Privacy policy
What we do with your data, said plainly. It is a short document because we collect little, and we collect little on purpose.
01In two lines
This site carries no advertising and sells data to no one. It uses cookies to count visits and to measure our ads, and those run only after you say yes. Otherwise we collect data only when you write to us or buy something, and we use it to reply and to deliver.
The rest of this document explains that in detail, because some of it the law requires us to say and some of it we prefer to say even without being asked.
02Who handles your data
The controller of the data described in this document is Sakuzo AI, based in Lisbon, Portugal.
Sakuzo AI, Lda. Lisbon, Portugal. Email for privacy questions: hello@sakuzoai.com.
We have no designated data protection officer, because our activity does not require one. Privacy questions are handled directly by the company, at the address above.
03When we are the controller and when we are not
There is a distinction here that changes who answers for what, and it is worth understanding.
We are the controller
When we decide why and how data is handled. That covers people who visit this site, people who contact us, people who buy a digital product, and our own clients and suppliers. This document is about that handling.
We are the processor
When we handle data on behalf of a client, inside a service we provide them. For example, when an agent we built answers messages from that business's own customers. In those cases the data belongs to our client, not to us, and we only do what they instruct, under a written agreement that governs it.
If you are a customer of a business that works with us and you want to exercise your rights over that data, the route is to contact that business. If you write to us, we pass it along.
04What we collect, and why
We collect little, and nothing out of habit. Every line in this table exists because it has somewhere to go.
| When | What we collect | What for | On what basis |
|---|---|---|---|
| Visiting the site | Nothing, until you choose in the cookie banner. If you accept, measurement and advertising cookies stay, with an identifier for your browser | To know which pages get read, and whether our ads are worth what they cost | Your consent, which you can withdraw at any time |
| When you fill in the contact form | Name, email address, phone with the country code, what you write, and the record that you accepted these terms | To reply and to follow up | Steps taken at your request before a contract, or our legitimate interest in answering people who approach us |
| If you check the updates box | Your email address and the record of that permission | To send you Sakuzo AI updates | Your consent, given separately from accepting the terms, which you can withdraw at any time |
| When you request the account review, inside a program you subscribed to | Name, email address, and the name of the account you want reviewed | To carry out the review, send it to the address you gave, and make sure each subscriber gets one | Performance of the contract |
| When you buy a digital product | Name, email address, country, and the record of the purchase | To deliver the product, support the buyer, and meet the accounting and tax obligations that fall to us | Performance of the contract and legal obligation |
| When you subscribe to a program | Name, email address, country, the payment records, and the record that you asked for immediate access | To deliver the service, invoice, give access to the program pages, and keep proof of the request for immediate access | Performance of the contract and legal obligation |
| When you are a client | Contact and billing details, and whatever the service requires | To deliver the service, invoice, and maintain the relationship | Performance of the contract and legal obligation |
| If you allow it | Email address | To send you our own communications | Your consent, which you can withdraw at any time |
We do not collect special categories of data, such as health, beliefs or origin, and we ask that you do not send us that kind of information in writing without need.
Our services are not directed at anyone under sixteen and we do not knowingly collect their data.
05What this site loads from elsewhere
The site is made of static pages and small functions, which run only when someone sends a form or enters the area reserved for subscribers. Those functions store nothing on this site. There are, even so, third-party connections that have to be declared.
The contact form
What you write in the forms on this site, the one on the contact page included, reaches our email through our email and storage provider, which handles it under its own privacy policy.
The account review request lives on a page of this site that only subscribers can reach. What you write there reaches our email and a record of ours, kept with the same provider, and is used to carry out the review and to make sure each subscriber gets one.
Program emails, meaning the welcome email, the sign-in email, and the newsletter, are sent through an email delivery provider, which receives your name and email address for that purpose only.
Protection against automated submissions
To stop messages sent by automated programs, the contact page uses a verification service. When you open that page, your browser connects to that service and sends it technical data, such as your IP address and characteristics of your browser and device. The service uses that data to tell whether a person is writing and to improve that check, and handles it under its own privacy policy. We do this on the basis of our legitimate interest in protecting the form and our inbox.
Measurement and ads
If you accept in the cookie banner, the site loads the measurement and advertising tools declared in our cookie policy. Until you accept, none of them loads. The data they collect goes to the providers of those tools, who handle it under their own policies.
Hosting
The site is hosted by a hosting provider which, like any server, logs the requests it receives for technical and security reasons, IP addresses included. Those logs keep the service running and protect it from abuse, and we do not use them to identify visitors. If you want to know who that provider is, write to us and we will tell you.
Payments
Single purchases are processed by an external payment platform that acts as the merchant of record and handles the card details as controller of that data, under its own privacy policy. The invoice for those purchases is issued by that platform.
Subscriptions are sold by us and charged through a payment provider, which receives the card details directly. The invoice for subscriptions is issued by us.
In neither case do we see or store your card number. From each purchase and each subscription we keep the name, the email address, the country, and the payment records.
06Who we give access to
We do not sell, rent or trade personal data. Full stop.
We give access only to those who need it to provide us a service, and always under a written contract that binds them to use it for that purpose alone. These are providers of hosting, email, email delivery, forms, payment, storage and work organization, and accounting.
We do not name each provider here. These services change over time, and a list of names written on a page goes stale without anyone noticing, which serves you worse than not having it. If you want to know which providers we use, specifically and at a given date, write to us and we will tell you.
We may also have to disclose data to public authorities where the law requires it. In that case, we disclose the minimum required.
07If data leaves Europe
Some of the providers we use have infrastructure outside the European Economic Area, among them email, payment and artificial intelligence services.
When that happens, the transfer is made only under a mechanism the law provides: an adequacy decision by the European Commission, or the standard contractual clauses it has approved, with whatever additional measures are necessary.
If you want to know, specifically, which providers we use and under which mechanism, write to us and we will tell you.
08How long we keep it
| What | How long |
|---|---|
| Messages from people who contact us and do not become clients | Up to two years after the last contact |
| Client data and the service provided | For the duration of the contract, and five years after it ends, as evidence |
| Invoices and documents with tax relevance | Ten years, as the law requires |
| Address for communications you allowed | Until you withdraw permission |
Once the period ends, the data is deleted or irreversibly anonymized.
09Your rights
Over the data we handle as controller, you have the rights European law gives you, and they are these.
- Know what data we hold about you and get a copy of it
- Correct anything wrong or incomplete
- Erase, where it is no longer needed or where the handling rests on your consent
- Restrict the handling, while a question is being resolved
- Object to handling that rests on our legitimate interest
- Take your data with you, in a machine-readable format
- Withdraw consent at any time, without affecting what was done before on that basis
To exercise any of these, write to the address at the end. We answer within one month, extendable by two more if the request is complex, in which case we tell you. We charge nothing for this, unless the request is manifestly unfounded or repetitive.
If you believe we handled your data badly, you can complain to the Comissão Nacional de Proteção de Dados in Lisbon, or to the supervisory authority of the European Union country where you live. We would appreciate hearing from you first.
10If you are in the United States
We are a Portuguese company and we apply the same principles and the same practices described in this document to everyone, whatever country you write from.
We do not sell personal data and we do not share it for targeted advertising, in the sense those terms carry in United States privacy laws.
If you live in a state whose law gives you rights over your data, among them to know what we hold, to ask that it be deleted, to correct it, or not to be discriminated against for exercising those rights, write to us and we will handle the request. We do not ask you to prove where you live in order to do it.
11Security
We keep data in services with restricted access and two-step authentication, and we limit who reaches it to what is needed to work.
No system is infallible and we do not promise otherwise. What we do promise is that, if there is a data breach that could put you at high risk, we tell you and we tell the competent authority, within the deadlines the law sets.
12Changes to this policy
This policy can change, above all when the services we use change. The version in force is the one on this page, with the date at the top.
If a change is significant and affects handling that already concerns you, we tell you.
13How to reach us
For any question about this policy or about your data, write to us.
Email: hello@sakuzoai.com. Address: Lisbon, Portugal.
See also our terms and conditions and our cookie policy.
This policy covers the data we handle as controller. Data we handle on behalf of clients, inside a service, is governed by the processing agreement signed with that client.