Privacy Policy

This Privacy Policy explains what personal data we collect, why we collect it, how we use it and what rights you have over it when you use the website sietedigitalagency.com or the application Comando Gestor Ocupado (comando.sietedigitalagency.com), together the "Service".

1. Data controller

Si3te – Investimentos, Lda. (trading as Siete Digital)
Bairro Futungo 2, Rua 11, n.º 26, Luanda, Angola · Tax number (NIF) 5417247090
Email: sieteinvestimentoslda@gmail.com · Phone / WhatsApp: +244 923 502 844

2. What data we collect

2.1 Data you provide directly

• Account data: name, email address, business name, display name and application preferences (for example, topics of interest, alert thresholds).
• Content you enter into the application: reminders, notes, weekly goals, tasks.
• Commercial contact data sent through the website's forms or channels (name, email, phone, message).

2.2 Data collected automatically

• Technical and usage data: IP address, device and browser type, pages visited, date and time of access, error logs. Used for security, diagnostics and improvement of the Service.
• Cookies on the website, as described in our Cookie Policy. The application uses only local storage that is strictly necessary for it to work (signed-in session, preferences).

2.3 Data from your Google account (only with your authorisation)

Comando Gestor Ocupado can connect to your Google account to provide certain features. This connection is optional, is made through Google's official consent screen and only happens when you expressly authorise it. We request only the permissions ("scopes") needed for each feature:

Scope	Purpose
email, openid	Identify which Google account you connected.
gmail.labels	Show how many unread conversations are in your inbox. Comando reads only that number: it does not read message content, subjects or senders, and it never creates, changes or deletes labels.
calendar.events.readonly	Show your daily and weekly agenda. Read-only: Comando does not create or change events.
calendar.calendarlist.readonly	Show the agenda across all the calendars you selected.

What we do not do with Google data: we do not read your emails for our own purposes, do not sell them, do not use them for advertising, do not share them with third parties beyond the subprocessors described in section 6, and do not use them to develop, improve or train generalised artificial-intelligence models.

3. How we use data from Google APIs — Limited Use

Siete Digital's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

• Data obtained from Google APIs is used exclusively to provide or improve the user-facing features described in section 2.3.
• We do not transfer that data to third parties, except (a) as necessary to provide those features through the subprocessors in section 6, (b) as required by law, (c) as part of a merger or acquisition, with prior notice, or (d) with your explicit consent.
• We do not use that data for advertising or marketing purposes.
• No human reads your Google data, except (a) with your explicit consent for a support request, (b) for security purposes, such as investigating abuse, (c) as required by law, or (d) for internal operations after the data has been aggregated and anonymised.
• We do not use that data to develop, improve or train generalised AI or machine-learning models.

3.1 Automated processing by artificial intelligence

To generate summaries and suggestions, the relevant content of your emails (subject, sender and excerpt) may be sent, in an automated and encrypted manner, to a large-language-model provider (see section 6) for the sole purpose of producing the summary or draft shown to you. That provider acts as a subprocessor, is contractually prohibited from using the data to train its models and does not retain it beyond what is needed to return the response. The result (the summary) is stored in your account on the Service; the original email content is not stored by us.

3.2 What we actually store from your Google data

From Gmail, Comando stores only the number of unread conversations in your inbox, updated several times a day. It does not read or store message content, subjects or senders, nor copies of your mailbox.

3.3 How to revoke access

You can disconnect your Google account at any time under Settings → Connections in the application, or directly at myaccount.google.com/permissions. On revocation we immediately delete the access credentials and stop accessing your Google account. Summaries and reminders already created remain in your account on the Service until you delete them or close the account.

4. Purposes and legal basis of processing

Purpose	Data	Legal basis
Create and manage your account and provide the Service	Account data, entered content	Performance of a contract
Features linked to your Google account	Google data (section 2.3)	Consent (revocable)
Send notifications you configured	Reminder title and short text	Performance of a contract
Invoicing and collection	Account and payment data	Performance of a contract and legal obligation
Security, abuse prevention and diagnostics	Technical data	Legitimate interest
Respond to commercial contact requests	Contact data	Pre-contractual steps
Communications about the Service (changes, security)	Account email	Performance of a contract

We do not make automated decisions with legal effects about you.

5. Who we share data with

We do not sell personal data. We share data only with:

• Subprocessors that operate the Service's infrastructure (section 6), contractually bound to process data only on our instructions;
• Authorities, where required by law or court order;
• An acquirer, in the event of a merger, acquisition or sale of assets, with prior notice to you.

6. Subprocessors and data location

Provider category	Function	Location
Database and authentication provider	Storage of account data, encrypted credentials and server-side functions	European Union (Ireland)
Web hosting provider	Delivery of the web application and website	Global content-delivery network
Automation provider	Execution of automated jobs (summaries, reminders)	[CONFIRM: European Union or United States]
Large-language-model provider	Generation of summaries and drafts from the content described in section 3.1	United States
Push-notification provider	Delivery of notifications (title and short text only)	European Union
Google	Gmail and Google Calendar, when connected by you	As per Google's policy

Some of these providers are located outside Angola. Where we transfer data internationally, we do so on the basis of contracts that ensure an adequate level of protection, including standard contractual clauses where applicable. The current named list of subprocessors is available on request via the contact details in section 1.

7. How long we keep data

• Daily agenda and unread count: 90 days after they are generated.
• Follow-up reminders: until you delete them, or 12 months after completion.
• When your account is cancelled, we delete all your data (tasks, deadlines, contacts, connections and records) within 30 days.

We record the days on which you open the dashboard — the date only, with no times, pages or clicks — to measure use of the service. This record is deleted together with your account.

8. Security

We apply appropriate technical and organisational measures: encryption in transit (TLS) and at rest, Google credentials stored in an isolated table accessible only by the server, row-level access control in the database (each customer can only access their own data), restricted team access, and access logging. No system is entirely secure; in the event of a data breach affecting you, we will notify you without undue delay.

9. Your rights

You have the right to access your data, correct it, request its deletion, restrict or object to processing, withdraw consent at any time (without affecting the lawfulness of prior processing) and, where applicable, obtain a copy in a portable format. To exercise these rights, contact us using the details in section 1. We respond within 30 days. You also have the right to lodge a complaint with the competent data-protection authority — in Angola, the Agência de Proteção de Dados (APD).

10. Minors

The Service is intended for businesses and professionals and is not directed at anyone under 18. We do not knowingly collect data from minors; if we become aware that we have, we will delete it.

11. Applicable law

This Policy complies with Law No. 22/11 of 17 June (Angola's Personal Data Protection Law) and, for users located in the European Union, Regulation (EU) 2016/679 (GDPR).

12. Changes to this Policy

We may update this Policy. The current version is always on this page, with the date of the last update. Material changes — in particular to the Google permissions requested or to how Google data is used — will be communicated by email or in the application before they take effect.

13. Contact

For any privacy question or to exercise your rights: sieteinvestimentoslda@gmail.com · +244 923 502 844 · Bairro Futungo 2, Rua 11, n.º 26, Luanda, Angola.