This policy describes how the personal data of users of the mobile application PosturEasy® (marketed as Posturafacile® in Italy) — the “App” — is processed, in accordance with Regulation (EU) 2016/679 (GDPR).
Posturafacile S.r.l.
Via Carlo Noè 53 – 20038 Busto Garolfo (MI), Italy
VAT / Tax code 10395860967
Certified email (PEC): [email protected]
Email: [email protected] · Website: posturafacile.it
| Category | Data | When |
|---|---|---|
| Registration data | First name, last name, email | Only if you choose to register after a test |
| Test results | Postural sway metrics (path, area, velocity, Romberg quotient, etc.) | On each test; stored locally on your device |
| Assistant content (AI) | The messages you send to the “Pòsturo™” assistant and a numeric summary of your last test (balance index, sway metrics, Romberg quotient), without name or email | Only when you use the assistant chat and only after your explicit consent |
| Anonymous contribution (optional) | Test metrics and demographic data (age, sex, and height/weight if provided), linked only to a random identifier — no name or email | Only if you enable “Contribute anonymously” in Settings |
| Technical data | Minimal information needed to operate the online features (e.g. request outcomes) | While using online features |
The App does not collect advertising identifiers and does not perform advertising profiling. Raw motion-sensor data never leaves your device.
The App includes an AI-based assistant. Only after your explicit in-app consent, given before any transmission, when you use the assistant chat the following are sent:
This data is sent to our intermediary server (Cloudflare) and to the AI provider Anthropic PBC (the “Claude” service, United States), solely to generate the reply. Data transmitted through Anthropic’s API is not used to train AI models.
| Purpose | Legal basis |
|---|---|
| Save your tests and provide the Diary and App features | Performance of the service / consent |
| Send you tips, content and updates by email | Consent (Art. 6(1)(a) GDPR) |
| Answer your questions via the AI-based assistant | Explicit consent (Art. 6(1)(a) GDPR) |
| Manage the subscription and purchases | Performance of the contract |
| Build more accurate balance norms (anonymous normative database) | Consent (Art. 6(1)(a) GDPR); anonymized/pseudonymized data |
To deliver the services we rely on providers that process data on our behalf:
| Provider | Function | Country |
|---|---|---|
| ActiveCampaign | Email marketing and contact management (first name, last name, email) | USA |
| Cloudflare | Intermediary server (proxy) infrastructure for the online features | USA / global network |
| Anthropic PBC | Processing of assistant messages to generate replies (AI “Claude”). Does not train models on data sent via API | USA |
| Apple | App distribution and in-app purchase management | USA / EU |
We do not sell or transfer your data to third parties for their own independent purposes.
Some providers are based in the United States. Transfers take place in compliance with the GDPR, on the basis of appropriate safeguards (e.g. the European Commission’s Standard Contractual Clauses and/or adherence to applicable adequacy frameworks).
Test data remains on your device until you delete it. Registration data is kept until you request deletion or unsubscribe. Assistant content is processed for the time needed to provide the reply and to secure the service.
You may exercise at any time the rights under Articles 15–22 GDPR: access, rectification, erasure, restriction, objection, portability and withdrawal of consent.
You also have the right to lodge a complaint with your competent data protection authority (in Italy, the Garante per la protezione dei dati personali, www.garanteprivacy.it).
Communications with our servers use encrypted connections (HTTPS). External service keys are kept server-side and are not present in the App.
The App is not intended for children under 16. We do not knowingly collect data from minors without the consent of a person with parental responsibility.
PosturEasy® is a wellness and educational tool, not a medical device. Results do not constitute a diagnosis and do not replace assessment by a professional.
We may update this policy; the updated version will be published at this address with its date.