Privacy Policy
This policy explains what personal data we collect on proactiva.app, why we collect it, and what rights you have. It is written in line with the General Data Protection Regulation (EU) 2016/679 (GDPR).
1. Data controller
The data controller is the Proactiva project team. Contact for data protection matters: info@proactiva.app. The official legal entity details will be published on this page before the platform launches.
2. What we collect before launch
The platform is still in preparation, so we currently collect only waitlist data: your email address, your chosen site language and, if you decide to share it, a free-form comment. If you came to the site from another website (for example, a search engine or a social network) or through an ad or a link with campaign tags, we store where you came from together with your address: the domain of that website (for example, “google.com”, never the full address), the campaign tags from the link (the source and traffic type, the campaign and ad names), the ad-click identifier (such as “fbclid” or “gclid”) and the page where you started or signed up — so we know which channels bring people to us. We do not store search words, and we do not pass this data to advertising platforms. We also count, anonymously, how often a sign-up form was shown on screen: we record only the page section, the type and position of the form, the language and the date — no cookies, no IP address and no device data. We also count page views anonymously: we record only the date, the site section and the site you came from (for example, google.com) — no cookies, no IP address, no exact page address and no device data. To count visitors we use Umami, an analytics program running on our own server. It uses no cookies and stores nothing in your browser; we send it only the site section (never the exact page address), the site you came from, your browser language and screen size. From your IP address Umami determines the country and city, from your browser the browser and device type, and from these it builds an anonymous visitor identifier that changes every month; it does not store the IP address itself. If Do Not Track is on in your browser, we send nothing. If you close the newsletter offer at the bottom of a page or subscribe through it, your browser remembers only that, so the offer is not shown again. The site uses only essential cookies for language selection and sign-in sessions — we use no advertising or tracking cookies.
3. Why and on what basis
We use your email address for a single purpose — to announce the platform launch and activate the promised 2 months of free access. The legal basis is your consent (GDPR Art. 6(1)(a)), which you can withdraw at any time.
4. Health data after launch
Once the platform launches, it will process health data (GDPR Art. 9) — laboratory test results and related information. It will be collected only with explicit separate consent, and we will publish a detailed policy for this data before launch. AI interpretation does not make diagnoses — assessments are confirmed by a doctor.
5. Where we store data
Data is stored in a Supabase database in the European Union (Frankfurt region, Germany). Access is restricted by technical measures: waitlist data cannot be reached through the public API — only our own server writes to it. The same signup also stays in our website server's records at our hosting provider Railway, whose server runs in the United States; that copy is a backup, so a signup is not lost if the database is briefly unreachable.
6. How long we keep it
We will keep waitlist data until the launch announcement and no longer than 12 months after it, unless you withdraw your consent earlier — in that case we delete the data without delay.
7. Your rights
You have the right to access your data, correct it, delete it, restrict processing, receive a portable copy, and withdraw consent at any time. Contact info@proactiva.app — we will reply within 30 days. You also have the right to lodge a complaint with your supervisory authority (in Lithuania: vdai.lrv.lt).
8. Data recipients
We do not sell your data or pass it to third parties for marketing. Data is processed only by our service providers (hosting and database infrastructure) operating in the EU and bound by data processing agreements.
9. Changes
When we update this policy, we will publish the new version on this page with the updated date.