / Carlo Frinolli], [full registered address]. You can reach us about privacy matters at [privacy@numena.app]. This policy explains how we handle personal data when you use Numena.

## 2. The short version

- We collect only the minimum we need to run the Service.
- We never use your email for marketing, and we never sell your data.
- AI providers process survey content to generate your results; we use providers that offer data-protection safeguards.
- You stay in control: you can access, export or delete your data at any time.

## 3. Data we collect

- **Account data:** your email address and any name you choose to provide.
- **Survey content:** the questions you create and the responses participants submit, which may include opinions and any personal data they choose to include.
- **Participant data:** if you invite participants, we process their responses on your behalf and may process their email solely to deliver the invitation.
- **Usage data:** basic technical data (device, browser, IP address, log data) used to operate and secure the Service.

We do not intentionally collect special-category data. Please do not include sensitive personal data in survey responses.

## 4. How and why we use data, and our legal bases

Under the GDPR we rely on the following legal bases:

- To provide the Service to you — performance of our contract.
- To generate Brand Compass outputs through AI, following your instructions — performance of our contract.
- To keep the Service secure and to improve it — our legitimate interests.
- To send operational messages — performance of our contract; and, only with your consent, to send optional brand updates — consent.
- To comply with legal obligations where they apply.

## 5. Email: our commitment

**We will never use email addresses collected through Numena for commercial or marketing communications of any kind, and we never sell your data.** We send only operational messages needed to run the Service and — only if you explicitly opt in — occasional updates about the brand, which you can unsubscribe from at any time.

## 6. AI processing and international transfers

To generate your results, we share survey content with AI subprocessors, including [Anthropic (Claude), OpenAI (GPT models), Perplexity], and we host the Service with [Vercel]. Some of these providers are located outside the European Economic Area (for example, in the United States). Where data is transferred outside the EEA, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses and/or the EU–US Data Privacy Framework.

These providers process data only on our instructions and are contractually bound to protect it. Our AI providers do not use data submitted through their APIs to train their models.

## 7. Sharing your data

We do not sell personal data. We share data only with: the subprocessors listed above; public authorities where we are legally required to; our professional advisers under confidentiality; and a successor entity in the event of a business transfer.

## 8. Retention

We keep personal data for as long as your account is active or as needed to provide the Service, after which we delete or anonymise it. You can request deletion of your data at any time.

## 9. Your rights

Under the GDPR you have the right to access, rectify, erase, restrict and port your data, to object to certain processing, and to withdraw consent at any time. To exercise these rights, email [privacy@numena.app]. You also have the right to lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali ([garanteprivacy.it](https://www.garanteprivacy.it)).

## 10. Survey participants

If you received a survey invitation: the organisation that invited you is the controller of that survey, and Numena processes responses on its behalf. To exercise your rights in relation to a specific survey, contact the inviting organisation. You may also contact us at [privacy@numena.app] and we will help route your request.

## 11. Cookies

We use only essential cookies that are strictly necessary to run the Service, such as keeping you signed in. We do not use cookies for advertising. [If you add analytics, disclose the tool here and obtain consent where required.]

## 12. Security

We apply reasonable technical and organisational measures to protect personal data. No method of transmission or storage is completely secure, but we work to safeguard your information and to limit access to it.

## 13. Children

Numena is not directed to children. You must be at least 16 years old to use the Service.

## 14. Changes to this policy

We may update this policy from time to time. When we do, we update the date above and, where appropriate, notify you of material changes.

## 15. Contact

[Legal entity / Carlo Frinolli], [full registered address] — [privacy@numena.pro].

Privacy Policy

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