Saelia is operated by Convallaria S.r.l., Via Santa Elisabetta 8, 24121 Bergamo (BG), Italy, VAT IT04585850169 ("Convallaria", "Saelia", "we"). Convallaria is the data controller for the Saelia website, the invitation-only dashboard at app.saelia.ai, and related beta support. Privacy requests may be sent to info@convallaria.it.

The beta is intended only for invited users aged 18 or over. Most data comes directly from the account holder through registration, settings, recordings, text notes, mood check-ins, support requests and connected features. Saelia also creates technical records and AI-assisted outputs from that material.

Users must not provide another person's data unless they have a lawful basis, have given any required notice, and have obtained any required permission.

Depending on the features the user chooses, Saelia may process the following categories:

• Account data: name, email, language, timezone, password hash, invitation and account status.
• Security data: sessions, IP address, user agent, timestamps, login attempts, rate limits, audit events and optional two-factor records.
• User content: voice recordings, text notes, titles, context, file metadata and mood check-ins.
• Derived data: transcripts, summaries, highlights, tags, mood labels, confidence signals and requested synthetic speech.
• Control records: settings, notification choices, legal acceptance, consent, deletion, export and support history.
• Provider data: identifiers required to operate transcription or a private synthetic voice.

Voice and text may reveal health, emotional state, beliefs, relationships, political opinions or other sensitive information. A voice model or voice-verification step may constitute biometric or special-category data where it is used to identify a person. Saelia does not require users to place highly sensitive information in the beta.

Users should record in a private environment, avoid third-party confidential information, and obtain permission before recording or uploading another person. Voice Identity is limited to the account holder's own authorized voice.

We identify a legal basis for each purpose rather than treating every activity as consent-based.

• Contract: registration, account operation, private storage, text notes, exports and other features requested by the user.
• Legitimate interests: account security, fraud prevention, rate limiting, service integrity and proportionate diagnostics, subject to user rights.
• Legal obligation: records or disclosures required by applicable law.
• Consent: optional voice transcription and Voice Identity where consent is the applicable basis; it may be withdrawn prospectively at any time.
• Not active: product research, biometric integrations and continuity processing remain disabled until a future interface presents a specific purpose and legal basis.

Audio collection is off by default. When the user enables Voice archive consent and submits audio, Saelia stores the recording on its private server and sends the audio to ElevenLabs for speech-to-text processing. Saelia stores the returned transcript and may create a local extractive summary, tags, highlights and mood-oriented signals.

The current beta does not send transcripts to ChatGPT or OpenAI. Turning Voice archive consent off stops new and queued transcription; existing recordings and outputs remain available until the user deletes them or the account.

Voice Identity requires a separate versioned consent and confirmation that the recording contains the account holder's own voice. Selected samples are sent to ElevenLabs to create a private voice model. Saelia stores the provider identifier and generated files needed to operate the feature.

Revoking Voice Identity stops future generation, cancels queued work, removes generated audio from Saelia and requests deletion of the provider voice. It does not authorize public sharing, impersonation, payment use, post-mortem use, or use by relatives or third parties. Synthetic audio must be treated and disclosed as AI-generated.

Transcripts, summaries, mood labels, tags and synthetic audio are probabilistic and can be incomplete, inaccurate or misleading. They are provided for personal organization and reflection.

Saelia does not use these outputs to make decisions producing legal or similarly significant effects about beta users. The service is not a medical device, emergency service, therapist, identity authority, legal adviser or financial adviser.

Data is accessible only to authorized Convallaria personnel and suppliers who need it to operate, secure or support the beta. Categories include managed hosting and database infrastructure, ElevenLabs for speech-to-text and private voice services, and professional advisers or incident-response providers when necessary.

ElevenLabs processes customer content under its applicable agreement and Data Processing Addendum, while some trust, safety and account operations may be performed under its own legal responsibilities. Data may be disclosed to authorities where legally required. Saelia does not sell personal data, use archive content for advertising, or make a user's archive available to employers, family members, other users or investors.

Saelia's primary application storage is operated on its managed server. ElevenLabs and its subprocessors may process data outside the European Economic Area. Its Data Processing Addendum includes transfer mechanisms such as the EU Standard Contractual Clauses and, where applicable, adequacy frameworks.

The current Creator-plan integration does not provide Enterprise Zero Retention. ElevenLabs states that default service data and safety or debugging logs may be retained under its policies, that deleted database items may remain in backups for up to 30 days, and that voice data is not retained longer than three years after the last interaction unless law permits or requires otherwise. Saelia requests provider deletion when supported but cannot shorten provider backup or mandatory retention periods. Users may request information about transfer safeguards from info@convallaria.it.

Active account data and archive content are retained while the account is active and the user keeps the material. Archive items moved to trash are recoverable for 30 days and then permanently removed by scheduled maintenance. An account-deletion request has a 30-day recovery period before account data and stored files are purged. Sessions expire after 30 days and can be revoked earlier.

Operational rate-limit and failed-login records are short-lived. Security and audit records are retained only for a proportionate period needed to investigate incidents and demonstrate compliance. Versioned legal-acceptance evidence may be retained after account closure for the applicable limitation period to establish, exercise or defend legal claims. Production backups rotate on a short operational schedule; deleted records may remain in protected backups until those backups expire. Provider-side retention follows Section 10.

The dashboard allows users to pause new collection, manage optional processing choices, export account data, download or delete materials, restore items during the 30-day trash period, revoke Voice Identity, revoke sessions and schedule or cancel account deletion.

Subject to applicable law, users may request access, rectification, erasure, restriction, portability, or object to processing. Consent can be withdrawn without affecting processing already lawfully performed. Identity verification may be required. Requests can be sent to info@convallaria.it and are handled within the periods required by law.

Users may lodge a complaint with the competent supervisory authority. In Italy this is the Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, www.garanteprivacy.it. The right to seek a judicial remedy remains unaffected.

Name, email, a password, invitation evidence, adult confirmation, acceptance of the Beta Terms and Acceptable Use Policy, and acknowledgment of this notice are required to create an account. Without them Saelia cannot provide the beta.

Voice, text, mood and other archive content are optional. Declining Voice archive or Voice Identity consent does not prevent use of unrelated account functions.

Measures include TLS in transit, password hashing, HttpOnly session cookies, optional two-factor authentication, rate limits, private file storage, access controls, audit trails, provider-key separation, backups and deletion workflows. No system can guarantee absolute security.

Suspected unauthorized access should be reported promptly to info@convallaria.it. Personal-data breaches are assessed and notified where required by Articles 33 and 34 GDPR.

The dashboard uses only storage necessary for authentication, security and requested preferences in the current beta. Details, names and durations are in the Saelia Cookie Policy. No advertising or cross-site profiling cookies are intentionally used on app.saelia.ai in this release.

Material changes receive a new version and will be presented in the product or otherwise communicated before materially different processing begins. Where required, users will be asked to accept or acknowledge the updated document. Previous versions and acceptance evidence are retained as necessary for accountability.