English
Scope
This policy covers the public Smoothie Website and requests for, sign-in to, and use of Smoothie Studio early access. Smoothie Studio early access is currently provided through Google or GitHub sign-in. It does not cover billing, paid services, customer content outside the early-access flow, analytics, advertising, or future product features that are not active in the current version of the service.
Controller and contact details
QWIRKLABS SRL is the controller for the processing described in this policy.
Data, purposes, legal bases, and retention
We process only the information necessary to operate the Website and manage Smoothie Studio early access. To request or use Smoothie Studio early access, you sign in with a Google or GitHub account. Smoothie does not collect or store a Smoothie password for this sign-in flow. Your email address is required to request and manage early access. Without it, we cannot assess your request or provide access.
Where Smoothie Studio early access uses AI features, prompts, instructions, selected context, generated outputs, model/provider metadata, and related security or usage metadata may be processed by authorized AI providers only as needed to provide Studio functionality. We may use one or more authorized AI providers to deliver Studio functionality. Information about the categories of providers and applicable safeguards is available upon request.
Google or GitHub sign-in identity data, including provider name, provider account ID, email address, display name or name, and avatar or profile image if provided; Smoothie account and profile data, including username, account and workspace identifiers, organization metadata, access status, and timestamps; authentication and session identifiers, IP address, user agent, technical logs, and security data; provider-connection data if you connect a personal AI provider by API key or OAuth, including provider name, connection label, credential metadata such as fingerprint, last four characters, status, and timestamps, and the provider secret or OAuth token material where needed to operate the connection; prompts, instructions, selected context, outputs, model/provider metadata, and security or usage metadata where AI features are used in Smoothie Studio early access.
Authenticate users through Google or GitHub; assess and manage requests for Smoothie Studio early access; create and administer Smoothie accounts, profiles, workspaces, and active early access; route prompts and related context to authorized AI providers where needed to provide Studio functionality; communicate about that request or access; and protect the Website and Studio against abuse and security incidents.
Article 6(1)(b) GDPR for steps requested before access and for providing early access. Article 6(1)(f) GDPR for documented legitimate interests in security, abuse prevention, and service administration.
We retain active early-access records while your access remains active. Records relating to pending, denied, withdrawn, inactive, or closed early access are generally retained for up to 12 months, unless a longer retention period is required by law or is necessary to establish, exercise, or defend legal claims.
Recipients and international transfers
We may use providers that support infrastructure and hosting, authentication and access, email delivery, AI model processing where Studio functionality requires it, security, and support. They process personal data only where necessary to provide their services to us and subject to appropriate contractual or legal safeguards.
Where a provider processes personal data outside the European Economic Area, QWIRKLABS will use an applicable transfer mechanism and will provide information about the relevant safeguards on request.
Cookies, tracking, and automated decisions
The current Website and Smoothie Studio early access do not use billing, direct marketing, advertising, analytics, or non-essential tracking. We may use technically necessary cookies or session storage where needed to provide the Website or Studio securely.
We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you.
Your rights and complaints
Subject to applicable law, you may request access to, rectification, erasure, restriction, or portability of your personal data, and object to processing based on legitimate interests. You may submit a request to email@qwirklabs.gg or qwirklabs@pec.it. We may ask for information needed to verify your identity.
You may also lodge a complaint with the Garante per la protezione dei dati personali or another competent supervisory authority.
Changes to this policy
We may update this policy when the Website, Smoothie Studio early access, or applicable requirements change. We will publish the updated version on this page and update the last-updated date. Questions about this policy or transfer safeguards can be sent to email@qwirklabs.gg or qwirklabs@pec.it.