Legal
Privacy notice
Draft version 0.1 · last edited 17 October 2026
1. Who we are
Dawni is run by [FULL NAME], a sole trader (empresário em nome individual) registered in Portugal, of [ADDRESS], NIF [NIF], email [CONTACT EMAIL] (“we”, “us”). We are the controller of the personal data described here. Contact us about privacy at [CONTACT EMAIL].
2. What we collect and why
| Data | Why we use it | Legal basis (GDPR / UK GDPR) |
|---|---|---|
| Email address, and the name you’d like Dawni to use | To create your account, send sign-in links and service emails (trial reminders, receipts of withdrawal) | Contract (Art. 6(1)(b)) |
| Waitlist details: email, optional phone type, country and time zone, and your consent choices | To manage your place on the waitlist and, if you opted in, tell you when Dawni launches | Consent (Art. 6(1)(a)); you can withdraw it at any time |
| Phone number(s), whether each is a mobile or a landline, an optional backup mobile, and your consent to be called | To place the wake-up calls you schedule and, on a mobile, send one text if we can’t reach you | Contract (Art. 6(1)(b)) |
| Your schedule: wake time, time zone, days, voice, call-back settings | To call you at the right moment, including across clock changes | Contract |
| Call logs: when each call was placed, whether it was answered, whether you pressed 1, how many attempts, whether a text was sent | To run the service, show your morning log, stop calls once you’re up, and investigate problems | Contract; legitimate interests in keeping the service reliable (Art. 6(1)(f)) |
| Membership status (trial, active, cancelled), plan and renewal dates, received from our reseller | To give you access to what you’ve paid for | Contract |
| Withdrawal notices and the record of your consent to start during the withdrawal period (text, time and date) | To handle your consumer rights and prove what you agreed to | Legal obligation (Art. 6(1)(c)); legitimate interests |
| Technical data: IP address and browser type, kept briefly in security logs and rate limits | To keep accounts safe and prevent abuse | Legitimate interests |
We don’t record the audio of your calls. [CONFIRM ONCE THE CALLING PROVIDER IS CHOSEN] We don’t sell your data or use it for advertising, and we don’t use tracking cookies (see the cookie note).
3. Payments
Memberships are sold by Paddle.com, our reseller and merchant of record. Paddle collects your payment details and billing address directly and acts as an independent controller for that data under its own privacy notice. We never see your full card number. Paddle tells us your membership status, plan, renewal dates and a customer reference.
4. Who processes data for us
We use these service providers (processors) under data-processing terms. [CONFIRM EACH PROVIDER, ITS ROLE AND TRANSFER SAFEGUARDS BEFORE LAUNCH]
- Hosting, database and transactional email: [HOSTING PROVIDER]
- Telephone calls and text messages: [TELEPHONY PROVIDER]
- Fallback email delivery (if used): [EMAIL PROVIDER]
- Payments, tax and invoicing: Paddle.com (independent controller as merchant of record)
- Privacy-friendly, cookieless website statistics (if enabled): [ANALYTICS PROVIDER]
5. International transfers
Where a provider processes data outside the EEA or the UK, we rely on an adequacy decision or Standard Contractual Clauses (with the UK Addendum where relevant). [LIST TRANSFERS]
6. How long we keep it
| Data | Proposed retention |
|---|---|
| Account, phone numbers and schedule | While your account is open; deleted when you delete your account |
| Morning log and call records | [12 MONTHS], or until you delete your account |
| Waitlist entry | Until launch plus [6 MONTHS], or until you ask us to remove it |
| Sign-in links | Expire after 15 minutes; deleted within a day |
| Session cookie and sessions | 30 days, or until you sign out |
| Consent records and withdrawal notices | [LIMITATION PERIOD, E.G. 5 YEARS] to show we handled your rights properly |
| Security logs and rate-limit counters | Up to [30 DAYS] |
7. Your rights
You can ask to access, correct, delete or export your data, to restrict or object to how we use it, and to withdraw consent at any time (this doesn’t affect what we did before). You can delete your account yourself from Settings. To exercise any right, email [CONTACT EMAIL]. We’ll reply within one month.
You can also complain to a supervisory authority: in Portugal, the Comissão Nacional de Proteção de Dados (CNPD, cnpd.pt); in the UK, the Information Commissioner’s Office (ICO, ico.org.uk); or the authority where you live.
8. Security
Sign-in links are single-use and expire after 15 minutes, and we store only a scrambled (hashed) version of them. Sessions use a secure, HttpOnly cookie. Data is encrypted in transit.
9. Children
Dawni is for people aged 18 and over. [CONFIRM MINIMUM AGE]
10. Changes
If we change this notice in a meaningful way, we’ll tell you by email or in the app before the change takes effect.