PRIVACY NOTICE (Rehably)
Rehably is committed to respecting your privacy and protecting your personal data. This Privacy Notice explains clearly how we collect, process, and safeguard your data when you use our online Services, including our website, platform, and mobile applications (collectively, the “Services”), regardless of where you access them.
This Notice also informs you about your personal data protection rights and how the law protects them.
Users of our Services may be healthcare professionals or patients of healthcare professionals, unless otherwise specifically indicated.
Updated version: 01/11/2026
1. Purpose of this Privacy Notice
This Privacy Notice explains how Rehably collects, uses, and protects your personal data when you use our Services. This includes data you may provide when you subscribe to our newsletter, take part in a free trial, or request a demo.
This Notice applies to the following categories of users:
- Healthcare professionals who provide healthcare services as a business activity (either as individuals or as legal entities) and who use our Services directly.
- Representatives of healthcare professionals organized as companies, such as employees or collaborators, who access our Services on behalf of their employer.
- Patients who access our Services as part of the treatment they receive from a healthcare professional.
From this point onward, these individuals will also be referred to as “Users”, “you”, or “your”.
We invite you to read this Notice together with any other specific privacy notices we may provide to you at specific times when we collect or process your personal data. This Notice supplements those communications and does not replace them.
Data Controller
The Data Controller of your personal data is Environet di Angoni Lorenzo (also referred to as “Rehably”, “we”, “us”, or “our”), which determines the purposes and means of processing your personal data.
When we process personal data on behalf of others, we may act as a Data Processor. In some situations, we may perform both roles, as explained in this Notice.
Contact details
If you have any questions about this Notice or our privacy practices, you can contact us as follows:
- Company name: Environet di Angoni Lorenzo
- Email: info@rehably.it
- Postal address: Via Repubblica 8/a, Mazzano (BS), Italy
You have the right to lodge a complaint with the data protection supervisory authority in your country. However, we ask that you contact us first, so we have the opportunity to address and resolve any issues directly with you.
Changes to this Notice and data updates
We regularly update this Notice. We may make changes from time to time; the updated version will take effect upon publication.
If the changes are significant, we will inform you through the Services, by email, or via other communication channels. We encourage you to periodically check this page to stay informed about our privacy practices.
It is important that the data we hold about you is accurate and up to date. Therefore, please let us know about any changes to your data during your relationship with us.
Links to third-party websites
Our Services may contain links to third-party websites, plug-ins, or applications. When you interact with these links, those third parties may collect or share data about you. We have no control over those websites and are not responsible for their privacy notices. We encourage you to always read the privacy notices of the websites you visit.
2. Data we collect
2.1 As Data Controller
Personal data or personal information means any information that identifies, relates to, or describes, directly or indirectly, an identifiable individual. This does not include anonymized data that cannot be used to identify you.
As Data Controller, we may collect, use, store, and transfer different types of personal data about you, grouped as follows.
Healthcare professional data
- Identity data: first name, last name.
- Contact data: billing address, email, phone numbers.
- Customer relationship data: name of your business or employer, role or professional title, contact details, classification within our customer management system, information contained in communications between you and us or between us and your employer.
- Transaction data: payment details and information about products or services purchased.
- Technical data: IP address, login data, browser family and version, language, operating system, platform, client type and application version used to access the Services or receive our emails; approximate area (country and region) derived from the IP address, used only in aggregate form.
- Profile data: API token, email, account creation and modification dates, website settings.
- Usage data: information on how you use our Services.
- Marketing and communications data: preferences and consent to receive marketing materials, such as newsletters. You can withdraw consent at any time by unsubscribing or contacting us at info@rehably.it.
- Financial data: invoices and other accounting information containing personal data. Payment card details are entered and handled directly by Stripe and are not stored by Rehably.
- Service data: data provided by you to facilitate use of the Services and data generated by use of the Services, including analytics, statistics, and performance.
Patient data
As Data Controller we process only the Patient data needed for the security and operation of the platform:
- Usage data: pseudonymised or aggregated information on how you use the app, used for service statistics.
- Technical data: IP address, login data, browser family and version, language, operating system, platform, device type and application version used; approximate area (country and region) derived from the IP address, used only in aggregate form.
Patients' identity, contact and health data (including exercise programmes, feedback and reported pain level) are processed on behalf of the Healthcare Professional, as described in section 2.2.
Aggregated data
We also collect and use Aggregated Data, such as statistical or demographic data about groups of users. This data does not allow you to be identified directly or indirectly. If combined with personal data in such a way that it can identify you, it will be treated as personal data under this Notice.
Special categories of data
We do not collect Special Categories of Personal Data (such as information about race, religion, political opinions, health, genetic or biometric data, criminal offences, or criminal convictions) when we act as Data Controller.
Failure to provide data
If you do not provide the mandatory data required to deliver the Services, we may not be able to properly perform the contract and may have to cancel products or services, informing you promptly.
2.2 As Data Processor
We act as a Data Processor for Healthcare Professionals, collecting data on their behalf. In this role, our use and disclosure of data are limited by the agreements entered into with Healthcare Professionals.
This Notice does not reflect the privacy practices of Healthcare Professionals, and we are not responsible for their policies or practices. We do not monitor or verify their compliance with their respective notices.
For Patient data entered into or generated in the Services, we act as a Data Processor on behalf of the Healthcare Professional, who is the Data Controller. This includes:
- Identity and contact data: first name, last name, mobile phone number and email address, entered by the Healthcare Professional.
- Access data: the app access code.
- Health data: assigned exercise programmes, feedback (including completion and reported pain level), programme adherence, questionnaire answers, and videos and images of personalised exercises.
This data is processed only on the Healthcare Professional's instructions and to provide the Services; it is not shared with analytics or advertising providers.
Data retention (as Data Processor)
In accordance with data protection law, the controller may request that personal data be returned or deleted at the end of the contract. If we do not receive instructions within 30 days after contract termination, we will permanently delete personal data from our systems.
3. How we collect data
We collect data about you using different methods, including:
a) Direct interactions
You may voluntarily provide personal data, such as Identity, Contact, and Financial Data, by filling in forms or communicating with us by post, phone, email, or other means.
In particular, we collect data when you:
- Request to use our products or Services.
- Create an account on our Services.
- Subscribe to newsletters, publications, or other services.
- Request marketing materials to be sent to you.
- Request further information from us.
b) Automated technologies or interactions
When you interact with our Services or our emails, we (and our third-party partners) automatically collect Technical Data about your device, your browsing actions, and usage patterns.
This data is collected through tools such as cookies and server logs. For cookies and similar technologies, see the “Cookies and measurement tools” section of this Notice; optional tools on the website and web applications are subject to the choices described there.
c) Third parties
We may receive personal data about you from various third parties, including:
- Providers of technical and payment services: Contact, Financial, and Transaction Data.
- Meta, if you choose to register through Meta Instant Forms: Identity and Contact Data and, where provided, studio name, as described in the “Registration through Meta Instant Forms” section.
- Healthcare Professionals and other parties for whom we act as Data Processor: personal data provided by them in connection with the Services offered.
4. How we use the data we collect
We use your personal data mainly to manage our Services and perform internal activities, in the following cases:
- Performance of a contract: where it is necessary to enter into or perform a contract with you.
- Legitimate interests: where it is necessary for our legitimate interests (or those of a third party), provided your fundamental rights and interests do not override those interests.
- Legal obligations: where we must comply with an obligation required by law.
- Consent: for specifically identified optional purposes, such as newsletters and advertising measurement.
Use of personal data as Data Processor
When we act as a Data Processor, we use personal data received through the Services exclusively for internal purposes connected with the Services, as provided by the contracts entered into with the Healthcare Professionals for whom we process data.
This use may include, by way of example:
- Extracting, analyzing, and communicating data.
- Preparing reports and documentation on Patient data.
- Managing recommendations and communications between Healthcare Professional and Patient.
- Activities related to providing and improving the Services.
Purposes / data / lawful basis table
| Purpose/Activity | Type of data | Lawful basis for processing (incl. legitimate interests) |
|---|---|---|
| Register you as a new User and create an account/profile | Identity; Contact | Performance of a contract with you |
| Provide our services to you, including: managing payments/fees/charges; collecting sums owed to us; operational management of the Services; provision of the Services | Identity; Contact; Financial; Transactions; Marketing and Communications; Customer relationship; Service Data (Patient data is processed on behalf of the Healthcare Professional, section 2.2) | Performance of a contract with you; necessary for our legitimate interests (to recover debts owed to us) |
| Manage our relationship with you, which will include: notices about changes to terms or the Notice; requesting reviews/surveys; necessary service communications | Identity; Contact; Profile; Marketing and Communications; Customer relationship | Performance of a contract with you; necessary to comply with a legal obligation; necessary for our legitimate interests (keeping records up to date and studying product/service usage) |
| Send newsletters and promotional offers | Contact; Marketing and Communications | Optional, withdrawable consent |
| Measure campaigns and registrations through Meta Pixel | Technical data; cookie identifiers; registration event | Separate optional, withdrawable consent |
| Establish or defend legal rights | Identity; Contact; Profile; Usage; Marketing and Communications; Service Data | Necessary for our legitimate interests (protecting and asserting our legal rights, your legal rights, and the legal rights of third parties) |
Marketing and promotional offers
You may receive newsletters or promotional communications from us or on our behalf only if you have provided consent. We are committed to always offering you clear choices about how we use your data for marketing. In each communication you will find mechanisms to manage your preferences, and you can unsubscribe at any time through the Platform or by sending an email to info@rehably.it.
We may use your Identity, Contact, Technical, Usage, and Profile Data to determine which services or offers may be most relevant to you, so that we can personalize communications (an activity defined as “marketing”).
Cookies and measurement tools
We use technologies necessary to operate the Services and, separately, optional tools for support, statistics and advertising measurement. This section provides the cookie information referred to elsewhere in this Notice.
On the public website you can accept, reject or separately choose support through OpenWidget, statistics through Google Analytics 4, and marketing through Meta Pixel. These optional tools load only after the corresponding choice. You can change it using the cookie preference control available on the website after your initial choice. The website preference stays in your browser until changed or deleted; it is not automatically transferred to the physiotherapist application.
Product analytics in the physiotherapist portal and Help Center use PostHog, where configured, with separate consent through their respective privacy controls. Selected usage events are measured without sending entered text, patient data or screen recordings. Refusing optional cookies and analytics does not prevent registration or use of essential features. Blocking necessary technologies may affect operation of the Services.
Meta Pixel and physiotherapist registration
Purpose and lawful basis. With your optional consent, we use Meta Pixel to measure advertising campaign effectiveness and attribute registrations to campaigns. The lawful basis for this measurement is consent under Article 6(1)(a) GDPR, together with the applicable rules on accessing and storing information on your device. Accepting the terms, reading this Notice or consenting to newsletters/offers does not constitute consent to Meta Pixel.
Data and event. On the public website Meta may receive information about page visits. In the physiotherapist registration form, CompleteRegistration is sent only after the backend confirms account creation. The event adds no name, email, account identifier, patient data, clinical content, form contents, monetary value or currency. This does not make the communication anonymous: connecting to Meta may transmit your IP address, browser/device information, URL and request metadata, and may read or set cookie identifiers such as _fbp and, where present, _fbc. Meta may combine this information with other data it holds, as described in its own notices.
Scope and choice. In the physiotherapist application, the Pixel is limited to the registration form and loads only when you select the dedicated Meta checkbox, which is initially unchecked. The code does not send Meta events from clinical pages. Your choice applies to that visit to the form: you can withdraw it by clearing the checkbox before continuing; leaving the form causes the code to revoke SDK consent. A later visit requires a new choice. On the public website, you instead change your marketing choice through the cookie preference control. You can also block or delete cookies using your browser settings; doing so does not automatically delete data already transmitted to the provider. The dedicated Meta checkbox is accessed through “Cookie preferences” on the registration page, outside the form fields. Accepting the service terms does not activate the Pixel.
Registration through Meta Instant Forms. If you choose this route, Meta collects the information you submit under its own notices and shares it with Rehably. We use your first name, last name, email and optional studio name to initiate the registration you request. Explicit acceptance of the service terms is required; submitting a form does not authorise newsletters, advertising cookies or optional analytics. You receive an email link to confirm your address and choose a password. We retain lead, form and ad identifiers and, where available, campaign and ad set identifiers, together with the accepted terms reference. We internally link acquisition source to registration, confirmation, first programme creation and first paid subscription to assess the acquisition channel, without including programme content or patient data in reports. This integration does not send these stages to Meta through the Conversions API and does not provide social login to your Rehably account.
Recipient, retention and transfers. Measurement data is shared with Meta under the applicable business tool terms. Cookies and data received by the provider may have different retention periods: withdrawal stops new transmissions authorised by this integration, but does not automatically erase data already received. For the applicable periods, Meta's processing, possible transfers outside the European Economic Area and the related safeguards, see Meta's Privacy Policy, Meta's Cookie Policy and Business Tools Terms. For information about processing for which Rehably is responsible and to exercise your rights, email info@rehably.it. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Providers used by the different features
Depending on the feature you use and the service configuration, Rehably uses the following providers. Not every integration is present on every page or application; optional services remain subject to the activation choices described above.
| Provider / service | Feature and relevant data categories |
|---|---|
| Meta Pixel | Public website visits and physiotherapist registration measurement; the event and technical/cookie data described above, with the corresponding consent |
| Google Analytics 4 | Public website statistics and technical browsing data, after consent to the statistics category |
| OpenWidget | Public website support, technical data and content you choose to submit through chat, after consent to that feature |
| PostHog Cloud EU | Selected physiotherapist portal and Help Center usage events, where configured and after their respective analytics consent |
| Amazon Web Services (AWS) | Infrastructure, content storage and service email delivery; data necessary for the feature being used |
| Stripe | Payment and subscription management; billing, payment and business relationship data |
| Brevo | Account lifecycle communications, where enabled; professional contact/profile data, trial/subscription status, marketing preferences and communication delivery/interaction data |
| Sentry | Patient application error diagnostics; technical data, errors and release metadata. The application configuration disables session recording and default inclusion of identifying data |
| Google Firebase | Remote configuration of supported patient application versions and the SDK technical data needed to fetch it. The patient application does not send usage events to Firebase |
Meta consent covers only the advertising measurement described above: it does not authorise other services or patient application tracking. For details about the feature you use and to exercise your rights, contact info@rehably.it.
Change of purpose
We will process your personal data only for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is closely related to the original one.
If you wish to better understand the link between the original purpose and the new purpose, you can contact us for a detailed explanation.
If we need to use your personal data for unrelated purposes, we will notify you in advance, explain the lawful basis and, where required by law, obtain your explicit consent.
In accordance with applicable law, we may also process your data without consent or direct communication when required or permitted by law.
5. Disclosure of personal data
We may share your personal data for business and commercial purposes, such as operating the Services, with the following categories of recipients:
- Healthcare Professionals who use the Services to collect and process the data of their Patients.
- Service providers acting as Data Processors, providing IT, hosting, and system administration services (as indicated in the chapter “Transfers to third parties”).
- Affiliated companies, acting as controllers or processors, for business and commercial purposes.
- Professional advisors, including lawyers, bankers, auditors, and insurers, providing consulting, legal, banking, insurance, or accounting services.
- Regulators and other governmental authorities, where required by law.
- Third parties involved in corporate transactions, such as the sale, transfer, or merger of parts of our business or our assets, or acquisitions or mergers with other companies.
In these cases, new owners may use personal data in the same manner set out in this Privacy Notice.
6. International transfers of personal data
Where necessary, we may need to transfer your personal data to another country to provide the Services to you, for marketing purposes, or for customer relationship management.
Many of our external providers are based outside the country where you live, so their processing of your personal data may involve a transfer outside your country of residence.
How we protect data during transfers
Whenever we transfer your personal data outside your country, we take reasonable measures to ensure it receives a similar level of protection.
Transfers outside the European Economic Area are subject to the conditions and safeguards required by applicable law, such as an adequacy decision or, where necessary, appropriate safeguards. Provider information does not replace the rights you can exercise against Rehably.
For the providers involved, see “Providers used by the different features”. For information about transfers involving your data and the applicable safeguards, contact info@rehably.it.
7. Security of personal data
We adopt reasonable security measures to comply with applicable legal requirements and to prevent accidental loss, misuse, unauthorized access, alteration, or disclosure of your personal data.
While we strive to protect your personal data, we cannot guarantee the security of any data transmitted online. We limit access to personal data to employees, agents, collaborators, and third parties who have a business need to know. These parties process data only on our instructions and are subject to confidentiality obligations.
We also have procedures in place to deal with any suspected personal data breach and will notify you and the competent authority where required by law.
8. Data retention
We retain your data for as long as necessary to fulfill the purposes for which we collected it, including meeting contractual, legal, regulatory, tax, accounting, or reporting requirements. In particular:
| Data | Retention period |
|---|---|
| Healthcare professional account and profile | For the duration of the contractual relationship |
| Invoices and accounting records | 10 years, as required by Italian civil and tax law |
| Patient data processed on behalf of Healthcare Professionals | For the duration of the contract with the Healthcare Professional; returned or deleted within 30 days of termination, as described in section 2.2 |
| Audit log of operations (action, actor, outcome, date and IP address, without clinical content) | 7 years, for security, accountability and the protection of legal rights |
| Technical operating logs of the Services | 90 days |
| Pseudonymised sign-in register and daily counts by approximate area (without IP address or identifiers), used only for aggregate statistics | 35 days; afterwards only non-identifying aggregate data is kept |
| Product statistics collected with PostHog | 12 months |
| Marketing preferences and consents | Until the choice is withdrawn |
Data received by third-party providers for optional features, such as Meta and Google, is retained by those providers under their own notices.
The retention period may vary in the event of a complaint or if a dispute may arise regarding our relationship with you.
Once the appropriate retention period has expired, data will be securely deleted.
In some circumstances you can ask us to delete your data: see the “Data subject rights” section for more information.
9. Data subject rights
Depending on your country of origin, you may have the following rights:
- Request access to your personal data (data subject access request).
- Request rectification of the personal data held.
- Request erasure of personal data.
- Object to the processing of your personal data.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data to you or to a third party, in a structured, commonly used, and machine-readable format (within the limits set out in the document).
- Withdraw consent at any time.
To exercise any of the rights listed above, contact us by email: info@rehably.it.
Supplement to the Terms and Conditions: consent and advertising measurement
Updated 16/10/2026. This supplement concerns only choices about cookies, advertising measurement and promotional communications. It supplements the terms applicable to your relationship with Rehably and does not change agreed prices, duration, renewals, cancellation rights or services.
- Separate choices. Accepting the service terms and acknowledging the Privacy Notice do not automatically authorise advertising cookies, optional analytics or newsletters. Each optional choice is requested through its own control.
- Freedom of choice. You can register and use essential features without consenting to Meta Pixel or promotional communications. Refusing or withdrawing consent is not a contractual breach and does not incur an additional charge.
- Registration measurement. If you consent to Meta Pixel through the cookie preferences on the physiotherapist registration page, Rehably may communicate account creation to measure campaigns. This event does not establish a payment, subscription purchase or subsequent email verification, and does not change your plan.
- Withdrawal and rights. The ways to change your choices and the technical data involved are described in the “Cookies and measurement tools” section on this page. Consent to one purpose is not extended to other purposes. For requests about your data, contact info@rehably.it.