Privacy notice

1. 1.1This notice applies to the website, the web application and the desktop and mobile applications of εpsγlo. They form one product with one account. Whichever of them you use, your personal data is processed in the same way and by the same persons.
2. 1.2In this notice, "we", "us" and "our" refer to the controller of your personal data, who is identified in the final section. "You" refers to the person whose personal data is processed.

Each part of the product processes a different kind of data. Where a feature processes data without retaining it, this is stated expressly.

1. 2.1Account. Your email address; a sign-in credential (a password hash, a magic-link token, or a Google or SSO identity, and never your Google password); and the times at which you signed in. These are required in order to hold an account. If you sign in through an organisation’s single sign-on (SSO), that organisation can see that you are a member of its workspace.
2. 2.2Translation requests and history. The sentences you translate, the settings with which you translate them, and the explained result. They are sent to the language models described below and stored in your account so that you can return to them. You may delete any entry; deleting the account deletes them all.
3. 2.3Vocabulary and Learn progress. The words and phrases you save, your review schedule, your placement results and your lesson progress. They are stored in your account so that they follow you across devices.
4. 2.4Critique. Text submitted for correction is processed by the model and returned to your device. We do not store Critique text on our servers.
5. 2.5Scan. The images and PDF pages you scan are processed in transit: sent to the model, read and discarded. We retain the extracted text only as part of a translation you chose to keep, and never the image.
6. 2.6Tutor (text). The transcript is stored on our servers by design, to provide continuity of the conversation and to protect the integrity of the Service. Deleting the account deletes it, subject to the retention rules below.
7. 2.7Tutor (live call). Audio is streamed through our relay to Google and back. We do not record or store the audio. We retain the duration of the call and usage metadata in order to meter the Service.
8. 2.8Billing. Paddle, our merchant of record, processes payments, calculates and remits tax, and holds payment-card data; we hold no card data. We retain purchase amounts, subscription status, billing identifiers and the details needed for invoices, including a business name or VAT number where supplied.
9. 2.9Device copy. A copy of your account state (settings, vocabulary, recent translations) is kept on your device, in the browser’s IndexedDB and localStorage, so that the application opens immediately and the vocabulary bank works offline. You may clear it at any time; the copy on our servers is the authoritative one.
10. 2.10Security and abuse prevention. Request logs containing the IP address, timestamps, the endpoint called and the result, retained for a limited period in order to rate-limit abuse, diagnose failures and attribute model usage. They are not used to profile you.
11. 2.11Usage statistics and service improvement. We record which feature you used, when, how much of your allowance it consumed and which model served it, and never the content, in order to meter your plan and to observe, in aggregate, which parts of the product are used. We may also review stored translation requests and their results internally in order to improve prompts, detect failures and check quality. Critique text, scanned images and call audio are never stored and are therefore never reviewed. We do not sell this data and do not use it to train third-party models. You may object at any time by writing to [email protected].
12. 2.12Promotions and referrals. When you redeem a promotional or referral code we record the code, the time of redemption, what it granted (a plan for a period, or a discount) and when that grant ends; for a referral, which account referred which. This is needed to apply the offer and to enforce its conditions, such as one use per account.
13. 2.13Withdrawal and refund requests. If you withdraw from a purchase or request a refund, we record your name, your email address, the purchase concerned, any message you add, and the date and time at which we received the request, so that we can acknowledge it, carry it out and prove that we did so.
14. 2.14Tester programme. If we invite you to test the product, we record the invitation, your acceptance of the tester conditions, the test account created for you and the feedback you choose to write.
15. 2.15Waitlist. If you join the waitlist before launch, we store your email address, a salted hash of your IP address and the record of your consent. An unconfirmed address is deleted after 30 days; a confirmed address is retained until launch or until you ask us to remove it.
16. 2.16We do not sell personal data, do not serve advertising, and do not use your text to train models of our own. Processing and retention by our providers depend on the applicable service terms and account configuration; contact [email protected] for the safeguards applicable to your data.

1. 3.1Performance of a contract (Article 6(1)(b) GDPR), for everything the Service consists of: the account, translations, vocabulary, Learn, Critique, Scan, the tutor and billing.
2. 3.2Consent (Article 6(1)(a) GDPR), for optional processing that asks for your permission, including any future non-essential storage. You may withdraw consent at any time without affecting the lawfulness of earlier processing. Authentication, including Google sign-in and SSO, is carried out in order to perform the contract.
3. 3.3Legitimate interest (Article 6(1)(f) GDPR), for security, rate limiting, the prevention of fraud and abuse, and keeping the Service in operation. Our interest is the one every online service has; your interests are protected by keeping these logs short-lived and using them for no other purpose. The same basis covers aggregated usage statistics, cookieless visit statistics, internal quality review of translation requests, and the keeping of withdrawal and refund requests as evidence. You may object at any time.
4. 3.4Legal obligation (Article 6(1)(c) GDPR), for the invoices and payment records that Italian tax law requires us to keep.

The following providers support the Service as processors under the applicable data processing agreements. Some of them also act as independent controllers for their own purposes: Paddle, our merchant of record, for payment compliance, tax and fraud prevention, and Google for your Google account. Their own privacy notices govern those activities.

Our providers may process personal data outside the European Union and the European Economic Area, including in the United States and in other countries used by upstream model providers such as OpenAI, Microsoft Azure, Friendli, DeepInfra, Crusoe, Parasail and CoreWeave. Where applicable, such transfers rely on an adequacy decision, including the EU–US Data Privacy Framework for certified recipients, or on the European Commission’s Standard Contractual Clauses, with supplementary safeguards where required. A copy of the relevant safeguards may be requested from [email protected].

We use encryption in transit, access controls that limit who can reach the database, and the retention limits described below, in order to reduce what could be exposed. If a personal-data breach is likely to result in a risk to your rights and freedoms, we notify the Garante within 72 hours of becoming aware of it (Article 33 GDPR), and we inform you directly where the risk to you is high (Article 34 GDPR).

1. 7.1Account data, translation history, vocabulary, Learn progress and tutor transcripts are retained for the lifetime of the account, unless you delete supported items sooner. You may request deletion by writing to [email protected] or by using the Delete account control in Settings → Privacy & data. Records that must be kept by law are retained separately, with restricted access.
2. 7.2Billing records, invoices and payment records needed to meet Italian fiscal obligations are retained for 10 years, including after the account has been deleted. Paddle also retains data under its own legal obligations and privacy notice.
3. 7.3Security logs are retained for up to 90 days, unless a specific incident requires longer.
4. 7.4Withdrawal and refund requests are retained for 10 years from the request, including after the account has been deleted, as evidence of what was requested and done.
5. 7.5Promotion and referral records are retained for the lifetime of the account, so that one-per-account conditions can be enforced.
6. 7.6Usage records (feature, time, allowance consumed and model, with no content) are retained for the lifetime of the account; aggregated statistics, which identify nobody, are retained indefinitely.
7. 7.7Critique text, scanned images and live-call audio are not retained at all. They are processed and discarded, as described above.
8. 7.8Waitlist signups: an unconfirmed address is deleted after 30 days; a confirmed address is retained until launch, or deleted on request.

1. 8.1Under Articles 15 to 22 GDPR you may request access to the personal data held about you, request its rectification or erasure, request that processing be restricted, object to processing based on our legitimate interest, and receive the data you provided in a portable format. Where processing rests on consent, you may withdraw it. A single email to [email protected] is sufficient. We reply within one month and may first ask you to prove that you are the account holder. If you belong to a Team organisation, deletion may be blocked until you leave it or transfer its ownership; the application tells you which applies.
2. 8.2If you consider that your personal data has been processed unlawfully, you may lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali (garanteprivacy.it), or with the supervisory authority of the EU member state in which you live or work. You may also seek a judicial remedy.
3. 8.3No decision producing legal or similarly significant effects on you is taken by automated means. The models produce translations and explanations; they decide nothing about you.

εpsγlo requires its users to be at least 18 years old. Please contact [email protected] if a younger person has opened an account.

When the product changes in a way that changes what is done with your personal data, this notice is revised and the date at the top of the page is updated. A change that introduces a new purpose or a new recipient of your data is announced at least 30 days before it takes effect, on the website and, for account holders, by email. A correction or clarification that does not change what is done with your data may take effect immediately.

The controller of your personal data is:

Name

Simone Piccagli

Address

Piazza della Pace 11, 40134 Bologna (BO), Italia

Email

[email protected]

Certified email (PEC)

[email protected]

VAT number (Partita IVA)

04407441205

Requests concerning your personal data, including the exercise of the rights described in this notice, may be sent to [email protected].