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Política de Privacidade da Relovisa: assistente de IA, contas e planos pagos
Relovisa Privacy Policy: AI assistant, accounts and paid plans
Effective date: 1 October 2026. Last updated: 8 October 2026.
A. Who is responsible for your data
Relovisa is operated by Rezollo Limited, a limited company incorporated in Hong Kong, Company Registration No. (CR No.) 78114304, registered office at Unit 1603, 16/F, The L. Plaza, 367-375 Queen's Road Central, Sheung Wan, Hong Kong. This company is the controller of your personal data. Contact: hello@relovisa.co, +351 967 143 317.
The same company operates Tobira.ai, the platform that powers the assistant, so Tobira.ai is not a separate recipient of your data.
B. What we collect
| Category | What it includes | Where it comes from |
|---|---|---|
| Account data | Email address, sign-in method, account ID, language, creation date | You |
| Google sign-in data (only if you choose it) | Name, email address, profile picture, Google account ID and the sign-in tokens Google returns. We ask Google only for basic sign-in information; we do not get your Google password or access to your Gmail, Drive or contacts. | |
| Chats | Your messages, the assistant's answers, time stamps, chat titles and feedback on answers. Voice input is sent for transcription, turned into text and not stored by us: only the text is kept, as your message. | You, and generated by AI |
| Uploaded files | Documents and images you upload. We do not keep the original file: it is read to extract its text, and we keep that text with your chat until you delete the chat. | You |
| Contact details and requests | Name, email, phone or messenger contact and the request you leave for the team, for example a consultation request | You |
| Strategy call data (Premium) | Name, email, chosen time and notes you add when booking | You |
| Usage and spend records | Number and type of requests, Deep thinking use, AI model used, amount of AI processing and its cost to us, plan limits and limit reset dates | Our systems |
| Subscription and billing data | Plan, status, dates, amounts, country of the customer, receipts and invoices, Stripe customer ID, card brand and last four digits | You and Stripe |
| Payment card and bank details | Full card number, security code, bank details | Held by Stripe, not by us |
| Support messages | What you write to us | You |
| Technical and security data | IP address, device and browser type, sign-in sessions, logs, security events | Your device |
Sensitive information. Please do not share health details or criminal record information in the chat or in uploaded files. We do not need them to answer your questions, and we ask all visitors not to submit them. If you have shared such information, delete the chat or write to hello@relovisa.co and we will delete it. Share identity documents, such as a passport, only if your question really needs them.
Information about other people. If you share information about family members or others, make sure they know and that you are allowed to share it.
C. Why we use your data and our legal bases
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Provide the assistant and answer your questions, including Deep thinking | Chats, extracted file text, account data | Contract (art. 6(1)(b)) |
| Create and secure your account; sign-in by email code or Google | Account data, Google data, security data | Contract; legitimate interest in security (art. 6(1)(f)) |
| Save and sync your chats across devices | Chats | Contract |
| Let the Relovisa team see your main chat and the chats you share, and help you | Main chat and shared chats | Contract (personal support is part of the service); legitimate interest in providing support |
| Handle contact and consultation requests you leave | Contact details, requests | Steps taken at your request before a contract, and contract (art. 6(1)(b)); legitimate interest in following up |
| Apply plan limits, track usage and our AI costs, prevent abuse | Usage and spend records | Contract; legitimate interest in fair use, cost control and abuse prevention |
| Sell and manage subscriptions, payments, refunds and withdrawals | Billing data | Contract |
| Keep accounting and tax records | Billing data, receipts and invoices | Legal obligation (art. 6(1)(c)) |
| Book and hold the Premium strategy call | Booking data; main chat, so the consultant can prepare | Contract |
| Send service emails: sign-in codes, receipts, notices about changes and deletion | Email address | Contract; legal obligation |
| Send tips and news | Email address | Consent, which you can withdraw at any time |
| Improve the Services with aggregated statistics | Usage records, aggregated | Legitimate interest |
| Comply with the law, answer authorities, defend legal claims | Relevant data | Legal obligation; legitimate interest |
Which AI services process your chats. OpenAI generates the assistant's answers for all chats. Google's Gemini API transcribes voice input and reads uploaded files; we may switch these tasks to OpenAI. The providers, their roles and the transfer safeguards are listed in Section G. We do not use your chats to train AI models. We do not sell your personal data and do not use your chats for advertising.
D. Private chats: what our team can and cannot see
- Main chat. Your first chat, including messages you sent before creating an account, is visible to authorised Relovisa team members, so they can help you and prepare your strategy call. We tell you this before your first message. The main chat cannot be made private.
- Private chats. Chats you start after signing up are private by default: they are hidden from the team's standard tools, including their messages, answers, file text and titles. Chats you started without an account and then saved to your account stay visible, because the team could already see them. You can switch privacy off, or back on, for any chat except the main chat. If you share a private chat with the team, for example before a booking or when you leave your contact details, the whole chat, including earlier messages, becomes visible to the team.
- What we can see about private chats. For private chats, the team's tools show only that the chat is private, when it started, when it was last active, the number of messages, the chat language and whether you left contact details. If you ask for the team from a private chat, the team receives only a notice that a visitor in a private chat asked for help, without the content. Usage and cost records, the AI model used and your plan are kept in our database for limits and cost control.
- Limited exceptional access. A small number of authorised technical staff may access private chat content only: (a) if you ask us to, for example for support; (b) where strictly necessary to investigate a security incident, abuse of the Services or a report of illegal content; or (c) to comply with a legal obligation or a binding order of a competent authority. Access is limited to what is necessary.
- Automated processing. To answer you, every chat, including private ones, is processed automatically by our systems and by the AI providers listed in Section G. Private chats are hidden from the team's standard tools. Limited exceptional access is described above.
- Private is not end-to-end encrypted. Chats are encrypted in transit (HTTPS), and message texts are stored encrypted in our database (AES-256-GCM), but our systems must process them to provide the Services. Other data, such as chat titles you set and account data, is not separately encrypted by us.
E. How long we keep data
| Data | How long |
|---|---|
| Account data | While your account exists. Deleted within one month of your deletion request. |
| Inactive accounts | If you do not sign in for 24 months, we delete your account and its chats. We warn you by email 30 days before. Accounts are not deleted for inactivity while a paid subscription is active. |
| Chats and extracted file text | Until you delete them or your account is deleted. Deleting a chat removes its messages, the assistant's answers, the text extracted from its files and its summary at once. We do not keep original uploaded files. |
| Chats started without an account | Deleted after 24 months without new messages. You can also save the chat to an account and delete it yourself, or ask us at hello@relovisa.co. |
| Contact details and consultation requests | 36 months after your last contact with us |
| Strategy call booking data | 36 months after your last contact with us |
| Usage and spend records | While your account exists; deleted with it. Aggregated statistics without personal data may be kept longer. |
| Billing, receipts, invoices and tax records | 10 years, as required by Portuguese accounting and tax rules |
| Security logs | 12 months |
| Backups | Kept for up to 30 days and then overwritten |
| Data needed for a legal claim | Until the claim is resolved or time-barred |
| Copies kept by AI providers | Paid plans (OpenAI API): abuse-monitoring logs for up to 30 days, unless the law requires longer. Google Gemini API: prompts kept for 55 days for abuse monitoring. Free plan and chats without an account: as set out in OpenAI's privacy policy. |
F. Export and deletion
- Export. In Settings you can download your chats at any time as one JSON file. It contains your email address and account creation date, your plan and its start date, your usage as a percentage of your plan limits, and each chat with its title, icon, creation date and the messages from you and the assistant with their times. Original files are not included, because we do not keep them.
- Delete a chat. You can delete individual chats or all chats at once. Deleting your main chat removes its messages, answers and file text, but it stays your main chat, so what you write there next is again visible to the team. If you delete all chats, your next chat becomes your main chat. Contact details, requests and bookings you left stay with Relovisa as customer records for the period in Section E; only their link to the deleted message is removed.
- Delete your account. For now, write to hello@relovisa.co from the email address of your account and we will delete it; a delete button in Settings will follow. We delete your account data and chats within one month. If you have a paid plan, it is cancelled and ends at the end of the current paid period, without renewal. We keep billing records where the law requires.
- Deletion is permanent. Export first if you want a copy.
G. Who receives data, their role and transfer safeguards
| Recipient | What it does | Role | Transfers outside the EEA |
|---|---|---|---|
| OpenAI Ireland Limited (Dublin, Ireland) | Generates the assistant's answers on paid plans, including Deep thinking | Processor under OpenAI's Data Processing Addendum | Onward transfers by OpenAI under Standard Contractual Clauses (in the provider's DPA) |
| OpenAI Ireland Limited (Dublin, Ireland) | Generates the assistant's answers on the Free plan and in chats without an account | Independent controller under OpenAI's own terms and privacy policy | As described in OpenAI's privacy policy |
| Google, contracted through Google Cloud (Gemini API) | Transcribes voice input and reads uploaded files | Processor under Google's data processing terms for products where Google is a processor; Google does not use this data to improve its products | Google LLC is certified under the EU-U.S. Data Privacy Framework; Standard Contractual Clauses in Google's data processing terms |
| Google Ireland Limited (Google Meet) | Video call for the Premium strategy call | Provides Google Meet under the Google terms that apply to our account | Google LLC is certified under the EU-U.S. Data Privacy Framework |
| Google Ireland Limited (Google sign-in) | Google sign-in, if you choose it | Independent controller for your Google account | As described in Google's privacy policy |
| Stripe Payments Europe, Limited (Dublin, Ireland) | Payments, subscriptions, receipts and invoices, fraud prevention | Processor for part of the processing and independent controller for other purposes, such as fraud prevention and its own legal obligations | Stripe, Inc. is certified under the EU-U.S. Data Privacy Framework; Standard Contractual Clauses in Stripe's data transfer terms |
| Plus Five Five, Inc. (Resend), United States | Sends emails, such as sign-in codes and service notices | Processor under Resend's Data Processing Addendum | Certified under the EU-U.S. Data Privacy Framework |
| Railway Corporation, United States | Hosting and database for the Services | Processor under Railway's Data Processing Addendum | Standard Contractual Clauses (in the provider's DPA) |
| Cal.com, Inc., United States | Booking the strategy call | Processor under Cal.com's Data Processing Agreement | Standard Contractual Clauses (in the provider's DPA) |
| Cloudflare, Inc., United States | Security and delivery of the website relovisa.co | Processor under Cloudflare's Data Processing Addendum | Certified under the EU-U.S. Data Privacy Framework; Standard Contractual Clauses as a fallback in Cloudflare's addendum |
| Google Ireland Limited (Google Analytics) | Statistics on how the website relovisa.co is used (Google Analytics 4). Until you allow analytics cookies, it works without cookies in Google's consent mode (see Cookie Usage) | Processor under the Google Ads Data Processing Terms, which cover Google Analytics | Google LLC is certified under the EU-U.S. Data Privacy Framework; Standard Contractual Clauses in Google's data processing terms |
| Microsoft Ireland Operations Limited (Microsoft Clarity) | Heatmaps and session recordings of how the website relovisa.co is used, only if you allow analytics cookies (see Cookie Usage) | Independent controller under the Microsoft Privacy Statement | Microsoft Corporation is certified under the EU-U.S. Data Privacy Framework; Standard Contractual Clauses between Microsoft Ireland Operations Limited and Microsoft Corporation |
Sign-in to Relovisa itself runs on our own servers; we do not use an outside authentication provider.
We share your data with independent lawyers or advisers only if you ask us to refer you and agree to it. We disclose data to authorities only where the law requires it.
H. International transfers
Some recipients are located outside the European Economic Area (EEA), mainly in the United States, or transfer data there. Where data is transferred outside the EEA, we rely on the European Commission's Standard Contractual Clauses or, where the recipient is certified, the EU-U.S. Data Privacy Framework. Section G shows the basis for each recipient. You can ask for a copy of the relevant safeguards at hello@relovisa.co.
I. Automated processing
The assistant's answers are generated automatically. We do not make decisions with legal or similarly significant effects on you based solely on automated processing (GDPR art. 22). Plan limits are applied automatically according to your plan, as described in the Terms of Use (https://relovisa.co/terms).
J. Your rights
You have the right to access your data, correct it, delete it, restrict its use, receive it in a portable format, object to processing based on legitimate interest, and withdraw consent at any time (this does not affect processing before the withdrawal). Use Settings or write to hello@relovisa.co. We answer within one month; for complex requests this can be extended by two more months, and we will tell you why. We may need to confirm your identity.
You can complain to the Portuguese data protection authority, Comissão Nacional de Proteção de Dados (CNPD, www.cnpd.pt), or to the authority in the country where you live or work.
K. Security
We use access controls, least-privilege access for staff, encryption in transit (HTTPS), encryption of message texts in our database (AES-256-GCM), and confidentiality obligations for everyone with access. If a personal data breach is likely to result in a high risk to you, we will tell you without undue delay.
L. Age
The Services are for people aged 18 or older. We do not knowingly collect data from children.
M. Changes and contact
We will tell you about material changes to this policy by email or in the product before they apply. Questions: hello@relovisa.co, +351 967 143 317, Rezollo Limited, Unit 1603, 16/F, The L. Plaza, 367-375 Queen's Road Central, Sheung Wan, Hong Kong.