Privacy Policy - SafeNotes

Introduction

SafeNotes ("we", "our" or "app") respects your privacy. This Privacy Policy explains how we collect, use and protect your information when you use our mobile application, in compliance with EU Regulation 2016/679 (GDPR).

Data Controller

Luciano Colombo VAT: IT11193860969 Email: lucky@luckysistemi.com

Information We Collect

• • Local usage data: The app stores your notes locally on your device in encrypted form using AES-256-GCM encryption. The encryption key is derived from your YubiKey via HMAC-SHA1 challenge-response and is never saved to disk. This data is never transmitted to external servers. Legal basis: legitimate interest (Art. 6.1.f GDPR).

Data We Do NOT Collect

• • We do not collect personally identifiable information
• • We do not collect your location
• • We do not collect contacts or photos
• • We do not use third-party SDKs, trackers or analytics
• • We do not sell any data to third parties
• • We have no access to the content of your notes (they are encrypted with your hardware key)

Internet Connection

The app never connects to the Internet. It works exclusively offline. There are no advertisements, analytics or cloud services of any kind.

Security

All app data is stored locally on your device in encrypted form (AES-256-GCM). The encryption key is derived from your YubiKey and does not exist on disk or on any server. Without the physical hardware key, the data is inaccessible. There are no user accounts or servers storing your information.

Children

SafeNotes does not collect any data and does not require registration. Use of the app requires a YubiKey with HMAC-SHA1 configured.

User Rights

As a data subject, you have the right to access, rectification, erasure, restriction of processing and data portability, where applicable. To exercise these rights, contact us at the email address below.

Changes to This Policy

We may update this Privacy Policy from time to time. We recommend reviewing it regularly for any changes.

Contact

For privacy questions or to exercise your rights:

• • Email: lucky@luckysistemi.com
• • Data Controller: Luciano Colombo — VAT IT11193860969