Privacy Policy

1. What this policy covers

This policy covers the data of the people who use PMU Studio Vault: the studio owner, the members of the team, visitors to the website.

The data of the studio's own clients — records, health questionnaires, signed consents, photos — follows different rules: the studio is the controller of that data and we process it only on its behalf, as a processor. That relationship is set out in the Data Processing Agreement published at /legal/dpa, which forms part of the contract.

2. What we process and why

Account data: name, email address, studio name, language, time zone, password in hashed form (bcrypt, never in clear text). Needed to create and run the account. Legal basis: performance of the contract.

Billing data: business name, address, country, VAT number where provided, invoice history. Legal basis: performance of the contract and tax and accounting obligations.

Proof of acceptance of the terms: email address, version of the documents accepted, date and time, country, browser type and a non-reversible fingerprint of the IP address (hash). We do not store the IP address in clear text. Legal basis: our legitimate interest in being able to show when and what was accepted, and legal obligation.

Technical operating data: server logs and a record of actions taken inside the application (who created or changed what, and when). Used for security and for reconstructing events. Legal basis: legitimate interest in the security of the Service.

Communications: service emails (welcome, trial expiry, subscription notices, support replies). Legal basis: performance of the contract.

3. What we do not do

We do not sell data to anyone, for any reason.

We do not use the studio's client data for our own purposes: we do not analyse it, we do not aggregate it into product statistics, we do not use it to train models.

We show no advertising inside the application and use no profiling cookies there: inside the application there are only technical cookies, needed to keep the session open and remember language and theme.

On the public website (home page, sign-in and sign-up), and only if you accept it in the cookie banner, we use the Meta pixel (Meta Platforms Ireland Ltd.) to measure our advertising on Facebook and Instagram. When you open your studio we tell Meta that a trial has started, together with your email address and country in the form of a non-readable fingerprint (SHA-256 hash), the IP address and the browser type of the request. We never send Meta anything you enter in the application, nor any data about the studio's clients. For this data Meta is a joint controller with us and also processes it under its own policy (facebook.com/privacy/policy). Legal basis: your consent, which you can withdraw at any time from the “Cookie preferences” link at the bottom of the site; if you decline, the site and the application work just the same.

Prior consent applies to visitors from the European Economic Area, the United Kingdom or Switzerland, and whenever the country cannot be determined. For visits from other countries (for example the United States, Canada, Australia) the pixel is active from the moment the site opens, with a notice and a “Don't track me” button that turns it off; we also honour the browser's Global Privacy Control signal, which counts as “Don't track me”. The country is derived from the network of the connection and is not stored.

Anonymous visit statistics: we count how many times the home page and the sign-up page are opened, how many sign-ups are submitted, the type of error shown in the form if any, how many people accept or decline cookies, and whether the visit comes from one of our ads. These are only daily numbers: no cookies, no IP address, no identifier, nothing that could lead back to a person.

4. The built-in assistant

The application includes an assistant that answers questions about using the software. The model is provided by Anthropic PBC, which runs it on our behalf. It receives the text of the question and context about the page, not the client archive.

The assistant is not a medical or legal adviser, and its answers are not used to train third-party models.

5. Who we share data with

With the providers that process data on our behalf, listed below. Each is bound by a contract requiring it to process data only on our instructions:

Vercel Inc. — application hosting and file storage (photos and attachments). Execution in the Frankfurt (Germany) region.

Neon Inc. — managed database holding the application data.

Resend (Plus Five Five, Inc.) — transactional email. No health data is ever placed in the body of an email.

Stripe Payments Europe Ltd. — subscription payments and invoicing. Card details are handled by Stripe directly and never pass through our systems.

Google Ireland Ltd. — only for users who choose to sign in with Google: identity verification at sign-in.

Anthropic PBC — the application's built-in assistant: it receives the text of the question and page context, never the client archive. Conversations are not used to train models.

With judicial or public authorities, where we are required to do so by law.

With a buyer of the business, in the event of a sale, under the same safeguards and with prior notice to data subjects.

6. Where the data is

The application and the files run and are stored in the European Union (Frankfurt region).

Some of the providers listed are established in the United States. Where a transfer outside the European Economic Area is necessary, it takes place on the basis of the Standard Contractual Clauses approved by the European Commission, or an adequacy decision, with supplementary measures as appropriate.

7. How long we keep it

Account data and data entered in the studio: for the duration of the relationship.

If the free trial is not converted into a subscription: studio, data and files are permanently deleted 30 days after the trial ends. Before that date you receive two warning emails and you can download a complete copy of your data.

If you cancel an active subscription: the data remains available until the end of the paid period and is permanently deleted 30 days later, unless you ask us to delete it sooner, in which case we act within 30 days of the request.

Invoices and accounting records: kept for the period required by tax law, which is longer and prevails over the deletions described above. Invoices contain billing data, not client data.

Proof of acceptance of the terms: kept for the duration of the relationship and the subsequent limitation period.

8. How we protect it

Passwords stored only in hashed form with bcrypt. Transmission always over HTTPS.

Photos and attachments stored privately, with no public address: every file passes a session and studio-membership check.

Data separated by studio: every query is scoped to the studio of the signed-in user.

A record of the actions taken in the application, with author and date.

No measure makes a breach impossible. In the event of a personal data breach we comply with the notification duties under the Regulation and inform affected customers without undue delay.

9. Your rights

You may request access, rectification, erasure, restriction and portability of your data, and object to processing based on legitimate interest. Write to info@pmustudiovault.com from your account address: we reply within 30 days.

The application includes a full export function: you can download your data at any time without asking us.

If you believe the processing infringes the Regulation you may contact the Cypriot data protection authority (Office of the Commissioner for Personal Data Protection, 15 Kypranoros, 1061 Nicosia, commissioner@dataprotection.gov.cy) or the supervisory authority of your country of residence.

10. Minors

The Service is aimed at professionals and is not intended for anyone under 18. We do not knowingly collect data about minors as users of the Service.

Where the studio processes data about minor clients, obtaining the consent of the holder of parental responsibility is the studio's task, as controller of that data.

11. Changes

If we change this policy materially we will tell you by email or in the application at least 30 days beforehand. The version in force is always the one published on this page, with the date shown at the top.