PRIVACY POLICY
The 40s Reset – www.silviopaiva.com and app.silviopaiva.com
Last updated: 05-10-2026
1. WHO WE ARE
The data controller is Silvio Paiva, Tarragona, Spain, tax id 225486347.
Contact: sp@silviopaiva.com
This policy covers our website, the free Reset Profile, The 40s Reset App (app.silviopaiva.com), our e-books and the 1:1 Launch Partnership.
2. WHAT PERSONAL DATA WE COLLECT
- Contact data: your name, email address and, only if you give it, your phone number.
- Purchase data: what you bought, the price, the date and invoice details. Card and PayPal details are handled by Stripe and PayPal; we never see your full card number.
- App content: the answers you type in the app (for example your career, skills, results, goals and preferences), your Reset Profile, your conversations with the Reset AI and Reset Coach, and your progress. Please do not enter sensitive information such as health data.
- Technical and usage data: IP address, browser, device and pages visited, collected by our website platform and, if you accept analytics cookies, by Google Analytics.
- Communications: emails and contact-form messages you send us, and the details you give when booking a call.
3. HOW THE APP HANDLES YOUR DATA
- Your Reset Profile, conversations and progress are saved in your own browser on your device (local storage), not on our servers. If you clear your browser data they are deleted, other devices cannot see them, and we cannot recover them.
- When you sign in, the app checks your email against our contact list in systeme.io to know which access level you have, and keeps a sign-in session in your browser for up to 180 days.
- When you use an AI feature, the information needed for that answer (your message, relevant parts of your profile and the conversation in that step) is sent through our server, hosted by Netlify, to an AI provider that generates the answer. We do not keep copies of your conversations on our servers.
4. WHY WE USE YOUR DATA AND OUR LEGAL BASIS (GDPR)
- To provide the free Reset Profile, the app, the e-books and the 1:1 Partnership: performance of a contract or steps you ask for before one (Art. 6(1)(b)).
- To process payments, issue invoices and meet tax obligations: legal obligation (Art. 6(1)(c)).
- To answer your questions and give support: performance of a contract and our legitimate interest in helping our customers (Art. 6(1)(b) and (f)).
- To send newsletters and marketing emails: your consent (Art. 6(1)(a)), which you can withdraw at any time with the unsubscribe link.
- For analytics cookies: your consent. Storage that is strictly needed for the app to work (such as your sign-in session) does not require consent.
- To keep the service secure and prevent misuse, for example daily usage limits: our legitimate interest (Art. 6(1)(f)).
5. ARTIFICIAL INTELLIGENCE
The Reset AI and Reset Coach generate suggestions (such as skills, niches, business models and plans) from your answers. These are suggestions only: there is no automated decision-making with legal or similarly significant effects on you (Art. 22 GDPR), and you decide what to use. AI answers can contain mistakes, so please review them.
Our AI providers are Google (Gemini API) and, as a backup, OpenRouter, which forwards requests to AI model providers. We use paid services and settings intended to exclude providers that use your content to train their models.
6. WHO WE SHARE YOUR DATA WITH
We only share data with service providers that help us run the business, under data processing terms:
- systeme.io (website, checkout, contact list and emails)
- Stripe and PayPal (payments)
- Netlify (hosting of the app and its server functions)
- Google (Gemini API for AI answers; Google Analytics, if you consent)
- OpenRouter and the AI model providers it forwards requests to (backup AI answers)
- Our calendar and video-call tools, for booked calls
- Our email provider, for messages you send us
- Our accountant and the tax authorities, when the law requires it
We do not sell or rent your personal data.
7. INTERNATIONAL TRANSFERS
Some of these providers are based in the United States or other countries outside the European Economic Area. When your data is transferred outside the EEA, we rely on the EU-US Data Privacy Framework (where the provider is certified) or the European Commission's Standard Contractual Clauses. You can ask us for more information about these safeguards.
8. HOW LONG WE KEEP YOUR DATA
- Contact and marketing data: until you unsubscribe or ask us to delete it, or after 24 months of inactivity.
- Purchase and invoice records: for as long as Spanish tax and commercial law requires (generally 4 to 6 years).
- App content: on your own device until you delete it. AI providers process it to generate answers, under their own retention rules.
- Support messages: up to 24 months.
- Analytics data: according to our Google Analytics retention settings.
9. COOKIES AND LOCAL STORAGE
We use storage that is strictly necessary for the website and app to work, such as your sign-in session and your saved app progress. Analytics cookies are only used if you accept them in our cookie banner. Embedded videos may set their own cookies.
10. YOUR RIGHTS
You can ask us to:
- give you a copy of the personal data we hold about you (access);
- correct inaccurate data (rectification);
- delete your data, except what we must keep by law (erasure);
- limit how we use it (restriction);
- send it to you in a common, machine-readable format (portability);
- stop using it for direct marketing or based on our legitimate interests (objection).
You can also withdraw your consent at any time.
To exercise any right, email sp@silviopaiva.com. We reply within one month.
If you think we have not handled your data properly, you can complain to the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es) or to the data protection authority where you live.
11. IF YOU LIVE IN THE UNITED STATES
We do not sell your personal information, and we do not share it for cross-context behavioral advertising. You can ask to access or delete your personal information by emailing sp@silviopaiva.com. We will not treat you differently for making a request.
12. SECURITY
All traffic to our website and app is encrypted (HTTPS). Sign-in sessions are signed and expire, and our service keys are stored securely on the server and never in your browser. Access to data is limited to what is needed to run the service. No method of transmission or storage is completely secure, but we work to protect your data.
13. CHILDREN
Our website, products and app are intended for adults and are not directed at anyone under 18.
14. CHANGES TO THIS POLICY
We may update this policy. The date at the top shows the latest version, and we will tell you about important changes by email or on the website.
15. CONTACT
Questions about your privacy: sp@silviopaiva.com