Privacy policy

This policy covers the dialogicom.com website (and its previous address, dialogicom-ai.com, where the app still lives) and the Minerva application, on the web and on mobile. It is written to be read: if anything is unclear, write to us and we will answer.

Who processes the data

The data controller is Dialogicom s.r.l.s., Via Francesco Olgiati 26, 20143 Milan, Italy, VAT IT08940250965. For anything concerning your data write to info@dialogicom.com.

What we collect, and why

Data	Why	Legal basis
Account: email address and, if you sign in with Google, your Google profile name and picture	To create the account, let you sign in, and tie conversations to you	Performance of the contract
Conversations and materials: the questions you ask, the answers you receive, the files you upload and what is derived from them	To provide the service, let you find past conversations, and align answers to your own materials	Performance of the contract
Inclusive teaching: the adaptations you choose (simple language, guided steps, comprehension checks) and, if you do learning support, the functioning profile (the ICF codes with their qualifiers), saved under a reference you choose yourself	To adapt answers and materials to a pupil, and to find the same configuration again next time	Performance of the contract
Usage: amount of service used, type of operation, date	To compute the free allowance and your subscription's allowance, and to show your usage in your area on the website	Performance of the contract
Billing: name or company name, address, tax code or VAT number, if you enter them	To issue the tax documents for your purchases	Legal obligation
Preferences: interface language, your confirmation of sending content to artificial intelligence providers (date), your choice about promotional emails (date and where you made it)	To write to you in your language, and to be able to show what you agreed to and when	Performance of the contract; duty to document consent
Promotional emails: your email address, only if you ticked the optional box at sign-up or in your area	To send you news and offers from Dialogicom	Consent, which you can withdraw at any time
Technical data: IP address, device and browser type, access and error logs	To keep the service running, protect it from abuse, and investigate faults	Legitimate interest in security
Activity log: what you do in the app (content you create, tests and scores, reviews, exports, shares, sign-ins), with the date and a short summary	To support you when something does not work and to improve the quality of the service	Legitimate interest

About the functioning profile. Those data are not about you but about one of your pupils, and they describe learning difficulties: they are special category data under Article 9 GDPR. This is why the app never asks for a diagnosis and explicitly asks you not to write names: the pupil is identified by a reference you choose («3A-07», «Wednesday»), and we have no way of telling who they are. You decide what to enter, and you, with your school, remain accountable to the pupil's family; we process those data on your behalf, only to produce the adapted material, and we delete them with your account.

Payment card details never pass through us and we do not store them: payment happens on our provider's pages, and they process those details as an independent controller.

Who else sees them

To run the service we rely on providers who process data on our behalf, as processors, and only as far as needed:

• OpenAI (United States): language processing to produce answers and materials, search in the documents you upload, reading scanned pages, generated images, fallback speech synthesis. See the section below.
• ElevenLabs (United States): speech synthesis, when you ask to listen to an answer.
• Resend (United States): sending emails.
• Google Firebase Cloud Messaging (United States): delivering push notifications, if you turn them on.
• OVHcloud (European Union): hosting and database infrastructure.
• Google Drive (United States): backup copies, encrypted in transit and with restricted access.

Payments, which happen only on the website and never inside the app, are handled by Stripe as an independent controller. We do not sell data and we do not use it for advertising. For providers based outside the European Economic Area, transfers rely on the standard contractual clauses approved by the European Commission or on the EU-US Data Privacy Framework. For any question about our providers write to info@dialogicom.com.

When we send you an alert, we record whether and when you open it, and whether you open it from the app or by tapping the notification on your phone: only the first time, not how many times you go back to it. This is linked to your account, so it is not anonymous, and it is visible, together with your name and email, to whoever administers the platform. It is there to tell us whether an alert reached you, so we can decide whether to resend it: we do not use it to measure how much you use the app.

When you use the assistants on the site (Wilhelm, Patrick, Cocò, Giulietta, Leonardo, Harmony Hub and Mary Star) we record the IP address from which you send each message and sign in. We need it for the security of the service and to protect it from abuse, on the basis of our legitimate interest. The IP address is never sent to the model that generates the answers, does not appear in the conversations and is visible only to whoever administers the platform. We keep it for at most 12 months, after which it is deleted.

We also record the activities you carry out in the app: what content you create (conversations, tests, flashcard decks, class tests, lessons, maps), the tests you complete with their score, your reviews, exports and PDFs, and what you share with a link. The log is linked to your account and is visible to whoever administers the platform, so we can support you and improve the quality of the service; we keep it for 12 months. It never contains passwords, nor the data of functioning profiles, nor the full text of what you write: only a short summary.

Artificial intelligence

Minerva produces answers, materials, images and speech with artificial intelligence systems run by third-party providers (currently OpenAI and ElevenLabs, see above). To do so, those providers receive the messages you write, the files you attach and the settings needed to answer (subject, school level, chosen adaptations). They do not receive your email address, your name or your password. Before first use the app asks you to confirm this; without your confirmation the features that need it stay off. Under the providers' terms for business use, the data sent is not used to train their models and is kept by them only for the limited time needed to prevent abuse.

The emails we send

Service emails, to every account: address confirmation, password reset, notices about your allowance (when it is running low, when it has run out, when it changes or renews) and about subscriptions. They are part of the service and cannot be turned off while the account exists.

Promotional emails (news, offers, invitations to subscribe): only if you gave consent with the optional box, which is never pre-ticked. You can withdraw it at any time with the “unsubscribe” link at the bottom of every promotional email or with the switch in your area on the website. Nothing is sold inside the app: purchases and subscriptions happen only on the website.

Sharing with a link

When you share a test or a flashcard deck with “Share with a link”, we keep a copy of that content (texts and images) and the name your account shows, for as long as the link is active: at most 90 days. Of the link itself we store only a code derived from it in a way that cannot be reversed, not the link. Whoever opens the link sees the title, how many items it contains and your name; nobody sees your email. Whoever adds it gets their own copy, which stays theirs even after the link expires, is revoked or your account is deleted (in that case without your name). You can revoke a link at any time from “Shared links”: the copy we were keeping is deleted at once, and the line with the title and the number of additions disappears after 30 days. Whoever receives content can report it (“Report”: the content and who sent it reach us, and we review it) and block the sender, who from then on cannot send them anything; the list of blocked senders is in “Blocked senders”, where they can be unblocked.

Reviews

If you write a review on our site (about Dialogicom or about Minerva), we keep your rating, the text, the name and the optional company or role you enter, your email and, if you are signed in, the link to your account. We publish only the rating, the text, the name and the company or role, and only after checking the review, with your consent. The email is never published: we use it only to check the review. Of your connection we keep only an irreversible code, to limit abuse. You can ask us to remove your review at any time by writing to info@dialogicom.com. If you choose to publish it on Google as well, you do it yourself with your Google account, under Google’s terms.

How long we keep them

• Account, conversations and materials: as long as the account exists. On deletion they are removed immediately.
• Tax documents and accounting record: 10 years, as the law requires, even after the account is deleted, without your name: amounts, dates and transaction references remain, not your personal details.
• Inclusive teaching settings and functioning profiles: as long as the account exists. On deletion they are removed immediately, along with the rest.
• Proof of consent (date and origin): as long as the account exists, and for promotional emails also after withdrawal, so we can show when consent was given and withdrawn.
• Technical logs: up to 12 months.
• IP addresses of messages and sign-ins to the assistants on the site: at most 12 months, then deleted.
• Activity log in the app: 12 months. When the account is deleted it is removed immediately; only an anonymous line remains, saying when an account was deleted, not whose.

Deleting your account and data

You can delete your account yourself, from the app (on your phone or in the browser, at dialogicom-ai.com/en/minerva): menu → “Delete account”. The operation is immediate and permanent, and applies to every Dialogicom product, because the account is one. The account, the linked identities (Google, Apple, with their tokens revoked), lessons, profiles, conversations, uploaded materials, settings, the usage log and any remaining credits are deleted; credits are not refunded automatically, so for a refund write to us before proceeding. Only tax documents already issued and the accounting record remain, which the law obliges us to keep, without your name. Alternatively you can write from the email address of your account to info@dialogicom.com with the subject “Account deletion”: we do it within 30 days. If you would rather delete only part of it, such as single conversations or materials, you can do that yourself in the app, without writing to us.

Your rights

You can ask to access your data, to correct it, to erase it, to restrict its processing, to receive it in a machine-readable format, and to object to processing based on our legitimate interest. Write to info@dialogicom.com: we answer within one month. If you believe your data is not being handled properly you can complain to the Italian data protection authority, the Garante per la protezione dei dati personali (garanteprivacy.it).

Age

Dialogicom services, Minerva included, are meant for adults: you must be at least 18 to create an account, and we ask you to declare it when you sign up. If we learn that an account belongs to a minor, we delete it. Whoever holds parental responsibility can ask us to do so at info@dialogicom.com.

That rule is about whoever holds the account. If you are a teacher using inclusive teaching, you may record observations about your students at any school level, young children included: those people hold no account here and are not reading this page. Before entering that information you must be entitled to do so, and whoever holds responsibility for that child must be informed. Do not write names: a student is identified by a code you choose.

Cookies

We only use technical cookies, needed to keep you signed in and to remember your preferences: they require no consent and are not used to profile you. We use no advertising cookies and no third-party tracking. Details are on the dedicated page.

Changes

If we change this policy we will publish the updated version here, with its new date. If a change materially affects how your data is used we will tell you by email or inside the application.

Last updated: 27 September 2026.