PrivacyTermsCookiesDPASubprocessorsRecords of processingPortuguês
On this page1. Who we are2. What data we process, why and on what legal basis3. How long we keep it4. Who we share it with, and transfers outside the EU5. Your rights6. Security7. Cookies8. Minimum age9. Contact and complaints

Privacy policy

Version 1 · in force since Oct 15, 2026

⚠️ Draft for legal review. The highlighted fields must be filled in before there are paying customers.

We keep the minimum needed for Bolas Planner to work, in the European Union. We do not sell data or use it for advertising. You can download or delete your data whenever you want.

1. Who we are

The controller for your account data is [COMPANY NAME], tax number [TAX NUMBER], registered at [ADDRESS]. Privacy contact: [PRIVACY EMAIL].

What your team writes in an organization (tickets, comments, pages and attachments) belongs to the organization. For that data, your company is the controller and we process it on its behalf, under the Data processing agreement (GDPR Art. 28).

2. What data we process, why and on what legal basis

DataWhat forLegal basis (GDPR Art. 6)
Name, email, password (stored protected), photo, language, time zoneCreate and manage your accountPerformance of the contract
Role and display name (optional)Prepare your home screen and show your name the way you preferPerformance of the contract
Two-step verification, sign-in history, device and network (hashed only)Protect your account and detect abuseLegitimate interest (security)
Notice and security emailsNotices you chose and security alertsPerformance of the contract; legitimate interest
Error logs (without the content you write)Keep the service workingLegitimate interest
Which version of the terms you accepted, and whenProve the agreementLegal obligation; legitimate interest
The organization’s country, size and sectorApplicable law, future billing and workflow suggestionsPerformance of the contract
Network address and technical browser data in the anti-bot check (Cloudflare Turnstile), when signing in and creating an accountProtect the service against automated attacksLegitimate interest (security)

We do not process special categories of data (for example, health data) on our own initiative. We ask organizations not to put them in tickets without their own safeguards.

There are no automated decisions with effects on you. Artificial intelligence features only make suggestions; a person always decides.

3. How long we keep it

DataHow long
Account (name, email, photo, preferences)While the account exists
Organization content (tickets, comments, pages, attachments)While the organization exists; 30 days after the contract ends, for export, then deleted
Sign-in history12 months
Read notifications6 months
Unread notifications12 months
Organization activity log24 months
Error logs (no content)90 days
Export files7 days
Proof of accepting the termsWhile the account exists, plus 5 years
GDPR requests and the answers3 years after they close (proof of compliance)
Deleted accountOnly an empty record remains, with no name or email; what you wrote in organizations stays as «Former member»

Clean-up is automatic, every day.

4. Who we share it with, and transfers outside the EU

We do not sell or hand over data. We use these subprocessors, each under a data processing agreement:

WhoWhat forWhere the data isSafeguard for outside the EU
Supabase Inc.Database, accounts, files and realtimeIreland (EU)Data processing agreement with standard contractual clauses (for support access)
Vercel Inc.Hosting of the site and server functionsDublin (Ireland, EU); global delivery networkData processing agreement; EU-US Data Privacy Framework or standard contractual clauses
Resend (Plus Five Five, Inc.)Sending the app’s emailsUnited StatesStandard contractual clauses
Anthropic PBCArtificial intelligence features, only when the organization uses themUnited StatesStandard contractual clauses; data is not used to train models
GitHub Inc. (Microsoft)Code integration, only when the organization connects it (read-only)United StatesEU-US Data Privacy Framework and standard contractual clauses
Cloudflare, Inc. (Turnstile)Checking that whoever signs in or creates an account is a person (protection against automated attacks); processes the network address and technical browser dataGlobal network, including the United StatesEU-US Data Privacy Framework and standard contractual clauses

When data leaves the European Union, we use the GDPR safeguards (Art. 44 to 49): the EU-US Data Privacy Framework adequacy decision or the European Commission’s standard contractual clauses. We notify organizations 30 days before adding a new subprocessor.

5. Your rights

  • Access and portability (Art. 15 and 20): download a file with all your data.
  • Rectification (Art. 16): correct your profile whenever you want.
  • Erasure (Art. 17): delete your account; you have 7 days to change your mind.
  • Restriction (Art. 18) and objection (Art. 21): make a request and we answer.
  • Withdraw consent, when there is any, at any time, without affecting what was done before.

Most of this is one button in Profile → Privacy and GDPR; the rest is a request there or to [PRIVACY EMAIL]. We answer within 1 month, free of charge (Art. 12). For what you wrote in an organization, we forward the request to that organization’s owner.

6. Security

Encrypted connections, data separated per organization in the database itself, two-step verification, passwords checked against known data leaks, backups and an activity log (Art. 32).

If a data breach puts you at risk, we tell you without delay and notify the CNPD (the Portuguese data protection authority) within 72 hours (Art. 33 and 34).

7. Cookies

We only use necessary cookies. There is no advertising and no third-party statistics. The full list is in the Cookie policy.

8. Minimum age

Bolas Planner is a service for professionals. You must be at least 16 to create an account.

9. Contact and complaints

Write to [PRIVACY EMAIL]. You can also complain to the Comissão Nacional de Proteção de Dados (CNPD), at www.cnpd.pt.

If we change this policy in an important way, we tell you and ask you to accept it again.

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