Mobile Application "VOSTRO – Life Network"
Notice issued pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR)
This Privacy Notice outlines the methods by which personal data belongs to users (hereinafter, "Users" or "You") is processed within the mobile application Vostro – Life Network (package identifier com.vostro.lifenetwork, hereinafter, the "App" or "Vostro") and its associated online services, including the domains vostrolifenetwork.com and go.vostrolifenetwork.com.
The Data Controller invites you to review this document carefully prior to account registration and usage, paying strict attention to Section 7 regarding automated behavioral profiling via Artificial Intelligence (IntelliVOS), which represents a core infrastructure layer of the Service.
The Data Controller responsible for processing your personal information is:
The Data Controller has assessed that appointing a formal Data Protection Officer is not currently mandatory under Article 37 of the GDPR. For any questions regarding your data privacy rights, contact our core team directly at privacy@vostrolifenetwork.com.
Note: Due to processing structural geolocational data metrics alongside conducting systematic behavioral profiling (Article 22 GDPR) via native AI services, the Data Controller continuously monitors active user volume thresholds. We promise to formally appoint a DPO should requirements under GDPR Article 37(1)(b) become applicable.
In operating the App, the Data Controller processes the following distinct brackets of personal data:
Third-Party Service Integration Data (Consensual): Should a User choose to securely link their Google Account to enable calendar integration, we process OAuth 2.0 access tokens strictly bound to writing events (calendar.events) alongside internal technical event IDs, uniquely to fulfill the operations detailed in Section 4, Paragraph 14.
Government Identification Documents (Optional "Verified User" Path): Where a User voluntarily chooses to verify their identity, we process clear images of the front and back of a valid government ID asset (e.g., identity cards, driver’s licenses, passports) and the corresponding registration details. These text and photo assets are subject to a highly isolated offline data retention protocol under Section 11.1, engineered for maximum minimization: all live identification document images are permanently purged from all online cloud servers immediately when manual verification concludes.
By computing user activity metrics and parsing natural text prompts, our background systems automatically synthesize derived behavioral data categories, which constitute personal data under law, detailed under Section 7 (Profiling). These include:
gemini_result or gemini_empathy_summary) that structurally encapsulate the user profile.Strict Legal Transparency: Algorithmic inferences are not natively input by users but are dynamically synthesized by AI. They constitute personal data to all legal extents and remain subject to all GDPR protections, including rights of access, rectification, objection, and total deletion.
The Data Controller never mandates or requires the input of sensitive personal parameters under Article 9 of the GDPR (such as ethnic origins, religious leanings, political stances, health records, or sexual orientation data tracks).
Nonetheless, a User might voluntarily inject such points inside custom text areas (bio statements, room chat logs, or prompts submitted to IntelliVOS). Furthermore, derived AI emotion tracking metrics, while not constituting clinical files, may interact closely with aspects of personal psychological state and must be managed with exceptional care.
Therefore:
Government Documents and Biometric Boundaries. Government ID image files processed for the optional trust verification tier contain facial photographs. We explicitly declare that:
Personal data is processed under the following lawful legal bases:
| # | Processing Purpose (Ref: §4) | Lawful Legal Basis | GDPR Validation Section |
|---|---|---|---|
| a | Service Execution (account creation, Room management, encrypted chat, proximity mapping, token invites) | Performance of a contract to which the User is party (EULA compliance) | Art. 6(1)(b) GDPR |
| b | Statutory Law Enforcement Compliance (tax duties, fraud mitigation, executing judicial warrants) | Compliance with a legal obligation | Art. 6(1)(c) GDPR |
| c | Application Integrity and Abuse Mitigation (anti-spam filtering, firewalls, load balancing, cyber intrusion tracking) | Legitimate interest of the Data Controller to assure software infrastructure security | Art. 6(1)(f) GDPR |
| c-bis | Optional Identity Verification ("Verified User"): Document integrity review for fraud prevention, anti-spoofing, and minor protection safety controls regarding peer communications | Legitimate interest of the Data Controller and the user base to maintain a safe community space and protect vulnerable groups (Recital 75 GDPR) | Art. 6(1)(f) GDPR |
| d | Essential Baseline Profiling required for core app mechanics (sorting nearby events, displaying relevant local categories) | Performance of a contract / Legitimate interest | Art. 6(1)(b) and (f) GDPR |
| e | Advanced Behavioral Profiling via IntelliVOS (mood checking, sentiment mapping, personality tracking) | Explicit Consent of the data subject | Art. 6(1)(a) and Art. 9(2)(a) GDPR |
| f | Direct Product Marketing and feature announcements concerning VOSTRO tools | User Consent, subject to soft-spam exceptions under local electronic privacy codes (e.g., Art. 130(4) of the Italian Privacy Code) | Art. 6(1)(a) GDPR |
| g | Targeted Behavioral Advertisements | Explicit and Granular Consent, completely revocable | Art. 6(1)(a) GDPR |
| h | Aggregated and Fully Anonymized Statistical Analytics (product optimization) | Legitimate Interest | Art. 6(1)(f) GDPR |
| i | Legal Defense Operations and dispute tracking | Legitimate Interest | Art. 6(1)(f) GDPR |
Core Note. All data operations resting upon user consent (rows e, f, g) are entirely optional. Denying consent will never prevent you from using the base features of the App, though it will turn off customized behavioral tools (such as tailored adaptive IntelliVOS replies).
Personal data is processed exclusively to:
(Subject to Consent Opt-In, Google Auth Users Only) Google Calendar Integration: Writing event modules inside the user's connected calendar for scheduled Rooms they organize or join, with automated archival sync. Our scripts never read outside calendar events.
(Optional Onboarding Tier) Identity Verification: Validating government identification papers voluntarily shared by the user to apply a "Verified User" status flag, aiming to check user validity and shield minors from unverified identities. Detailed data destruction rules apply under Section 11.1.
6.1 All personal information is handled securely via modern electronic systems, armored with appropriate technical and structural safeguards under Article 32 of the GDPR.
6.2 Our primary operational security layers include:
6.3 While we enforce enterprise-grade security controls, no system connected to the internet is entirely impenetrable. In the event of a structural data breach threatening user rights and freedoms, VOSTRO will notify supervising Privacy Authorities within 72 hours and alert affected individuals without undue delay under Articles 33 and 34 of the GDPR.
This section is essential to understand how VOSTRO customizes real-life event planning. Please read it thoroughly before choosing to opt in.
The Service executes automated behavioral profiling under GDPR Article 4(4) via the IntelliVOS AI engine and backend scripts (aiMemoryService, ai_profile, gemini_result, gemini_empathy_summary).
This pipeline NEVER renders automated decisions that yield legal restrictions or similarly critical real-world impacts under GDPR Article 22(1) (such as altering loan eligibility, blocking job applications, or restricting core civic services). Instead, analytics are used exclusively to tailor your planning experience (sorting relevant venue ideas, organizing invitation shortcuts, and adapting assistant response tones).
Even though these operations do not trigger strict Article 22(1) legal restrictions, VOSTRO remains dedicated to absolute transparency regarding our algorithmic logic, honoring the explicit data rights detailed under Paragraph 7.5.
Our profiling scripts parse the following indicators:
Our background profiling runs across structured operational steps:
users/<uid>/ai_memory and matching sub-collections) containing transactional event parameters.dominant_mood, sentiment_trend;communication_style;dominant_personality_traits;engagement_score, support_needed_count;top_topics, top_activities;gemini_empathy_summary (a descriptive text summary synthesized by AI).In addition to your global privacy protections (Section 10), you hold specific rights regarding our AI profiling features:
If VOSTRO implements personalized behavioral ads or commercial venue sponsorships in the future, it will do so strictly on the basis of a separate, distinct, and explicit consent opt-in (GDPR Article 6(1)(a)), fully unlinked from your core application preferences.
Personal data is shared with third parties strictly to deliver the Service, confined to the following categories of recipients:
| Vendor / Sub-Processor | Operational Processing Role | Infrastructure Location / Safeguards |
|---|---|---|
| Google Ireland Ltd. / Google LLC (Firebase suite: Authentication, Cloud Firestore, Cloud Functions, Cloud Storage, FCM push engines, static asset hosting) | Primary backend infrastructure provider. Data storage region is locked to europe-west1 (GCP Belgium) |
European Union data centers. Transnational fallback flows are governed by official SCC frameworks |
| Google LLC — Gemini API endpoints | Provides foundational generative LLM compute layers for IntelliVOS features | United States nodes (secured via active Standard Contractual Clauses under GDPR Article 46) |
| Google LLC — Google Maps / Places API (New) | Executes geographic geocoding, venue address completion, and map rendering | United States data centers |
| Apple Inc. (APNs delivery routes, App Store ecosystems) | Routes secure iOS background push indicators and distributes App packages | United States data centers |
| Google LLC — Google Play Services | Distributes Android app builds and routes Android FCM notification indicators | United States data centers |
| Google LLC — Google Calendar API (Exclusively for Users signing in via Google who explicitly choose to turn on calendar syncing) | Writes organization events inside the user's primary calendar (restricted to calendar.events write scopes). Our scripts never read outside schedule data |
United States nodes (Certified under the EU-U.S. Data Privacy Framework) |
VOSTRO NEVER sells, rents, or monetizes personal data to third-party data brokers or marketing companies.
For Users who onboard via Google Sign-In and choose to activate calendar synchronization:
https://www.googleapis.com/auth/calendar.events — The minimum authorization scope required by Google security frameworks to write calendar events created by the app.vrooms/{roomUid}/calendarLinks/{userUid} to prevent duplicate entries and push archival updates. This technical record contains no user content.9.1 Key data sub-processors listed under Section 8.1 (specifically Google LLC for generative AI compute nodes and specific backend Firebase instances) operate primary clusters inside the United States. These cross-border data transfers are structured under Chapter V of the GDPR using authorized safeguards:
9.2 You can request a copy of our data transfer compliance agreements by contacting us at the address listed in Section 1.
As a data subject under European regulations, you hold the following rights:
| GDPR Article Reference | Data Subject Right | Functional Scope |
|---|---|---|
| Article 15 | Right of Access | Request formal confirmation of data processing and export a copy of your personal data logs. |
| Article 16 | Right to Rectification | Correct inaccurate, out-of-date, or incomplete data attributes. |
| Article 17 | Right to Erasure ("Right to be Forgotten") | Request the permanent deletion of your data files, within statutory legal limits. |
| Article 18 | Right to Restriction | Temporarily freeze data processing under specific legal scenarios. |
| Article 20 | Right to Data Portability | Export your data in a structured, machine-readable, and commonly used digital format. |
| Article 21 | Right to Object | Object to processing based on legitimate interests or direct marketing actions. |
| Article 22 | Automated Decision Protections | Guarantees against automated legal exclusions (see Section 7 context). |
| – | Consent Withdrawal | Revoke any granted consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. |
| – | File a Formal Privacy Complaint | Submit an official regulatory complaint to a supervising Data Protection Authority (see §10.3). |
You can exercise your privacy rights at any time through two methods:
VOSTRO will process and answer your privacy requests without undue delay, and within 30 days of receipt. This window may be extended by an additional 60 days for highly complex or multi-layered requests, with a formal explanation sent to the user.
You have the right to file a formal complaint with a data protection authority. For Italy, you can contact the Garante per la protezione dei dati personali:
Users residing in other EU Member States can contact their local national Data Protection Authority.
Personal data is retained only as long as necessary to fulfill the operational purposes outlined in this notice, using the following retention schedules:
| Personal Data Bracket | Mandated Retention Lifespan |
|---|---|
| Core Account Parameters | Retained for the active lifecycle of your account. Data is permanently deleted within 30 days of a formal account deletion request, subject to standard system backup overwrite windows. |
| User-Created Rooms | Retained until manually deleted by the user or until account closure. |
| Chat Message Packets | Preserved on servers only until delivery confirmation is received from the recipient's device (typically lasting only a few seconds), then permanently purged. Message databases stored locally on-device remain under the exclusive control of the user. |
| AI Profiling Data (sentiment parameters, extracted attributes, gemini summaries) | Retained until you revoke your consent or request account closure. Users can wipe their derived AI memory profile at any time while keeping their core account active. |
| System Access & Cyber Security Logs | Retained for 12 months to support forensic safety reviews, fraud investigations, or legal defense actions. |
| Commercial Transaction & Tax Records | Retained for 10 years to comply with statutory financial laws (pursuant to Article 2220 of the Italian Civil Code). |
| Room Invitation Tokens | Retained until expiration or revocation. Aggregate invitation counts are logged within Firestore collections. |
Google Calendar Integration Strings (calendarLinks) |
Retained until the corresponding Room is archived or calendar consent is revoked. These entries store technical IDs and contain no user content. |
| Judicial and Litigation Hold Data | Retained for the entire duration of the legal dispute, up to the expiration of statutory appeal windows. |
| Government Identification Documents | Subject to a highly restricted safety protocol outlined in Section 11.1. To summarize: permanently deleted from all online networks immediately when the verification check concludes. Approved document records are stored strictly offline and encrypted. Refused document checks are deleted immediately. |
Once these retention periods expire, personal data is permanently erased or irreversibly anonymized.
Government identification documents uploaded through our optional "Verified User" trust system are protected by a highly restricted, isolated, and multi-layered security protocol. This infrastructure enforces strict data minimization (Article 5(1)(c) GDPR), storage limitation (Article 5(1)(e) GDPR), and privacy by design and by default (Article 25 GDPR) principles, aligning with European guidelines regarding identity document retention.
Phase 1 — Secure Upload and Verification Check. ID images are uploaded over encrypted channels and reviewed by authorized compliance team members solely to verify identity. During this review window, data access is strictly limited to verified compliance personnel, and all assets are encrypted at rest.
Phase 2 — Final Review Actions. Immediately when the validation check concludes, the uploaded document images are permanently purged from all online cloud servers and network-connected databases. This online erasure occurs regardless of whether the verification request is approved or denied. No identification images remain on network-accessible servers.
Following this online erasure, the system processes verification states through the following rules:
If the Request is APPROVED: A copy of the ID file is transferred and stored strictly offline, hosted on an isolated backup medium completely disconnected from the internet, using AES-256 encryption. This offline archive is kept solely for legal audit purposes and to protect our community against legal liability or fraud. This offline record is preserved for the duration of your active "Verified User" status and is permanently destroyed 24 months after account closure or verification revocation. (This 24-month window is aligned with statutory limitations for legal claims and is subject to continuous legal review).
If the Request is DENIED: All uploaded ID images are immediately deleted from all systems, with zero offline archiving. The system logs only a technical flag indicating a failed verification attempt and its date, without retaining any document media assets.
Identification document files are never processed for any other purpose, are never shared with commercial third parties, are never used to train machine learning models, and are never processed for automated biometric facial profiling (see Section 2.4).
Users can revoke their "Verified User" status at any time, which triggers the permanent destruction of the corresponding offline record according to the timelines listed above.
12.1 Minimum Age Entry Threshold: 16 Years. The Service is strictly closed to individuals under 16 years of age (EULA Article 3). This age limit directly applies the default protective baseline established by Article 8(1) of the GDPR for information society services targeted toward minors. While individual EU countries may lower this standard through national exceptions (such as Italy setting it at 14 years via Legislative Decree 196/2003, Article 2-quinquies), VOSTRO has deliberately chosen to maintain the highest protective standard set by European regulations.
12.2 Age Gate Onboarding Controls. Our registration workflow requires users to declare their exact date of birth. Our system programmatically calculates age and completely blocks account creation for anyone under 16. We recognize the inherent limits of self-declared age gates on the internet, which is why we deploy reinforcing safety guardrails (including active chat moderation, peer reporting systems, and our voluntary identity verification tier detailed in Section 11.1).
12.3 Heightened Safety Controls for the 16-17 Age Bracket. For minor users aged 16 and 17, our systems enforce protective default settings:
12.4 Privacy Policy Evolution Record. Prior legacy iterations of this Privacy Notice (v.1.1.0 and older) set our age limit at 14 years to match local Italian exceptions. Effective with v.1.2.0 (May 20, 2026), VOSTRO increased this safety threshold to 16 years globally to align with the strictest European regulatory trends. This policy shift was enforced during our pre-launch phase when no actual active user base aged 14–15 existed, meaning no retroactive account grandfathering was required. Should age policies adjust under future product expansions, this notice will be updated and presented to users for review.
12.5 If a parent or legal guardian discovers that their child has falsified onboarding fields to bypass our age gate, please contact our privacy desk at privacy@vostrolifenetwork.com for immediate account closure and data erasure.
13.1 Our mobile application utilizes secure on-device local storage architectures (such as SharedPreferences encryption wrappers, local secure sandboxes, and unique installation strings) to execute technical operations. While these do not function as browser cookies, they serve similar technical roles and are deployed to:
13.2 Web platforms operated at go.vostrolifenetwork.com or connected landing pages deploy tracking cookies according to our standalone Cookie Policy, which can be reviewed on our website.
14.1 The platform relies on automated filtering systems to moderate public content (detecting spam strings, bot activity patterns, malicious links, or explicit violations of our community standards). These tools can trigger automated content removal or temporary account locks.
14.2 If you believe an automated content moderation action was made in error, you hold the right to request a manual human review by emailing us at privacy@vostrolifenetwork.com.
15.1 VOSTRO reserves the right to modify this Privacy Notice to reflect changing regulatory requirements, technical architecture updates, or new data processing operations.
15.2 Major modifications will be communicated to users at least 15 days in advance via prominent in-app notifications, email alerts, or updates on our website.
15.3 The current valid version of this policy is always accessible within the App settings and at https://www.vostrolifenetwork.com/privacy.
For any questions or to exercise your personal privacy rights, contact us at:
Last review date: August 8, 2026.
