Privacy Policy
Last updated: [Insert Date]
1. Introduction
This Privacy Policy explains how Motivoriginal Lda (“we”, “us”, or “our”) collects, uses, and protects personal data when you use Springloop (the “Platform”).
We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and applicable Portuguese data protection laws.
2. Data Controller
For most personal data processed through the Platform:
- Motivoriginal Lda acts as the data controller for account and platform-related data
- Users who host sessions act as data controllers for recordings and participant data within their sessions
Contact details:
Motivoriginal Lda
[Insert Address]
[Insert Email Address]
3. Personal Data We Collect
3.1 Account Information
- Name
- Email address
- Account credentials
3.2 Usage Data
- Session activity (e.g., sessions joined, duration)
- Device and browser information
- IP address
- Log data
3.3 Payment Data
Payments are processed by third-party providers such as Stripe.
We do not store full payment card details.
We may store:
- Payment status
- Transaction identifiers
- Subscription details
3.4 Recording Data
If recording is enabled, we may process:
- Audio and video recordings
- Chat messages
- Files shared during sessions
- Metadata (timestamps, participants, duration)
4. How We Use Personal Data
We use personal data to:
- Provide and operate the Platform
- Enable video calls, scheduling, and recordings
- Process payments and manage subscriptions
- Generate AI-based summaries and insights
- Improve performance, security, and user experience
- Communicate with users
5. Legal Basis for Processing (GDPR)
We process personal data based on:
- Contractual necessity — to provide the Platform
- Legitimate interests — to improve and secure the Platform
- Consent — where required, particularly for recordings
6. Recordings and Data Roles
For recorded sessions:
- The session host is typically the data controller
- Motivoriginal Lda acts as a data processor, processing data on behalf of the host
Users are responsible for:
- Informing participants that recording is taking place
- Obtaining any required consent under applicable laws
We do not verify whether consent has been obtained.
7. Data Sharing
We may share personal data with:
- Stripe (payment processing)
- Cloud infrastructure providers (e.g., hosting and storage in the EU)
- Service providers supporting analytics, monitoring, or communication
We do not sell personal data.
All third-party providers are required to process data in compliance with applicable data protection laws.
8. Data Storage and Location
- Data is stored within the European Union, including infrastructure hosted by Hetzner
- We implement appropriate safeguards to protect personal data
9. Data Retention
We retain personal data only as long as necessary:
- Account data → until account deletion
- Payment data → as required for legal and accounting purposes
- Recordings → until deleted by the user or according to retention settings
Users are responsible for managing retention of their recordings where applicable.
10. User Rights (GDPR)
You have the right to:
- Access your personal data
- Request correction of inaccurate data
- Request deletion of your data
- Restrict or object to processing
- Withdraw consent (where applicable)
- Request data portability
To exercise your rights, contact us at: [Insert Email Address]
11. Security Measures
We implement appropriate technical and organizational measures, including:
- Encryption in transit (HTTPS)
- Access controls and authentication
- Monitoring and logging
However, no system is completely secure, and we cannot guarantee absolute security.
12. AI Processing
The Platform may process data using AI to generate:
- Summaries
- Notes
- Insights
These outputs:
- Are automatically generated
- May not be fully accurate
- Should not be relied upon without verification
Unless explicitly stated otherwise, user data is not used to train general AI models.
13. Cookies
We may use cookies and similar technologies for:
- Authentication and session management
- Performance and analytics
- Improving user experience
You may control cookies through your browser settings.
14. International Data Transfers
Where data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards, such as:
- Standard Contractual Clauses (SCCs)
- Use of compliant service providers
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time.
If changes are significant, we will notify users through the Platform or other appropriate means.
16. Contact
For any questions or requests regarding this Privacy Policy:
Motivoriginal Lda
[Insert Address]
[Insert Email Address]