GDPR COMPLIANT // Effective from: 1 July 2026

Privacy Policy

Of the implic.it platform, provided by the operator of implic.it.

1. Introduction

The operator of implic.it ("we", "our", or "us") respects the privacy of its users ("you" or "your"). This Privacy Policy explains how we collect, use, share, and protect your personal data in connection with your use of the implic.it platform (the "Services").

This policy is issued having regard to Regulation (EU) 2016/679 of the European Parliament and of the Council (the "GDPR") and, where applicable, any equivalent data-protection law of the jurisdiction in which the operator is established or in which you reside.

2. Data controller

The controller of your personal data is the operator of implic.it. The full legal name, registered office, and registration details of the controller will be confirmed and inserted here before this document is treated as final.

For any questions regarding the processing of your personal data, please contact us at: help@implic.it.

3. Personal data we collect

Personal data contained in text you submit for analysis is automatically replaced with placeholder identifiers before the analysis (anonymisation); the conversion key is stored only in your browser, never on our servers. Anonymisation is an automated process and may not be complete for atypically written data; you may remove sensitive details from the text before submitting it.

We may collect and process the following categories of personal data:

• Account data: your email address and any authentication data (such as a sign-in link or hashed credentials) provided when creating an account.
• Billing data: name, billing address, email address, telephone number, and company registration numbers provided when placing an order, used to issue proof of payment.
• Payment data: details of the payment method you use; we do not collect or store full payment card numbers.
• Consultation data: when you book a consultation, the appointment may be linked to a calendar entry for scheduling purposes.
• Usage data: information about how you interact with the Services, including analyses run, session duration, and feature usage.
• Technical data: IP address, browser type and version, operating system, and other device or connection information collected automatically when you access the Services.
• Communications: any messages you send us, including support requests or feedback.
• Cookies and similar technologies: see Section 9 below.

4. Purposes and legal bases for processing

• Performance of a contract (Art. 6(1)(b) GDPR): we process account and billing data to create and maintain your account, provide access to the Services, issue proof of payment, process orders, and respond to your requests.
• Compliance with legal obligations (Art. 6(1)(c) GDPR): we process invoice and billing data as required by applicable accounting and tax law.
• Legitimate interests (Art. 6(1)(f) GDPR): we process technical and usage data to ensure the security and proper functioning of the Services, prevent fraud and abuse, and improve our platform. We may also use your contact details for direct marketing of our similar services if you are an existing customer. You may object to this at any time.
• Consent (Art. 6(1)(a) GDPR): where we rely on your consent (for example for certain cookies or marketing communications beyond our legitimate interest), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5. Data retention

Retention periods reflect the account and data-retention rules set out in our Terms of Service (in particular the article on access, data retention, and inactive accounts):

• Account data, submitted text, generated outputs, and purchased content are retained for as long as you actively use your account, but no longer than one year from the relevant activation or last-paid-period date, and may be deleted earlier if your account becomes inactive, as described in our Terms of Service.
• Billing data and proof of payment are retained for as long as required by applicable accounting and tax law.
• Data processed under our legitimate interests is retained for no longer than necessary, and in any case for no more than one year after your last use of the Services, unless a longer period is required by law.
• Data processed on the basis of consent is retained until you withdraw your consent or until the purpose is fulfilled.
• Data from an unfinished anonymous trial (without registration) is deleted automatically no later than 48 hours after creation.

6. Recipients of personal data

We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• IT service providers and hosting partners who process data on our behalf under data processing agreements.
• AI model providers, for the purpose of generating analytical outputs; only anonymised text is transferred, providers operate under data processing agreements (DPA), and any transfer outside the EEA takes place under an appropriate transfer mechanism (see Section 7).
• Calendar or scheduling service providers in connection with consultation booking, where used.
• Accounting and legal advisors bound by professional secrecy obligations.
• Public authorities, if required by applicable law or a binding legal order.

We do not sell your personal data to third parties.

7. International transfers

We primarily store and process your data within the European Economic Area (EEA). Where data is transferred outside the EEA, in particular to AI model providers based outside the EEA, such transfers take place under an appropriate safeguard recognised by the GDPR, such as an adequacy decision, the EU-US Data Privacy Framework (where the recipient is certified under it), or standard contractual clauses approved by the European Commission under Art. 46 GDPR. Equivalent safeguards apply to any other transfer of your data outside the EEA.

8. Your rights under GDPR

You have the following rights with respect to your personal data:

• Right of access (Art. 15 GDPR): you may request a copy of the personal data we hold about you.
• Right to rectification (Art. 16 GDPR): you may request correction of inaccurate or incomplete data.
• Right to erasure (Art. 17 GDPR): you may request deletion of your personal data ("right to be forgotten") where the data is no longer necessary or processing is unlawful.
• Right to restriction of processing (Art. 18 GDPR): you may request that we limit processing of your data in certain circumstances.
• Right to data portability (Art. 20 GDPR): you may request a copy of data you provided to us in a structured, machine-readable format.
• Right to object (Art. 21 GDPR): you may object at any time to processing based on our legitimate interests, including direct marketing.
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, please contact us at help@implic.it. We will respond within one month. If you believe we have violated your rights under the GDPR, you have the right to lodge a complaint with the supervisory authority competent for your place of residence, place of work, or the place of the alleged infringement.

9. Cookies

The Services use cookies and similar tracking technologies. We use:

• Strictly necessary cookies: required for the operation of the Services (e.g. session management, authentication). These cannot be disabled.
• Functional cookies: remember your preferences (e.g. language, theme settings).
• Analytics cookies: help us understand how users interact with the Services so we can improve them. These are only placed with your consent where required by law.

You can control and delete cookies through your browser settings at any time.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, disclosure, or destruction. These include encrypted connections (HTTPS), access controls, and regular security reviews.

11. Automated decision-making

We do not carry out fully automated individual decision-making or profiling that produces legal or similarly significant effects on you. The analytical outputs generated by the platform (Section 2 of our Terms of Service) are provided as a basis for your own review and decisions and are not used by us to make automated decisions about you.

12. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of material changes via our website or by email. The date of the most recent revision is shown at the bottom of this page.

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