Privacy notice
Last updated: 02/11/2026
Controller and contact
The data controller is Giuseppe Ferraro, ditta individuale (sole proprietorship), VAT no. 09189071211, Italy.
For any privacy question, write to info@giddup.me.
This notice, given under Article 13 of Regulation (EU) 2016/679 (GDPR), covers the giddup.me site with its blog, the GiddUP coach and your personal page.
What data we process
If you visit the site or the blog
- Technical data: IP address, browser type, requested page, date and time. The server uses them to deliver the page. Our web server configuration does not enable a log of individual visits. Technical data may appear in system logs, for example when an error occurs.
- Google Analytics data: only if you accept statistics cookies. Details are in the cookie policy.
If you use the coach
- Telegram identity: chat identifier, username, display name and app language.
- Phone number: on Telegram the coach asks you to share your number with the app's button. Without the number the conversation with the coach does not continue. We use it to recognise you and find your conversation.
- First name, last name and email: if you give them to us.
- Messages and content: the texts, voice messages, photos and documents you send us, and the coach's replies. Voice messages are transcribed. For photos and documents a description or an extract is created. The files stay on our server.
- Profile: what you tell us about yourself, for example age, gender, habits, available time, difficulties, time zone and preferences.
- Path: goals, programme, activities and their outcomes, diary, forms you fill in on your personal page, comments you leave us.
- Generated audio: the narrated lessons created for your programme.
Your personal page opens through a private link, with no password: anyone who has the link can open it. Do not share it.
When the WhatsApp channel is active, we will also process your WhatsApp number and the messages that come from there.
Sensitive data
Coaching may lead you to talk about wellbeing, health, emotions or relationships. You do not need to share this data to use the service.
GiddUP is not a medical or psychological service and does not replace a professional.
If you choose to share this data, we process it on the basis of your explicit consent (Article 9(2)(a) GDPR). You can withdraw it at any time by writing to us. Withdrawal does not affect the lawfulness of processing already carried out.
Artificial intelligence
Messages are processed by third-party artificial intelligence models. The coach's replies are generated by artificial intelligence and may contain errors.
No decision with legal effects is taken by automated means.
Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Providing the coach service: conversation, programme, reminders, personal page | Contract (Article 6(1)(b)) |
| Processing the sensitive data you choose to share | Explicit consent (Article 9(2)(a)) |
| Security of the site and service, technical logs | Legitimate interest (Article 6(1)(f)) |
| Site statistics with Google Analytics | Consent (Article 6(1)(a)) |
| Complying with legal obligations | Legal obligation (Article 6(1)(c)) |
We do not send promotional messages. The coach's messages, such as reminders and check-ins, are part of the service.
Recipients and providers
| Provider | What it does | Where |
|---|---|---|
| Amazon Web Services (Lightsail) | Server and database | Stockholm, Sweden (eu-north-1 region) |
| Telegram | Conversation channel | According to its privacy policy, for people who signed up from the EEA or the UK data is stored in the Netherlands. The group also has offices outside the EEA |
| OpenRouter | Routes messages to the AI model that writes the coach's replies. The configured model is Google Gemini | United States and other countries |
| Google (Gemini) | Transcribing voice messages, describing photos and documents, creating the programme, text and voice of the audio lessons | Also outside the EEA |
| Google (Analytics) | Site statistics, only with consent | Also outside the EEA |
| Aruba | Email for the info@giddup.me mailbox | Company based in Italy |
| Meta (WhatsApp) | Conversation channel, when active | Also outside the EEA |
Telegram also processes data as an independent controller: see its privacy policy. The OpenRouter privacy policy is public too.
People authorised by the controller can read conversations from the admin panel and reply by hand, for support and to check the quality of the service.
We disclose data to authorities only when the law requires it. We do not sell personal data.
Transfers outside the European Economic Area
Some providers, including Telegram, OpenRouter, Google and, when active, Meta, may process data outside the European Economic Area. These transfers take place on the basis of an adequacy decision, where applicable, or of standard contractual clauses.
You can ask for information on the safeguards applied by writing to info@giddup.me.
Retention
- Coach data: kept as long as the service is active or until your deletion request, fulfilled within 30 days.
- Technical records of message processing: up to 7 days.
- Server logs: for the time strictly necessary for security.
- Google Analytics data: 14 months.
- Cookie choice: 6 months.
We may keep for longer what the law requires us to keep.
Your rights
You have the rights set out in Articles 15 to 22 GDPR: access, rectification, erasure, restriction, portability and objection.
You can withdraw any consent at any time. Withdrawal does not affect the lawfulness of processing already carried out. For site statistics, just use the «Cookie preferences» link at the bottom of the page, if present.
To exercise your rights, write to info@giddup.me.
You can also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).
Age, provision of data, changes
Age. The service is reserved for adults.
Provision of data. You do not need to give us any data to visit the site, and statistics are optional. To use the coach we need your channel identity and, on Telegram, your phone number: without them we cannot provide the service. Other data is optional, but without it the programme will suit you less well.
Changes. We may update this notice. The version in force is on this page, with the date of the last update.