Privacy Notice

Last updated: 29 October 2026

1. Controller

José Leonardo Pinto Gonçalves (Portugal), operating Gapyra, is the data controller for personal data processed through the service. Contact: gurusmastermind@gmail.com.

2. Data we collect and why

3. Sharing

We share data with: service providers (hosting, database, authentication and AI processing providers); Paddle.com, our Merchant of Record, for the sale of products, payments, tax compliance and invoicing; professional advisers (legal, accounting); and authorities where required by law. We do not sell your data.

4. International transfers

Some providers may process data outside the EEA. Where this happens we rely on adequacy decisions or Standard Contractual Clauses.

5. Retention

We keep account data and reports while your account is active, and delete or anonymise them within 30 days of account deletion, except records we must keep by law (e.g. tax records).

6. Your rights

Under the GDPR you may request access, rectification, erasure, restriction, portability, object to processing, and withdraw consent at any time. Contact gurusmastermind@gmail.com; we reply within one month. You can complain to the Portuguese supervisory authority, CNPD (www.cnpd.pt).

7. Security

We use appropriate technical and organisational measures, including encryption in transit, access controls and per-user data isolation.

8. Cookies

We only use essential storage needed to keep you signed in and remember your language. We do not use advertising cookies. The payment checkout, provided by Paddle, may set its own essential cookies.