Policy Avatar AI

Metagate SRL
Via Giosuè Carducci 32, 20123 Milan, Italy
REA: 2667780 – P.I. 12525640962 – SDI: SUBM70N
📧 Email: metagate@legalmail.it

1. Introduction

Metagate SRL (hereinafter "Metagate" or "the Company") develops immersive experiences in Augmented and Mixed Reality, based on the interaction between the user and intelligent Non-Player Characters (NPCs), generated through AI technology.

This policy describes the responsible and compliant use of AI technologies, with reference to the EU Regulation 2016/679 (GDPR) and to the Swiss Federal Act on Data Protection (FADP). In particular, it regulates the use of GPT-based customizable assistants, with or without activation of the memory function, by the end user.

2. Purpose of processing

The data is processed exclusively for the following purposes:

  • Training and configuration of NPC/AI assistants through inputs voluntarily provided by the user;

  • User-assistant conversation management to enable smooth and coherent interactions;

  • Optional activation of the "memory" function (persistent thread), only with explicit consent;

  • Aggregated and anonymous analysis of interactions to improve the quality of the experiences offered.

⚠️ No personal data is used to train general AI models.

3. Type of data processed

Metagate does not automatically collect personal data through NPCs or assistants. However, in the event that the user:

  • intentionally enter identifying information in the prompts,

  • activate the memory function of their GPT assistant,

the following data may be processed:

  • User ID (generated via Supabase)

  • Avatar, settings, and content associated with AI assistants

  • PDFs associated with the assistant's knowledge

  • Prompt and responses saved for conversational continuity

Such data is accessible only to the authenticated user and can be modified or deleted at any time.

4. Legal basis

Pursuant to Art. 6 of the GDPR and the equivalent provisions of the LPD, the legal basis for processing is:

  • Explicit consent for memory activation and content saving;

  • Execution of the contract for the provision of AI services at the user's request;

  • Legitimate interest for the technical improvement of experiences, without profiling.

5. Restriction of processing and self-determination

  • The memory function is disabled by default.

  • The user has full control over:

    • Activation/deactivation of memory for each assistant;

    • Upload and removal of the knowledge base (PDF);

    • Deletion of assistant and saved conversations.

6. Data Security

Metagate adopts appropriate technical and organizational measures, including:

  • Encryption in transit and at rest (Supabase + HTTPS)

  • Secure Authentication (OAuth, JWT)

  • Separate storage of threads and assistants

  • Encrypted backups and granular access controls

  • Periodic audit of assistant behavior to prevent bias or misuse

7. Data Transfer

Data is not transferred outside the European Union except through providers that offer adequate guarantees (e.g. OpenAI via Standard Contractual Clauses). No personal data is transferred to third parties for commercial purposes.

8. User Rights

The user can at any time:

  • Access, modify, or delete your assistant and conversations

  • Disable memory

  • Withdraw consent

  • Request the export of your data

  • Submit a complaint to the Supervisory Authority

Requests to be sent to: dpo@themetagate.it

9. Artificial Intelligence and Minors

The use of AI assistants is intended for a adult audience. The Company does not promote interaction with NPCs by individuals under 16 years of age, nor does it intentionally collect data from minors. Parents are encouraged to monitor app usage in shared environments or during public events.

10. Privacy Contacts

📧 DPO: Marco Pizzini
📬 Email: dpo@themetagate.it

11. Policy Updates

Metagate reserves the right to modify this policy at any time. Changes will be communicated via email and published on the website and web app.



Data Update: 23/05/2025 (20/03/2024)