Privacy policy

Updated 12/11/2026. Translation of the Italian text; the Italian version prevails.

This policy explains how Melograna handles your personal data, in particular the health data you write in the diary. If anything is unclear, write to us.

1. Data controller

Controller: Danilo Carboni, address to be completed, VAT number to be completed. Privacy contact: assistenza@melograna.it. Data Protection Officer (DPO), if appointed: [DPO: da valutare con il consulente].

2. Data we process

• Account data: email and sign-in data.
• Health data (special category, Art. 9 GDPR): periods, pain, symptoms, mood, sleep, sexual life, fertility, medications, notes, medical history and, if you upload them, test results.
• Settings data: average cycle length, goal, date of birth (only to check that you are an adult).
• Subscription data: active plan and expiry. Payment details (card, bank) are handled only by the store or the payment service: we never see them.
• Messages with the AI assistant, if you use it.
• Minimal technical data to run and protect the app, without health data.

3. Why we process it and the legal basis

• Running the app (diary, predictions, pathways): explicit consent to the processing of health data, required to use the app. Without it we cannot provide the service.
• AI assistant reading the diary: separate, optional consent, off until you give it.
• Sharing with a professional or partner for a visit: separate, optional consent, requested for each visit.
• Anonymous statistics to improve the app: separate, optional consent.
• Marketing emails: separate, optional consent; we never use health data for marketing.
• Managing the subscription, answering requests, security and legal obligations: performance of the contract, legal obligations and legitimate interest.

4. Consents are separate and revocable

Each consent is a separate choice and is never pre-ticked. You can withdraw it at any time from the "Privacy and data" section of your profile. Withdrawing does not affect what was done before. If you withdraw the mandatory consent, the app can no longer process your health data.

5. What we do NOT do

• We do not sell your data to anyone.
• We do not show advertising based on your health and we do not use advertising trackers.
• We do not use your health data to train artificial intelligence models.
• We do not show health data in notifications.
• App administrators cannot read your diary.

6. Where the data is and who processes it

Data is stored on servers in the European Union (Supabase, Frankfurt region), with row-level access protection: each person sees only their own data. We use providers who process data on our behalf under a data processing agreement (DPA):

• Supabase (database, sign-in, file storage and functions): EU servers.
• AI assistant provider: [da scegliere, con trattamento dei dati in UE e senza uso dei dati per addestrare i modelli].
• RevenueCat and Apple (in-app purchases), [Paddle o Lemon Squeezy] (web purchases): they handle payments and do not receive health data.
• Error reporting and email services: [da scegliere], without health data.

If a provider transferred data outside the EU, we would do so only with the safeguards required by law (standard contractual clauses or an adequacy decision).

7. Security

We use encrypted connections, row-level access protection, additional encryption of the most sensitive fields, a private file storage with expiring links, a log of administrator actions and backups. In case of a data breach we will notify the supervisory authority within 72 hours and, if necessary, you too.

8. How long we keep data

As long as you have an account. If you delete your account we delete your personal and health data from active systems, and from backups within 30 days. Some administrative data (e.g. invoices) is kept for the time required by law.

9. Your rights

You can access, correct, delete, restrict, object, withdraw consents and receive your data in a readable format (portability). From the app you can:

• download your data (export) from "Privacy and data";
• delete your account and data from the same section. See how to delete your account.

For other requests write to assistenza@melograna.it. You also have the right to lodge a complaint with your data protection authority (in Italy: Garante per la protezione dei dati personali, www.garanteprivacy.it).

10. Minimum age

Melograna is for people aged 18 or over. At sign-up we ask for your date of birth; if you are under 18 you cannot create an account. We do not knowingly collect data from minors.

11. Artificial intelligence

The assistant is an AI, not a person, and we remind you in the chat. It does not diagnose or prescribe. It reads your diary only if you allow it. In urgent cases it refers you to emergency services (112). You can delete the conversation history.

12. Automated decision-making

Cycle predictions are estimates calculated from the data you enter. They have no legal effect on you and are not medical decisions.

13. Changes

If we make important changes to this policy we will tell you in the app before they take effect. The current version is always available in the app.

Versione italiana: Italiano