Socializza privacy notice
Draft, not in force. Version 0.1 of 6 October 2026.
This notice takes effect on {{EFFECTIVE_DATE}}.
This notice explains how we process your personal data when you use Socializza, under Articles 13 and 14 of Regulation (EU) 2016/679 ("GDPR"). "We" means ITALDRONI S.r.l.
1. Controller
Socializza is a product of ITALDRONI S.r.l. ITALDRONI S.r.l. is the controller of the processing described in this notice.
ITALDRONI S.r.l. has its registered office in Via Camillo Benso Conte di Cavour 13, 10019 Strambino (TO), Italy, VAT number and tax code 13399080012, REA number TO-1360305. Its share capital is EUR 3,000.00, fully paid up. Its certified email address (PEC) is italdroni@ultracert.it.
For any question about your data and to exercise your rights, write to privacy@socializza.com.
We have not appointed a data protection officer.
2. What this notice covers
We act as controller for:
- the waiting list;
- member accounts, sign-in and two-factor authentication (2FA);
- billing and payments;
- security and abuse-prevention logs;
- product counters;
- device tokens for push notifications;
- everything that takes place in a personal workspace (section 10).
For the content of a business workspace we act as processor on behalf of the customer. Section 12 explains what changes.
At launch Socializza connects Facebook Pages, Instagram, Threads and X, from the website and from the app for iOS and Android.
This notice exists in Italian, English, Spanish, French and German. In the event of any discrepancy the Italian text prevails.
3. Terms used
A workspace is a customer's space in Socializza, with a plan, billing, its accounts and its agents.
An account is a social account connected to Socializza, such as a Facebook Page or an Instagram profile.
An agent is an artificial intelligence (AI) program that you choose and run yourself, outside Socializza.
A grant links an agent to an account with the scopes, the mode and the limits that you choose on Socializza's consent screen.
An approval record documents, for each post, how a person examined it and with what outcome.
A personal workspace is a workspace used for purely personal or household purposes, outside any professional or business activity. Every other workspace is a business workspace.
4. Processing, data, legal bases and retention
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| Waiting list, confirmation and launch notice | Email; optional answer to the question "Which agent do you use?", 200 characters at most; sign-up date | Art. 6(1)(b) GDPR, steps taken at your request prior to entering into a contract | 12 months from launch if you do not sign up. Earlier, if you ask for erasure. |
| Member accounts, sign-in and 2FA | Email, name, role in the workspace, language, 2FA method (email or authenticator app), session and device data for sign-in alerts | Art. 6(1)(b) GDPR, performance of the contract | For the life of the account. After deletion of the workspace, deleted within 30 days. |
| Billing and payments | Workspace name and country, VAT number, customer reference at Stripe, plan, purchase channel (Stripe, Apple, Google), subscription status and expiry | Art. 6(1)(b) GDPR, performance of the contract; for invoices, Art. 6(1)(c) GDPR, legal obligation | Invoices for 10 years, as Italian law requires. Other data until deletion of the workspace, then deleted within 30 days. |
| Security and abuse prevention | IP address, date and time, request and outcome in the security logs of sign-in and abuse prevention; counts for the rate limit | Art. 6(1)(f) GDPR, legitimate interest in protecting the service and the people who use it | 30 days. We remove personal data at ingestion from the operational logs and metrics. The IP address of anyone who fills in the waiting-list form stays in memory only, for the limit of 10 sign-ups per hour, and does not enter the database. |
| Product counters | Daily counts per workspace, account and grant of published posts, agent calls and searches | Art. 6(1)(f) GDPR, legitimate interest in applying the plan limits and measuring use of the service | Until deletion of the workspace, then deleted within 30 days. |
| Push notifications | Device token; opaque notification identifier | Art. 6(1)(b) GDPR, performance of the contract | For the life of the account. After deletion of the workspace, deleted within 30 days. |
| Data deletion requests from Meta | The Facebook identifier, specific to the Socializza app, of the person who connected a Facebook Page or an Instagram account, kept on the connected account; the confirmation code of the request | Art. 6(1)(f) GDPR, legitimate interest in carrying out the deletion requests Meta forwards to us at https://app.socializza.com/meta/data-deletion | The identifier, while the account stays connected or until the deletion request. The confirmation code, 180 days, for the request's status page. |
| Reports and content decisions (Regulation (EU) 2022/2065) | Name and email of the reporter; grounds of the report and the reported content; decision, statement of reasons, challenge and reply | Art. 6(1)(c) GDPR, legal obligation (Articles 16, 17 and 18 of Regulation (EU) 2022/2065); for the challenge, Art. 6(1)(b) GDPR (section 15.10 of the terms of service) | 12 months from the final decision. Longer only until the end of a dispute over the decision. |
| Personal workspace | Connected accounts, content, agents, grants, records (section 10) | Art. 6(1)(b) GDPR, performance of the contract | Per item, in the table in section 10 |
| Third-party data in a personal workspace | Username and text of comments, mentions, direct messages and search results | Art. 6(1)(f) GDPR, legitimate interest in providing the service the user requested | 30 days at most |
5. Waiting list
We send you a confirmation email when you sign up and a notice when Socializza opens. Each sign-up also generates an internal notification to ITALDRONI with your address and your answer.
We do not send you newsletters or promotions. They would require your separate consent, under Art. 130 of the Codice privacy (the Italian Personal Data Protection Code), and we send none at launch.
6. Member accounts and sign-in
2FA is mandatory for workspace owners and admins and available to every member. We alert you to sign-ins to your account. We ask you to authenticate again before you change a grant, use the kill switch or change billing.
Our service emails carry approvals, alerts and sign-in links. They contain the account username, the agent name and a link to the app. They never contain the text of posts, media or comments.
7. Payments
On the web, payments go through Stripe, via Stripe Payments Europe, Limited. If you buy a plan in the app, the seller is Apple (App Store) or Google (Google Play), under its own terms.
Stripe processes payment data partly as an independent controller and partly as a processor on our behalf, under its own data processing agreement. Fraud-prevention, anti-money-laundering and identity-verification checks are processing by Stripe as controller, described in its privacy notice. Apple and Google process purchase data as independent controllers, under their privacy notices.
From Stripe, Apple and Google we receive subscription data, such as product, status and end of the period. We never put workspace content in Stripe's description fields or metadata.
8. Security, counters and no tracking
The public pages of the website set no cookies. Neither the website nor the app uses analytics tools, tracking tools or third-party scripts.
Product counters count actions, not people. We do not build profiles.
Security logs serve to block unauthorised access and attacks, and to reconstruct an incident.
9. Push notifications
A push notification contains only an opaque identifier. When you open the notification, the app downloads the content from our servers in the European Union.
To deliver notifications, Apple Push Notification service (APNs) and Google Firebase Cloud Messaging (FCM) receive your device token and that identifier. They receive no text, media or account names.
10. Personal workspace
If you use Socializza for purely personal or household purposes, the GDPR does not apply to you as a user (Art. 2(2)(c) GDPR). It applies to us, as we provide the means of processing (Recital 18 GDPR). For this reason we act as controller for everything you do in the personal workspace.
We process this data:
- connected accounts, with username, display name, profile picture and public profile, refreshed daily;
- platform tokens, encrypted in our vault;
- drafts, posts, replies and media;
- agents, grants and their history;
- the audit log, with an entry for every agent call and every member action;
- approval records, one per post.
| Data | Retention |
|---|---|
| Platform tokens | Destroyed within one minute of the account being disconnected or of revocation |
| Media | Deleted no later than 7 days after publication or cancellation |
| Drafts and publishing requests, with the text of posts | 2 years, then anonymised |
| Comments, mentions, direct messages and search results | 30 days at most |
| Audit log | By plan: Gratis 7 days, Osserva 30 days, Pubblica 90 days, Interagisce and Agenzia 365 days, Enterprise as agreed in the contract. Then deleted. |
| Approval records | 5 years from publication, on every plan, including after deletion of the workspace (section 15) |
| Connected accounts, agents and grants | Until deletion of the workspace, then deleted within 30 days |
10.1 Third-party data
Your personal workspace receives data about other people through the platforms' official APIs: people who comment on your posts, mention you, send you a direct message or appear in search results. The source of this data is the platform. We process it only to show it to you and your agents, for 30 days at most. Anyone in this situation can exercise the rights in section 16 by writing to privacy@socializza.com.
10.2 Minimum age
To open a personal workspace you must be at least 16, in every State. Before opening it you state your age. If you are 16 or 17 you do not need a parent's consent (Art. 2-quinquies of d.lgs. n. 196/2003 and Art. 4(4) of Legge n. 132/2025, the Italian law on artificial intelligence). To buy a paid plan you must be 18, or have the consent of a parent or guardian (section 5.5 of the terms of service).
We wrote this notice, and section 11 in particular, so that a minor can also read and understand it.
11. AI agents and your data
This section meets Art. 4(3) of Legge n. 132/2025. It explains in plain words what happens to data when an AI agent uses Socializza, what risks exist and how you can object.
11.1 Who decides
The agents are yours. You choose them, you run them and you decide what they can do.
An agent never chooses accounts or scopes. It acts only within the grants you create on Socializza's consent screen.
For each grant you choose a mode:
- ask-first, where you approve each action before it runs;
- autonomous, where the agent acts on its own within the limits you set;
- dry-run, where the agent tries actions without publishing anything.
11.2 What we do not do
Socializza does not write content. It does not process your content with AI models.
We do not use platform content to train anything, neither our own models nor anyone else's. We do not use the content of your accounts for our own purposes.
The agent never receives platform tokens. It receives from us credentials that are valid for one hour at most and usable only with Socializza.
11.3 The risks
What the agent receives leaves Socializza. The agent processes it where it runs, under the terms of whoever provides it. We have no control over that processing.
Comments, mentions and direct messages are written by other people. A text can contain instructions written to deceive the agent. We deliver it to the agent as untrusted data, with a provenance marker and a length cap, never as an instruction. How the agent reacts depends on the agent.
In autonomous mode the agent publishes and replies without your approval, within the limits. Whatever goes out without human review automatically receives a label, for example "Text generated with artificial intelligence".
11.4 How to stop an agent and object
You can pause or revoke an agent at any time. The kill switch stops one agent, one brand or the whole workspace in a single action. Revocation invalidates the agent's credentials within one minute.
The audit log shows every call of every agent.
You can object to processing based on our legitimate interest by writing to privacy@socializza.com (section 16).
12. Business workspace
In a business workspace the customer is the controller of the workspace content. We act as processor, under Art. 28 GDPR, on every plan, Gratis included.
Workspace content comprises the connected accounts, drafts, published posts, comments and audience data received from the platforms, agent credentials and logs, and approval records. The full list is in Annex II of the data processing agreement.
We process this data only on the customer's instructions, that is the configuration it sets in the app, and under the data processing agreement.
On the customer's instruction we keep approval records for 5 years from publication, including after the contract ends. When the contract ends the customer receives the signed export of the records and can order their early deletion (section 11 of the data processing agreement).
To exercise your rights over this data, contact the customer. We help the customer answer you.
We continue to process the data of your member account, sign-in and billing as controller, under this notice.
13. Recipients
We disclose data only to these recipients:
- the providers that process data on our behalf as processors, namely Amazon Web Services EMEA SARL for hosting and media (Amazon Lightsail), for sending email (Amazon SES) and for encrypted backups (Amazon S3), and Google LLC for delivering push notifications to the Android app through Firebase Cloud Messaging (FCM);
- Stripe, as independent controller and as processor for payments on the web, and Apple and Google, as independent controllers for in-app purchases (section 7);
- Apple, which delivers push notifications to the iOS app through its APNs service (section 9);
- the platforms you connect, namely X and Meta for Facebook Pages, Instagram and Threads, which receive what you or your agents publish and act as independent controllers under their terms with you;
- your agents, for the data your grants allow;
- public authorities, where the law requires us to.
The name, registered office, function and safeguards of Amazon Web Services EMEA SARL are in the list of sub-processors. For Google LLC the same details are in the data residency statement.
14. Where the data is and transfers outside the EU
We store the database, media, backups and logs in the European Union.
Some flows involve companies based in the United States or US groups:
- Stripe, LLC takes part in payments on the web. Stripe's Data Transfer Addendum relies first on the adequacy decision on the EU-US Data Privacy Framework, under which Stripe, LLC is certified, and in the alternative on the standard contractual clauses. Stripe offers no option that keeps payment data in the EU only.
- Google LLC receives in the United States the data of push notifications sent through FCM and of purchases on Google Play. Google LLC is certified under the EU-US Data Privacy Framework, so the transfer relies on the adequacy decision, Commission Implementing Decision (EU) 2023/1795 of 10 July 2023. For FCM, Google LLC acts as our processor under the Firebase Data Processing and Security Terms, and the standard contractual clauses of those terms apply in the alternative.
- Apple Inc. receives in the United States the data of push notifications sent through APNs and of purchases on the App Store. Apple Inc. is not certified under the Data Privacy Framework. The transfer relies on standard contractual clauses, as Apple's privacy policy states.
- Amazon Web Services EMEA SARL is part of a US group. We use its services for hosting, media, email and backups in the eu-central-1 region, Frankfurt, Germany. For backups it receives only encrypted data, with keys that AWS does not hold.
What you publish on a platform is processed by that platform, under its terms, outside the EU as well.
The safeguards for each transfer, under Chapter V GDPR, are in the data residency statement and in the list of sub-processors.
15. Deletion and backups
When you disconnect an account, we destroy its tokens within one minute.
When you delete the workspace, we delete its data within 30 days. The exceptions are invoices, kept for 10 years, and approval records, kept for 5 years from the publication of each post, on every plan. At that point you receive the signed export of the approval records and can ask for their early deletion.
Finally we destroy the workspace's encryption key. Whatever was encrypted with that key becomes unreadable, in copies too. The exception is the backups taken before the deletion, which keep the encrypted data until they expire, at most 13 months later.
We make encrypted backups. We keep 30 days of rolling backups and one monthly copy for 12 months. Deleted data can therefore remain in a backup, in encrypted form only, for up to 13 months. We cannot remove it from a single backup. It expires on its own with the backup that holds it.
16. Your rights
You have the right to:
- access your data and receive a copy of it (Art. 15 GDPR);
- obtain its rectification (Art. 16 GDPR);
- obtain its erasure (Art. 17 GDPR);
- obtain restriction of processing (Art. 18 GDPR);
- receive it in a structured, commonly used and machine-readable format and transmit it to another controller, where we process it on the basis of a contract or of your consent (Art. 20 GDPR);
- object to processing based on our legitimate interest, namely security, product counters and third-party data (Art. 21 GDPR);
- not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (Art. 22 GDPR);
- withdraw at any time any consent you have given us, without affecting the processing carried out before the withdrawal (Art. 7(3) GDPR).
We take no decisions based solely on automated processing that produce legal effects concerning you.
We communicate any rectification, erasure or restriction to the recipients of the data, unless this proves impossible or involves disproportionate effort (Art. 19 GDPR).
To exercise a right, write to privacy@socializza.com. If we cannot identify you from the request, we ask you for information to verify your identity. The request is free of charge. We reply within one month of receipt. For complex or numerous requests that period may be extended by two further months, and in that case we tell you within the first month.
You can do some things yourself in the app, such as revoking an agent or disconnecting an account.
17. Required data
For the waiting list we need your email; the answer about your agent is optional. To create an account we need your email. To buy a plan we need billing details. Without this data we cannot provide the service you request.
18. Complaints
If you believe that we process your data in breach of the GDPR, you can lodge a complaint with the Garante per la protezione dei dati personali (the Italian data protection authority), Piazza Venezia 11, 00187 Roma, www.garanteprivacy.it. You can also turn to the supervisory authority of the Member State of your habitual residence, of your place of work or of the place of the alleged infringement (Art. 77 GDPR).
19. Changes
When we change this notice, we publish the new version with its date. A new service enters this notice through a new version, and we notify you 30 days before it applies. We do not use your data for a new purpose without informing you first (Art. 13(3) GDPR).