Version 2026-09-23
Privacy Notice
Version 2026-09-23, under Articles 13 and 14 of Regulation (EU) 2016/679 ("GDPR"). This is a translation: if it differs from the Italian version, the Italian version prevails.
1. Controller
Federico De Cillia, sole proprietorship GPT Chatbot di Federico De Cillia, Via Ernesto Teodoro Moneta 50, 20161 Milan, Italy, VAT IT13990330964. For any request: info@flylabs.ai; certified email (PEC) federico.decillia@spidmail.it.
2. Who this notice is for
- Users of Stellar Reviews: people who sign in to the app on behalf of a customer property.
- Visitors of the public pages and the demo.
- Review authors: for their reviews Stellar Reviews acts on behalf of the reviewed property, which is the controller (section 7).
3. Data, purposes, legal bases, retention
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| Create and manage the account, give access, provide the service | name, email, property, role, settings | Contract (Art. 6(1)(b)) | life of the account, then 30 days |
| Service emails: sign-in links, alerts about reviews and drafts, trial and plan | Contract | life of the account | |
| Service security and abuse prevention | IP address, browser, requests and technical logs | Legitimate interest (Art. 6(1)(f)) in protecting the service and customers | as long as hosting providers keep them, at most 90 days |
| Internal statistics on service use, to improve it | usage data linked to the account (drafts copied, published, edited) | Legitimate interest in improving the service | life of the account; afterwards only in aggregate form |
| Register of AI-generated drafts and public verification | non-reversible fingerprints computed from draft text, model, date | Legal obligation, Article 50 of Regulation (EU) 2024/1689 (Art. 6(1)(c)) | 5 years from generation |
| Marketing to customers about similar services | name, email | Art. 130(4) Italian Legislative Decree 196/2003; you can object at any time, including through the link in every email | until you object |
| Accounting and tax obligations, defence of rights | billing and contract data | Legal obligation; legitimate interest | 10 years |
Payments for paid plans are handled by Link (Stripe), which sells subscriptions as merchant of record and is an independent controller of payment data under its own privacy notice. Stellar Reviews does not receive your card details.
No decision based solely on automated processing produces legal or similarly significant effects on you.
4. Recipients
Data is processed by the controller and by the providers supporting it as processors, listed on the sub-processors page (hosting, database, email, AI models, review extraction). We do not sell data and do not disclose it to third parties for their own purposes.
5. Transfers outside the EU
Some providers are based in the United States. Transfers rely on the EU-US Data Privacy Framework, for certified providers, or on the European Commission's Standard Contractual Clauses, as indicated on the sub-processors page. Database and application functions are in the European Union (Frankfurt).
6. Cookies
We use only necessary technical cookies: the sign-in session and form protection. We do not use profiling cookies or third-party analytics cookies, so no consent banner is needed.
7. If you wrote a review
The property you reviewed uses Stellar Reviews to read the public reviews of its listings and prepare replies. For that data the property is the controller; Stellar Reviews is a processor and handles only what is public on the platform (name or pseudonym, text, rating, dates). To exercise your rights, contact the property; if you write to us, we forward the request. A review deleted from our systems stays on the platform until you remove it there.
8. Your rights
You can request access, rectification, erasure, restriction and portability, and object to processing based on legitimate interest, by writing to info@flylabs.ai. We reply within one month. You can lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it), or with the authority of your country.
9. Changes
If we change this notice we update the version at the top and, for significant changes, inform users by email or in the app.