1. Who we are
Gino ("we", "us") is an AI email assistant operated over Telegram, reachable at hello@purevitadubai.com. It is provided by Pure Vita LLC, a Limited Liability Company registered with the Dubai Multi Commodities Centre (DMCC), Media City, Dubai, United Arab Emirates — Formation No. 2536870, Trade License No. 2536870.01, managed by Karim Azzam. This policy explains what data we process, why, and the choices you have.
2. What Gino processes
- Email metadata and content — when you connect a mailbox (via Google OAuth, Microsoft OAuth, or IMAP credentials), Gino reads message subjects, senders, timestamps and, only to draft replies, the text of pending messages you select.
- Drafts you approve — replies are generated by an AI model and sent only after you tap approve in Telegram.
- Account data — your Telegram ID, tenant settings (language, signature, tone), and OAuth tokens used to access your mailbox.
- Usage data — basic service logs (errors, request counts) needed to keep the service healthy.
3. What Gino does NOT do
Gino does not sell your data, does not use your emails to train models, and does not share mailbox content with third parties or advertisers.
4. Why we process it (legal basis)
- Performance of a contract — running the assistant you subscribed to.
- Consent — mailbox access via OAuth is granted explicitly by you, and can be revoked at any time from your Google/Microsoft account settings or by disconnecting the mailbox in Gino.
- Legitimate interest — security logging and abuse prevention.
5. Where data lives and how long
Gino runs on a private server in the European Union (Italy). OAuth tokens are stored encrypted at rest; email content is processed in memory and only cached for the duration needed to produce your daily brief and pending drafts. You can request deletion of all tenant data at any time by writing to hello@purevitadubai.com — deletion is completed within 30 days. Where the law requires it (for example a data breach), we will notify you and the competent authority without undue delay, and within 72 hours of becoming aware of the breach.
6. AI processing
Drafts and briefs are generated by large language models hosted on Cloudflare Workers AI, which acts as a processor under our instructions. Prompts sent to Cloudflare contain only the minimum email content required for the task, and are not used by Cloudflare to train its models. No other subprocessor receives your mailbox content.
7. Your rights
Your personal data is protected by the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) for residents of the United Arab Emirates, the Saudi Personal Data Protection Law (PDPL) for residents of Saudi Arabia, and the EU General Data Protection Regulation (GDPR) where applicable. Under these laws you have the right to:
- Access — request a copy of the personal data we hold about you.
- Rectification — correct inaccurate settings or personal details.
- Erasure — delete your account and all associated data.
- Portability — receive your data in a machine-readable format.
- Objection and restriction — object to processing or ask us to pause it.
- Withdraw consent — disconnect your mailbox at any time; this stops all email processing immediately.
To exercise any right, contact hello@purevitadubai.com. You also have the right to lodge a complaint with the competent data protection authority — the UAE Data Office (UAE), the Saudi Data & AI Authority / SDAIA (KSA), or your national supervisory authority (EU).
8. Security
Credentials are stored with restricted file permissions and never displayed in full after entry. Access to the dashboard is protected by signed links and authentication keys. All traffic is served over HTTPS.
9. Children
Gino is not directed at anyone under 16 and we do not knowingly process their data.
10. Changes
We will update this page if our practices change, and update the date above accordingly.