PALO Framework Privacy Policy

Privacy information Local-first tools Last reviewed: July 15, 2026

1. Introduction

Welcome to PALO Framework ("we," "our," or "us"). We are committed to protecting your privacy and ensuring you have a positive experience when using our website, web tools and Android/iOS applications.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website paloframework.org, use our web tools or use the PALO Mobile apps (Android com.fabriziodegni.paloframework, iOS com.fabriziodegni.paloframeworktoolbox), in compliance with the General Data Protection Regulation (GDPR - EU 2016/679) and other applicable data protection laws. This notice describes the current website and mobile implementations and is not legal advice.

Privacy by Design:

PALO Framework tools are designed with privacy at their core. Model Canvas processing happens locally in your browser. Android app cases, assessments and evidence metadata are processed locally on your device. Local content is not uploaded automatically. The optional assistant processes only questions, voice input and the case summary you explicitly consent to share, as described below.

2. Data Controller

For the purposes of GDPR, the Data Controller is:

Organization: PALO Framework

Website: https://paloframework.org

Email: info@paloframework.org

Country: Italy (European Union)

3. Data We Collect

3.1 Data We DO NOT Collect

We want to be clear about what we do not collect:

3.2 Mobile Local Processing and Optional Services

The P.A.L.O. Framework Toolbox Android app is designed to operate locally without an account. Its optional Approval Inbox connects only after the user provides an HTTPS PALO-AI governance endpoint and an ephemeral bearer token. The app does not automatically transmit app content to PALO.

Local Data or Operation How It Is Used Developer Access
Cases, assessments, evidence metadata and settings Stored in local application storage and SQLite to provide the governance workflow. None
Documents selected by you Accessed through the Android document picker only after your explicit selection. None
Biometric operation Performed by Android device security to support local evidence signing. The app does not receive raw fingerprint or other raw biometric data. None
Case File and Evidence Bundle exports Created locally and passed to the Android share sheet only when you explicitly request an export. You choose the destination and recipient. None, unless you independently choose a PALO contact address as the recipient

Uninstalling the app or clearing its storage removes app-managed local data. Files that you previously exported remain in the destination you selected and must be deleted there separately.

PALO Mobile 3.0: optional assistant and voice

Local cases, controls, notes and attachments work without an account. The optional assistant requires an enabled PALO account and a network connection. Authentication takes place in the system browser through the PALO identity service; passwords are not entered in the native app. The app holds temporary access and refresh tokens in memory.

Before a session starts, the app requests consent to send questions and conversation context to the PALO assistant service and Google Gemini. Sharing a selected case summary requires separate consent and shows the fields first. The complete case file, attachments and Vault are not uploaded automatically. Microphone input is sent only after voice consent and starting dictation. Gemini Live returns a transcript that the user must confirm before requesting an answer.

The mobile conversation is held in memory and is cleared on disconnection. Leaving the assistant or backgrounding the app closes the active assistant session and microphone stream; the browser transition during sign-in is an exception before a session is opened. A disconnected server session expires after at most ten minutes. You can voluntarily save an answer, its question, citations and provenance as a local draft. This is separate from conversation memory.

The configured Gemini project uses paid services. Google states that paid-service prompts and responses are not used to improve its products, but may be retained for abuse monitoring. Its published abuse-monitoring notice specifies a 55-day retention period. Closing a PALO session does not delete provider records. Review Gemini data handling and abuse monitoring before sharing sensitive information. PALO does not promise zero retention or EU-only inference.

The identity service stores account information necessary for access. Infrastructure may retain security/access logs, including IP addresses and request metadata. PALO's assistant application does not intentionally log question or answer content. Its persistent budget ledger records reservation time, request kind and reserved amount, without conversation content. Optional public PolicyWatcher requests disclose ordinary connection metadata to PolicyWatcher; loading the feed does not launch research or upload a case. The separate research-request feature sends only the organization name, cleaned public source URL, policy categories, optional notice/effective dates and language shown in its confirmation preview. PolicyWatcher may store that request for operator review; it is not an automatic scan. PALO cases, attachments, emails and assistant conversations are not included. Saving a research receipt in PALO is a separate local draft action.

Use the case's delete action to remove its local evidence, attachments and import backups. Files previously exported to another app remain subject to that app's controls. To request account deletion or ask about server-held data, contact io@fabriziodegni.com. Clearing local data or uninstalling does not by itself delete server accounts, provider records or exports held elsewhere.

3.3 Website Data We May Collect

Data Type Description Purpose
Server Logs IP address, browser type, pages visited, timestamps Security and troubleshooting. PALO does not operate product analytics on this website.
Contact Form Data Email, name, message content (if you contact us) Respond to inquiries
Cookie Data Session identifiers, preferences Essential website functionality

In accordance with GDPR Article 6, we process personal data only when we have a valid legal basis:

Legal Basis GDPR Article When We Use It
Consent Art. 6(1)(a) Newsletter subscription, non-essential cookies
Legitimate Interest Art. 6(1)(f) Website security, analytics, fraud prevention
Contract Art. 6(1)(b) Responding to your inquiries
Legal Obligation Art. 6(1)(c) Compliance with applicable laws

5. How We Use Your Data

When we do collect data, we use it for:

6. Data Sharing & Transfers

6.1 Who We Share Data With

We do not sell your personal data. The mobile apps do not automatically share locally stored app content. If you explicitly use the system share sheet, the operating system sends the selected export to the destination you choose under that destination provider's terms. For website operations, we may share data with:

6.2 International Transfers

When your browser loads third-party technical resources, the relevant provider may process connection data outside the European Economic Area (EEA). Please consult that provider's privacy information for the applicable safeguards and transfer mechanisms.

7. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

Data Type Retention Period Reason
Server Logs 30 days Security monitoring
Contact Messages 2 years Record of communications
Mobile App Local Data Until you delete it, clear app storage or uninstall the app Provide the locally stored governance workspace

8. Your Rights Under GDPR

Under GDPR, you have the following rights regarding your personal data:

Right GDPR Article Description
Access Art. 15 Obtain a copy of your personal data
Rectification Art. 16 Correct inaccurate personal data
Erasure Art. 17 "Right to be forgotten" - delete your data
Restriction Art. 18 Limit how we use your data
Portability Art. 20 Receive data in a machine-readable format
Object Art. 21 Object to processing based on legitimate interest
Withdraw Consent Art. 7(3) Withdraw previously given consent

To exercise any of these rights, please contact us at info@paloframework.org. We will respond within 30 days as required by GDPR.

Right to Lodge a Complaint:

You have the right to lodge a complaint with a supervisory authority. In Italy, this is the Garante per la protezione dei dati personali (www.garanteprivacy.it).

9. Cookies & Tracking

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and improve your experience.

9.2 Cookies We Use

PALO does not intentionally set cookies for advertising, behavioural profiling, or product analytics. Hosting and third-party resource providers may apply their own technical cookies or similar technologies; please review their notices for current details.

The native app does not use advertising identifiers, analytics or tracking SDKs. Browser authentication may use essential identity-provider cookies.

9.3 Managing Cookies

You can control cookies through your browser settings. Note that disabling certain cookies may affect website functionality.

10. Children's Privacy

Our website is not intended for children under 16 years of age. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately at info@paloframework.org.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by:

We encourage you to review this policy periodically.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

Privacy Inquiries: info@paloframework.org

Security Issues: info@paloframework.org

General Contact: info@paloframework.org

Android App Support: io@fabriziodegni.com

Website: https://paloframework.org

This Privacy Policy was developed in compliance with the General Data Protection Regulation (GDPR - EU 2016/679), the ePrivacy Directive (EU 2002/58/EC), and Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018.