Privacy Policy

Last updated: May 2026

1. Information We Collect

Castori Club collects information you provide directly when you request an introduction, register as a member, create engagements, or communicate with the Concierge. This may include:

• Personal identification data (name, email, phone number)
• Professional information (firm, profession, VAT/NIF)
• Account credentials and authentication data
• Engagement details (client names, service descriptions, values)
• Financial information required for Stripe Connect payouts
• Usage data and device information collected automatically

2. How We Use Your Information

We use the information we collect to:

• Verify member identity and process admission applications
• Manage the engagement lifecycle (creation, negotiation, approval, activation, billing)
• Calculate and distribute allocations through the lineage cascade
• Communicate with you about your account, engagements, and Club matters
• Detect, prevent, and address fraud or unauthorized access
• Comply with legal obligations under Portuguese and EU law

3. Data Sharing and Third-Party Processors

Client identities, engagement values, and service details are visible only to the two parties directly involved in the engagement. No other member - including those in the lineage - can access client-specific information. We do not sell or share your personal data with third parties for marketing purposes.

To operate the platform we use a small number of carefully selected sub-processors. Each one receives only the data necessary for its function, under a Data Processing Agreement (DPA) where applicable:

• Stripe (payments & Stripe Connect payouts) - receives the contract reference, the amount, and your tax identifier (NIF) as Stripe Checkout metadata. Stripe is GDPR-compliant and processes data under its own privacy policy.
• Moloni (Portuguese invoicing/accounting, optional per enterprise) - when an enterprise account enables the Moloni integration, contract and client billing data is forwarded to Moloni to generate the legally required invoice. Moloni is a Portuguese SaaS subject to GDPR and the Portuguese tax authority's e-invoicing regime.
• Email delivery (SMTP) - transactional emails (verification, password reset, invitation, payment confirmation) are sent through our internal SMTP relay. The relay sees the recipient address and message body only; it does not have access to the rest of your account data.
• CDN Auth Gateway / Autenticação.Gov (optional) - members who choose to sign in with the Portuguese government's digital identity (Chave Móvel Digital) are redirected to the official Autenticação.Gov service via our auth gateway at auth.cdncore.eu. The gateway forwards only the assertion of identity back to the platform.
• Vertex Intelligence - an internal AI assistant deployed on the same infrastructure as the platform. It analyzes anonymized aggregate data to surface insights to admins; no personal identifiers leave the platform's network.

We do not use third-party analytics, tracking pixels, or advertising networks. No data is shared with Google Analytics, Meta, Hotjar, Sentry, or comparable services.

4. Data Security

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. All data is encrypted at rest and in transit. Our infrastructure runs on access-controlled servers, and database backups are encrypted and stored in geographically separated locations.

For session telemetry, IP addresses are truncated to a /24 network prefix (IPv4) or /48 prefix (IPv6) before they reach the database, so we never persist a full address that could individually identify a device.

5. Data Retention

We retain your personal data for as long as your membership is active. The platform also enforces specific retention windows for operational data:

• Active sessions: until the session expires (default 7 days), then deleted automatically.
• Refresh tokens: revoked at logout, otherwise expire alongside the session.
• System and security logs: 90 days, then deleted by the cleanup worker.
• Backups: rotated under a configurable retention policy (default 30 days).

Upon resignation or termination, personal identifiers are removed from the active ledger within 30 days. Financial records (invoices, payout history) are retained for the period required by Portuguese tax law - typically 10 years - after which they are also purged.

6. Your Rights

Under the General Data Protection Regulation (GDPR), you have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete data
• Request deletion of your personal data
• Object to or restrict certain processing of your data
• Data portability - receive your data in a structured, machine-readable format
• Withdraw consent at any time, without affecting the lawfulness of prior processing

Most of these rights can be exercised directly from your account: Profile → Privacy contains a "Download my data" button (Art. 20) and a "Delete my account" button (Art. 17). For anything you cannot self-serve - for example, restriction of processing or a complaint - contact our Data Protection Officer at the email in section 8.

7. Data Protection Officer

Castori Club has appointed a Data Protection Officer who can be reached at [email protected] for any questions or requests related to your personal data.

8. Contact