Legal
This Privacy Policy describes how Paolo Rivosecchi, with registered office at Via Sandro Pertini 10, Vistrorio, 10080, Italia, VAT/Tax ID 12835040010 (the "Controller", "we", "us"), collects, uses and protects the personal data of users (the "User", "you") who purchase or request the "Your Life Project" service — a personalized astrological, Vedic, numerological and/or related reading — delivered through the Sutra.co platform and with the support of artificial intelligence tools.
The processing of personal data is carried out in compliance with Regulation (EU) 2016/679 (the "GDPR") and applicable Italian/EU data protection law.
The Controller of the personal data processing described in this Policy is:
Paolo Rivosecchi
Via Sandro Pertini 10, Vistrorio, 10080, Italia
info@harmoniccircleacademy.org · P.IVA / C.F.: 12835040010
For any request regarding the processing of your personal data, you can contact us at the email address above.
To generate your personalized reading, we collect — through a form embedded in the Sutra.co platform — the following categories of data:
Date, time and place of birth are essential to perform the astrological, Vedic and numerological calculations and are therefore a necessary requirement to deliver the requested service.
The answers to the optional personal questions are filled in freely by the User and may, at the User's own discretion, contain special categories of personal data under Article 9 GDPR (for example, information relating to health, sexual life or sexual orientation, religious or philosophical beliefs).
Such information is processed solely on the basis of the explicit consent provided by the User when submitting the form, and only for the purposes described in this Policy. We recommend that the User does not share this type of information unless they expressly wish to, as the service can be fully enjoyed by providing generic answers instead.
The data collected (name, date/time/place of birth, email, personal questions) is processed to generate and send the User the requested personalized reading. Legal basis: performance of a contract / pre-contractual measures requested by the User (Art. 6(1)(b) GDPR).
Where the answers to the personal questions contain data referred to in Art. 9 GDPR, processing is based on the User's explicit consent (Art. 9(2)(a) GDPR).
The email address is used to send the reading, service-related communications, and to respond to any support requests. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).
If the User provides specific consent, the email address may be used to send promotional communications about new services. Legal basis: consent (Art. 6(1)(a) GDPR). This consent is optional and can be withdrawn at any time.
Providing your name, date, time and place of birth is necessary to deliver the service: without this data, it will not be possible to process the requested reading. Providing answers to the optional personal questions is, by contrast, entirely voluntary.
The data collected is shared with the following parties, acting as data processors under Art. 28 GDPR, exclusively for the purposes described in this Policy:
The Controller does not sell or disclose personal data to third parties for third-party marketing purposes. Data is not transmitted to parties other than those listed above, except where required by law or requested by competent authorities.
As noted in Section 4, some personal data is transferred to providers based in the United States (Anthropic, PBC) in connection with the delivery of the service. Such transfers are supported by appropriate safeguards under Articles 44 et seq. GDPR, including the Standard Contractual Clauses adopted by the European Commission. Users may request a copy of these safeguards by contacting the Controller at the details provided in Section 1.
Personal data collected to deliver the reading is retained for the time strictly necessary to perform the service. Once the reading has been delivered, the data is deleted from our systems within 30 days.
This period may be extended only where required by law (e.g. billing data, retained for the periods set out by applicable tax and civil law, generally up to 10 years).
With regard to data processed by Anthropic, PBC (the provider of the AI tools used in the preparation of the reading), retention is governed exclusively by Anthropic's own policies. The Controller has no visibility into or control over Anthropic's internal retention practices, and Users are encouraged to consult Anthropic's Privacy Policy directly at anthropic.com/privacy for further information.
As a data subject, you have the right, under Articles 15–22 GDPR, to:
To exercise these rights, please contact the Controller at the details provided in Section 1.
The Controller adopts appropriate technical and organizational measures to ensure a level of security appropriate to the risk, in order to protect personal data from unauthorized access, loss, destruction or unlawful disclosure.
The service is not intended for individuals under 18 years of age. The Controller does not knowingly collect data relating to minors. Should we become aware that data relating to a minor has been processed without the consent of a holder of parental responsibility, such data will be deleted without delay.
The Controller reserves the right to modify this Privacy Policy at any time. Any changes will be published on the website/platform along with the date of the last update. We recommend checking this page periodically.
For any question regarding the processing of your personal data, or to exercise your rights, please write to: info@harmoniccircleacademy.org.