Privacy Policy

Embrace Pregnancy — The 2-in-1 of Pregnancy An app by Embrace Life Technologies S.P.A. Società Benefit

As of: April 2026

1. Data Controller

Embrace Life Technologies S.P.A. Società Benefit Bozner Str. 5B, 39044 Neumarkt (BZ), Italy

Email: [email protected] Website: https://embrace-pregnancy.app

2. Overview: Our Data Protection Principles

The protection of your personal data is of utmost importance to us. The Embrace Pregnancy app is designed so that as little personal data as possible leaves your device. Nearly all data you enter in the app — your name, your due date, diary entries, photos, and your chat history — is stored exclusively on your device and encrypted with the industry-standard AES-256. It does not leave your device.

Only when you actively use the AI companion feature or the read-aloud feature is data transmitted for that specific purpose. Details can be found in the sections below.

3. Locally Stored Data (remains on your device)

The following data is stored exclusively on your device and is never automatically transmitted to our servers or third parties:

Encryption

All of the above data is encrypted locally with AES-256-GCM before being stored on your device. Each device generates a unique encryption key. Photo data is also stored in encrypted form. Your data is never sent to our servers.

Legal basis:

• Strictly operational data (display setting, selected language): Art. 6(1)(b) GDPR — necessary to provide the app functionality you have requested.
• Health-related data (estimated due date / pregnancy week, diary entries, baby family tree content, chat history): Art. 6(1)(a) in conjunction with Art. 9(2)(a) GDPR — your explicit consent to the processing of special-category health data, given through the in-app AI consent dialog for the chat feature and through your voluntary use of the corresponding local features. You can withdraw this consent at any time in the settings.

Retention period: Local data remains on your device until you delete it via the app settings, revoke AI chat consent (which clears the chat history), or uninstall the app. No automatic expiry applies.

Data Export (voluntary, user-controlled)

You can export your data at any time as a JSON file to your device. This export file is unencrypted — you are responsible for its safe storage. There is no automatic cloud sync and no cross-device synchronisation.

4. Data Transmitted When Actively Using Certain Features

4.1 AI Companion (Verena)

When you use the AI companion Verena, the following data is transmitted to our servers and from there to our AI service provider:

No identifying data is transmitted — neither your name, nor your due date, nor a device ID or email address.

Data flow: App on your device -> Embrace Life Technologies server (Bolzano, IT) -> Anthropic (AI provider)

Retention period: The proxy server does not store your chat content. Messages are processed only for the duration of the request and are not logged afterwards. For processing by Anthropic, their own privacy policy applies (see Section 6).

The chat history on your device is retained until you manually delete it. You can delete it at any time using the reset button in the app.

Legal basis: Art. 6(1)(a) in conjunction with Art. 9(2)(a) GDPR — your explicit consent to the processing of special-category health data, given through the in-app AI consent dialog. The chat feature is disabled until consent is granted. You can withdraw this consent at any time in the settings, which also clears your local chat history.

4.2 Read-Aloud Feature (Text-to-Speech)

When you activate the read-aloud feature, the corresponding book text section (max. 5,000 characters) is transmitted for speech synthesis. This consists exclusively of companion book content — no personal data.

Data flow: App -> Embrace Life Technologies server (Bolzano, IT) -> OpenAI (TTS service)

The generated audio file is streamed back to your device. Pre-generated audio files of the app’s static content (weekly companion-book texts) may additionally be cached in Cloudflare R2 object storage to reduce latency and synthesis cost. The cache key is a content hash derived from the static text, model, and voice identifier; it contains no user identifier. Only the app’s own static content is cached — never user-generated chat content, diary entries, photos, or other personal data.

Legal basis: Art. 6(1)(b) GDPR (provision of the requested feature)

5. Technical Safeguards

6. Third-Party Providers

The backend infrastructure runs on a self-managed Proxmox cluster located in an EU colocation facility (Bolzano, Italy). Hardware is owned and operated by Embrace Life Technologies S.P.A. Società Benefit. No third-party cloud provider is involved in the internal processing chain — the only external sub-processors are the three listed below.

6.1 Anthropic (AI Companion)

For the AI companion feature, we work with Anthropic, PBC, 548 Market St, PMB 90375, San Francisco, CA 94104, USA.

Anthropic processes your chat content to generate AI responses. For the transfer to the USA, we rely on the Standard Contractual Clauses offered by Anthropic pursuant to Art. 46(2)(c) GDPR.

More information: Anthropic Privacy Policy

6.2 OpenAI (Read-Aloud Feature)

For the read-aloud feature, we use the text-to-speech service of OpenAI, LLC, 3180 18th Street, San Francisco, CA 94110, USA.

OpenAI processes exclusively the read-aloud book text sections (no personal user data). For the transfer to the USA, Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR are used.

As a technical fallback, the read-aloud feature may alternatively use the Cloud Text-to-Speech service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. OpenAI is the currently active provider in production; Google is retained as a configurable alternative to ensure service availability. In both cases, only static companion-book text sections are transmitted — no personal user data. For the transfer to the USA, Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR apply.

More information: OpenAI Privacy Policy · Google Cloud Privacy Notice

6.3 Cloudflare (Network Infrastructure and Static-Content Cache)

Our proxy server is accessible via a Cloudflare Tunnel. In this process, Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA, processes connection metadata (in particular IP addresses) to secure network access.

We additionally use Cloudflare R2 object storage to cache pre-generated read-aloud audio of the app’s own static content (weekly companion-book texts). Cache objects are keyed by a content hash and contain no user identifier. Cloudflare R2 does not receive any user-generated content — no chat messages, diary entries, photos, or other personal data. For the transfer to the USA, Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR apply.

Cloudflare does not have access to the content of your messages.

More information: Cloudflare Privacy Policy

7. Your Rights (Data Subject Rights Under GDPR)

You have the following rights at any time:

• Access (Art. 15 GDPR): You can request information about the data stored about you.
• Rectification (Art. 16 GDPR): You can have incorrect data corrected.
• Erasure (Art. 17 GDPR): You can request the deletion of your data. Since your data is stored exclusively on your device, you can delete it at any time directly in the app (Settings -> Reset data).
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR): Using the app’s export function, you can download your data as a structured, machine-readable file.
• Objection (Art. 21 GDPR)
• Automated decision-making (Art. 22 GDPR): You have the right not to be subject to a decision based solely on automated processing. The Verena AI chatbot provides informational responses only and does not make automated decisions that produce legal effects or similarly significantly affect you.
• Complaint to the competent data protection supervisory authority: Garante per la protezione dei dati personali (Italy)

For enquiries, please contact: [email protected]

8. Data of Minors

The app is intended for adult users. We do not knowingly collect data from individuals under the age of 18.

9. Changes to This Privacy Policy

We reserve the right to amend this privacy policy as needed. The current version is always available on our website. The date of the last update is indicated at the beginning of this document.

10. Contact

For data protection enquiries, please contact:

Embrace Life Technologies S.P.A. Società Benefit Email: [email protected] Bozner Str. 5B, 39044 Neumarkt (BZ), Italy

This privacy policy was prepared based on a technical analysis of the app’s source code (as of March 2026). Responsible: Embrace Life Technologies S.P.A. Società Benefit.