This Privacy Policy explains how Pavlo Golovatyy (“we”, “us”, or “our”), the creator of Syntra, collects, uses, and processes your personal data when you use Syntra and its related services (collectively, the “Services”). We are committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) and applicable Italian and European data protection law.
1. Data controller
The data controller responsible for your personal data is:
Pavlo Golovatyy
Via Papa Giovanni XXIII
Sambuceto, 66020 Chieti (CH)
Italy
Email: [email protected]
2. Data we collect
We collect only the data that is strictly necessary to provide and improve the Services. This includes:
- Account information — your phone number and any profile details associated with the communication channels you use to access the Services (for example, messaging platforms such as WhatsApp, including your display name and profile information).
- Conversation data — the messages and content you send to and receive from Syntra during your sessions.
- Usage data — information about how you interact with the Services (e.g. features used, session length, error events), collected through our own internal analytics infrastructure. We do not use any third-party analytics services.
We do not use cookies or any browser-based tracking technologies.
3. How and why we use your data
We process your personal data for the following purposes and on the following legal bases under the GDPR:
- Providing the Services (legal basis: performance of a contract) — to authenticate your account and enable your interactions with Syntra.
- Improving the Services (legal basis: legitimate interest) — to analyse usage patterns and conversation quality in order to make Syntra more accurate, safe, and useful. We carry out this analysis using our private internal platform; no data is shared with external analytics providers.
- Safety and security (legal basis: legitimate interest) — to detect and prevent misuse, abuse, or violations of our Terms of Service.
- Legal compliance (legal basis: legal obligation) — to comply with applicable laws and regulations when required.
4. AI Model
Syntra uses AI models developed by xAI to generate responses. We do not share your personal data with xAI or any other third party — your data remains within our own systems at all times.
We do not share your personal data with any third parties.
5. Data retention
We retain your personal data only for as long as necessary to fulfil the purposes described in this Policy or as required by law. Account data is retained for the duration of your account. If you delete your account, we will delete or anonymise your personal data within 30 days, unless a longer retention period is required by applicable law.
Usage data used for internal analytics is retained in aggregated or anonymised form and is not linked back to individual users once anonymisation is applied.
6. Your rights
Under the GDPR, you have the following rights regarding your personal data:
- Access — you may request a copy of the personal data we hold about you.
- Rectification — you may ask us to correct inaccurate or incomplete data.
- Erasure — you may ask us to delete your personal data (“right to be forgotten”), subject to certain legal exceptions.
- Restriction — you may ask us to restrict the processing of your data in certain circumstances.
- Portability — you may request your data in a structured, machine-readable format.
- Objection — you may object to processing based on our legitimate interests.
- Withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the Italian data protection authority (Garante per la protezione dei dati personali) at garanteprivacy.it.
7. Children
Our Services are not directed towards, and we do not knowingly collect, use, disclose, sell, or share any information from children under the age of 18. If you become aware that a child under the age of 18 has provided any personal data to us while using our Services, please email us at [email protected] and we will investigate the matter and, if appropriate, delete the personal data.
8. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will update the effective date at the top of this page and, where appropriate, notify you. We encourage you to review this Policy periodically.
9. Contact information
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us at:
Pavlo Golovatyy
Via Papa Giovanni XXIII
Sambuceto, 66020 Chieti (CH)
Italy
[email protected]