Your data

What we collect

• The email address you connect, and the text of the emails Segretario reads to draft replies.
• If you use the Kit IOD21: the activation code, a technical fingerprint of your computer (it only serves to recognise the device, it is not data about you) and the status of your subscription (active, renewed or cancelled), which we need to know until when to send you updates.
• Watermark and licence check (Kit IOD21): in the Kit files we put the licence number and the email in masked form (for example g***@gmail.com); when you use the linked functions, the Kit sends our server the licence number and a technical fingerprint of the computer. They are used to make the licence work and to recognise copies spread without authorisation (contract and legitimate interest in protecting our rights, article 6(1)(b) and (f) GDPR).
• If you choose the Student Kit: the school or university you enter at checkout and, only if we ask for it, proof of enrolment, which we use solely to check the student price.
• If you choose the Student Segretario and connect your school portal with your login details: the portal username and password, stored encrypted on our server and used only to read your timetable and deadlines at night. You can delete them whenever you want by writing «scollega il portale». Portals that ask for a second code on your phone are not supported: in that case we use the calendar link.
• If you use Interprete IOD21: the code, a technical fingerprint of your Mac, the subscription status and the count of minutes translated in the month; with the voice plan, also the synthetic copy of your voice and the date of your consent. All the details are in the section Interprete IOD21.
• Payment data: Stripe handles it; we don’t see it and we don’t store it.
• If you join a waiting list or request the Full Setup analysis: your email address, the list you chose and which ad you came from, so we can get back to you.

Interprete IOD21

• Audio stays on your Mac. Speech recognition, yours and your client’s, happens on the Mac with Apple’s technology. We don’t record calls and we don’t save audio, neither on the Mac nor on our servers.
• Only the text to translate goes out. Each transcribed sentence goes to our server (api.iod21.com) and from there to Anthropic, which translates it (United States, with the European standard contractual clauses). We keep neither the text nor the translation: we only keep the count of characters translated in the month, which is used for the plan’s minutes.
• Licence. As for the Kit: the code, a technical fingerprint of the Mac (only used to recognise the device) and the subscription status. The app checks the licence with our server at least every 7 days.
• Your voice, only in the voice plan. In the app you read a short text and confirm your consent, which we save with the date and the version of the text you accepted. The recording goes to ElevenLabs to create the synthetic copy of your voice: we don’t keep it, and on the Mac we delete it as soon as the voice is ready. The voice copy stays on ElevenLabs, in our account, linked to your licence, and only says the translation of your sentences during your calls. To make it speak, the translated text goes to ElevenLabs (United States, with the European standard contractual clauses). We create it only with your explicit consent, which you can withdraw at any time by deleting the voice.
• Only your own voice. In the app you only record your own voice, never someone else’s.
• Deleting your voice. From the app, with “Delete my voice”, we delete it right away from ElevenLabs and from our records. You can also ask by writing to information@iod21.com. When the subscription ends we delete it within 30 days.
• The person you talk to. Their voice is transcribed on your Mac and the text translated to show you the subtitles: let them know you use an AI interpreter (the app has a ready-made sentence, “Introduce the interpreter”). For this data you are the controller; we process the text only to translate it, as processor.

Where it is kept (our providers)

How long we keep it

• The text of the emails Segretario processes: 30 days, then it is deleted.
• Technical logs (for security and support): 12 months.
• Licence data: for the whole duration of the subscription, plus 2 years.
• Proof of enrolment for the student price: only for as long as the check takes, then we delete it and keep only the outcome.
• Your school portal login details (Student Segretario): as long as the portal stays connected; with «scollega il portale» we delete them.
• Interprete IOD21: we don’t keep translated sentences (the server holds them in memory only while translating); the month’s minute count stays with the licence data.
• The synthetic copy of your voice: until you delete it, and at most until 30 days after the subscription ends; date and version of the consent for the whole subscription plus 2 years, so we can show it was given.

What we never do

• We don’t train any model on your data.
• We don’t sell it or share it with anyone for marketing.
• We don’t read it by hand, unless you explicitly ask (for example to solve a problem together).

How to delete everything

Just send a written request to information@iod21.com. We delete everything within 30 days and confirm it to you in writing.

Who is responsible for your data

You remain the controller of your data: it’s yours and it stays yours. IOD21 Srl acts as processor on your behalf, under a contract (Article 28 of the EU General Data Protection Regulation) signed when the subscription is activated.

For purchase, subscription and licence data (email, payments, code, proof of enrolment) IOD21 S.r.l. is instead the data controller: it uses them only to provide the Kit or Segretario, to handle payments and renewals and to meet legal obligations.

Version of 4 October 2026, under legal review. Any changes will be announced 30 days in advance.