Last updated: September 4, 2026.
1. Data controller
The data controller is Michele Wolfango Fogli. Kymra AI is the name of the project. For privacy-related requests you can write to michele@kymra-ai.com.
2. Data processed
Browsing data
The systems that deliver the site may process IP address, date and time of the request, page requested, browser and device information, request outcome, and technical data necessary for security and operation.
Data submitted through the form
We process name, email address, optional company or business, type of need, and message content. We ask that you do not include health data, credentials, identity documents, or other sensitive information.
3. Purposes and legal bases
- Responding to requests and assessing possible services: performance of pre-contractual measures requested by the data subject, Article 6(1)(b) GDPR.
- Ensuring operation, security and abuse prevention: legitimate interest of the controller, Article 6(1)(f) GDPR.
- Complying with legal obligations or defending a right: legal obligation or legitimate interest, Articles 6(1)(c) and 6(1)(f) GDPR.
Acknowledging the notice required in the form is not commercial consent. Data is not used for newsletters, profiling, or advertising.
4. Provision of data
Name, email and message are required to send a request. Company and type of need are optional. Without the required data we cannot reply through the form.
5. Providers and recipients
Data may be processed, to the extent necessary, by the following providers:
- Cloudflare, Inc., provider of the site’s hosting and infrastructure.
- Hostinger, provider of the business email inbox that receives form submissions and direct email requests.
- Google LLC (Gmail), used only as the technical system (SMTP) for sending form notifications to the business inbox.
- Authorized consultants, only when necessary.
Data is not sold or shared with third parties for advertising purposes.
6. Contact via WhatsApp
If you prefer to write to us on WhatsApp instead of using the form, the message passes through the infrastructure of WhatsApp Ireland Limited and its parent company Meta Platforms, Inc. Message content is protected by end-to-end encryption: we don’t see or store it outside the app. WhatsApp nonetheless processes, independently and according to its own notice, the conversation’s metadata (phone number, timestamps, delivery status and other technical data). This processing remains WhatsApp/Meta’s responsibility as an independent controller for its own infrastructure and cannot be changed by Kymra AI. By writing to us on WhatsApp you also accept WhatsApp’s privacy notice, available at whatsapp.com/legal/privacy-policy-eea.
7. Transfers outside the European Economic Area
Cloudflare and Google are based in the United States and may process data outside the European Economic Area. If you write to us on WhatsApp, Meta Platforms, Inc. may do so as well. Where required, transfers take place using safeguards provided for by the GDPR, including the standard contractual clauses approved by the European Commission. Information on these safeguards can be requested from the controller.
8. Retention
- Contact requests: up to 12 months from the last communication, unless a contractual relationship arises or longer retention is required by law or to protect a right.
- Technical data and logs: for the period strictly necessary for service delivery, security and diagnostics, according to the settings and timeframes applied by the hosting provider.
- WhatsApp messages: remain in the app according to retention periods decided by WhatsApp, not by the controller (see point 6).
Messages are not saved in a database on the site.
9. Rights
Where provided for under Articles 15–22 GDPR, you may request access, rectification, erasure, restriction, portability, or object to processing. You may also lodge a complaint with the Italian Data Protection Authority (Garante).
10. Automated decisions and minors
The site does not carry out profiling or automated decision-making with legal or similarly significant effects. The services are not specifically directed at minors.
11. Updates
This notice will be updated if purposes, tools or providers change. The date at the top indicates the current version.