Privacy Policy, izilda

1. Preamble

This policy is written to be precise and understandable. izilda is designed to work without a name, email address, or phone number tied to your loyalty account. This architecture relies on strong pseudonymisation.

Pseudonymisation is not legally equivalent to anonymity: we state this clearly rather than use a misleading term.

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 data controller (Article 4(7) GDPR) for the loyalty programme and anomaly detection. For communications sent by merchants, the merchants concerned are the data controllers and D4P Tech acts as a processor (Article 28 GDPR).

3. What data we process

When you sign up, we generate a random internal identifier (UUID). No name, email address, or phone number is associated with it. The data processed is:

• Pseudonymous internal identifier: a UUID generated by the app at first installation and stored locally on your device. It is not derived from your device's characteristics: no information about your model, operating system, fonts, or sensors is read. If you uninstall and then reinstall the app, a new identifier is generated and your previous history can no longer be linked to you.
• Loyalty events: for each in-store scan, a timestamp, the merchant identifier, and an opaque token representing the transaction, unintelligible to the merchant.
• Loyalty balance: number of stamps, points, or rewards, per merchant.
• Communication preferences: one toggle per merchant, and a global toggle for merchants you are not a customer of.

We do not process:

• Your first name, last name, email address, or phone number.
• Your GPS location. If you use the proximity filter, filtering is carried out entirely on your device; no coordinates are sent to our servers.
• Your purchases, the contents of your basket, or the amounts paid.

4. Purposes and legal bases

4.1 Loyalty programme

Purpose: to issue, validate, and accumulate your rewards with partner merchants.
Legal basis: performance of the contract (Article 6(1)(b) GDPR) constituted by your enrolment in the service.

4.2 Network anomaly detection

Purpose: to identify fraudulent behaviour at network scale (fake scans, abused accounts, automation). The analysis relies on aggregated patterns and never triggers any automated decision producing legal effects or significantly affecting you (Article 22 GDPR). Every alert is subject to human review.
Legal basis: legitimate interest (Article 6(1)(f) GDPR). A documented balancing test concludes that this interest does not disproportionately harm your rights, notably because of strong pseudonymisation. You may object to this processing (Article 21 GDPR; see section 7).

4.3 Statistics for merchants

Purpose: to provide merchants with indicators on the average behaviour of their customer base. The indicators delivered are anonymised within the meaning of the GDPR: they meet a minimum k-anonymity threshold (k >= 5) and do not allow an individual to be identified.
Legal basis: performance of the contract.

4.4 Communications from your merchant

Purpose: to allow merchants you are a customer of to send you messages, exclusively within the izilda app.
izilda's role: processor for the merchant (Article 28 GDPR). The merchant defines campaigns by abstract criteria; it receives neither your identifier nor the list of recipients.
Legal basis: your consent (Article 6(1)(a) GDPR; Article 13-A of Portuguese Law No. 41/2004). This consent is granular per merchant and can be withdrawn at any time in the app.

4.5 Communications from merchants you are not a customer of

Purpose: to allow merchants in your area to send you announcements if you have explicitly authorised it.
izilda's role: processor for the merchants concerned.
Legal basis: your explicit, global consent for this category, revocable at any time. No GPS coordinates are sent to our servers: proximity filtering is carried out on your device.

5. Who your data is shared with

We do not sell any data. We do not use your data for advertising purposes and do not share it with third parties for such purposes. Your data is accessible to:

• Our technical processors, including OVH (European Union) for hosting the infrastructure.
• Merchants: only in the form of anonymised statistical indicators (section 4.3) or through the campaign mechanism, with no access to your identifier (sections 4.4 and 4.5).

Any data that merchants collect independently of izilda (point of sale, customer file, their own tools) is their sole responsibility.

Transfers outside the European Union: we favour infrastructure established in the European Union. Any transfer outside the EU would be governed by the standard contractual clauses adopted by the European Commission or an equivalent safeguard.

6. Retention periods

• Active account: kept for as long as you use the service.
• Inactive account: account and associated events deleted after 24 consecutive months without activity.
• Voluntary deregistration: loyalty data deleted within 30 days.
• Anomaly detection data: 12 months maximum in pseudonymised form, then purged.
• Technical security logs: 6 months.

Anonymous indicators (section 4.3) do not allow an individual to be identified and remain in our statistics.

7. Your rights

In accordance with Articles 15 to 22 GDPR, you have the rights of access, rectification, erasure, restriction, portability, objection (to processing based on legitimate interest, notably anomaly detection), and withdrawal of consent for communications, at any time via the toggles in the app.

7.1 How to exercise your rights, Article 11 GDPR

Our architecture is founded on the absence of directly identifying data. We therefore cannot identify you without your cooperation: this is the trade-off for the guarantee we offer to your privacy. Two channels are provided:

• From the izilda app, via the "My data" menu.
• By email, at contact@d4ptech.com, stating your internal identifier (visible on the "My data" screen).

Without this identifier, it will be materially impossible for us to find your data (Article 11(2) GDPR). We respond within one month, extendable by two months for complex requests.

7.2 Complaint to a supervisory authority

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

8. Local identifier and on-device storage

The internal identifier described in section 3 is a random number generated by the app and stored locally on your device. It is not derived from any characteristic of your device and constitutes neither an advertising identifier nor a profiling identifier. No fingerprint of your device is read or transmitted.

Within the meaning of Article 5(3) of the ePrivacy Directive (Portuguese Law No. 41/2004), storing this identifier is strictly necessary to provide the loyalty service you request and therefore does not require separate consent.

If you uninstall the app, the identifier disappears from your device; on reinstallation, a new identifier is generated and your previous data can no longer be linked to you.

9. No automated decisions with legal effect

We make no automated decision producing legal effects concerning you or significantly affecting you (Article 22 GDPR). Anomaly detection never results in automated exclusion or sanction: it alerts our teams for human review.

10. Changes to this policy

This policy may be updated to reflect changes in the service or in regulation. Any substantial change will be notified to you in the app at least 30 days before it takes effect. The version history is accessible from the app.

11. Contact

For any question regarding 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