Privacy & Data Governance Policy

Last Updated: February 10, 2026

1. Data Controller Fidamen (Yeah Up S.r.l., registered office: Udine, Italy) acts as the Data Controller for information processed through our platforms and websites.

• Contact: info@fidamen.com

2. Categories of Processed Data

• Technical & Usage Data: IP addresses, browser telemetry, and technical logs required to maintain platform availability and security.

• Logic Input Data: Data voluntarily entered into our calculators or decision models. This data is processed in real-time to generate outputs but is not stored unless a user explicitly saves a scenario or requests a report.

• Contact & Account Data: Names, professional emails, and company details provided for account creation or communications.

3. Purposes and Legal Basis for Processing

We process data under the following legal bases:

• Performance of a Contract: To provide the services you requested.

• Legitimate Interest: To improve our platforms, ensure security, and enhance performance for our users.

• Consent: For marketing communications and non-essential analytical cookies.

4. Automated Decision-Making and Transparency (Art. 22 GDPR) When our tools provide automated projections or rankings:

• The Logic: Decisions are based on hierarchical decision graphs and standardized business rules (Decision Tables).

• Significance: These outputs are designed for decision-support and should be validated via a "Human-in-the-Loop" protocol.

• User Rights: Users have the right to obtain human intervention, express their point of view, and contest automated outputs by contacting us at info@fidamen.com.

5. Security We adopt industry-standard security practices to protect your data.

• Data Protection: All data is encrypted in transit (TLS 1.3) and at rest (AES-256).

• Integrity: We perform periodic security reviews and vulnerability assessments to safeguard the integrity of processed data.

6. Your Rights and Data Subject Access Requests (DSAR)

Under GDPR, you maintain eight fundamental rights, including access, rectification, and the right to data portability.

7. Data Retention and Deletion

We adhere to the principle of "Storage Limitation." Usage logs are anonymized after 26 months, while Logic Input Data for guest users is purged immediately after the session ends to maximize privacy.