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Operator-approved private beta within the recorded Romania-only, adults 18+, maximum-five scope · external legal review pending and advisory · not a declaration of general legal compliance.

Version: 0.2.0-private-beta · Effective: 2026-07-18 · Status: operator_approved_for_private_beta · SHA-256: 547da054e018bbf58425ed614c0f314cbe3aee5dfd76be9108ec584ce6deb0be

Privacy Notice

Status: operator approved for the narrowly bounded Romania-only private beta. External legal review remains pending and advisory. This is not a declaration of general legal compliance.

Living Book stores account and session records, reading position, private branches, whispers, character and causal state, generated or quarantined passages, provider usage, legal acknowledgements, and explicit margin notes. Optional improvement telemetry starts off. The owner operations view shows only grouped reader-account statuses, grouped coarse active-session clients, grouped invitation states, and account-free global spend totals; it does not expose per-reader behavior or private book content.

Whispers are sent server-side to the configured AI provider to operate the personal reading experience. The current OpenAI adapter uses the Chat Completions API. They are not placed in ordinary logs, Sentry, optional telemetry, browser caches, marketing systems, or Living Book model-training features. Voluntary OpenAI data sharing is disabled. Standard abuse monitoring may retain prompts and outputs for up to 30 days. The staging project is configured as Global; no European data-residency claim is made. Zero Data Retention is not claimed, and Modified Abuse Monitoring is not enabled.

Your branch is private to your account. Administrators do not receive whisper content by default. Restricted private-data access must be justified and audited.

Machine-readable export, correction/contact, objection where applicable, consent withdrawal, and deletion controls are part of the compliance spine. Backup expiry and any lawful hold must be reported honestly rather than hidden.

Required-service processing and optional improvement telemetry are separate purposes; optional telemetry defaults off. The controller is UNCENTERED S.R.L. OpenAI processes applicable API customer data under its published DPA; for an EEA customer the DPA is entered with OpenAI Ireland Ltd. Transfers outside the EEA or Switzerland use agreements containing the 2021 EU Standard Contractual Clauses or an applicable European Commission adequacy decision, as stated in the current DPA. Final legal-basis and notice wording remain subject to external review.