Privacy policy

This is a translation provided for convenience. The Italian version is the legally binding one: in case of any discrepancy, the Italian text prevails.

This page explains what data we collect from people who visit posely.it and people who use the app, and what we do with it. It's written in plain language on purpose: if something isn't clear, write to us and we'll rewrite it better.

Who processes the data

The data controller is NEURAFIT S.R.L., Corso Italia 214, 52027 San Giovanni Valdarno (AR), Italy, VAT number and tax code 02512130515, REA AR-223872, certified email (PEC) neurafit@pec.it. For any request about this policy you can write to info@posely.it.

What we collect

If you signed up for the waiting list

• Your email address, which you give us by filling in the form.
• Where you came from: the name of the site that linked to us or the campaign label (for example «instagram»). It helps us understand which content works.
• The date you signed up, added automatically.

We don't ask for your name, phone number or health data, and we don't need them.

If you just read the website

We don't use cookies, we don't use analytics tools and there are no social buttons that follow you around. The fonts are hosted on our own server, so your browser doesn't contact Google or anyone else while you read. The server records access (IP address, page requested, date) in its technical logs, like any web server: they're needed to keep it running and for security, and they're kept for 30 days.

If you leave a comment on the blog

• The name and text you write. Once we've read and approved them they're public, below the article: just your first name or a nickname is fine.
• The date of the comment, added automatically.
• A fingerprint of your IP address: not the address itself, but a code derived from it with a secret key, used only to recognize anyone sending comments in bulk. We delete it when the comment is approved. To count attempts, the server keeps the address in memory, without writing it anywhere, for at most one hour.

We don't ask for an email address or any other data. The name and text are used to publish the comment, and the legal basis is your consent (Art. 6(1)(a) GDPR), which you give with the checkbox on the form; the IP fingerprint is based on our legitimate interest in keeping the blog free of spam (Art. 6(1)(f)). Comments are stored on our PocketBase server (api.posely.it), the same one the app uses, hosted by Hostinger in Vilnius, Lithuania: they stay in the European Union. A copy of the name and text is sent to the info@posely.it mailbox, to let us know there's a comment to read.

Comments we don't approve are deleted automatically within thirty days. Published ones stay as long as the article is online, or until you ask us to remove them: write to info@posely.it with the article, the name you used and roughly when you wrote, and we'll delete it, along with the copies in our mailbox.

Why we do it, and on what legal basis

We use your email for one thing only: to let you know when the app is available. The legal basis is your consent (Art. 6(1)(a) GDPR), which you give by signing up and can withdraw at any time. The technical logs, on the other hand, are based on our legitimate interest in keeping the service running (Art. 6(1)(f)).

We won't send you a regular newsletter and we won't use your address for anyone else's advertising. If we ever wanted to write to you about something else, we'd ask you first.

Where the data goes

The addresses are stored on one of our servers hosted by Hostinger in Vilnius, Lithuania: the data therefore stays within the European Union. Hostinger hosts the server and acts as a data processor on our behalf, without using the data for its own purposes. We don't sell the data, we don't pass it on and we don't upload it to third-party email marketing services. The only people who can read it are those who work on the project.

How long we keep it

Until the app launches, plus the time needed to send you the notice; after that, the list is deleted within six months of launch. If you ask to be removed earlier, we remove you right away.

Your rights

You can ask us at any time to access your data, correct it, delete it, restrict its use, receive it in a file or object to its processing. Just send an email to info@posely.it: we reply within one month, usually much sooner. If you think we're getting something wrong, you can contact the Italian data protection authority, the Garante per la protezione dei dati personali (garanteprivacy.it).

The app

Posely can be used in two ways, and they differ quite a lot: without an account nothing leaves your phone; with an account your assessments are synced to our servers so you can find them on another device. It's your choice, and you can change your mind later. In both cases the photos stay on the phone that took them: we don't store them on our servers. The only exception is sharing to improve recognition, which is off until you turn it on (see below).

On your phone, the photos in your history are encrypted with a key that stays on the phone and never leaves it (AES-256, held in the Keychain on iOS and in the Keystore on Android). They're kept out of iCloud and Google backups and out of transfers to a new phone, and they can't be opened while the phone is locked (on Android from version 9). After each assessment, no other copy of the shot remains on the phone.

If you use the app without an account

Photos, values, scores, completed exercises and reminders stay in the app's private storage, on your phone. The photos are analyzed on the device, with Google's pose recognition library built into the app: the images are not sent to us or anyone else for processing. If you uninstall the app, that data goes with it.

The app also records technical events about how it's working — opened, assessment completed, paywall seen — in a local queue. Until you create an account they stay on the phone; if you create one some day, that queue is sent with its original dates. If you don't want that, clear the app's data before signing in.

If you create an account

You can only sign in with Apple or Google: we don't create or manage passwords. From the provider we receive your email address and, if you share it, your name. From then on we sync to our servers:

• your profile: name (if you enter it), year of birth, chosen goal, areas where you feel discomfort, the situations where you should take it easy and any strong discomfort you have right now (see below), how much it hurts if you record it, your plan answers (time, days, equipment, how active you are), articles you liked, days of activity;
• your assessments: date and score for each area. Not the photos: they stay on the phone that took them, they don't come back on a new phone and, if you sign out, they're deleted from the phone along with everything else (the key that opens them is destroyed);
• the exercise programs you've started and how they're going;
• the usage events described above, linked to your account.

We don't collect your location, we don't read your contacts, there's no advertising and there's no third-party SDK following you across different apps and websites.

If you search for a professional near you and tap «Use my location», the app asks for permission and reads your approximate location once: it calculates distances on the phone and neither stores nor sends it, not even to us. The professionals who appear are those who have agreed to be listed; we download their whole list, without telling the server where you are. You can also decline permission and search by city or postcode.

Health data, stated plainly

Areas of pain, how much it hurts, the situations where you should take it easy that you tell us about (pregnancy, surgery or an injury in the last six months, dizziness or unsteady balance, a walking aid, difficulty getting down to the floor, another reason), any strong discomfort you have right now, posture scores and photos of your body are data concerning health: the GDPR gives them special protection (Art. 9). We process them only to make the app work for you — calculating your score, suggesting exercises, showing you how your scores change over time — and the legal basis is your explicit consent (Art. 9(2)(a)), which you give by creating an account and turning on sync, and which you can withdraw by deleting your data or your account. The photos are analyzed by the phone and stay there: only the scores reach the server. The situations and strong discomfort are used only to remove from your plan the exercises that aren't right for you; when you change them we keep a history (before, after, when) to readjust the plan, which nobody else sees and which goes away with your account. For the rest of the service the legal basis is our contract with you (Art. 6(1)(b)); for usage events, our legitimate interest in understanding where the app gets stuck (Art. 6(1)(f)).

We don't use this data to profile you for advertising, we don't sell it and we don't pass it on to anyone. Posely is not a medical device and does not provide diagnoses.

Age and warning signs

At the start the app asks how old you are and stores only your year of birth. It's used for two things: choosing exercises suited to your age and enforcing the minimum age of fourteen. If you've reported pain, the app also asks you five questions about warning signs, the ones for which it's better to see a doctor before exercising. The answers stay on your phone: the server only receives the fact that at least one of them hasn't yet been seen by a doctor, so that the plan stays light while that's the case. The professional who guides you sees your age, not your year of birth, and that signal only if you choose to share your personal data with them.

The pain diary

If you've reported pain, the app asks you from time to time how much it hurts, from 0 to 10: on the Home screen once a week, at the start of a plan session and after an assessment. Answering is optional. Without an account the answers stay on your phone; with an account they're synced like your assessments, with the date and the point in the app where you answered. They're used to show you how the pain changes over time, and by the plan to avoid stepping up the exercises when it hurts. The professional who guides you sees them only if you choose to share your personal data with them. Usage events only record that you answered, never the number. They're deleted with your account.

Sharing to improve recognition

In your Profile there's an option, «Share to improve the recognition model», which is off until you turn it on. To turn it on you must give your consent and confirm that you're at least eighteen. From then on, for each new assessment:

• sent: the unannotated photo of each view, with the head covered by a solid oval drawn on the image, together with the body points the app found, the tilt of the phone, the operating system (iOS or Android) and the version of the method;
• not sent: name, email, account, phone identifier, day and time of the assessment (the server keeps only the month it was sent), scores, the photos with your values written on them, the photos from assessments done before you turned it on.

The photos aren't sent right away: they stay queued on the phone and are sent later, at least an hour afterwards and in shuffled order, to a server address that doesn't ask who you are and doesn't log successful uploads. They leave already locked with a Posely public key: they stay locked on the server, and the key to open them is kept off the server, only on Posely's computer. The server doesn't accept unencrypted photos. They end up in a separate archive, with no name or account, that only we can access. We use them only to improve how Posely recognizes body points: we don't sell them, pass them on or use them for anything else. We keep them as long as they're needed for this purpose, and in any case no longer than 24 months from the month they were sent: then we delete them.

The legal basis is your explicit consent (Art. 9(2)(a)). You can turn the option off whenever you like from your Profile: from then on nothing more is sent, and photos still in the queue are deleted from the phone. Those already sent, however, can't be found or deleted: with no link to you, not even we know which ones are yours. Keep this in mind before turning it on: a photo of a body is still a photo of a body, and a tattoo, the room or a distinctive piece of clothing could make it recognizable to someone who knows you.

In the test builds distributed to testers, and only there, sharing is always on and the photo is sent without the oval over the head, still with no name or date: testers read this in a notice before their first assessment.

The professional who guides you

If you enter the code of a professional who uses Posely, from then on they see what you choose to share: the results of your assessments (scores and values, not the photos, which stay on your phone) and the programs they assign you. The link always starts with you: without that code no professional sees anything. You can unlink them whenever you like from the app settings, and from then on they no longer see new data. The professional is personally responsible, as an independent data controller, together with their studio, for how they store and use what they see.

Who else is involved

• Apple and Google: they handle sign-in, app downloads and subscriptions. We see nothing of the payment — neither card nor billing details — but we know whether your subscription is active.
• MapTiler (MapTiler AG, Zug, Switzerland): draws the maps in the professionals section using OpenStreetMap data. When you open the map, its server sees your phone's IP address and the area of the map you're looking at, as with any website. Switzerland is recognized by the European Union as providing an adequate level of data protection.
• OpenStreetMap (OpenStreetMap Foundation, United Kingdom): up to version 1.2.5 (24) of the app, the maps came directly from its servers instead of MapTiler. If you still have one of those versions (you'll find it at the bottom of your Profile), when you open the map its server sees your phone's IP address and the area you're looking at. From later versions the app no longer contacts it: update it and this item no longer applies to you. The United Kingdom is also recognized by the European Union as providing an adequate level of data protection.
• Hostinger: hosts our server, as a data processor on our behalf.

Where the data is stored and for how long

On the same server mentioned above, in Vilnius, Lithuania: it stays within the European Union. We keep it as long as you keep your account. You can delete single assessments or your whole history directly from the app (Profile → Clear local history): they disappear from the phone and the server, and the photos from the phone. If you delete your account the data disappears immediately; the encrypted backup copies lose it within thirty days. The exception is photos shared for recognition, with no name or account: since we don't know whose they are, we can't find them to delete them.

How to delete your account

From the app: Profile → Delete account. After one confirmation the account and everything in it — profile, assessments, programs, link with your professional, and the photos on the phone — are deleted immediately, from the server and from the phone, without asking you why. If you'd rather write to info@posely.it from the address you sign in with, we'll do it for you within thirty days and confirm. Any subscription still needs to be cancelled on the App Store or Google Play: that part is handled by them, not by us.

Children and teenagers

Posely is not intended for anyone under fourteen and we do nothing to attract them. If we become aware of an account belonging to someone under fourteen without the consent of their parent or guardian, we delete it.