Privacy notice
This notice describes what data R-TITAN collects, why, where it is stored and which rights you can exercise. It is written to be readable: if anything is unclear, get in touch.
Last updated: 28 September 2026
Service status
R-TITAN is currently a restricted-access product preview. The service is not open to the public and does not process third-party documents. This notice will be updated before any opening to external users.
Who processes the data
The data controller is Giorgio Di Tommaso, founder of the EDT R-TITAN initiative, reachable at founder@r-titan.com. Incorporation is in progress: this notice will be updated with the entity's details when available.
Public site
The public pages use no profiling cookies, integrate no traffic analytics and carry no advertising. No personal data is collected by simply browsing the site. The hosting provider records the technical access logs necessary to operate and secure the service.
Restricted area: data collected
Console access requires an account. We process: email address, password stored in encrypted form by the authentication provider, and technical session data. For each uploaded document we retain file name, type, size, cryptographic digest and admission status. For each run we retain the stated objective, requested mode, status and events.
Uploaded documents
Documents are held in a private archive, reachable only after a server-side authorisation check. They are not published, not made freely accessible and not indexed by search engines. To perform the requested functions they are processed by the authorised providers described in this notice.
Purposes and legal basis
Data is processed to deliver the requested service, secure access and maintain traceability of operations. The legal basis is performance of the relationship with the user and the legitimate interest in protecting the service from unauthorised access.
Where data is stored
Identity, database and document archive of the web platform are hosted in the European Union, in the Frankfurt region. For missions, the analysis runtime and its working archive operate in the Google Cloud europe-west1 region. The public site is distributed through a delivery network with global presence: this concerns public content only, never user documents. The location of one component does not automatically extend to other services, including the models.
Retention
Account data is retained while the account remains active. In the pilot, the analysis runtime provides for this retention: documents transmitted for a mission, 30 days; outputs produced, 90 days. For a deletion request write to founder@r-titan.com: we will tell you what can be removed and which metadata must be kept for the integrity of audit records.
Providers
The service relies on third-party providers for authentication and database, file storage and site publishing. Each processes data on our behalf and within the limits of the service provided. A specific list of providers and their processing locations is available on request.
Artificial intelligence and automated processing
The document translation service uses a generative model provided by Google Cloud (Vertex AI), with processing in a European region; this indication concerns translation and does not automatically extend to generation and embeddings in the analysis runtime. Documents or passages you choose to translate are transmitted to the provider solely to produce the requested translation. Under Google Cloud terms, customer data is not used to train models without permission and is not made available to other customers. Training restrictions do not, however, rule out logging, temporary caching and abuse monitoring, which depend on the service, the terms and the configuration: R-TITAN does not claim zero data retention for these services. The R-TITAN document analysis engine, connected to the platform in a restricted-access pilot, also transmits the text of a mission's documents to the Google Cloud generative models provided for by its configuration, to produce the requested analysis. In the pilot, missions concern public or synthetic documents, and the outputs produced are not certified. This notice will be updated before any extension of automated processing, in particular before confidential documents are admitted.
Transparency on generated content (AI Act, Art. 50)
Text produced by the translation service is generated by an artificial intelligence system, and is declared as such in the interface and in every translation file. Regulation (EU) 2024/1689 has imposed transparency obligations on artificially generated content since 2 August 2026: the platform complies by visibly stating the nature of the content, the model used, the version of the principles applied and the limits of the rendering. Regulation (EU) 2026/1744, in force since 27 July 2026, postponed the application of obligations for Annex III high-risk systems to 2 December 2027, without amending the transparency obligations.
System classification and human oversight
As things stand, R-TITAN is a document analysis support tool for professionals, and is not used for purposes that Annex III of Regulation (EU) 2024/1689 classifies as high risk. Classification depends, however, on the concrete intended purpose: use in the administration of justice or in other areas listed in Annex III would require a specific assessment before adoption. The outputs produced are not automated decisions: they produce no legal effects and do not similarly significantly affect any person, and remain subject to the assessment of a qualified professional who retains responsibility for them.
Your rights
You may request access to your data, rectification, erasure, restriction of processing, portability and objection. You may also lodge a complaint with the competent supervisory authority. To exercise these rights write to founder@r-titan.com: we respond within the time limits set by Regulation (EU) 2016/679.
Security
Access is verified on the server for every request. Tenant isolation is enforced at database level, not only in the interface. Documents are not reachable without a current authorisation check. No security measure removes risk entirely: any significant incident will be notified as required by law.
Data outside the current scope
At this stage the service is not intended for special categories of data, data relating to minors, or confidential case files. Do not upload documents of this kind until the scope is extended with the necessary assessments.
This notice is drafted in good faith and describes how the service actually works. It does not replace professional legal review, which will be carried out before opening to external users.
Contact
For any request concerning this page: founder@r-titan.com