Privacy Notice

Who we are

BROOSBAY is provided by Luca Torriani, trading as BROOSBAY. Luca Torriani is the data controller for the personal data described here, meaning we decide why and how it is processed. Contact: support@broosbay.app.

What we collect and why

• Account data (email, name, profile picture, timezone, password credentials) — to create and secure your account. Legal basis: performance of our contract with you.
• Content you create (journal entries and captures, voice recordings and transcripts, goals, intentions, open loops, daily state entries, memories, Life DNA items, coach conversations, and the insights and patterns derived from them) — to provide the service. Legal basis: contract.
• Support messages — to answer you. Legal basis: contract and our legitimate interest in supporting users.
• Technical data (device identifiers, IP address, log and usage telemetry, error reports) — for security, fraud prevention, reliability and product improvement. Legal basis: legitimate interests.
• Subscription status — to give you access to the plan you bought. Legal basis: contract and legal obligation (accounting).

Who can see it

Your data is scoped to your account. Database access rules restrict every record to its owner, so other users cannot read your entries. Nothing you write is public and nothing is shared with other users. We do not sell your data.

Who we share it with

• Paddle.com Market Ltd — our Merchant of Record. Paddle handles the sale of subscriptions, checkout, payments, subscription management, invoicing, tax compliance, refunds and related buyer support. Paddle collects your billing details directly at checkout and acts as controller for that payment data; we receive only your subscription status and non-sensitive order information. See Paddle's privacy notice.
• Service providers (processors) — hosting, database and authentication infrastructure, error monitoring and email delivery, acting on our instructions.
• AI provider (OpenAI) — when you use analysis, insights, patterns or the Coach, relevant excerpts of your own data are sent to generate a response. Only the context needed for that request is sent, never your entire history, and it is not used to train models.
• Professional advisers and authorities — legal or accounting advisers, and authorities where we are required by law.

International transfers

Some providers are located outside the EEA/UK/Switzerland. Where that happens we rely on adequacy decisions or Standard Contractual Clauses with appropriate safeguards.

Retention

Content stays until you delete it or close your account, after which it is deleted or anonymised; backups may retain copies for a limited period. Invoicing and tax records are kept for as long as the law requires.

Your rights

• Access, correct, delete, or export your data — self-serve from Settings → Privacy & data.
• Restrict or object to processing, and withdraw consent where processing relies on it.
• Turn proactive intelligence off in Settings so no new insights are generated.
• Complain to your local data protection authority.

Write to support@broosbay.app and we will respond within one month.

Security

We use appropriate technical and organisational measures, including encryption in transit, row-level access controls scoped to your account, and restricted administrative access.

Cookies

We use essential cookies and local storage only — to keep you signed in and remember interface preferences. We do not use advertising or third-party tracking cookies. Paddle sets cookies necessary for checkout. You can clear or block cookies in your browser, though sign-in will stop working.

Changes

If this notice changes materially, the updated date above will change.