Privacy Notice

• Account data: email address and password (stored only as a hash, never in plain text).
• App usage data: selected countries, day thresholds you set, logged days (date + country, with an indication of whether the day is actual or planned), travel days, badges earned.
• Documents uploaded as proof (tickets, receipts, etc.): encrypted on your device before upload, together with any associated notes.
• Payment data: handled entirely by Stripe. We only store the Stripe customer and subscription identifiers, the subscription status, and expiry/trial dates. We never see or store your card data.
• Sign-in with Google (optional): if you choose "Continue with Google", we receive your email address and account identifier from your Google account (and your display name, if available). We never receive your Google password or access other data in your account. In this case, encryption of notes and documents uses a dedicated passphrase that you choose and that we never know.
• Technical data: the authentication system stores the IP address and user agent associated with sessions, for security purposes.
• Location: detected only when you explicitly tap the dedicated button, never in the background. Coordinates are rounded, used once to derive the country code, and are never stored.

• Providing the service (account, calendar, counts, documents, subscription management) — legal basis: performance of a contract (Art. 6.1.b).
• Managing payments and accounting/tax obligations — performance of a contract and legal obligation (Art. 6.1.b and 6.1.c).
• Service security (abuse prevention, technical session logs) — legitimate interest (Art. 6.1.f).
• Location on request — your explicit consent given by tapping the button (Art. 6.1.a), revocable simply by not using it.

We do not do marketing, we do not profile users, and we do not use analytics or advertising tools.

To understand how Halfhere is used and improve it, the controller measures aggregate usage on its own infrastructure: technical event counts, number of registered and active users, onboarding completion, subscription and cancellation figures. No third-party analytics is used — no Google Analytics, no pixels, no advertising SDKs.

These measurements come from technical logs that never contain personal data or your content: only an event key, a technical user identifier and a few non-personal fields.

For service management the controller can consult account and subscription data (email address, registration date, language, onboarding status, subscription status, last activity date and the number of days recorded). The content of your presence data — countries, dates, notes, documents, locations — is never displayed in the administration area. There is no profiling and no automated decision-making.

Encrypted on your device: notes and proof files. They are protected with AES-256-GCM using a key that stays on your device, derived from your password via PBKDF2 (600,000 iterations). They arrive already encrypted: only unreadable blocks exist in the database and storage.

Stored in plain text in the database: email, logged days (date and country), thresholds and settings, subscription status. These are protected by per-user database isolation and the infrastructure provider's encryption at rest.

A limit worth knowing, stated honestly: the encryption key is derived from the same password you use to sign in. This effectively protects against access to the database and backups (even in the event of a breach or a request made to the provider), but not against whoever controls the service's code: in theory, whoever runs the server could intercept the password at login and derive the key from it. So: "not even the developers can read your notes" holds true for data at rest, not as a mathematical guarantee against the service operator.

• Hosting, database, authentication and storage provider (the cloud platform the app is published on, with a managed database) — data processor under Art. 28 GDPR.
• Stripe Payments Europe, Ltd. (Ireland) and Stripe, Inc. (USA) — payment and subscription management, acting as independent controller/processor depending on the case.
• Google Ireland Ltd. / Google LLC — only if you use Sign-in with Google: the provider handles authentication and sends us the email and account identifier.
• Reverse geocoding service (BigDataCloud) — used only when you request country detection, and called from our server: the provider receives coordinates rounded to 2 decimals and the server's IP, not yours.
• Resend (Plus Five Five, Inc., USA) — sending product emails (welcome message, threshold alerts, inactivity reminders): the provider processes your email address and the message content, acting as a data processor under Art. 28 GDPR.

Our emails never contain presence data: no countries, no day counts, no travel dates, no notes and no file names, not even in the subject line. An email only tells you that there is something to check inside the app.

Some of these providers may process data outside the European Economic Area (in particular in the United States). In those cases, the transfer relies on the Standard Contractual Clauses approved by the European Commission and, where applicable, the EU-US Data Privacy Framework. No data is sold or shared for marketing purposes.

• Account and usage data: for as long as the account exists.
• Deletion: removal from the app is immediate; complete removal from backup copies as well happens within 30 days of the request.
• Tax-related payment data: kept by Stripe for the period required by legal obligations (typically 10 years).
• Technical logs and payment events: 90 days.

You can exercise, at any time, the rights of access, rectification, erasure, restriction, portability and objection, as well as withdraw any consent given.

In the app, under Settings, you already have two immediate tools: exporting your data (CSV/JSON) and permanently deleting your account. For everything else, write to alessandro@menatcode.it: we reply within 30 days.

If you believe the processing is not compliant, you can lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) (garanteprivacy.it) or refer the matter to the courts.