PreventivOk Privacy Policy

Last updated: 07/08/2026


1. Data Controller

The data controller is Augello Antonio, acting as a natural person. PreventivOk is the name of the service.

Address: Via Scaramuzzi, 6, 71013 San Giovanni Rotondo (FG), Italy

Contact email: [email protected]


2. Categories of Data

PreventivOk may process:

- username, email address and password stored using hashing

- profile, tax, professional and contact data

- client data entered by the user

- quotations, items, notes, costs, payments and collection status

- generated or uploaded PDF documents

- support requests and communications

- strictly necessary technical, security-log and error data

- marketing preferences and evidence of consent

- technical identifiers, product, status and subscription period received from Apple or Google

- if the user activates and uses Poki, the data described in the dedicated sections that is relevant to the request.

Data may be accessed by the relevant user and, where necessary, by Augello Antonio, authorised persons and technical providers used to deliver, protect and support the service.


3. Purposes of Processing

Data is processed to create and manage accounts; manage clients, quotations, costs and payments; generate PDFs; synchronise data; provide requested support; and verify the plan. If the user activates and uses Poki, strictly necessary data is processed to understand the request; retrieve authorised information; assist with client management and quotation creation or editing; generate PDFs; prepare communications; assist with costs, payments and collections; explain tax and administrative data calculated by the backend; and propose reminders and available operations. The question and visible answer may also be retained temporarily, after redaction and encryption, to improve Poki’s language understanding, relevance and tool execution. Technical data may be processed for security, abuse prevention, service protection, error diagnosis and operational continuity. Promotional communications are a separate, optional purpose.


4. Legal Bases

Performance of a contract or pre-contractual measures: account, clients, quotations, PDFs, synchronisation, plan verification, requested support and Poki only after voluntary activation and during use. Activating Poki is a separate, revocable feature choice and is not marketing consent.

Legitimate interests: security, prevention of abuse and fraud, service protection, necessary technical logs, error management and improvement of Poki’s understanding, relevance and tool execution through temporary redacted and encrypted retention, subject to the required balancing and the right to object.

Consent: only for marketing and other processing that expressly requires it. Marketing consent is separate, optional and revocable; it is not the basis for processing necessary to provide the service.


5. Apple and Google Subscriptions and Historical Stripe Data

New paid subscriptions are available exclusively through the Apple App Store or Google Play Store. PreventivOk does not offer web checkout and does not process or store complete card data. Purchases, renewals, cancellations and refunds are handled by the store under its terms. PreventivOk receives only the technical information needed to verify the purchase, product, status and subscription period and enable the plan. Apple and Google process data under their own notices and terms.

Stripe is no longer available for new subscriptions. Technical and administrative data relating to past subscriptions may be kept for as long as needed to manage the relationship, comply with legal obligations and protect legal rights.


6. Providers and Recipients

Data may be processed by selected technical providers only as needed to deliver, secure and manage the service:

- Hetzner, for hosting, databases and object storage in the European Union

- Cloudflare, for content delivery, network availability and security

- Apple and Google, for authentication when chosen and for purchases and subscriptions in their stores

- Amazon SES, in the Milan region, for email delivery

- OpenAI, provider of the artificial intelligence models used by Poki, only after voluntary activation and during use

- Sentry, for crash monitoring and technical error diagnosis; error messages, stack traces and technical context data may be transmitted, while automatic default transmission of PII is disabled.


7. Transfers Outside the European Economic Area

Hetzner’s primary hosting and Amazon SES are configured in the European Union. Processing or access from countries outside the EEA may nevertheless occur as follows:

- Cloudflare: global network and entities or subprocessors in the United States and other countries listed by the provider; applicable safeguard: an adequacy decision where available and European Commission Standard Contractual Clauses for other transfers

- Amazon Web Services: limited access or transfers necessary for delivery, maintenance, support or legal obligations, including from the United States or subprocessor countries; applicable safeguard: Standard Contractual Clauses incorporated into the AWS DPA and supplementary measures

- OpenAI: OpenAI Ireland and affiliates or subprocessors, including in the United States and countries published in its subprocessor list; applicable safeguard: an adequacy decision where available or Standard Contractual Clauses under the OpenAI DPA

- Sentry: infrastructure and entities or subprocessors in the European Union and the United States; applicable safeguard: an adequacy decision and the Data Privacy Framework where applicable, or Standard Contractual Clauses under the Sentry DPA.

A data subject may request a copy of or information about safeguards by writing to [email protected]. Current terms and lists are available in each provider’s DPA and official pages.


8. Poki — Artificial Intelligence Assistant

Poki is the AI assistant integrated into PreventivOk for users with an active Premium plan. Availability may be rolled out progressively and may require an app update. Use is optional and requires separate activation: accepting the Terms and acknowledging the Privacy Policy do not activate Poki. Processing starts only when the user activates and uses it; disabling Poki stops access without removing other Premium features.

Depending on the functions made available in the app, Poki may consult authorised data; create new clients; create or edit quotations, prices, quantities, VAT, discounts and descriptions; generate PDFs; prepare emails and send them only after confirmation showing the recipient, subject, body and attachments; create, edit or delete costs and payments; update a quotation’s payment status; and create separate reminders. Every operation that creates, changes, deletes or sends data requires a preview, summary and explicit confirmation. Poki cannot edit or delete existing clients, change tax settings or credentials, manage accounts or subscriptions, perform bulk deletions, delete the account, access others’ data, send bulk campaigns or make autonomous decisions with significant effects.

Poki is identified as an AI assistant: answers, extractions and transcriptions may be incomplete, inaccurate or outdated and must be checked by the user; they do not replace tax, legal, accounting, medical or financial advice. Authentication, authorisation, account isolation, data validation, official tax calculations and amounts remain deterministic in the Django backend.

To preserve context during an active chat, Poki stores the last ten relevant exchanges on the server, up to a total of 30,000 characters, using application-level encryption. The content is used only to formulate subsequent answers in the same chat, is not available as browsable history, and is deleted when the chat is closed. The app stores only the active chat identifier and, on the next launch, deletes any chat left open. This operational memory is separate from copies that may be retained for product improvement.

To improve Poki’s language understanding, relevance and tool execution, PreventivOk may retain the question and visible answer for no more than 90 days after automated redaction and application-level encryption. Redaction reduces recognisable data, but the residual content continues to be treated as personal data. Internal access is restricted to the owner, opens one conversation at a time and is recorded without copying text into the audit. Retention relies on a balanced legitimate interest: users may object at any time and erase captures early from settings. Objecting does not prevent use of Poki. Users must not enter passwords, authentication codes, complete card data, health data, patient names, special-category data, data without a valid legal basis or unnecessary information. Poki and the backend may block, mask or reject such content. By PreventivOk’s choice, user and client data is not designated for model training, other users or global catalogues.


9. Data Processed by Poki

When activated and used, Poki processes only data relevant to the request: text messages; audio, PDFs or images voluntarily supplied when the relevant feature is available; necessary profile or client data; quotations and items; costs, payments and collection status; viewable tax settings; and minimised backend-tool results. The backend selects data according to the request and permissions: not all account data is sent automatically, and complete documents are transmitted only where indispensable. Passwords, credentials, complete card data, health data, patient names, unnecessary third-party data and unlawful content are prohibited. Filters and controls reduce risk, but the user must minimise what they communicate.


10. Artificial Intelligence Provider

To provide Poki, data strictly necessary for the request is sent to OpenAI through calls made exclusively by the Django backend; the API key is not exposed in clients. Requests use store=false and PreventivOk does not enable voluntary data sharing for training. OpenAI may retain technical abuse-monitoring logs for up to 30 days. Processing is governed by the OpenAI DPA; transfers and safeguards are described in the dedicated section. No data is sent to OpenAI before voluntary activation and actual use of Poki.


11. Data Security

PreventivOk adopts technical and organisational measures intended to protect personal data against unauthorised access, loss, alteration or improper disclosure. Verified measures include HTTPS encryption in transit, authentication and access controls, limiting access to authorised persons and services, primary hosting in the European Union and maintenance of application components. Measures are reviewed in light of the data, technological change and processing risks. This description is not an absolute security guarantee.


12. Data Retention

Data is retained under the following criteria:

- account, profile, clients, quotations, items and PDFs: for the life of the account, subject to requested deletion and applicable obligations

- costs, payments and administrative documents: for applicable accounting, tax or claims periods, up to 10 years where required

- support: until closure and necessary follow-up

- internal technical, security and error logs: no more than 90 days

- marketing: until consent is withdrawn or the purpose ends; evidence of consent and suppression data remain as long as needed to demonstrate and honour the choice

- individual email sending or error logs: after 90 days the address, user and error are deleted or made non-identifying; bounce and complaint data remain in the suppression list as long as needed to prevent further sending

- Apple and Google data: for plan verification, support and disputes within applicable periods

- historical Stripe technical identifiers: no more than 10 years after the historical relationship ends, then deleted; documents subject to tax duties follow their statutory periods

- Poki: the question and visible answer, after redaction and encryption, for no more than 90 days for product improvement unless the user objects or erases them early; structured drafts for no more than 30 days; execution metadata for no more than 90 days; audit records of administrative openings for no more than 12 months without text; OpenAI may retain abuse-monitoring logs for up to 30 days.


13. Marketing and Amazon SES

Promotional campaigns are sent only to users with valid marketing consent. The choice is separate, optional and not preselected; refusal does not prevent use of the service. Consent may be withdrawn at any time using the unsubscribe link or by contacting the controller. Amazon SES is used for delivery. PreventivOk uses and persists only sending, error, bounce and complaint data in the application; it does not use or persist individual open or click events in its database.


14. Client Data Entered by Users

Professional users determine the purposes and legal basis for processing their clients’ data and must be authorised to enter it in PreventivOk. Augello Antonio processes such data to provide the service under the user’s instructions and does not use it for incompatible purposes. For professional users, the Article 28 GDPR Data Processing Agreement forms an integral part of the service terms and is available at https://preventivok.com/accordo-trattamento-dati/.


15. User Rights

Where provided by law, individuals may request access, rectification, erasure, restriction, objection and data portability. They may withdraw consent without affecting prior processing and may complain to the Italian Data Protection Authority or another competent authority. Poki is not intended to make solely automated decisions producing legal or similarly significant effects.

To exercise rights or request information, contact [email protected]. Proportionate identity verification may be required where necessary.


16. Changes to this Privacy Policy

The Privacy Policy may be updated. For material changes, the new version will be shown and acknowledgement recorded; acceptance of the Terms is not privacy consent for optional processing.