Insieme privacy policy

DRAFT — to be reviewed by a lawyer. This text describes what the app does today, taken from the code. It is not yet a valid privacy policy: every point marked [TO BE VERIFIED] cannot be checked in the code and must be decided or confirmed by the founder or the lawyer before the beta. The placeholders in square brackets must be filled in.

Translation of the Italian text; the Italian version prevails.

Version: 2026-10-bozza-4

Last updated: 26 October 2026

1. Who we are

The data controller is [CONTROLLER: name or company name, address, VAT number — to be decided with the accountant, decision D12]. The name “Insieme” is provisional (decision D1) and may change before publication.

For any request about your data, write to [PRIVACY CONTACT EMAIL — to be created]. We have not appointed a data protection officer (DPO): [TO BE VERIFIED with the lawyer whether one is needed].

2. What Insieme is

Insieme is an app for organising the family: you write or send a message, a photo or a PDF, the assistant suggests something to remember with a date and a person in charge, you confirm, and the family receives the reminders. Nothing becomes a reminder until a person confirms it.

The app is meant for adults (18 or over). Children do not have an account: their names are entered by their parents. [TO BE VERIFIED with the lawyer: minimum age and parents' responsibility.]

Teens from 14. A parent (an admin of the family) can give a son or daughter who is already 14, the age of digital consent in Italy (Article 8 GDPR and Article 2-quinquies of the Italian Privacy Code, Legislative Decree 101/2018), their own "teen" account. They do it from the child's card: choosing "Teen (14+)" is the parent's statement that the age is reached; we do not ask for a date of birth. Under 14 there is no account: the child stays a card managed by the parents. For a teen we process the same account data as for an adult (email, name if they enter it, acceptance of this notice) and the link between their account and their card. A teen sees only their own things: what they add, what is given to them and what is about them (their card), with their reminders; they do not see other people's things, expenses, bills, subscriptions, amounts, emergency cards (not even their own), lists, useful numbers, forwarded messages and files, the plan and payments, or carpools with other families. They do not invite or remove anyone and do not change the family. What they add, the parents see too. The notifications they receive are only the reminders of their things and the things someone passes to them, with the title only (section 6); they get no family summaries. A teen does not use automatic reading (section 5): nothing of theirs goes to the assistant. No advertising and no use of their data to train artificial intelligence models, as for everyone. On the Free plan a teen sees their things but cannot change them; with Insieme Family they can. The teen can download their data and delete their account from "Your data": their archive contains only what they see in the app. [TO BE VERIFIED with the lawyer: the age of digital consent, the parent's statement instead of age verification, the notice to give the teen in a form suited to their age, and the legal basis for a teen's data entered by the parents.]

3. What data we process

Account data

Family data, entered by you or by someone in your family

Technical data

Special categories of data (health data). Insieme can keep the dates of visits, tests, vaccines and medicines of the people in the family, children included, as things to do with a date and a person who takes care of them. This is data concerning health (Article 9 of the GDPR). We process only what you write or confirm from a message: the title (for example “Paediatrician visit”, “Vaccine booster”), the date or time, the person and who takes care of it. We do not ask for or calculate doses, symptoms or diagnoses, and we do not suggest vaccines or schedules. There are two explicit consents, separate from everything else (Article 9(2)(a)):

Health things are seen only by the people in your family on Insieme, like everything else: no public links, no outside people. In notifications, with “Discreet health notifications” (on unless you turn it off) a health thing appears as “Health reminder”, without the title (point 6). [TO BE VERIFIED with the lawyer: the Article 9 legal bases for children's data (the parent who enters it), for the data of the other adults in the family entered by a family member, and whether the impact assessment on health data is sufficient.]

The emergency card. For each person in the family (adults, children, grandparents) you can keep a card for an emergency: who to call (up to 3 contacts with their phone), date of birth and languages, and, if you want, blood group, allergies with their severity, conditions, regular medicines, devices (for example a pacemaker), the choice about organ donation, the doctor or paediatrician with their phone, the health card number, a note for whoever helps, for a child the school and who may do the school pick-up, for an older person who provides care and their needs. These are the family's own words: Insieme does not check them and gives no advice. The health parts (blood group, allergies, conditions, medicines, devices, organ donation, doctor, health card, needs, note for whoever helps) can only be saved by someone who gave the health consent above; the contacts to call do not need it. Who sees and edits it: the card of an adult with an account is created and edited only by that adult; the other adults of the family see it on Insieme read-only (that is what an emergency card is for), unless its owner chooses “Only me and my emergency contacts”: from then on the other adults no longer see it in the app and only know that the owner fills it in themselves, and the card no longer sends another adult the reminder about changed medicines or allergies. The cards of children, teens and people without an account are seen and edited by the adults of the family. A teen sees no card (see above). So that it opens with no signal, a copy is kept on the phone, encrypted like the session (the key stays in the phone's keychain, not in backups); we remove it from the phone when you sign out, delete the account or leave the family. The card leaves Insieme only if you send it: “Send the card” makes an image or a PDF on your phone with its expiry written on it and you pass it on with the phone's share sheet (no link, nothing on our servers); the health card number stays off unless you choose to include it; whoever receives it keeps a copy we cannot take back. Every six months, and when medicines or allergies change, Insieme adds the thing to do “Check <name>'s emergency card” for the family: the notification contains only this title, never the card's data (section 6). Insieme cannot write into the iPhone Medical ID or Android Emergency information: it shows you the data to copy and you copy it; what you put there is handled by the phone's system, not by Insieme. On the locked phone you choose item by item what to show (by default nothing is visible), with the explicit warning that anyone holding the phone can read the chosen details; you can generate a lock-screen wallpaper image with only the chosen details placed in the safe area between the clock and system buttons. [TO BE CHECKED with the lawyer: the Article 9 basis for the health data of another adult or of a child entered in the card by a family member, and vital interests (Article 9(2)(c)) for whoever reads it in an emergency.]

What Insieme does not do: no medical advice, no doses, no interaction checks, no vaccination schedule. For doses and treatments ask your doctor.

If you ask to try the beta on the website (insieme.day, the “Try me before everyone else” form), even without an account: your email; the optional answers you choose (who you live with: alone, as a couple, with children, with a parent to look after; your phone: iPhone, Android or both; how you heard about us, one line of text); the language of the page; the moment you gave your consent and the version of this notice the page showed; a random code used only by the link to delete the request. A second request with the same email does not create another one and does not change the answers of the first. To limit abuse we count, for 24 hours, the requests coming from the same IP address and for the same email: we keep a fingerprint encrypted with a secret key, never the IP address or the email in clear. The form uses no cookies and no third-party scripts. We use these data only to invite you to the beta and to choose the families (for example iPhone and Android, different households); we do not use them for newsletters or advertising. [TO BE VERIFIED with the lawyer: this paragraph, the legal basis and the retention period of beta requests.]

We do not collect location or advertising identifiers. The microphone is used only if you tap “Speak” or say a sentence to Siri, Gemini or the Assistant (point 5): speech recognition is the phone's, and we receive the text, never your voice. From the phone's address book we read only the contact you choose for the useful numbers (see “Useful numbers” in point 3), never the whole address book. We do not use analytics or tracking tools in the app: the only diagnostics library is the one for error reports (Sentry, above), which does not count how you use the app and which you can turn off. [TO BE VERIFIED before every build: no analytics SDK has been added. Separately, the usage and diagnostic data that the Google ML Kit library may send to Google must be assessed, point 5.]

4. Why we process it and on what legal basis

We do not sell your data. We do not use it for advertising. We do not use it to train artificial intelligence models. Whether the assistant's provider also never uses it for training is not yet confirmed in writing (section 5): [TO BE VERIFIED]. We do not make automated decisions that produce legal effects on you: the assistant suggests, a person confirms.

5. Who we share it with

The people in your family see the things to do, the people and the names of the members. A teen from 14 sees only their own things (section 2). Nobody sees those of another family: the database enforces this, with a rule for every row and with automated tests, also for what a teen sees.

The other families of a carpool. A carpool with other families (point 3) and «Give a month» (next paragraph) are the only things Insieme shares outside your family. A carpool is shared only with the families of that carpool, each of which joined with its own account (there is no guest access and no web page of the carpool). They see: the carpool (activity, days, times, place), which family drives each leg, swap requests, your surname, your free seats and the first name of your children in the carpool. They see nothing else of your family: not the things to do, the people, the members or their names, the documents, nor which of your adults drives. A one-off ride is seen only by the families it is offered to, who are already in a carpool with you. The database enforces this too, with automated tests. The “Share the turns” message is sent by you, from your phone, in the chat you choose (for example WhatsApp): it contains the next dates with the surname of who drives, the invite and, in the picture, also the children's first names and the seats; whoever receives it reads it in their chat, outside Insieme.

«Give a month». If your family joins Insieme through another family's link, the adults of that family (not teens) see, for each family that joined with their link, only «Another family», how many of the new family's first 3 things to do are confirmed (0-3), whether the month was given and whether their own reward hit the yearly cap (12 months in 365 days). They never see your family's name and we do not keep it. They see nothing else of yours: not the things to do, the people, the members or their names. The database enforces this, with automated tests. You see nothing of the family that invited you beyond what the person who sent you the link told you; if you invite, the same holds the other way round.

To make Insieme work we use providers (data processors). With each one a data processing agreement (DPA) is needed. [TO BE VERIFIED: no DPA has been signed yet.]

Planned, not yet active: RevenueCat (for subscriptions through the App Store and Google Play, decision D13). Before activating it we will update this policy and ask you to accept it again.

We may disclose data if the law or an authority requires it.

6. What goes into notifications and the phone calendar

Never notes or amounts. The title is written by the family, or suggested by the app when you create a thing from a person (“Festa di Leo”, “Regalo per Leo”, “Controlla la scheda di Leo” in Italian): then the name is in the title and shows in the reminder. Avoid sensitive data in titles (including names). For health things, “Discreet health notifications” (in the notification settings, on unless you turn it off, a choice for each person) shows only “Health reminder · today at 17:15”, even when someone hands it to you (“For you: Health reminder”), so the title cannot be read on the lock screen; this also applies to the notification provider (Expo, Apple, Google), which then does not receive the title.

7. How long we keep it

8. Your rights

You have the right to access your data, correct it, delete it, restrict its processing, receive it in a readable format (portability), object and withdraw consent (Articles 15 to 21 of the GDPR). In Insieme:

If you think the processing breaches the law, you can lodge a complaint with the Garante per la protezione dei dati personali (www.garanteprivacy.it), or with the authority of your country.

9. Security

Data travels encrypted. The database is protected by row-level rules: one family cannot read another's data. Files are kept in a private store. The sign-in code is single-use. On the phone the session is encrypted. The assistant cannot change anything by itself: its answers are checked against a schema and confirmed by a person. Use of the assistant has monthly limits per family and a global spending cap. No measure is perfect: if we become aware of a personal data breach we will report it as required by law. We have a draft impact assessment (DPIA) for health data. [TO BE VERIFIED: breach notification procedure; review of the DPIA with the lawyer before the beta.]

10. Transfers outside the European Union

We prefer providers that process data in the European Union. Sentry keeps error reports in its EU region (Frankfurt), but is based in the United States. Where a provider (for example Expo, Apple, Google, Sentry) is outside the EU or is based outside the EU, the transfer relies on an adequacy decision or on standard contractual clauses. [TO BE VERIFIED case by case.] This also applies to Google as the assistant's provider (section 5): requests may be processed outside the European Union. [TO BE VERIFIED: which Google company signs the contract, where the requests are processed and which transfer safeguard applies.]

11. Changes

If we change this policy in a significant way, we will ask you to accept it again the next time you open the app. The version accepted and the date remain recorded.