Website Privacy

Who is responsible

Gianfranco Gasbarri, acting personally in Portugal, is the controller for this marketing website. Email questions or privacy requests to privacy@hearworthy.com.

This page covers the public Hearworthy website. It does not cover the future iPhone app, app accounts, prompts, generated scripts, audio, libraries, payments, or subscriptions.

Data this site handles

• Cloudflare processes request and security metadata needed to deliver and protect the site. This can include an IP address, request details, device or browser details, timestamps, and security signals.
• Hearworthy can view aggregate Cloudflare zone metrics such as request, bandwidth, error, and cache totals.
• If you email Hearworthy, the controller receives your address, message, attachments, and normal email-routing metadata.
• If the App Store link is active and you choose it, your browser connects to Apple. The link contains the campaign label hearworthy-site, not an identifier assigned to you by Hearworthy.

The site has no account, contact form, client analytics beacon, advertising pixel, session replay, or site-side conversion event. It does not use cookies, local storage, or similar browser storage for analytics.

Why the data is used

Hearworthy relies on legitimate interests to deliver a secure website, prevent abuse, diagnose errors, and understand aggregate site operation. These limited uses help keep the public site available without tracking a visitor across pages or services.

When you choose to email, Hearworthy uses the message to answer you and handle the request. The legal basis depends on the request and can include legitimate interests, steps you ask for before a contract, or a legal obligation.

Providers and retention

Cloudflare

Hosting, security, DNS, aggregate zone analytics, and email routing.

Data: Request and security metadata, aggregate site metrics, and email-routing metadata.

When: A visitor requests any site page or sends email to the privacy address.

Retention: Cloudflare keeps service data under the account settings, contract, and operational requirements in force. Hearworthy does not keep a separate raw traffic or site-analytics dataset.

The controller's destination mailbox provider

Receive and store messages forwarded to privacy@hearworthy.com.

Data: The message, sender address, attachments, and email-routing metadata.

When: A visitor chooses to send email.

Retention: The controller keeps a message only while it is needed to answer or handle the request, then deletes it. Provider backups and security logs follow that provider's schedule.

Apple

Provide the external App Store listing and acquisition report.

Data: The browser request and the hearworthy-site campaign label after a visitor chooses the App Store link.

When: The app-store release state is active and a visitor follows the link.

Retention: Apple controls this processing under its own policy and account settings.

International transfers

Cloudflare and other providers can process data outside Portugal or the European Economic Area. Where required, the provider must use a valid transfer safeguard. Cloudflare states that it uses the EU-US Data Privacy Framework and Standard Contractual Clauses for relevant transfers. Ask privacy@hearworthy.com for information about the safeguards that apply to a request.

Your rights

Depending on the law and the data involved, you can ask for access, correction, deletion, restriction, or portability, and you can object to processing based on legitimate interests. Send a request to privacy@hearworthy.com. Hearworthy may need enough information to confirm your identity.

You can also complain to Portugal's Comissão Nacional de Proteção de Dados.

Policy owner

Policy owner and approver: Gianfranco Gasbarri. Material changes will appear on this page with a new effective or review date.