Captu-re Privacy Policy
Version 2026-09-v1 · Last updated 21 September 2026
| Version | 2026-09-v1 |
|---|---|
| Effective from | [date of publication] |
| Applies to | captu-re.com and the Captu-re application (the "Service") |
| Controller | Captu-re — the trading name of Joelson Saul Agostinho Castro, sole trader (trabalhador independente) in Portugal, NIF 286666111, [OWNER-1 — Portuguese fiscal address, pending] |
| Contact | [privacy contact e-mail] |
This policy explains what personal data we process when you visit captu-re.com or use Captu-re, why, on which legal basis, for how long, who receives it, and what your rights are. It is written under the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the Portuguese implementing law (Lei n.º 58/2019) and, for the waitlist e-mails and cookies, Lei n.º 41/2004. The Terms of Service (version 2026-09-v3) govern the contract; this policy governs the data.
1. Who we are
Captu-re is run by a sole trader established in Portugal. The controller of your personal data — the person who decides why and how it is used — is Joelson Saul Agostinho Castro, NIF 286666111, trading as Captu-re. Postal address: [OWNER-1 — Portuguese fiscal address, pending]. E-mail for privacy matters: [OWNER-2 — contact mailbox, pending]. Everywhere else in this policy, “we” and “Captu-re” mean this provider. We have not appointed a data protection officer; Article 37 GDPR does not require one for this Service.
2. What Captu-re is, in one paragraph
Captu-re is a writing application. You write in the browser, line by line; the Service stores what you write, measures how you write (speed, accuracy, session length), and — if you switch the AI features on — sends parts of your text to an AI provider to correct, improve or summarise it and to produce reports and recommendations. Paid plans are billed through Stripe. Everything below follows from that.
3. The personal data we process
3.1 Account data
- E-mail address, first name, last name — required to create an account.
- Password — stored only as a bcrypt hash; we never see or store the password itself.
- Google sign-in — if you sign up or sign in with Google, we receive your Google account id, e-mail, given name and family name. We do not store your Google profile picture, locale or Google tokens.
- Profile image — optional; stored in our database, resized and converted.
- Consent records — the date and time you accepted the Terms of Service and the version you accepted; your confirmation that you are 18 or older; the date and time of any AI-feature opt-in or opt-out (section 5).
- Password-reset tokens — valid for one hour.
We do not ask for a postal address, date of birth, gender, occupation or nationality to open an account.
3.2 What you write
- Every line you submit, and — when AI post-correction is on — the AI-rewritten line; "Improve article" outputs; session titles; goals and progress notes; saved AI phrases (only if you enable that setting).
- Your writing, article outputs, reports and recommendations are encrypted at rest inside our database with a key derived per user from a key held only by our server. The server decrypts them to show them to you and, when you use the AI features, to send them to the AI provider (section 5).
3.3 Writing measurements and insights
- Per session: start and end time, samples of typing speed and accuracy with timestamps; derived statistics (active hours, weekday pattern, session-duration buckets).
- Monthly reports (metrics plus AI-written summary, patterns, progress and recommendations), the current set of personalised recommendations and the ten previous sets, and productivity advice. Reports are generated as PDF on request and are not kept as files.
3.4 Billing and subscription data
- Held in our database: your Stripe customer, subscription and payment-method identifiers; your plan, status, trial and billing-period dates, cancellation flag, payment-failure count and dates; and the billing record we are legally required to keep for each invoice and refund (invoice number and date, amount, VAT treatment and rate, customer country, the evidence used to determine the country, and refund/credit-note references).
- Held by Stripe, not by us: your card number, expiry, security code and cardholder name are typed on Stripe's hosted checkout page and never reach our servers; we display card brand, last four digits and expiry by reading them from Stripe when you open the Subscription screen. Your billing address (required at checkout so that the invoice complies with Portuguese VAT law) is held by Stripe. We do not collect your tax number (NIF).
- Abandoned checkout: if you start a checkout and do not complete it, the customer record created for it at Stripe stays linked to your account and is erased when your account is erased (see “How long we keep your data”).
- AI usage accounting: for each AI operation we record the feature, the model, the token estimate/count, the length of the text and the time — never the text itself.
3.5 Technical and security data
- Login session: a server-side session (session id, user id, e-mail, role, plan snapshot, last login event) and the cookie
connect.sid(section 10). The session expires 24 hours after it is created. - Security log: IP address, user agent, path, timestamp and user id for requests relevant to account security (sign-in, sign-up, password reset, payment webhooks), kept for at most 30 days. We do not geolocate visitors, do not fingerprint devices and do not keep a general access log.
- Application logs: server logs are kept for operations and security and are configured not to contain your e-mail address or your writing.
3.6 Product analytics (first-party, without identifiers)
We measure how the Service is used with our own, first-party counters — not with Google Analytics, Meta or any other third-party analytics or advertising tool. The counters are aggregated per hour and per event (for example: page viewed, sign-up started, session completed) and do not contain your user id, session id, e-mail, IP address or any of your writing. The referrer is reduced to a fixed category (e.g. "search", "social", "direct"); the previous page is recorded only when it is a page of captu-re.com; the country is derived from the IP address at the moment of the request and only the country code is kept (the IP address is not stored). Your browser language is counted for the first 90 days after launch. No analytics cookie or local identifier is set on your device. Logged-in users can switch the counting off in Settings (section 10).
3.7 Waitlist (captu-re.com, before and after launch)
If you join the waitlist we store your e-mail address, the date and time you signed up, the confirmation and unsubscribe token (as a hash), and the date you confirmed. We send a confirmation e-mail first and only write to you after you confirm (double opt-in). Every e-mail contains an unsubscribe link.
3.8 Correspondence
If you write to us (support, privacy requests, complaints), we keep the correspondence and what is needed to answer and to document that we answered.
3.9 Optional connections to other services
If you choose to connect an X (Twitter) account in Settings, we store the access and refresh tokens X gives us, encrypted, so that the Service can act on your behalf when you use that feature. You can disconnect at any time in Settings, which deletes the tokens.
4. Why we process your data and on what legal basis
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Creating and running your account; storing and showing your writing, measurements, reports and recommendations | 3.1, 3.2, 3.3 | Art. 6(1)(b) — performance of the contract (Terms of Service) |
| AI features (correction, improvement, article, recommendations, reports, productivity advice) | 3.2, 3.3 as described in section 5 | Art. 6(1)(b) for features that are part of your plan, activated only after your opt-in (section 5); you may switch them off at any time |
| Billing, invoicing, VAT and refunds | 3.4 | Art. 6(1)(b) — contract; Art. 6(1)(c) — legal obligation (Portuguese VAT Code, in particular art. 36 and art. 52; invoicing and record-keeping rules) |
| Keeping the consent records (Terms acceptance, age confirmation, AI opt-in) | 3.1 | Art. 6(1)(c) — Art. 7(1) GDPR and consumer-law duties to evidence the contract; Art. 6(1)(f) — defence of legal claims |
| Login session, security log, protection against abuse | 3.5 | Art. 6(1)(f) — our legitimate interest in the security of the Service, and Art. 32 GDPR |
| Product analytics | 3.6 | Art. 6(1)(f) — our legitimate interest in understanding how the Service is used, satisfied with aggregated, identifier-free counters; you can object (section 10) |
| Waitlist e-mails | 3.7 | Art. 6(1)(a) — consent (double opt-in), Lei 41/2004 art. 13.º-A(1); withdraw at any time via the unsubscribe link |
| Transactional e-mails (password reset, welcome, trial ending, renewal reminder, payment failed, subscription changes) | 3.1, 3.4 | Art. 6(1)(b) — contract |
| Answering your requests and complaints | 3.8 | Art. 6(1)(b), (c) and (f) |
| Optional X connection | 3.9 | Art. 6(1)(b) — at your request |
We do not use your data for advertising, do not sell it, do not profile you for marketing, and do not take decisions with legal or similarly significant effects on you by automated means (Art. 22 GDPR).
5. AI processing — when, what and why data goes to the AI provider
Provider. The AI features are provided by OpenAI ([contracting entity per the account: OpenAI Ireland Ltd / OpenAI, L.L.C. — to be confirmed]) through its API. The AI features are off until you switch them on in Settings, where this section is summarised. You can switch each feature off at any time; nothing already written is affected.
What is sent, and when:
| Feature | What OpenAI receives | When |
|---|---|---|
| AI post-correction / content improvement | the text of the line you just wrote | each line, while the feature is on |
| Improve article | the whole text of the session | when you click it |
| Live mode styling | the text of the session | while live mode is on |
| Recommendations | the first 500 characters of each session and its date; then the AI's own summary | weekly and on request |
| Reports | the first 100 characters of each session, word counts, typing speed, accuracy, session counts, most active hour | when a report is generated |
| Productivity advice | aggregate metrics only (session length, peak hour, most productive day, counts) | on request |
What is never sent: your name, e-mail address, user id, IP address or payment data.
What the provider does with it. Under the API terms that apply to our account, OpenAI does not use API data to train its models and retains API inputs and outputs for up to 30 days for abuse monitoring, after which they are deleted, [unless zero-data-retention has been granted for our account — to be confirmed]. We have configured our account not to permit training on your content (Terms of Service §12).
Where. OpenAI processes the data in the United States (section 7).
Labelling. Text produced by the AI is shown as such in the Service (AI-rewritten lines, "Improve article" outputs, AI sections of reports and recommendations).
6. Who receives your data
We use the following processors (Art. 28 GDPR) and recipients. Each processor acts on our instructions under a data-processing agreement.
| Recipient | Role | What | Established / where processed |
|---|---|---|---|
| MongoDB, Inc. (MongoDB Atlas) | database hosting | everything in section 3 stored by us | Data stored in the European Union ([Atlas EU region to be named]) |
| [Hosting provider — DigitalOcean, LLC, EU data centre to be named] | application server and server logs | traffic to the Service, logs (3.5) | EU data centre |
| OpenAI | AI features | section 5 | United States |
| Stripe ([Stripe Payments Europe, Ltd. — to be confirmed]) | payments, invoicing data, billing address | 3.4 | Ireland / United States |
| Google (Google Ireland Ltd for EEA users) | sign-in with Google, only if you use it | Google learns that you sign in to Captu-re; we receive id, e-mail, names | Ireland / United States |
| Twilio Inc. (SendGrid) | transactional and waitlist e-mail delivery | e-mail address, first name, content of the e-mail | United States. Open- and click-tracking are disabled. |
| MaxMind, Inc. (GeoLite2 database, used locally) | country lookup for analytics (3.6) | none — the database is downloaded to our server; no visitor data is sent to MaxMind | — |
| Autoridade Tributária e Aduaneira (Portuguese tax authority) | recipient by law | invoice data required by the VAT Code (name and [the other invoice fields — to be confirmed by Finance]) | Portugal |
| X Corp. | only if you connect X (3.9) | OAuth connection | United States |
| Professional advisers, authorities, courts | when required by law or to defend legal claims | what the request requires | — |
We load no scripts, fonts or software from third-party servers on captu-re.com or in the application: no Google Analytics, no Meta/Facebook SDK, no Google Fonts, no public CDNs, no IP-geolocation service. Stripe's own script and cookies run only on Stripe's hosted checkout and billing pages, which are on Stripe's domain and covered by Stripe's privacy policy.
7. Transfers outside the European Economic Area
Your data is stored in the EU. Some processors are established in, or process data in, the United States: OpenAI, Stripe (parent), Twilio/SendGrid, Google (parent), X. For these transfers we rely on the European Commission's adequacy decision for the EU-US Data Privacy Framework where the provider is certified, and otherwise on the Standard Contractual Clauses (Commission Decision (EU) 2021/914) included in the provider's data-processing agreement, with supplementary measures where needed. You can ask us at [privacy contact e-mail] for a copy of the safeguards in force for a given provider.
8. How long we keep your data
| Data | Retention |
|---|---|
| Account, writing, measurements, reports, recommendations, AI-usage records | For as long as your account exists. After you delete your account (or we close it under the Terms) there is a 30-day recovery window during which you can restore it by signing in again; after 30 days everything is permanently erased from our database, including your writing, reports, recommendations, the security-log rows linked to your account and your Stripe customer record — except the billing record below. |
| Billing record (invoice and refund data required by tax law) | Until 31 December of the tenth calendar year after the year of the invoice (Portuguese VAT Code art. 52 and Personal Income Tax Code art. 118). This record contains the identification data needed for the invoice and nothing about your writing. After your account is erased you can still request a copy of the invoice (fatura-recibo) from us. |
| Consent records (Terms version, age confirmation, AI opt-in) | With the account; after erasure, only the fact and date of acceptance are kept with the billing record for paid accounts, for the same period. |
| Login session | Up to 24 hours. |
| Password-reset token | 1 hour. |
| Security log | 30 days at most. |
| Server logs | [rotation period to be stated by Engineering — at most 30 days]. |
| Product analytics | Aggregated counters contain no personal data and are kept indefinitely. |
| Abandoned checkout | The customer record created at Stripe is kept with your account and erased when the account is erased (row above). |
| Waitlist | Until you unsubscribe or we close the waitlist; unconfirmed addresses are deleted [W5 period — 30 days] after sign-up. |
| Correspondence | 3 years after the last exchange, or as long as a claim is open. |
We keep no backups that outlive these periods beyond [backup retention — to be stated after the backup decision], and erased data disappears from backups when they rotate.
9. Your rights
Under Articles 15 to 22 GDPR you have the right to access your data; to have it corrected; to have it erased; to restrict its processing; to receive the data you gave us in a machine-readable format (portability) and to have it transmitted to another controller; to object to processing based on our legitimate interests (sections 3.5, 3.6 and 3.8); and to withdraw consent at any time (waitlist, AI opt-in) without affecting the lawfulness of processing before withdrawal.
You can do most of this yourself in the Service: edit your account and profile in Settings; delete single sessions, reports and goals; switch AI features and analytics off; disconnect X; delete your account (Settings → Delete account — accounts created with Google delete themselves the same way; no password is asked). For everything else write to [privacy contact e-mail]. We answer within one month (Art. 12(3)); we may ask you to confirm that you control the account e-mail address before acting.
You have the right to lodge a complaint with the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD), Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, www.cnpd.pt, or with the supervisory authority of the EU Member State where you live.
10. Cookies and similar technologies
| Name | Set by | Purpose | Type | Duration |
|---|---|---|---|---|
connect.sid | captu-re.com | Keeps you signed in and protects the sign-in flow (including sign-in with Google) against cross-site request forgery. | Strictly necessary (Lei 41/2004 art. 5.º(2)); no consent required | Up to 24 hours |
That is the only cookie we set. We use no analytics, advertising or third-party cookies, and no local identifiers for tracking. The Service stores a few preferences in your browser's local storage (theme, layout, a cache of your own recommendations) that are never sent to anyone. Stripe sets its own cookies on its hosted checkout and billing pages (stripe.com), described in Stripe's cookie policy.
Product analytics toggle. Logged-in users can stop being counted in the anonymous product analytics (section 3.6) in Settings → Privacy. The toggle is stored with your account, not in a cookie. Because the counters contain no identifier, we cannot remove counts already recorded.
PT: Cookies. O único cookie que definimos é connect.sid, estritamente necessário para manter a sessão iniciada e proteger o início de sessão (incluindo com o Google) contra pedidos forjados entre sítios; dura no máximo 24 horas e não carece de consentimento (Lei n.º 41/2004, art. 5.º, n.º 2). Não utilizamos cookies de análise, publicidade ou de terceiros. As páginas de pagamento alojadas pela Stripe definem os seus próprios cookies, descritos na política da Stripe.
11. Security
Your writing, reports and recommendations are encrypted at rest with a per-user key; passwords are stored as bcrypt hashes; all traffic uses TLS; access to the database and to provider consoles is restricted to the controller with multi-factor authentication; secrets are rotated; the security log is limited to what section 3.5 describes. If a personal-data breach is likely to result in a high risk to you, we will inform you without undue delay (Art. 34 GDPR) and notify the CNPD within 72 hours (Art. 33).
12. Age
Captu-re is for adults. You must be 18 years of age or older to create an account, and you confirm this at sign-up. We do not knowingly process data of anyone under 18; if we learn that an account belongs to a minor we will close it and erase its data.
13. Changes to this policy
We may change this policy when the Service, the law or our providers change. Each version carries a version identifier (YYYY-MM-vN) and an effective date. For material changes we notify registered users by e-mail or in the Service at least 15 days before the new version takes effect; editorial changes are published without notice. Previous versions are available on request.
14. Contact
Privacy requests and questions: [privacy contact e-mail]. Postal address: [fiscal address]. Consumer-law information (complaints book, alternative dispute resolution) is in the Terms of Service §18.
Captu-re Privacy Policy · Version 2026-09-v1 · Controller identity, address and contact details: section 1. Terms of Service: captu-re.com/terms · Withdrawal form: captu-re.com/withdrawal.