Privacy Policy

1. Introduction and Data Controller

Savion App Technology (hereinafter "Savion", "we", "us" or "our"), with registered office at Rua Hermenegildo Pulquério Lotes 4A, 4B, e 6, Alcabideche, Cascais, 2645-019, Office no. 30, Portugal, is the data controller for personal data processed through the Savion platform, accessible at www.savionapp.com. Savion is a digital marketplace that enables content creators to sell digital products — including courses, communities, mentoring programs, trading signals, e-books, and trading robots — to end consumers. Protecting the privacy and personal data of our users is an absolute priority.

2. Scope of Application

This Privacy Policy applies to all users of the Savion platform, including:

• Visitors to www.savionapp.com;
• Registered users (consumers and content creators);
• Platform partners and affiliates;
• Anyone who interacts with our services, emails, or communications.

3. Personal Data We Collect

4. Purposes and Legal Basis for Processing

We process personal data for the following purposes and on the following legal grounds under the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679):

• Performance of a contract (Art. 6(1)(b) GDPR): Account creation and management, payment processing, access to purchased products, transaction-related communications.
• Legitimate interests (Art. 6(1)(f) GDPR): Fraud prevention, platform security, service improvement, aggregated statistical analysis.
• Legal obligation (Art. 6(1)(c) GDPR): Tax and accounting obligations, responses to competent authorities.
• Consent (Art. 6(1)(a) GDPR): Marketing communications, non-essential cookies, behavioural analysis for personalisation.

5. Data Sharing and Transfers

Savion does not sell, rent or trade personal data to third parties. We share data only in the following circumstances:

6. International Data Transfers

Some of our subcontractors are based outside the European Economic Area (EEA), in particular in the United States of America. In such cases, we ensure that transfers are carried out on the basis of appropriate legal mechanisms, including Standard Contractual Clauses approved by the European Commission or the EU-US Data Privacy Framework, as applicable. All our main providers are certified as required by the GDPR.

7. Data Retention Periods

• Account data: retained for the duration of account activity and for 3 years after closure, unless a longer legal retention obligation applies;
• Transaction and billing data: retained for 10 years, in compliance with applicable tax and accounting obligations;
• Support communications: retained for 2 years;
• Marketing data (consent-based): retained until consent is withdrawn;
• Security logs and data: retained for 12 months.

8. Cookies and Tracking Technologies

Savion uses cookies and similar technologies to operate the platform and improve the user experience. Cookies are classified as follows:

• Strictly necessary cookies: Essential for the operation of the platform (session, authentication, security). No consent required.
• Performance and analytics cookies: Collect information about how users interact with the platform (e.g. Google Analytics, Plausible). Consent required.
• Functionality cookies: Enable personalisation of the experience (e.g. language and theme preferences). Consent required.
• Marketing cookies: Used for targeted advertising. Explicit consent required.

Users may manage their cookie preferences at any time through the preferences panel available on the platform or through their browser settings. Rejecting non-essential cookies does not affect access to the platform's core features.

9. Your Rights

Under the GDPR, you have the following rights, which you may exercise at any time:

• Right of access (Art. 15 GDPR): Obtain confirmation of whether your data is being processed and access to that data;
• Right to rectification (Art. 16 GDPR): Correct inaccurate or incomplete data;
• Right to erasure / 'right to be forgotten' (Art. 17 GDPR): Request deletion of your data, except where legal retention obligations apply;
• Right to restriction of processing (Art. 18 GDPR): Restrict processing in certain circumstances;
• Right to data portability (Art. 20 GDPR): Receive your data in a structured, machine-readable format;
• Right to object (Art. 21 GDPR): Object to processing for direct marketing or based on legitimate interests;
• Right to withdraw consent: At any time, without affecting the lawfulness of processing based on consent given prior to withdrawal.

To exercise any of these rights, contact us at geral@savionapp.com. We will respond within 30 days. If unsatisfied with our response, you have the right to lodge a complaint with the Portuguese Data Protection Authority (CNPD) at www.cnpd.pt, or with the supervisory authority in your country of residence.

10. Data Security

Savion implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration or unlawful disclosure, including:

• Encryption of data in transit (TLS/HTTPS) and at rest;
• Secure authentication with password hashing;
• Role-based access control (Row Level Security on the database);
• Bot and attack protection (Cloudflare Turnstile);
• Rate limiting to prevent abuse (Upstash Redis);
• Continuous security monitoring and incident management.

11. Minors

The Savion platform is not intended for persons under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor without verifiable parental consent, we will immediately delete such data. If you are aware of such a situation, please contact us immediately at geral@savionapp.com.

12. Changes to this Privacy Policy

Savion reserves the right to amend this Privacy Policy at any time to reflect legal, regulatory or operational changes. In the event of material changes, we will notify users by email or through a prominent notice on the platform with a minimum of 30 days' prior notice. The effective date of the current version is indicated at the top of this document. Continued use of the platform after the changes take effect constitutes acceptance thereof.

13. Contact Us

For any questions regarding this Privacy Policy or the processing of your personal data, please contact us at:

• Email: geral@savionapp.com
• Address: Rua Hermenegildo Pulquério Lotes 4A, 4B, e 6, Alcabideche, Cascais, 2645-019, Office no. 30, Portugal
• Website: www.savionapp.com