Privacy Policy
Last updated: March 18, 2026 | Version 1.1
Our commitment: Anima is designed with respect for your privacy as a core principle. This privacy policy explains how we process your personal data in accordance with the General Data Protection Regulation (GDPR).
1. Data Controller
Identity: Franco Marcato
Address: Louvain-la-Neuve, Belgium
Contact: contact@larai.eu
Data Protection Officer: contact@larai.eu
2. Data Collected
2.1 Website (current)
This showcase website does not collect any personal data. We do not use tracking, analytics, or advertising cookies. Fonts are self-hosted to prevent any data transmission to third parties.
2.2 Anima Application (upcoming)
When the application launches, the following data will be collected:
- User account: email address, password (encrypted)
- Personal journal: text and audio entries (end-to-end encrypted storage)
- Questionnaire responses: introspection data (encrypted)
- Technical data: device type, OS version (for technical support)
- Encrypted backups: copies of your data (optional, with your explicit consent)
3. Legal Basis for Processing
| Purpose | Legal Basis (GDPR) |
|---|---|
| Account creation and management | Contract performance (Art. 6.1.b) |
| Personal journal and introspection | Explicit consent (Art. 6.1.a) |
| Encrypted backups | Explicit consent (Art. 6.1.a) |
| Technical support | Legitimate interest (Art. 6.1.f) |
| Security and abuse prevention | Legitimate interest (Art. 6.1.f) |
4. Data Recipients
Principle: Your personal data is never sold, rented, or shared for commercial purposes.
Technical Partners (GDPR Data Processors):
- OpenAI: AI conversation processing (GPT API) — we will establish a Data Processing Agreement (DPA) before launch
- Cloud hosting provider: encrypted backup storage (to be determined, with GDPR guarantees)
All data processors are selected for their GDPR compliance and sign data processing agreements.
5. Your Rights (Articles 15-22 GDPR)
In accordance with GDPR, you have the following rights:
- Right of access (Art. 15): obtain a copy of your personal data.
- Right to rectification (Art. 16): correct inaccurate data.
- Right to erasure (Art. 17): delete your account and all your data. **In the Anima mobile application, you can initiate this permanent deletion directly from your Settings. This action physically and immediately destroys all your local data, caches, and encryption keys (as well as encrypted backups within 30 days).**
- Right to portability (Art. 20): retrieve your data in a structured format. **The Anima mobile application integrates a complete export feature allowing you to download all your data in one click in the standard and open JSON format.**
- Right to object (Art. 21): object to certain processing activities.
- Right to withdraw consent (Art. 7.3): withdraw your consent at any time.
To exercise your rights: you can do so directly and autonomously within the Anima mobile application, or send an email to contact@larai.eu. We will respond within 30 days maximum.
6. Retention Period
| Data Type | Retention Period |
|---|---|
| Active account | Until deletion by user |
| Inactive account (no login) | 24 months then automatic deletion |
| Technical logs | 90 days maximum |
| Data after account deletion | Immediate erasure (30 days for backups) |
7. Data Security
We implement strict technical and organizational security measures:
- End-to-end encryption: your journal and questionnaires are encrypted locally before transmission
- Algorithm: TweetNaCl (NaCl/libsodium) for encryption
- Storage: encrypted databases with restricted access
- Transmission: HTTPS/TLS for all communications
- Authentication: passwords hashed with bcrypt
- Backups: encrypted with user key (we cannot access them)
8. Cookies and Trackers
Current website: no cookies or trackers are used. No Google Analytics, Facebook Pixel, or similar tools.
Consent management: Lemon Pie may be used only to store your GDPR cookie consent preferences (accepted/rejected categories and consent timestamp), without advertising tracking.
Anima application: the mobile app will only use local data necessary for its operation (no third-party cookies).
9. International Transfers
Whenever possible, your data is stored within the European Union. For third-party services (e.g., OpenAI in the United States):
- We establish Standard Contractual Clauses (SCCs) from the European Commission
- We encrypt data before transmission
- We minimize transmitted data to what is strictly necessary
10. Personal Crisis Detection
Important: Anima is a wellness tool, not a medical or therapeutic service. If the AI detects distress signals (suicidal language, self-harm), we may:
- Display emergency help resources (crisis hotline numbers)
- Suggest consulting a healthcare professional
We will never contact third parties without your explicit consent, except when legally required.
11. Changes to this Policy
We may update this policy to reflect changes in our practices or legislation. Any significant changes will be notified to you by:
- In-app notification
- Email to your account address
- Version and date update at the top of this page
12. Contact and Complaints
For any questions about this policy:
Email: contact@larai.eu
Right to complaint:
If you believe your rights are not being respected, you can lodge a complaint with the competent supervisory authority: