App privacy policy

This is an English translation of the Italian original. If the two differ, the Italian version prevails.

Version 1 · 4 October 2026

This policy covers the feelya app. For the waiting list on the website, the website privacy policy applies.

In short

feelya. is for a closed group of friends to think together about a question. To do this, we process your email address, the name and photo you choose, what you write and the positions you take on topics.

Positions on topics may reveal political opinions or religious or philosophical beliefs: under the law, these are special categories of personal data (Art. 9 GDPR). We process them only with your explicit consent, which you give the first time you sign in.

We do not sell your data, we do not show advertising, we do not profile you and we do not use what you write to train artificial intelligence.

1. Who the data controller is

The data controller is the feelya team.

For any question about your data, and to exercise your rights, write to hello@feelya.it. We have assessed whether Art. 37 GDPR requires us to appoint a data protection officer (DPO): at present we believe it does not, and we will repeat the assessment if the service grows. The contact point for data protection is hello@feelya.it.

2. What data we process

• Account: email address, the name you show to others, profile photo if you decide to add one, date and version of the consent you gave. If you sign in with Google or Apple, we receive from them only your email and name (with Apple you can choose to hide your email: in that case we receive a forwarding address).
• Circles: which circles you belong to, since when, your turn as host, whether you created the circle.
• Content: the ideas you write in the dark, the messages and replies in the discussion, the topics you propose, the positions you give on the slider before and after, the closing votes.
• Reports and blocks: the content you report and the reason, the people you block.
• Notifications: your device’s code for receiving notifications (push token), if you turn them on.
• Technical data: when the app or the server runs into an error, a report with the device type, the operating system, the app version and the point in the code where it happened. It does not contain your messages or your email. For security purposes, the servers also log the connections they receive (including the IP address).
• Usage statistics, only if you accept them: which screens you open, which elements you tap and certain steps (creating a circle, joining with a code, proposing a topic, reporting, blocking), tied to a random code on your phone that is not linked to your account, your email or your name. Never what you write, your positions, the names of circles or your geographic location.
• Access codes: when you request a code, we keep an encrypted (unreadable) version of it and the address we sent it to.
• Log of access to pseudonyms: every time a pseudonym is linked back to a person (at the reveal, or because of a legal obligation), a record remains of who, when and why.

What is required and what is not. Email, name and consent to the processing of your positions are required: without them, you cannot create an account or use the app. Content and positions are provided by you when you take part in a session. Profile photo, notifications and usage statistics are optional: if you do not provide them, the app works the same way (without notifications, we do not alert you when a session opens). Technical data and logs are generated by the use of the app and the server itself.

We do not collect your geographic location, your contacts, the microphone, advertising identifiers or browsing data outside the app.

3. Who sees what, inside the app

The pseudonym protects you from other people, not from us: on the server there is a table that links your pseudonym to you. It is needed for the reveal to work and for any legal obligations, and it is not consulted for anything else.

• During the dark phase (the first hour), no one reads what you write.
• During the discussion, the other members of the circle read your messages under a pseudonym.
• At the reveal, the members of the circle see your name next to your messages and your positions before and after. It is also seen by people who join the circle later, in the archive of past sessions.
• Your name and your photo are seen by the people in the circles you belong to or have belonged to. No one sees your email.
• No content is public: there is no feed, and nothing can be reached from outside the circle.

People who know you may recognise you from the way you write, even under a pseudonym. Keep this in mind when you write.

4. Why we process it and on what legal basis

• Running the service (account, sign-in, circles, sessions, notifications, blocks): performance of the contract you accept with the terms of service (Art. 6(1)(b) GDPR).
• Processing your positions and your content, which may reveal political opinions, religious or philosophical beliefs, or other special categories of data you choose to write: your consent (Art. 6(1)(a) GDPR), which for these data is explicit consent (Art. 9(2)(a) GDPR). The two bases apply together: the first makes the processing lawful, the second allows special categories of data to be processed. Without this consent the app cannot work, because giving a position on topics is the service itself.
• Usage statistics, to understand how the app is used and improve it: your consent (Art. 6(1)(a) GDPR), which you give with an optional tick box the first time you sign in and can withdraw whenever you want from «tu». Without it, the app works the same way.
• Handling reports of illegal content, responding to authorities, keeping proof of consent: legal obligations (Art. 6(1)(c) GDPR; Regulation (EU) 2022/2065, “Digital Services Act”).
• Protecting the service from abuse, fixing errors, keeping accounts secure (limits on access codes, technical logs, error reports, automatic filter for hate words): legitimate interest in offering a secure and working service (Art. 6(1)(f) GDPR).

We do not make decisions based solely on automated processing that produce legal effects concerning you (Art. 22 GDPR). The only automated mechanism is the filter that stops a message containing hate words before it is sent: you can rewrite it, and if you think the filter got it wrong you can write to us.

5. Who receives the data

We use certain providers that process data on our behalf, as data processors (Art. 28 GDPR), under a contract that requires them to use it only for the service they provide to us. The table shows, for each one, what it receives, where the data are stored and, if they leave the European Union, under which safeguard. For emails we use three providers in sequence: if the first has reached its sending limit or does not respond, the email is sent through the next one. Each email goes through only one of them.

Google and Apple have two different roles. For notifications, Google delivers the messages on our behalf, under the Firebase data processing terms: it is our processor. Apple, on the other hand, delivers them with the service built into the iPhone’s system, on its own terms: there it is an independent controller. For sign-in with Google or with Apple, both are independent controllers, with their own privacy policies.

We may disclose data to authorities when required by law (for example, by order of a court). We do not disclose data to anyone else.

6. Transfers outside the European Union

When a provider receives data in the United States, the transfer is based on the European Commission’s adequacy decision of 10 July 2023 on the EU-U.S. Data Privacy Framework (Art. 45 GDPR), in which all the providers in the table based in the United States participate. Where the provider’s contract provides for them, the standard contractual clauses approved by the Commission in 2021 (Art. 46 GDPR) also apply, and they remain valid even if participation in the Data Privacy Framework were to lapse.

You can request a copy of the safeguards applied by writing to hello@feelya.it.

7. How long we keep it

• Account: until you delete it. When you delete it, we immediately erase your email, name, photo, notification tokens, access codes and the link between you and your pseudonyms, including in sessions already revealed.
• What you have written: it remains in the circle under a pseudonym for as long as the circle exists. We erase the link between the pseudonym and your account, but this does not make the text anonymous: in a circle of a few people, those who know you may still recognise you from what you wrote and how. For this reason, if you wish, we also erase the text. Just write to us: we erase it within 30 days. Whoever created a circle can delete it, and everything it contains is erased with it.
• Positions and votes: they remain as numbers tied to an internal identifier, no longer linked to your account, so that the averages of sessions already closed do not change. Here too these are pseudonymous data, not anonymous data.
• Access codes: 24 hours at most.
• Reports: for as long as the circle they refer to exists. Report emails we receive are erased within 12 months of the decision.
• Usage statistics: 30 days at most from collection, after which they are erased automatically. If you withdraw consent from «tu», no more are sent.
• Error reports: 90 days at most. Technical server logs: 30 days at most.
• Proof of consent (date and version): as long as the account, and after deletion only as anonymous data.

feelya. is in beta. If the beta closes without a follow-up, we will tell you at least 30 days in advance and erase all data within 90 days of closure.

8. Your rights

At any time you can:

• access your data and receive a copy of it (Art. 15);
• rectify it (Art. 16): you change your name, email and photo from «tu»;
• erase it (Art. 17): «elimina l’account» (delete account) in «tu», or write to us;
• restrict its processing (Art. 18) and object to processing based on legitimate interest (Art. 21);
• receive it in a machine-readable format (Art. 20): «scarica i miei dati» (download my data) in «tu» sends it to you by email in a file;
• withdraw your consent (Art. 7(3)), without affecting what was done before. You withdraw consent to statistics from «tu», and the app keeps working. Consent to the processing of your positions is at the heart of the service: withdrawing it means deleting your account.

For everything else, write to hello@feelya.it. We reply within one month, free of charge. We may ask you to write to us from the account’s address, to make sure it is you.

If you believe we are processing your data in a way that does not comply with the law, you can lodge a complaint with the Garante per la protezione dei dati personali (Italian Data Protection Authority) (garanteprivacy.it) or with the authority of the EU country where you live or work.

9. Minimum age

feelya. is for people aged at least 16: when you sign up, we ask you to declare this. In Italy the law allows you to give consent on your own from the age of 14 (Art. 2-quinquies of the Italian Privacy Code). We have chosen a higher limit, because the app involves discussing topics that may touch on political and religious opinions. If we find out that an account belongs to a younger person, we delete it.

10. Security

Communications between the app and the server are encrypted. Sign-in uses a one-time code, with no password to steal. The link between pseudonyms and people is kept in a single table, which the app’s code can read from only one place, and every time a pseudonym is linked back to a name a trace remains. Photos are re-encoded on the server and stripped of location data.

If a data breach occurs that puts your rights at risk, we notify the Garante within 72 hours and, if the risk is high, you as well.

11. On your phone

The app stores on your phone only what it needs to work: the access key (in the system’s protected keychain, if you choose «resta connesso» (stay signed in)), a copy of the last screens you viewed so it can be used without a network connection, and drafts of what you are writing. We do not use cookies or tracking tools. When you sign out of your account, the key and the copies are erased.

12. Changes

If we change this policy substantially, we will ask you again in the app before the changes apply to you. Last updated: 4 October 2026.