PRIVACY POLICY

PRIVACY POLICY
Last Updated: 10/12/2025

1. Data Controller
EARTH'S DREAMS S.R.L. Stradela Carabus Nr. 15, Iasi, 700275, Romania CUI: 38752272 (J22/39/07.01.2019) | VAT ID: RO38752272 Data Protection Contact: 
info@earthsdreams.ro

2. Introduction and Principles
Welcome to Proactive Lab ("the Application"). Your privacy is our top priority. We recognize the sensitive nature of health data and are committed to protecting it in full compliance with the General Data Protection Regulation (GDPR - EU 2016/679).

This policy describes how we treat your data, based on the principles of Privacy by Design and Data Minimization.

3. Types of Data Processed
A. Data entered by the user (Special Categories of Data - Art. 9 GDPR):
To provide the service, the app processes data that you voluntarily provide, such as:

Personal and biometric data (age, gender, height, weight).
Health-related data (biomarkers, symptoms, medical notes, clinical history).
Visual documents (photos of medical reports uploaded for OCR/AI analysis).
B. Technical Data (Collected automatically):
Anonymized system logs and technical data strictly necessary for security, debugging, and app operation.
We do not use advertising trackers or third-party profiling cookies for marketing purposes.
C. Payment and Subscription Data:
The Application offers in-app purchases or subscriptions. EARTH'S DREAMS S.R.L. does NOT collect, process, or store your financial data (credit card numbers, bank accounts).

All financial transactions are handled entirely by third parties: Apple (App Store) for iOS and Google (Play Store) for Android. We only receive an anonymous "token" from these providers confirming payment or subscription status (active/expired), without any reference to your financial identity.

4. "Zero-Knowledge" Architecture and Place of Processing
The Application operates on a "Local-First" model:

Local Storage: Your health and personal data are saved encrypted exclusively on your device's memory.
No Proprietary Cloud: Earth's Dreams S.R.L. does NOT own, manage, or have access to a central database containing your health data. We developers cannot see, read, or retrieve your data.
Sovereignty: In case of app deletion or device loss without backup (which is the user's responsibility), data is unrecoverable by us.
5. Use of Artificial Intelligence and Data Transfer
To provide advanced analysis features, the Application uses Google Gemini APIs (provided by Google Cloud Platform).

Transmission Mode: When you request an analysis, only the strictly necessary textual or numerical data (stripped of your name and surname, if possible) are sent encrypted (HTTPS/TLS) to Google servers.
Data Usage Terms: We use Google services in "Enterprise" mode. Under Google Cloud's current terms, your data is NOT used to train Google's Artificial Intelligence models and is not persistently stored by their systems.
Role of Google: Google acts as a Data Processor or Sub-processor for mere technical processing.
6. Legal Basis for Processing
The processing of your health data takes place exclusively on the basis of your Explicit Consent (Art. 9.2.a GDPR), which you provide upon first launching the app and which is necessary for service provision. You can revoke consent at any time by deleting data or uninstalling the app.

7. Rights of the Data Subject
In accordance with GDPR, you have the right to:

Access your data (all already visible on your device).
Rectify inaccurate data.
Delete data ("Right to be forgotten"): You can fully delete your data using the "Delete all data" function in app settings or by uninstalling the application. Since we do not keep copies on our servers, this action is final.
Limit processing or object to it.
8. Minors
The Application is intended exclusively for users aged 18 or older. We do not knowingly collect data from minors. If we become aware of minors' data entered in the app, we invite parents to delete the app from the minor's device.

9. Changes
We reserve the right to update this policy. Substantial changes will be notified via the app.