Privacy Notice

1. Who is responsible

TRENDSYLVANIA DEVELOPMENT GROUP SRL (trading as Virtus Integra), Str. Rodnei 3, Ap. 1, 540342 Târgu Mureș, Mureș, Romania, trade register J26/673/2022, fiscal code 46041246, is the data controller for the personal data described here. Contact: hello@virtusintegra.com.

1a. Sensitive data and explicit consent

Two parts of Virtus Integra can involve data about your sex life or your inner state, which the GDPR treats as a special category:

• The Purity pillar of the Compass. Before those four statements appear, you are asked whether you want to answer them. If you decline, nothing about that area is asked, scored or stored, and the rest of your Compass is unaffected.
• Ledger reflections. Your entries are always private. They are only sent to an automated writing service if you have switched that on.

Both rely on your explicit consent under Article 9(2)(a) GDPR. You can withdraw either at any time in Settings, with effect for the future.

2. What we collect and why

• Account data — email, display name, sign-in credentials. To create and secure your account. Legal basis: performance of our contract.
• Programme data — Compass answers and results, daily completions, habits, streaks, covenant, cohort membership, invitations. To run the training you asked for. Legal basis: contract.
• Your writing — journal entries in the Ledger and posts on the Wall. Journal entries are private to you. Legal basis: contract. This may include sensitive reflections; you choose what to write, and you can delete it.
• Reflection replies — only if you switch them on, the text of an entry is sent to the Lovable AI gateway (using an OpenAI model) which returns one question, stored with your entry. Legal basis: explicit consent, Art. 9(2)(a) GDPR.
• Purity answers — only if you consent before those statements are shown. Legal basis: explicit consent, Art. 9(2)(a) GDPR.
• Notifications — push subscription details and email preferences, to send the daily nudge and Sunday Letter. Legal basis: consent, withdrawable at any time.
• Technical data — IP address, device and browser information, error logs. For security, fraud prevention and keeping the service working. Legal basis: legitimate interests.

We do not sell your data, and we never publish your journal or your Compass answers. Public pages show only what you explicitly choose to make public.

3. Who we share it with

• Supabase — database, authentication and file storage.
• Lovable — hosting of the application and the AI gateway used for Ledger reflections.
• OpenAI — the model behind those reflections, reached through the Lovable gateway.
• Paddle — our reseller and Merchant of Record, for the sale of membership, subscription management, payments, invoicing and tax compliance. Paddle collects payment details directly; we never see your card.
• Email and push delivery providers, for letters and notifications.
• Professional advisers (legal, accounting) and authorities where the law requires it.

Where data leaves the EEA, transfers are protected by adequacy decisions or standard contractual clauses.

4. How long we keep it

We keep your account and programme data while your account exists. Delete your account in Settings and it is removed, along with your journal, completions, habits and subscriptions to notifications. Records we must keep for tax or accounting reasons are retained for the period Romanian law requires; anything else is deleted or anonymised when no longer needed.

5. Your rights

You may request access, correction, erasure, restriction, portability, or object to processing, and withdraw consent at any time. Write to hello@virtusintegra.com and we respond within one month. You may also complain to the Romanian supervisory authority, ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal), B-dul G-ral. Gheorghe Magheru 28-30, Bucharest, dataprotection.ro, or to the authority where you live.

6. Security

Data is encrypted in transit, access is restricted to what is needed to run the service, and private data is protected by row-level access rules so one member cannot read another's writing.

7. Cookies and similar technology

We use only what the service needs to work. No advertising or tracking cookies.

• Sign-in session (cookie and local storage, set by us) — keeps you signed in. Strictly necessary. Kept until you sign out or it expires.
• Compass result (local storage, set by us) — remembers a result taken before you signed up so it can follow you into your account. Strictly necessary for that feature. Kept until you clear your browser.
• Consent and dismissal flags (local storage, set by us) — remembers choices such as a closed banner. Strictly necessary.
• Checkout (cookies set by Paddle) — required to complete payment and prevent fraud.

Clear them in your browser at any time; the app may then ask you to sign in again.

8. Children

Virtus Integra is for adults. You confirm you are 18 or older when you create an account. We do not knowingly collect data from anyone under 18.

9. Changes

We will announce material changes to this notice in-app or by email.