Note: In case of any conflict between the English and Portuguese versions of this policy, the English version shall prevail.
Summary: Verdaio collects only what is necessary to deliver our compliance tools. We do not sell your data. We use AWS-hosted infrastructure within the EU. You may request deletion of your data at any time by emailing privacy@verdaio.ai.
1. Data Controller
The data controller responsible for your personal data is:
Pragmatic Vibe - Unipessoal Lda (operating the "Verdaio" brand)
NIPC: 519377257
R. Hermano Neves 18, Piso 3, Escritório 7, V6039
1600-477 Lisboa, Portugal
Email: privacy@verdaio.ai
Website: verdaio.ai
When this policy refers to "Verdaio", "we", "us", or "our", it means Pragmatic Vibe - Unipessoal Lda acting as data controller for personal data collected through our website and tools.
2. Data We Collect
We collect the following categories of personal data:
2.1 Data stored in your account
| Data | Stored where | Purpose |
|---|---|---|
| Email address and password | Supabase (account) | Account authentication and report delivery |
| Assessment completion records (tool name, date) | Supabase | Usage tracking and rate limiting |
| AI-generated report records (tool identifier, job ID, status, structured report output) | Supabase | Internal record of service delivery for audit and accountability (GDPR Art. 5(2), AI Act post-market monitoring). Not surfaced back to users as a re-access feature. 3-year retention from generation, or until account deletion (whichever comes first). |
| Report feedback (tool, issue type, free-text description) | Supabase | AI Act human-oversight and product-quality monitoring; 3-year retention |
| Subscription or purchase records | Supabase | Access control and billing history |
| Pre-launch registration waitlist (email address, language preference, source) | Supabase | Notify you when account registration opens; retained until launch or until you request deletion |
| Company name, VAT number, billing address | Stripe and InvoiceXpress only | Payment processing and invoice generation. Not stored by Verdaio. |
2.2 Data processed but not stored
The following data is provided by you during assessments. It is sent to our AI engine (Claude model via Amazon Bedrock, hosted in AWS eu-west-1, Ireland) in real time to generate your report, then immediately discarded. Verdaio does not store this data on its servers, and the data does not leave the EU.
| Data | Purpose |
|---|---|
| Company name, sector, size, revenue, countries of operation | To generate a relevant, sector-specific AI analysis |
| Assessment questionnaire responses | To calculate your compliance profile and generate recommendations |
Your company profile is saved locally in your browser (localStorage) for convenience when using multiple tools. localStorage is browser storage local to your device and is not a cookie; it transmits no data to Verdaio. This data never leaves your device unless you submit an assessment.
2.3 Data collected automatically
Analytics. When you visit our website, we collect anonymous, aggregated usage data via Plausible Analytics (EU-hosted, no cookies, no personal data). This includes page views, engaged time per page (active focus time, no per-visitor profiles), referral sources, country, device type, browser, outbound link clicks, file downloads, and form submission events. Plausible does not store or transmit IP addresses. No individual visitors can be identified via our analytics.
Server access logs. We deliberately do not retain CloudFront access logs. Your IP address, URL, user-agent, and other request metadata are not captured at our CDN edge. If operational need arises in the future, we will re-enable logging under a documented lawful basis and update this section before doing so.
3. How We Use Your Data
We use your personal data for the following purposes:
- To deliver the service: Processing your assessment inputs through our AI engine to generate a personalised compliance analysis and sending a secure download link to your email address.
- To improve our tools: Analysing aggregated, anonymised assessment patterns to improve the quality and accuracy of our compliance analysis. Individual responses are never shared externally in identifiable form.
- To comply with legal obligations: Retaining records as required by applicable law.
We do not use your data for automated decision-making that produces legal effects or similarly significant impacts without human review.
4. Legal Basis for Processing
Under the General Data Protection Regulation (GDPR), we rely on the following legal bases:
| Processing activity | Legal basis (GDPR Art. 6) |
|---|---|
| Generating and delivering your assessment report | Performance of a contract / pre-contractual steps (Art. 6(1)(b)) |
| Sending your report download link by email | Performance of a contract / pre-contractual steps (Art. 6(1)(b)) |
| Recording assessment completions (tool name, date) for usage tracking | Legitimate interests (Art. 6(1)(f)), we have a legitimate interest in managing service usage and preventing abuse |
| Website analytics (Plausible Analytics, anonymous aggregated data) | Legitimate interests (Art. 6(1)(f)) - improving service quality. No personal data processed, no consent required. |
5. Third-Party Processors
We share data with the following third-party service providers who process data on our behalf under appropriate Data Processing Agreements:
| Processor | Purpose | Data shared | Location |
|---|---|---|---|
| Amazon Web Services EMEA SARL | Website hosting (S3 + CloudFront), serverless function execution (Lambda), and API routing (API Gateway) | All data transiting the platform | AWS eu-west-1 (Ireland) |
| Amazon Web Services EMEA SARL (Amazon Bedrock) | AI-powered analysis generation (Claude model via Amazon Bedrock) | Company profile and assessment inputs (processed in real time, not stored) | AWS eu-west-1 (Ireland). Data never leaves the EU. Amazon Bedrock does not retain input or output data. The AI model (Claude by Anthropic) is hosted on AWS infrastructure; Anthropic does not receive or access the data. Covered by the AWS Data Processing Addendum. Assessment inputs consist of company-level business data (company name, sector, size, assessment responses) and do not contain personal data of natural persons. |
| Sendinblue SAS (Brevo) | Transactional email delivery | Email address, recipient name, report download link (no report content attached) | France. Data stored on own servers in France and Germany, plus Google Cloud Platform in Belgium (EU). Contracting entity is Sendinblue SAS (Paris, France), under French CNIL supervision. |
| Supabase, Inc. | Database and authentication | Email, hashed password, assessment completion records (tool name, date), subscription status | AWS eu-central-2 (Zurich, Switzerland), Switzerland has EU adequacy status |
| Stripe Payments Europe, Limited | Payment processing, primary contracting processor (EU) | Name, email, billing address, VAT number, payment method details | Dublin, Ireland (EU), no international transfer at this layer |
| Stripe, LLC (affiliate of Stripe Payments Europe) | Shared platform, fraud detection, and risk infrastructure for the payments network | Same categories as above, shared by Stripe's EU entity with its US affiliate as part of the same payment-processing service | United States, Standard Contractual Clauses (SCCs) and EU–US Data Privacy Framework (DPF self-certification) |
| Tutao GmbH (Tuta Mail) | Active email hosting for Verdaio controller inboxes (@verdaio.ai addresses, e.g. privacy@, support@, legal@, contact@) since 2026-05-08 | Email metadata and content sent to Verdaio controller addresses by you or by counterparties corresponding with you, including any personal data included in message bodies or attachments (for example, DSR submission content and identification copies) | Germany (EU/EEA). All data stored in ISO 27001 certified data centres in Germany. No international data transfer. Data processing covered by Tutao GmbH's standard terms (Art. 28 GDPR), Hannover, HRB 208014, Amtsgericht Hannover, USt-IdNr DE280903265. |
| Google LLC (Google Workspace) (historic sub-processor only) | Retains email received at @verdaio.ai addresses before 2026-05-08. No new email is delivered to Google Workspace (MX records repointed to Tutao GmbH on 2026-05-08). The Google Workspace subscription is set to terminate on its 2027-04-03 renewal date, after which the historic mailbox content is deleted per Google's retention policy and the next Privacy Policy version will remove this row. | Same categories as above, scoped to historic mailbox content only | United States. Standard Contractual Clauses (SCCs) and EU–US Data Privacy Framework (DPF self-certification). Applies to historic content only. |
| InvoiceXpress (Invoicing) | Invoice generation and delivery | Name, email, billing address, VAT number, purchase amount | Portugal (EU) |
| Plausible Analytics (Plausible Insights OÜ) | Anonymous website analytics | Aggregated page views, referral sources, country, device type. No personal data, no IP addresses. | EU (Estonia). No personal data processed. Privacy policy: plausible.io/data-policy |
We do not sell, rent, or share your personal data with any third party for their own marketing purposes.
For enterprise customers requiring a formal Data Processing Agreement, please visit our DPA page to review our coverage and request the full agreement.
We maintain a full Record of Processing Activities (ROPA) per Art. 30(1) GDPR. The ROPA is an internal accountability document, available to the supervisory authority (CNPD) and to qualifying customers on request via privacy@verdaio.ai.
6. International Data Transfers
Your data is primarily processed within the European Economic Area (EEA). Where data is transferred to processors outside the EEA, we rely on the following safeguards:
- Stripe: Your contracting processor is Stripe Payments Europe, Limited (Dublin, Ireland), so data entry and primary processing occur within the EU. As part of Stripe's payment network, some personal data is shared with Stripe, LLC in the United States for platform, fraud, and risk operations. That US leg is covered by a double Chapter V mechanism: Standard Contractual Clauses (SCCs) approved by the European Commission and the EU–US Data Privacy Framework (DPF), Stripe, LLC is self-certified under the DPF. Either mechanism alone would provide a valid legal basis; Stripe uses both for defence-in-depth.
- Google Workspace (historic only): Google LLC (United States) retains email received at our controller inboxes (@verdaio.ai addresses) before 2026-05-08. From 2026-05-08 onwards, new inbound email is hosted by Tutao GmbH in Germany (see §5), so the active flow no longer involves any transfer outside the EEA. The historic transfer to the United States is covered by a double Chapter V mechanism: the Standard Contractual Clauses in Google's Data Processing Amendment (auto-accepted via Google Workspace terms) and the EU–US Data Privacy Framework under which Google LLC is self-certified. The Google Workspace subscription expires on 2027-04-03, after which historic content is deleted per Google's retention policy.
Controller-inbox email received since 2026-05-08 is hosted by Tutao GmbH in Germany (ISO 27001 certified data centres) and does not involve any international data transfer.
AI processing (Amazon Bedrock) takes place entirely within the EU (AWS eu-west-1, Ireland) and does not involve any international data transfer.
Transactional email (Sendinblue SAS, Brevo) is processed entirely within the EU (France, Germany, and Google Cloud Platform Belgium) and does not involve any international data transfer.
7. Data Retention
We retain personal data only for as long as necessary for the purposes described in this policy:
- Account data (email, password): retained until you delete your account.
- Assessment completion records (tool name, date): retained for up to 3 years, or until you request deletion.
- Subscription and purchase records: retained for the duration of your account, or as required by Portuguese tax law (minimum 10 years for invoices, held by InvoiceXpress).
- Assessment inputs (company profile, questionnaire responses): not stored. Processed in real time and discarded after report generation.
- AI-generated reports: stored temporarily in encrypted storage (AWS S3, eu-west-1) for up to 48 hours to enable download, then automatically deleted.
- Email notification logs: retained by Brevo (Sendinblue SAS) for up to 100 days within EU infrastructure. Brevo receives only the recipient email address, the download link, and message metadata. The actual report content is never transmitted through the email service.
- Website analytics data: aggregated, anonymised site metrics are retained indefinitely by Plausible; no individual-level data is collected in the first place (no cookies, no IP addresses, no cross-session identifiers).
You may request deletion of your data at any time. See Section 8 for how to exercise this right.
8. Your Rights Under GDPR
As a data subject under GDPR, you have the following rights:
- Right of access, request a copy of the personal data we hold about you.
- Right to rectification, request correction of inaccurate or incomplete data.
- Right to erasure, request deletion of your personal data ("right to be forgotten").
- Right to restriction, request that we restrict processing of your data in certain circumstances.
- Right to data portability, receive your data in a structured, machine-readable format.
- Right to object, object to processing based on legitimate interests.
- Right to withdraw consent, where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at privacy@verdaio.ai. We will respond within 30 days. You also have the right to lodge a complaint with your national data protection authority. In Portugal, this is the Comissão Nacional de Proteção de Dados (CNPD) at cnpd.pt.
Personal data breaches. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the CNPD within 72 hours of becoming aware of the breach, in accordance with Art. 33 GDPR. Where the breach is likely to result in a high risk, we will also notify affected users without undue delay, in accordance with Art. 34 GDPR. Our internal incident response procedure is documented in a runbook maintained under our compliance pack.
9. Cookies
Verdaio does not use tracking, advertising, or marketing cookies. Our analytics provider (Plausible) operates entirely without cookies. For full details, see our Cookie Policy.
10. Minors
Our services are directed at businesses and professionals. We do not knowingly collect personal data from individuals under the age of 16. If you believe we have inadvertently collected such data, please contact us at privacy@verdaio.ai and we will delete it promptly.
11. Changes to This Policy
We may update this Privacy Policy from time to time.
For minor editorial changes (clarifications, typo fixes, version-history updates), continued use of our services after changes are posted constitutes acceptance of the updated policy.
For material changes (introducing a new lawful basis, a new purpose, a new category of recipient, or a new category of personal data), we will provide prominent notice before the change takes effect. Where the change affects processing that relies on your consent, we will request renewed affirmative consent before continuing that processing.
We encourage you to review this policy periodically. The "Last updated" date at the top of this page reflects the latest revision.
Version history
| Version | Date | Changes |
|---|---|---|
| 1.13 | 18 May 2026 | Migration of controller email hosting from Google Workspace (Google LLC, United States) to Tuta Mail (Tutao GmbH, Hannover, Germany). All new email received at @verdaio.ai addresses has been hosted by Tutao GmbH in Germany since 2026-05-08, after the MX records were repointed away from Google. §5 sub-processor table adds Tutao GmbH and reframes Google LLC as a historic-only sub-processor that retains pre-2026-05-08 mailbox content until the Google Workspace subscription expires on 2027-04-03, after which the historic content is deleted per Google's retention policy and a follow-up Privacy Policy version will remove the Google LLC row entirely. §6 international transfers updated to reflect that the active inbound-email flow no longer involves any transfer outside the EEA; the Google LLC United States transfer mechanism is now scoped to historic mailbox content only. Tutao GmbH stores all data in ISO 27001 certified data centres in Germany. No new data categories, purposes, lawful bases, recipient categories, or cookies; this version reflects an infrastructure change to improve data residency posture (data minimisation by jurisdiction). |
| 1.12 | 5 May 2026 | Clarification of existing analytics scope, no new processing activity. §2.3 "Analytics" enumeration extended to align with the deployed Plausible tagged-script bundle (pa-nghaVkCvLQNoccyAqUOUe.js, 6,187 bytes, inspected 2026-05-05): added engaged time per page (active focus time only, no per-visitor profiles), outbound link clicks, file downloads, and form submission events. Same processor (Plausible Insights OÜ, EU/Estonia), same legal basis (Art. 6(1)(f) legitimate interest), same data subjects, same retention, same transfer profile (none). No cookies, no personal data, no fingerprinting introduced, the four extensions are event-listener-based behavioural counters processed in aggregate by Plausible. This bump documents what has already been collected; no change to the underlying processing. |
| 1.11 | 18 April 2026 | Legal Reality Check corrections aligning this policy with the deployed system. §2.1 extended with rows for the Supabase `jobs` table (AI-generated report records retained 3 years for audit and accountability, not surfaced for user re-access), the `report_feedback` table (user feedback for AI Act post-market monitoring, 3 years), and the `waitlist` table (pre-launch registration notification). §2.3 "Server access logs" rewritten: CloudFront standard logging is deliberately disabled as of 2026-04-10 (data minimisation); no IP, URL, user-agent, or referer is captured at our CDN edge. §5 adds Google LLC (Google Workspace) as the hosting provider for our controller inboxes (@verdaio.ai email); covers inbound email including DSR submissions and legal correspondence; US, SCCs + EU–US DPF double mechanism. §6 extended to describe the Google Workspace transfer mechanism. §7 retention: website analytics retention corrected from "26 months" (GA4 holdover, inaccurate since migration to Plausible) to "aggregated indefinitely by Plausible; no individual-level data collected". §8 adds an explicit breach-notification commitment (CNPD within 72 hours per Art. 33, affected users without undue delay where high-risk per Art. 34). §2.2 localStorage clarified: localStorage is browser-local storage, not a cookie, and transmits no data to Verdaio. §11 rewritten: minor editorial changes continue to apply under passive acceptance; material changes (new lawful basis, new purpose, new recipient category, new category of personal data) will be announced with prominent notice before taking effect, and where the change affects processing that relies on consent, renewed affirmative consent will be requested. No new core data categories introduced beyond what was already being processed internally; this version discloses it. |
| 1.10 | 14 April 2026 | Stripe sub-processor description made more precise: Stripe Payments Europe, Limited (Dublin, Ireland) is named as primary contracting processor (EU, no international transfer at that layer), with Stripe, LLC (United States) identified as the affiliated sub-processor for shared platform, fraud, and risk infrastructure. Transfer mechanism for the US leg updated to the double Chapter V mechanism actually used, Standard Contractual Clauses (SCCs) and EU–US Data Privacy Framework (DPF, Stripe, LLC self-certified). No new data, no new purpose, no new processor, clarifies existing flows for accuracy. |
| 1.8 | 13 April 2026 | Data minimisation (GDPR Art. 5(1)(c)): stopped capturing IP address at account registration. Purged existing `ip_at_registration` metadata from all user records. Clarified §2.3 to distinguish analytics (Plausible, IP-free) from server access logs (AWS CloudFront, IP retained 90 days for security under legitimate interest / Recital 49). Clarified that Verdaio does not retain IP addresses in user profiles, subscription records, or consent records. |
| 1.7 | 12 April 2026 | Migrated transactional email from Resend (United States) to Sendinblue SAS (Brevo, France). Email notification processing now happens entirely within the EU (France, Germany, and Google Cloud Platform Belgium). Removed Resend from sub-processors and from international transfer safeguards. Updated retention note for email logs (Brevo, 100 days, EU infrastructure). Clarified that the email service receives only the recipient address and download link; the report content itself is never transmitted through the email service. |
| 1.6 | 11 April 2026 | Clarified that AI processing uses the Claude model via Amazon Bedrock hosted in AWS eu-west-1 (Ireland), with explicit confirmation that data does not leave the EU. Updated cookie disclosure to reflect cookieless analytics. |
| 1.5 | 10 April 2026 | Migrated AI processing from Anthropic Direct API (US) to Amazon Bedrock (AWS eu-west-1, Ireland). Data no longer leaves the EU for AI processing. Removed Anthropic as direct sub-processor; AI processing now covered by AWS DPA. Updated data retention to reflect that Bedrock does not retain input/output data. |
| 1.4 | 10 April 2026 | Replaced Google Analytics 4 with Plausible Analytics (EU-hosted, no cookies, no personal data). Removed Google LLC as sub-processor. Simplified analytics legal basis. |
| 1.3 | 6 April 2026 | Clarified data collection: distinguished between stored data (account, completion records) and pass-through data (assessment inputs, company profile) that is processed but not retained. Added Google Analytics as sub-processor. Updated Anthropic retention to 30 days. Corrected Supabase data description. Updated retention periods. |
| 1.2 | 29 March 2026 | Replaced Netlify with AWS (S3, CloudFront, Lambda, eu-west-1 Ireland) as infrastructure provider. Removed Usercentrics CMP (no longer used). Updated cookie disclosures. |
| 1.1 | 21 March 2026 | Added Stripe and InvoiceXpress as sub-processors. Corrected Supabase region to Zurich (Switzerland). Added self-serve account deletion. |
| 1.0 | January 2026 | Initial policy published. |
12. Contact Us
For any privacy-related questions, requests, or complaints:
Verdaio, Data Privacy
Email: privacy@verdaio.ai
Website: verdaio.ai
If you are not satisfied with our response, you have the right to lodge a complaint with your national supervisory authority. In Portugal, this is the Comissão Nacional de Proteção de Dados (CNPD) at cnpd.pt.