Privacy Policy

1. Who is responsible

ICTUM is an independent product lab operated by Sandro Batista. For data protection enquiries, contact [email protected].

2. Scope

This policy applies to the ICTUM website (www.ictum.ai) and to the experimental products identified in the product-specific sections below: Relumia, Curatora and MorphAmp.

3. Information we collect

Depending on how you interact with ICTUM or its experiences, we may process:

• name and email address submitted through contact or idea forms;
• messages, ideas and other content you voluntarily submit;
• early-access or waitlist registrations (including optional professional details where a form asks for them);
• technical and security information (such as IP address, request metadata and basic logs) needed to operate and protect our services;
• cookie and analytics data only where those technologies are actually used on a given site (see our Cookie Policy);
• information needed to respond to support enquiries or data protection requests you send to us.

We do not collect payment card details, paid subscription data or advertising profiles through the ICTUM website. Product-specific sections below describe what each experience collects today.

4. How information is used

We use personal information to:

• read and respond to messages, ideas and enquiries;
• manage early-access and waitlist requests;
• operate, secure and improve our websites and experimental products;
• comply with legal obligations and defend legal claims where necessary;
• measure website use only where analytics tools are deployed and, where required, after appropriate consent.

5. Legal bases

Where the GDPR or similar laws apply, we rely on:

• Legitimate interests or steps at your request before a possible agreement — to respond to enquiries, review ideas and keep our services secure;
• Consent — for early-access marketing updates where you opt in;
• Legitimate interests — for security, abuse prevention and service reliability;
• Consent — for non-essential cookies and analytics where required by law;
• Legal obligation — where we must comply with applicable law.

6. Service providers

We use infrastructure and communication providers to host our sites, deliver messages and process form submissions. These may include hosting providers (such as Cloudflare), email and notification channels, and tools used to review early-access requests. Providers process data only on our instructions and for the purposes described in this policy.

7. International transfers

Some providers may process data outside your country, including in the European Economic Area, the United Kingdom, the United States or other jurisdictions. Where required, we use appropriate safeguards for such transfers.

8. Data retention

We keep personal information only as long as needed for the purposes above, including to respond to you, operate early-access programmes, maintain security logs and meet legal requirements. Retention periods vary by data type and product; contact us for details about a specific request.

9. Your rights

Depending on applicable law, you may have the right to:

• access your personal data;
• request correction of inaccurate data;
• request deletion;
• request restriction of processing;
• object to certain processing;
• data portability, where applicable;
• withdraw consent where processing is based on consent;
• lodge a complaint with your local data protection supervisory authority.

To exercise these rights, email [email protected] or see our Data Requests page.

10. Security

We apply reasonable technical and organisational measures to protect personal information. No method of transmission or storage is completely secure; please avoid sending sensitive information unless necessary.

11. Children

ICTUM experiences are not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided data, contact us so we can take appropriate steps.

12. Changes to this policy

We may update this policy from time to time. The “Last updated” date at the top indicates when it was last revised. Material changes will be reflected on this page.

13. Contact

For privacy questions: [email protected].

14. Product-specific information