Privacy Policy, Izilda Pro

1. Who this policy is for

It covers the merchant and the staff members who use Izilda Pro and the merchant portal.

It does not cover the end customers of the loyalty programme. Cardholder data is described in the Izilda privacy policy.

The Izilda Pro app gives no access to any identifying data of an end customer: the QR code shown at the counter carries an encrypted token, and the server returns only a cryptographic digest and a balance to the merchant.

2. Data controller

D4P Tech, Lda
Rua da Estrada Nova No. 19, Paradela, 5445-069 Santiago Ribeira de Alhariz, Portugal
NIPC: 519312678
Data protection contact: contact@d4ptech.com

D4P Tech, Lda is the controller for opening and managing merchant accounts, for the security of the service, and for subscription billing.

The employing business remains solely responsible for the processing it carries out by its own means: staff management, customer files, point of sale, third-party marketing tools. That processing falls outside the scope of this policy.

App distribution: Izilda Pro is published by D4P Tech, Lda. On Google Play, it is listed under the developer account of D4P Tech, Lda. On Apple's App Store, it is distributed under the developer account of Thierry Airault, managing director (gerente) of D4P Tech, Lda, acting on behalf of the company. This does not change this policy: D4P Tech, Lda remains the publisher of the service and the data controller. Apple and Google process data related to downloading the app as separate controllers, under their own privacy policies.

3. What data we process

3.1 Sign-in account

• Sign-in identifier chosen when the account is opened.
• Password, held only as a cryptographic digest by our identity provider. It is never stored or readable in clear text, including by our own teams.
• Email address, when provided: used for the initial invitation and for password resets.
• First and last name, optional: the account works without them.

3.2 Business data

Business name, address, phone number, contact email, time zone, language and billing identifier. These describe a company; they are personal data where the business is run as a sole trader.

3.3 Session and technical logs

Session tokens issued at sign-in and the related authentication events. Technical logs: IP address, timestamp, route called and response code, used to operate the service, rate-limit calls and detect abuse.

3.4 Counter activity

Every stamp granted and every reward redeemed is recorded with its timestamp, the business concerned and the account that issued it. The customer token stays opaque: the app reads no name, email or phone number, because the service processes none.

3.5 Operations queued on the device

When the network is down, stamps and rewards are queued on the phone. The customer token is encrypted there with AES-256-GCM, the key being held in the operating system secure storage. The queue is sent when connectivity returns, then cleared.

3.6 Audit log

Sensitive actions on an account (plan change, subscription change) are written to an append-only log, signed and chained, which cannot be altered afterwards.

3.7 What we do not process

• No camera image. The app requests camera access at scan time, and only to decode a QR code in the video stream, on the device. No photo or video is stored, transmitted or kept.
• No location data.
• No advertising identifier, no tracker, no third-party analytics tool. The app shows no advertising and embeds no behavioural analytics kit.
• No payment card data entered in the app: the subscription is taken out outside the app, in the merchant portal.

4. Purposes and legal bases

4.1 Opening the account and providing the service

Purpose: create the account, authenticate its sessions, make the app and portal available, and attach granted stamps and rewards to the business.
Legal basis: performance of the contract (article 6.1.b GDPR) where the account holder is the merchant themselves, a natural person. Where the account belongs to a staff member of an incorporated business, processing rests on our legitimate interest (article 6.1.f) in providing our customer with the service they subscribed to, in a named form that allows each counter operation to be attributed.

4.2 Service security and abuse prevention

Purpose: protect accounts and the network: call rate limiting, detection of access attempts and abnormal use, traceability of sensitive operations.
Legal basis: legitimate interest (article 6.1.f GDPR). You may object under article 21; objection cannot, however, allow an account to be operated without security logging.

4.3 Subscription billing

Purpose: issue and collect the subscription, keep the accounts.
Legal basis: performance of the contract (article 6.1.b) and compliance with accounting and tax obligations (article 6.1.c).

4.4 Support

Purpose: answer requests sent to our support and diagnose incidents on an account.
Legal basis: performance of the contract (article 6.1.b).

5. Who this data is shared with

We sell no data and share none for advertising purposes. Access is limited to:

• Authorised D4P Tech, Lda staff, on a least-privilege basis, for operations and support.
• Our hosting provider, OVH (France, European Union): hosting of the infrastructure, the identity provider and the databases.
• Our payment provider, solely for billing the subscription taken out in the merchant portal: billing identity, amounts and payment status. No card data passes through our servers.

Transfers outside the European Union: the service infrastructure is established in the European Union. Use of the payment provider may involve a transfer covered by the standard contractual clauses adopted by the European Commission.

6. Retention periods

• Sign-in account: for the term of the service contract, then deleted within 30 days of its termination.
• Business and billing data: for the term of the contract, then for the period required by Portuguese accounting and tax obligations, that is 10 years.
• Technical security logs: 6 months.
• Audit log of sensitive actions: 12 months.
• Operations queued on the device: until they are sent; uninstalling the app destroys them with it.
• Stamp and reward events: they belong to the loyalty programme and follow the retention periods of the Izilda privacy policy.

7. Your rights

Under articles 15 to 22 GDPR, you have the rights of access, rectification, erasure, restriction, portability and objection to processing based on legitimate interest.

Unlike end users, whose data we cannot find without their identifier, your account is named: we are able to identify you and answer your request directly.

Requests go to contact@d4ptech.com. We answer within one month, extendable by two months for complex requests.

Erasing an account ends the ability to use the app; the records required for billing and as evidence of counter operations already carried out are kept for the periods in section 6.

You may lodge a complaint with the CNPD, Comissão Nacional de Proteção de Dados (Portugal, www.cnpd.pt), or any supervisory authority competent in your Member State of residence.

8. Security

• Communications encrypted in transit (HTTPS, TLS 1.2 minimum).
• Passwords held as a digest by the identity provider, never in clear text.
• Session tokens kept in the device operating system secure storage, not in application preferences.
• Offline queue encrypted with AES-256-GCM, key held in the system secure storage.
• Access compartmentalisation, least privilege, append-only audit log, encrypted backups.

9. No automated decisions with legal effects

We make no automated decision producing legal effects concerning you or significantly affecting you (article 22 GDPR). Abuse detection alerts our teams, who review each case.

10. Changes to this policy

This policy may be updated to reflect changes in the service or in regulation. Any substantial change is notified to the merchant at least 30 days before it takes effect. Previous versions are archived.

11. Contact

For any question about this policy or the processing of your data:

• Email: contact@d4ptech.com
• Postal address: D4P Tech, Lda, Rua da Estrada Nova No. 19, Paradela, 5445-069 Santiago Ribeira de Alhariz, Portugal