Legal documents

Privacy Policy

Last updated: March 18, 2026 — GDPR (EU Regulation 2016/679)

Introduction

This Privacy Policy ("Policy") describes how OmegaMind ("Data Controller", "we", "our") collects, uses, stores, and protects the personal data of users ("data subject", "you") in compliance with Regulation (EU) 2016/679 (GDPR), Italian Legislative Decree 196/2003 (Privacy Code) as amended by Legislative Decree 101/2018, and any other applicable data protection legislation.

1. Data Controller

The Data Controller for personal data processing is OmegaMind.

Contact email: legal@omegamind.io

Data Protection Officer (DPO): dpo@omegamind.io

2. Categories of Personal Data Collected

2.1 Data voluntarily provided by the user

  • Registration data: full name, email address
  • Published content: comments, drafts, thematic proposals, votes
  • Newsletter subscription: email address
  • Communications: content of requests sent via email

2.2 Automatically collected data

  • Browsing data: IP address, browser type and version, operating system, pages visited, visit duration, referral URL
  • Cookies and similar technologies: session identifiers, user preferences (see Cookie section)
  • Usage data: interactions with Platform features, gamification progress, narrative choices, chronicles read

2.3 Derived data

  • Progression profile: cosmic level, experience points, creative mana, prestige titles (calculated from user interactions)
  • Reputation analysis: scores based on the frequency and quality of community contributions

3. Purposes and Legal Basis for Processing

PurposeLegal Basis (Art. 6 GDPR)Data processed
Service delivery and account managementContractual performance (art. 6.1.b)Registration, browsing
Community management (comments, votes)Contractual performance (art. 6.1.b)Content, usage
Gamification and progressionContractual performance (art. 6.1.b)Usage, derived data
Newsletter sendingConsent (art. 6.1.a)Email
Service analysis and improvementLegitimate interest (art. 6.1.f)Browsing, usage
Security and abuse preventionLegitimate interest (art. 6.1.f)Browsing, IP
Legal complianceLegal obligation (art. 6.1.c)All necessary data

4. Cookies and Tracking Technologies

4.1 Technical cookies (necessary)

Used for Platform operation: authentication session, user preferences. They do not require consent pursuant to art. 122 of the Italian Privacy Code.

4.2 Analytical cookies

We use Google Analytics (Google Ireland Limited) with anonymized IP to analyze aggregate Platform usage. These cookies are set with the user's consent.

4.3 Preference management

Users can manage cookie preferences through their browser settings. Disabling technical cookies may impair the functioning of the Service.

5. Services and Sub-processors

For the delivery of the Service, we use the following providers, each operating as a data processor pursuant to art. 28 GDPR:

ProviderPurposeLocation
Base44Hosting and application infrastructureEU/USA*
Google AnalyticsStatistical analysisEU (Ireland)*
ElevenLabsAudio generation (narration)USA*
OpenAI / AI ServicesAI content generationUSA*
LinkedInSocial publishingUSA*
Google DriveFile storageEU (Ireland)*

* Transfers to the USA are based on the EU-US Data Privacy Framework (DPF) or Standard Contractual Clauses (SCC) approved by the European Commission.

6. Extra-EU Data Transfers

Some data may be transferred to third countries (particularly the United States). Such transfers comply with Chapter V of the GDPR, specifically through:

  • Adequacy decisions of the European Commission (e.g., EU-US Data Privacy Framework)
  • Standard Contractual Clauses (SCC) pursuant to art. 46.2.c GDPR
  • Supplementary safeguards where necessary according to CJEU case law

Users may request a copy of the adopted safeguards by contacting dpo@omegamind.io.

7. Data Retention Period

  • Account data: retained for the entire duration of the account and up to 30 days after deletion
  • Published content: retained for the duration of the Service (may be anonymized upon request)
  • Browsing data and cookies: maximum 26 months
  • Newsletter: until consent is withdrawn
  • Gamification data: retained for the duration of the account
  • Backups: data in backups is deleted within 90 days of account deletion

At the end of the retention period, data is deleted or irreversibly anonymized.

8. Data Subject Rights

Pursuant to articles 15-22 of the GDPR, users have the right to:

  • Access (art. 15): obtain confirmation of processing and a copy of personal data
  • Rectification (art. 16): obtain correction of inaccurate or incomplete data
  • Erasure (art. 17): obtain deletion of data ("right to be forgotten")
  • Restriction (art. 18): obtain restriction of processing
  • Portability (art. 20): receive data in a structured, commonly used, and machine-readable format
  • Objection (art. 21): object to processing based on legitimate interest
  • Withdrawal of consent: withdraw consent at any time, without prejudice to the lawfulness of previous processing

To exercise your rights, contact: dpo@omegamind.io

We will respond within 30 days of receiving the request, extendable by an additional 60 days in case of complexity, with prior notification.

9. Right to Lodge a Complaint

Users have the right to lodge a complaint with the competent supervisory authority. In Italy, the reference authority is:

Garante per la Protezione dei Dati Personali

Piazza Venezia, 11 – 00187 Roma

Email: protocollo@gpdp.it

PEC: protocollo@pec.gpdp.it

Website: www.garanteprivacy.it

10. Protection of Minors

The Service is not intended for minors under 16 years of age. We do not knowingly collect personal data of minors under 16. If we become aware that we have collected data from a minor without the consent of a parent or legal guardian, we will proceed with the immediate deletion of such data.

11. Security Measures

We adopt appropriate technical and organizational measures pursuant to art. 32 GDPR to protect personal data, including:

  • Encryption of data in transit (TLS/HTTPS)
  • Role-based access controls
  • Secure authentication
  • Access monitoring and logging
  • Regular backups and disaster recovery procedures
  • Staff training on data protection

12. Changes to the Policy

This Policy may be updated periodically. In case of substantial changes, we will inform users through a notice on the Platform or via email. The date of the last update is always indicated at the top of this document.

13. Contact

For any questions regarding this Policy or the processing of personal data:

  • General email: legal@omegamind.io
  • DPO: dpo@omegamind.io