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Legal · Version 1.0

Privacy Policy

Full transparency on how we collect, use, and protect your personal data.

Last updated: 1 July 2026Version 1.0GDPR · Law 22/11 · LGPD

Table of contents

  • 01 Who we are
  • 02 Data we collect
  • 03 How we use it
  • 04 AI and content
  • 05 Sharing with third parties
  • 06 International transfers
  • 07 Data retention
  • 08 Your rights
  • 09 Data security
  • 10 Cookies
  • 11 Minors
  • 12 Account deletion
  • 13 Changes to this policy
  • 14 Contact
Data protection

Questions about your privacy? Talk to our DPO.

Contact DPO →
01

Who we are

MARKETING OS (hereinafter the "Platform", "we" or the "Service") is an autonomous marketing platform for small and medium businesses, operated by:

Legal name
FREDERICO CANTEIRO DA SILVA - COMÉRCIO E PRESTAÇÃO DE SERVIÇOS, (SU), LDA
Tax ID (NIF)
5003212467
Registered address
Benguela, Município de Lobito, Bairro Caponte, Rua Oliveira Cardonega
Contact email
[email protected]
Data Protection Officer (DPO)
[email protected]

This policy is drafted in accordance with the following laws:

Law 22/11
Angola
Personal Data Protection Law
GDPR
European Union
Regulation (EU) 2016/679
LGPD
Brazil
Law No. 13,709/2018

By using the Service, the user declares to have read, understood and accepted the terms described in this policy.

02

Data we collect

We collect different categories of data depending on how the user interacts with the Platform.

2.1 — Account data

When the user creates an account:

  • Full name
  • Email address
  • Password (stored encrypted — never in plain text)
  • Preferred language (Portuguese or English)
  • Google authentication data: name, email and unique identifier

2.2 — Company data (Brand Brain)

  • Business name and description
  • Website and social media profiles
  • Logo, color palette and visual identity
  • Target audience, products, services and competitors
  • Business goals
  • Content, images and assets uploaded by the user

2.3 — Social media data

When the user connects Instagram or Facebook via the Meta Graph API:

  • Account ID and username
  • OAuth access tokens (stored encrypted)
  • Public profile metadata (bio, followers, category)
  • Metrics for existing posts and future posts made via the Platform
We never access private messages or content unrelated to marketing. This data is used exclusively for audits, publishing and performance measurement.

2.4 — Data generated by the Platform

  • Monthly strategies, editorial calendars and AI-generated posts
  • Designs, images and videos produced automatically
  • History of approvals, edits and publications
  • Performance reports and audits

2.5 — Payment and credits data

  • Available credit balance
  • History of credit consumption by action
  • Bank transfer receipts (manual payment)
  • Card tokens via Stripe — we never store full card data

2.6 — Technical and usage data

  • IP address
  • Device type, operating system and browser
  • Pages visited, actions taken and session time
  • Technical errors and crash reports
  • Traffic source (referrer)

2.7 — Communications

When the user contacts us, we retain the content of the communication and associated data (email, date, subject) for support and record-keeping purposes.

03

How we use the data

We use the data we collect for the following purposes:

PurposeLegal basis
Create and manage the user's accountContract performance
Generate content, strategy and designs via AIContract performance
Publish content on connected social media accountsContract performance
Perform audits and generate recommendationsContract performance
Process payments and manage creditsContract performance and legal obligation
Send transactional emailsContract performance
Send marketing communications about the ServiceConsent — revocable at any time
Analyse usage to improve the productLegitimate interest
Detect fraud, abuse and violations of the termsLegitimate interest
Comply with legal and tax obligationsLegal obligation
04

Artificial Intelligence and content processing

The Platform uses LLMs and image/video generation models to create strategy, content, designs and other marketing assets.

  • 01
    Sending to AI providers
    The content provided is sent to OpenRouter and fal.ai to generate the requested outputs.
  • 02
    No training on your data
    These providers are contractually prohibited from using your data to train their own models, unless explicitly enabled by the user.
  • 03
    Controlled storage
    Generated content is stored only to make it available to the user, and is never shared with third parties without authorisation.
  • 04
    User responsibility
    The user is responsible for the final content approved and published, even when generated by AI.
05

Sharing data with third parties

To provide the Service, we rely on third-party providers (subprocessors) who are contractually required to meet security and privacy standards equivalent to our own.

ProviderPurposeLocation
OpenRouterAI language processingUnited States
fal.aiAI visual and audio content generationUnited States
Cloudflare R2File storageGlobal
Meta PlatformsSocial media connection and publishingUSA / Ireland
ElevenLabsAI voice synthesisUnited States
HeyGen (via fal.ai)AI video generationUnited States
StripeCard payments (outside Angola)USA / Ireland
ResendSending email communicationsUSA / EU
PostHogProduct usage analyticsEuropean Union
SentryTechnical error monitoringUSA / EU
GoogleOAuth authenticationGlobal
We never sell or rent personal data to third parties for marketing purposes. We may disclose data to comply with a legal obligation, court order, or a well-founded request from a competent authority.
06

International data transfers

Some providers are located outside Angola and the European Union, namely in the United States. When these transfers occur, we ensure appropriate safeguards:

  • Standard Contractual Clauses approved by the European Commission
  • Providers' adherence to recognised data protection frameworks
  • Prior assessment of the recipient country's level of protection
07

Data retention

We retain data for as long as necessary to fulfil the purposes for which it was collected, unless a longer period is required by law.

Data categoryRetention period
Active account dataFor as long as the account is active
Inactive or deleted account dataUp to 30 days after the deletion request
Content generated by the PlatformFor as long as the account is active
Social media OAuth tokensUntil disconnection or account deletion
Billing and transaction data10 years (tax and accounting obligation)
Aggregated and anonymised analytics dataIndefinitely
Technical logs and error reports90 days

After these periods end, data is securely deleted or anonymised.

08

Your rights

Under applicable law, the user has the following rights over their personal data:

Right of access
Obtain confirmation that we process your data and access a copy of it.
Right to rectification
Correct inaccurate or outdated data.
Right to erasure
Request the deletion of your data ("right to be forgotten").
Right to restriction
Ask us to temporarily suspend processing in certain circumstances.
Right to portability
Receive your data in a structured, machine-readable format.
Right to object
Object to processing of data based on legitimate interest.
Withdraw consent
Without affecting the lawfulness of processing carried out before the withdrawal.
Right to lodge a complaint
File a complaint with the competent data protection authority.

Competent data protection authorities:

  • Angola — Data Protection Agency (APD)
  • European Union — Supervisory Authority of the country of residence (Portugal: CNPD)
  • Brazil — National Data Protection Authority (ANPD)

To exercise any of these rights, contact us at [email protected] or visit delete data for deletion requests. We respond within the legal deadline (up to 30 days).

09

Data security

We apply technical and organisational measures to protect data against unauthorised access, loss, alteration or disclosure:

Encryption
Passwords and tokens stored with secure hashing
HTTPS / TLS
All communications encrypted in transit
RBAC
Role-based access control
Monitoring
Continuous detection of anomalies and unauthorised attempts

In the event of a data breach that may significantly affect the user's rights, we commit to notifying the competent authority and the user within the legal deadline.

10

Cookies and similar technologies

The Platform uses cookies and similar technologies for essential operation, usage analysis and improvement of the Service.

Full details are available in our Cookie Policy. Preferences can be managed at any time in your browser or Platform settings.

11

Minors

The Platform is intended exclusively for users aged 18 or older (or the legal age of majority in the user's country of residence). We do not knowingly collect data from minors. If we become aware that we have done so without parental consent, we will delete that data immediately.

12

Account and data deletion

The user can delete their account at any time in Account Settings or by sending a request to [email protected].

ImmediateThe account is deactivated
30 daysPersonal data and associated content deleted
Legal deadlineBilling data retained for tax obligations
ImmediateSocial media OAuth tokens revoked

More information at delete data.

13

Changes to this policy

We may update this policy to reflect legal, technical or Service changes. When that happens:

  • We publish the updated version on this page with a new revision date
  • We notify users by email in case of material changes
  • Continued use of the Service after notification implies acceptance of the new terms

We recommend checking this page periodically.

14

Contact

For any question, request or complaint related to this policy or the processing of your personal data:

General email
[email protected]
Data Protection Officer (DPO)
[email protected]
Postal address
Benguela, Município de Lobito, Bairro Caponte, Rua Oliveira Cardonega
Send emailContact page →
This policy reflects our current practices and our commitment to transparency and the protection of user data.
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