GABBI Privacy Notice

1. Controller and scope

Vladimir Bakula, operating GABBI in France is the controller for the account and product-service processing described here. Privacy requests may be sent to bakulavlad@gmail.com. Polar is a separate controller for its checkout, payment, tax and invoicing services.

This notice distinguishes the online website and account services from the offline desktop application. The application is designed so clinical notes, transcripts, audio and patient/client identifiers remain on your device. They are not stored in the GABBI account database and are not required for licensing.

2. Data we process

GABBI does not need or request patient or client data for the website, account, licence, downloads or Guide. Do not submit it. Automated Guide filters are safeguards, not a guarantee that every sensitive detail will be detected.

• Waitlist: email address, language, the price shown at signup, screening answers and signup time.
• Account and access: email, optional name, hashed login/session tokens, session dates and Polar customer identifier.
• Commerce and licence: product and plan codes, order/subscription identifiers and status, entitlement dates, licence identifier/key/status and Polar webhook records needed to reconcile access.
• Downloads and support: account identifier, requested artifact and time; messages you choose to send to support.
• Website operation: an essential session cookie, request/security logs, cookie-free aggregate Vercel Web Analytics, and Vercel Speed Insights (aggregate page-performance measurements, also without cookies).
• GABBI Guide: the product question you submit and its language. The Guide is online and may send accepted questions to the configured language-model provider.

3. Purposes and legal bases

• Contract and pre-contract steps (GDPR Article 6(1)(b)): create an account, authenticate you, link purchases, issue and validate entitlements/licences, provide downloads, support and cancellation/refund handling.
• Legitimate interests (Article 6(1)(f)): secure the service, prevent abuse, reconcile Polar events, diagnose failures, maintain limited download records and understand aggregate site performance. These uses are limited to what users reasonably expect from a paid software service.
• Consent (Article 6(1)(a)): send optional launch or product communications where consent is requested. You can withdraw consent at any time.
• Legal obligation (Article 6(1)(c)): retain and disclose transaction-related records where tax, accounting, fraud-prevention or lawful process requires it.

4. Recipients and providers

Access is limited to the operator and providers needed to run the service:

• Neon, for the hosted account, entitlement and licence database;
• Vercel, for website hosting, request processing, cookie-free web analytics and page-performance measurement;
• Polar, as merchant of record and reseller for checkout, billing, tax, invoices, customer portal and transaction support;
• the configured transactional-email provider, for one-time login links and service messages;
• Cloudflare R2, for time-limited product downloads; and
• Mistral AI, only when the optional online GABBI Guide is enabled and accepts a product question.

Providers process data under their own terms and/or data-processing terms. Some may process data outside the EEA. Where GABBI is responsible for a restricted transfer, it relies on an applicable adequacy decision, standard contractual clauses or another lawful safeguard. Contact us for the currently applicable safeguard.

5. Cookies and analytics

The site uses a secure, HTTP-only account session cookie (normally 30 days). It supports authentication and service operation; it is not an advertising cookie. Vercel Web Analytics and Vercel Speed Insights are both configured without analytics cookies: Web Analytics counts page views and Speed Insights measures page-loading performance, both only in aggregate. Browser or infrastructure logs may still contain technical identifiers such as an IP address and user agent for security and delivery.

6. Retention

Polar retains checkout, billing and invoice data under its own privacy and legal-retention rules. Local clinical content is retained solely under your control on your device.

• Login links expire after 15 minutes; account sessions normally expire after 30 days. Expired token/session rows are removed or anonymised on a regular housekeeping schedule.
• Waitlist and optional launch-contact data: until you opt out, or no more than 24 months after the last meaningful interaction.
• Account, entitlement and licence records: for the product relationship, then up to 5 years to establish, exercise or defend contractual claims; longer only where a legal record-keeping duty applies.
• Webhook and operational error records: only as long as needed for reconciliation, security and audit, normally no more than 12 months unless an unresolved dispute or legal duty requires longer.
• Download audit records: 12 months for abuse prevention and support.
• Support correspondence: up to 3 years after the request closes, unless linked to a contractual claim.

7. Your rights

Subject to the GDPR conditions, you may request access, correction, deletion, restriction and portability, object to processing based on legitimate interests, or withdraw consent. Email bakulavlad@gmail.com. We may ask for proportionate proof of identity and normally respond within one month.

You may also complain to the Commission nationale de l’informatique et des libertés (CNIL) at cnil.fr, or to the supervisory authority where you live or work. GABBI does not make decisions producing legal or similarly significant effects solely by automated processing.

8. Security and changes

Account tokens are random and stored as hashes; cookies are configured secure, HTTP-only and same-site. Access to production systems should be limited by role. No service can promise absolute security, so please report suspected account compromise promptly.

We will update this notice when processing materially changes and will show the new effective date. Material changes affecting account users will be communicated by a reasonable channel where practical.