Privacy Policy

Last Updated: December 24, 2025 | Version: 1.0 | Jurisdiction: Huesca, Spain

1. Introduction
LAI ("we," "us," or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website (letsaccelerate.it) and LAI Runtime software (collectively, the "Services").
We process personal data in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679, the EU AI Act (Regulation 2024/1689), and other applicable data protection laws within the European Union.
Beta Software Notice: LAI Runtime is currently in Beta and under active development. Features may change without notice. This beta status does not affect the applicability of this Privacy Policy.
AI System Disclosure: In compliance with Article 50 of the EU AI Act, we inform you that LAI Runtime is an Artificial Intelligence (AI) system. When you use this software, you interact with AI-powered language models that generate synthetic text, code, or data. All outputs are artificially generated by machine learning models and are not human-authored.

2. Data Controller
The data controller responsible for your personal data when you interact with our website or optional cloud-connected features can be reached by Email: privacy@letsaccelerate.it. Jurisdiction: Huesca, Spain.
Important: For the core local functionality of LAI Runtime, YOU are the Data Controller of any personal data contained in your inputs or files. LAI does not act as a Data Processor for locally processed data, as we have no access to it under our Zero-Knowledge Architecture (see Section 6).

3. Our Privacy-First Architecture
We value your privacy. By design, our AI runtime performs all processing locally on your device. There is no account signup required to use the core Services. We do not have access to the prompts you enter or the outputs you receive during local use. All input and output data remain on your device under your control.
3.1 Zero-Knowledge Architecture
For local AI processing, LAI has no visibility into, and creates no logs of, your AI interactions. We do not use your conversations or data to train our models, since we do not receive that data. Consequently, LAI cannot respond to Data Subject Access Requests (DSARs) regarding your local data - you retain full control.
3.2 Data You Control
The following data remains entirely on your device under your control: input data (prompts, text, files) you submit to the AI; output data (AI-generated responses, content, code); conversation history and interaction logs; and any files processed through the Software. Because all data remains on your device, you are solely responsible for the security, backup, and appropriate handling of your inputs, outputs, and any files processed through the Software.

4. Data We May Collect
4.1 Website Interaction Data
When you visit our website (letsaccelerate.it), we may collect: contact information you voluntarily provide (name, email address) when contacting support; communications with us (support requests, feedback); and standard web analytics data subject to your cookie consent (see Section 9).
4.2 Technical and Telemetry Data
We may collect or process certain non-personal, technical information for the purpose of delivering updates or ensuring the Service functions properly. This may include: app version and operating system type (when checking for updates); anonymized crash reports to improve stability; and aggregated, anonymized usage metrics. This data does not include your personal content, prompts, or AI outputs. Any such data collection is performed in compliance with applicable privacy laws.
4.3 Web Search Feature Data
If you choose to use the optional Web Search Feature, the search query you provide will be transmitted to third-party search providers (e.g., Google, Bing) at your explicit request. LAI acts solely as a technical conduit for this transmission - we do not store, index, or retain your search queries or the search results on our servers. The transmission is transient and ephemeral. See Section 7 for full details.

5. Legal Basis for Processing
Under the GDPR, we process personal data based on the following legal grounds:
Contract Performance (Art. 6(1)(b)): Processing necessary to provide our Services and fulfill our contractual obligations, including the Web Search Feature when you request it.
Legitimate Interests (Art. 6(1)(f)): Processing for legitimate business interests, such as improving our Services through anonymized analytics, ensuring security, and delivering software updates, where these interests are not overridden by your rights.
Consent (Art. 6(1)(a)): Where you have given explicit consent for specific processing activities, such as marketing communications or optional analytics cookies.
Legal Obligation (Art. 6(1)(c)): Processing required to comply with applicable laws and regulations.

6. How We Use Data
6.1 Service Delivery and Improvement
We use collected data to: provide, maintain, and improve our website and Services; deliver software updates and security patches; respond to support requests and communications; and improve Service stability through anonymized crash reports.
6.2 What We Do NOT Do
We do NOT: collect, access, or process your AI prompts or outputs; use your data to train AI models; sell your personal data to third parties; create profiles of your AI usage; or monitor your local AI interactions.

7. Web Search Feature
The Web Search Feature is an optional functionality that allows you to instruct the Software to query third-party search indices via the internet.
7.1 User-Initiated Transmission
This feature is active only upon your explicit request or configuration (such as clicking "search," "activate search," or "always allow web search"). By activating this feature, you acknowledge that your search terms will be transmitted to third-party search providers using your internet connection.
7.2 Third-Party Terms
Your use of the Web Search Feature is subject to the terms of service and privacy policies of the respective search engine providers. LAI is not responsible for the content, accuracy, or safety of third-party websites or search results. We do not guarantee the accuracy, safety, or legality of any third-party content retrieved via the web search feature.
7.3 Consent to International Transfer
By using the Web Search Feature, you explicitly consent to the transfer of your search query data to the applicable search provider, which may be located outside the European Economic Area (EEA), including in the United States.

8. Data Sharing and Disclosure
Given our Zero-Knowledge Architecture for local processing, data sharing is minimal. We may share data with the following categories of recipients only for website and support operations:
Service Providers: Third-party vendors who assist in operating our website (hosting, analytics), bound by contractual data protection obligations.
Legal Requirements: When required by law, court order, or governmental authority.
Business Transfers: In connection with a merger, acquisition, or sale of assets, with appropriate data protection safeguards.
We do not sell your personal data to third parties.

9. International Data Transfers
Your data may be transferred to and processed in countries outside the European Economic Area (EEA) in limited circumstances (such as when using the Web Search Feature or when third-party service providers are involved). When such transfers occur, we ensure appropriate safeguards are in place, including: Standard Contractual Clauses (SCCs) approved by the European Commission; adequacy decisions by the European Commission; or other legally recognized transfer mechanisms.
You may request information about the specific safeguards applied to your data by contacting us.

10. Cookies and Tracking Technologies
Our website uses cookies and similar technologies for the following purposes:
Essential Cookies: Required for website functionality and security. These cannot be disabled.
Analytics Cookies: Help us understand how visitors interact with our website. Require your consent.
Functional Cookies: Enable enhanced functionality and personalization. Require your consent.
You can manage your cookie preferences through our cookie consent banner or your browser settings. Please note that disabling certain cookies may affect website functionality. The LAI Runtime software itself does not use cookies or tracking technologies.

11. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected:
Local Data: Data processed locally on your device is retained under your control. You may delete it at any time by uninstalling the software or clearing local data.
Support Communications: Retained for the duration necessary to resolve your inquiry plus a reasonable period thereafter.
Telemetry Data: Anonymized technical data retained for up to 12 months for service improvement.
Marketing Consent Records: Retained until consent is withdrawn plus a reasonable period for compliance verification.

12. Your Rights Under GDPR
Under the GDPR, you have the following rights regarding personal data we hold about you:
Right of Access (Art. 15): Request a copy of your personal data and information about how it is processed.
Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
Right to Erasure (Art. 17): Request deletion of your personal data under certain circumstances.
Right to Restriction (Art. 18): Request limitation of processing of your personal data.
Right to Data Portability (Art. 20): Receive your data in a structured, commonly used format and transfer it to another controller.
Right to Object (Art. 21): Object to processing based on legitimate interests or for direct marketing purposes.
Right to Withdraw Consent: Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
Important Note: Due to our Zero-Knowledge Architecture, we cannot fulfill data subject requests regarding data processed locally on your device, as we do not have access to that data. You retain full control over local data and can delete it at any time.
To exercise any of these rights regarding data we hold, please contact us using the details in Section 15. We will respond to your request within one month, as required by the GDPR.

13. Data Security
We implement appropriate technical and organizational measures to protect personal data we process against unauthorized access, alteration, disclosure, or destruction. These measures include: encryption of data in transit (for website and web search communications); access controls and authentication mechanisms; regular security assessments and updates; and employee training on data protection.
Your Responsibility: You are responsible for maintaining the security of your device and the data stored on it while using LAI Runtime. If you choose to back up, sync, or share content generated by the Services, be aware of where that data might go and take appropriate measures to protect it.

14. Age Restriction
Our Services are intended exclusively for users who are at least eighteen (18) years of age. We do not knowingly collect personal data from individuals under 18. If you are a parent or guardian and become aware that your child has accessed or used the Software without your consent, please contact us immediately. We will take steps to remove any associated data and terminate unauthorized access.

15. Contact Information
For questions about this Privacy Policy or to exercise your data protection rights, please contact us:
LAI - Data Protection
Email: privacy@letsaccelerate.it
Website: letsaccelerate.it

16. Supervisory Authority
You have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates applicable law.
Agencia Espanola de Proteccion de Datos (AEPD) - www.aepd.es
If you are an EU consumer, you may also access the European Commission's Online Dispute Resolution (ODR) platform.

17. Regional Provisions
Certain jurisdictions have specific privacy requirements. Please refer to the corresponding sections in our Terms of Use and EULA for region-specific provisions applicable to users in: People's Republic of China; India; Kingdom of Saudi Arabia; Philippines; Japan; Germany; Italy; France; Poland; and United States.
For users in India: Complaints regarding the Software may be directed to contact@letsaccelerate.it. Acknowledgment within 24 hours; resolution within 15 days.

18. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will change the "Last Updated" date at the top of this Policy. We will notify you of significant changes by posting the new policy on our website and, where required, through the app or by other appropriate means. We encourage you to review this policy periodically.
Your continued use of the Services after the effective date of the updated Privacy Policy will constitute your acceptance of those changes.

19. Relationship to Terms of Use
This Privacy Policy is incorporated into and forms part of our Terms of Use and End User License Agreement (EULA). In the event of any conflict between this Privacy Policy and the Terms of Use, the Terms of Use shall prevail except with respect to matters specifically addressed herein regarding data protection.
By using LAI Runtime and our Services, you acknowledge that you have read and understood this Privacy Policy.