Privacy Policy

In short

• We keep what we need for you to be a member: your name, your email, your membership, your payments (without card details), who invited you and the nights you came in.
• Payments go through Stripe. We never see your card.
• We only send you the newsletter if you say yes. If you've been a customer at one of our parties, we may write to you about the club's nights. You leave with one click.
• We use one cookie to keep you signed in. Meta's cookies, which measure our ads, only if you say yes.
• We don't sell your data.
• You can ask us, at any time, to see, correct or delete your data.

The full text, below, is what counts.

1. Who processes your data

1.1. The controller is Lucas Galhardo Silva, NIPC (tax number) 313388369, registered office Rua de Santa Marta, 64, 1.º Dto., 1150-298 Lisboa. It's who runs Innerlabel and sells the membership.

1.2. For any question about your data: ola@innerlabel.pt.

1.3. Data protection officer: —

1.4. This Policy follows the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and Law no. 58/2019.

2. What data we process

2.1. Who you are. Your name, your email and your mobile number.

2.2. Your membership.

• your member number and the date you joined;
• if you joined before 28 September 2026, the pressing your member card got: the night, the pressing and the number, and when;
• where your membership stands (up to date, to settle, cancelled) and the date it's paid until;
• your role in the club (member, door or house);
• your invite code;
• how you found us: a member's link, an ad (the campaign, the source and the ad), the WhatsApp channel, or directly;
• if it happens, the date of a revocation and why.

2.3. Payments.

• the IDs of your customer record and your subscription in Stripe;
• where your payments stand, and your billing history;
• the payment method fingerprint: a code Stripe works out from your card (or other payment method). It can't be used to get back to the card number. It's only there to tell whether two payments use the same method.

We never see or keep your card number, your security code or your bank login details.

2.4. Invites. Who invited you, if you joined through a member's link (recorded at your first payment). And who joined through your link, and when. Once the invite programme is open, also the commission you earn and, if you ask to withdraw it, the IBAN, the account holder, your NIF (tax number), the receipt number and the self-billing agreement you accepted, with its date.

2.5. The nights.

• the nights you said "I'm going" to in the app, and whether you took it back;
• your entries at the door, once the door records them: which night, what time, and who at the door scanned the code.

2.6. Emails. Whether you asked for the newsletter, and when; whether you confirmed your email; whether you left the list; and which relationship emails we sent you, and when.

2.7. Signing in and security.

• the links and codes for signing in to the app: we keep only an encrypted version (a hash), when they were asked for and used, and how many tries there were;
• your IP address, used in the moment to limit repeated requests. It's held only in the server's memory, for 10 minutes at most, and never goes into the database. Our hosting provider may record it in the server's technical logs.

2.8. Photos. The house photographers take photos at the nights. You may be in them.

2.9. WhatsApp. If you tick the WhatsApp box, when you said yes to the house's messages there; if you opt out, when you did. The replies you write to the house's number stay in the house's WhatsApp. If you join the members' community, the house, as admin, sees your mobile number and your profile name. If you only follow the public channel, WhatsApp doesn't show the house your number.

2.10. If you're not a member yet.

• if you ask for the newsletter, we keep your email (without your name), when you asked for it and when you confirmed it;
• if the house writes to you directly about the club, it keeps the email address it wrote to, when, and an internal note;
• if you were a customer at one of our parties before the club, or signed up to one of our lists, we keep your email, your name if we have it, and which party or list you came from.

2.11. Ad measurement, only if you accept Meta's cookies (9.3): the club's pages you opened, whether you opened the payment, asked to hear about the nights or joined (with the amount), the ad click ID and Meta's cookies, your IP address and your browser. Your email and name only go to Meta as an encrypted version (a hash).

2.12. App notifications. If you turn on notifications in the app, the address your phone's browser gives us to deliver them, the kind of device (iPhone, Android or other), when you turned them on and whether the last notification arrived. If you turn them on without an account, we also keep the sentence you agreed to and the last time you opened the app, and nothing else: no name, no email. If you turn them off, we delete the address.

2.13. We don't ask you for sensitive data (health, origin, religion, sexual orientation or anything else under Article 9 of the GDPR).

3. Where the data comes from

3.1. From you: in the membership form, in the app, and when you say "I'm going".

3.2. From Stripe: where your payments stand and the payment method fingerprint.

3.3. From the link you used: the code of the person who invited you.

3.4. From the door: the record of your entry.

3.5. From your browser, if you accept Meta's cookies: the ad click ID, Meta's cookies, your IP and your browser.

3.6. From our earlier parties: the email and name of people who were customers at a party run by the house, or signed up to one of its lists, before the club.

3.7. From a member: if a member invited you by email, we use your email and the name they wrote only to send you that invite, through Resend (5.6), and we don't keep them.

4. What we use the data for, and on what legal basis

4.1. Giving you your membership. Creating your account, your number and your member card; letting you into the app and through the door; showing you the nights; sending you service notices (a payment missing, a night cancelled, changes to the Terms); and reaching you on your mobile when a night needs it (a change of time or venue, the door). Your mobile also makes sure one person doesn't have two accounts. News messages on WhatsApp only if you tick the box (4.8).

Legal basis: performance of the contract (Article 6(1)(b) of the GDPR).

4.2. Charging and invoicing. Charging the monthly fees, issuing invoices and meeting our tax and accounting obligations.

Legal basis: performance of the contract and compliance with legal obligations (points (b) and (c)).

4.3. Preventing fraud and abuse. Comparing the email and the payment method fingerprint, so nobody invites themselves or opens two memberships; refusing a second scan of the same member card on the same night; limiting repeated tries; keeping a record of revocations, so a revoked member card can't join again.

Legal basis: the house's legitimate interest in protecting the club, the members and the payments (point (f)).

4.4. The door and safety at the venue. Checking your member card, recording your entry and, when needed, confirming your age.

Legal basis: performance of the contract; legitimate interest in keeping the nights safe; and compliance with the law on the minimum age for entry.

4.5. Invites and where members come from. Knowing who brought whom and how members find us; showing the person who invited you that you came in through their link, and whether your membership is up to date, behind or ended, so they can keep in touch with the people they brought.

Legal basis: legitimate interest in organising the invites and understanding how the club grows. The commission and withdrawals, once the invite programme is open (Invite Rules): working out the commission, taking it off your monthly fee and paying you what you withdraw, for performance of the contract; keeping the receipts and transfers, for compliance with legal obligations (points (b) and (c)).

4.6. The club's numbers. We count members, how many are going to a night and how many came. We only show totals, never names.

Legal basis: legitimate interest.

4.7. Notices about the nights, to members. When the house sends them: the next night and reminders, by email. Only once your email is confirmed. We use your entries to choose the notice, for example a reminder to someone who hasn't come to a night yet. It isn't a decision with effects for you: it only chooses which email you get.

Legal basis: legitimate interest, because you're a member and the notices are about the service you pay for (Article 13-A(3) of Law no. 41/2004). You can say no to them at any time, with the link in every email.

4.8. Newsletter. Sending you news from the club.

Legal basis: your consent (point (a)). The box starts unticked, and you don't need to tick it to join. If you haven't signed in with the email link yet, we first ask you to confirm your email. Until you do, that request is the only thing we send you; if you don't confirm, we delete it after 30 dias. You can withdraw your consent whenever you like, with one click, and your membership isn't affected.

On WhatsApp. If you tick the WhatsApp box when you join, we send you a welcome and the house's updates on WhatsApp, from the club's number.

Legal basis: your consent (point (a)). The box starts unticked, and you don't need to tick it to join. To opt out, write "stop" to the house's number: we won't write to you there again, and your membership stays the same.

In the app's notifications. If you turn on notifications in the app (in Profile, under "Notifications from the house", or when the app asks you), we send short notifications to your phone: the nights, reminders and club news. To choose who gets each notification, we use what we already know about your membership: whether you said "I'm going" to the next night, whether you're in the first month without a charge, and whether your fee is up to date or unpaid. It's not a decision with effects for you: it only chooses which notification you get.

Legal basis: your consent (point (a)). Notifications only turn on when you tap the button, and you don't need them to be a member. You can turn them off whenever you like, in Profile or in your phone's settings, and we stop sending them.

In the app's notifications, without an account. If you installed the app and haven't joined yet, you can turn on notifications on the sign-in screen: we send you the nights (when they're announced, the day before and when the doors open) and, now and then, a short note from the house. We don't know who you are: only your device's address (2.12). If you later sign in or join, the notifications move to your account, and the paragraph above applies. Legal basis: your consent (point (a)), given when you tap "Notify me", and we keep the sentence you agreed to. You turn them off on the same screen or in your phone's settings, and we delete the address straight away.

4.9. Photos.

• In the archive of the nights, in the app, for members only, once the archive opens. Legal basis: legitimate interest in keeping a record of the club's nights. You can object and ask us to take down a photo you're in.
• In the club's public posts or in ads, we only use photos where you can be recognised if you've given your consent. Legal basis: consent.
• If you don't want your photo taken, tell the house photographer.

4.10. Emails to people who aren't members yet. When the house writes directly to someone about the club.

Legal basis: that person's consent or, where they already have a relationship with the club, the house's legitimate interest. Every email says how to ask us not to write again.

Customers from earlier parties. If you were a customer at one of the house's parties before the club, or signed up to one of its lists, the house may write to you about the club's nights, which are the same kind of thing. Every email says where your contact comes from and carries a link to leave, with one click: you leave, and we don't write to you again.

Legal basis: if you were a customer, the house's legitimate interest, because you already bought a ticket to one of its parties (Article 13-A(3) of Law no. 41/2004, and point (f) of the GDPR); if you signed up, the consent you gave (point (a)).

4.11. Measuring our ads. Knowing how many people reach us through our Instagram ads and how many join, so Meta shows the ads to people who'd like these nights most. We send Meta the events in 2.11, from your browser (the pixel) and from our server (the Conversions API).

Legal basis: your consent (point (a); Article 5(1) of Law no. 41/2004). Without your yes, none of this happens. You withdraw consent whenever you like, under "Cookies" in the footer, without affecting your membership.

4.12. Rights and disputes. Keeping what we need to answer complaints and defend the house's rights.

Legal basis: legitimate interest.

4.13. Legal obligations. Answering requests from the authorities, when the law requires it.

Legal basis: compliance with legal obligations.

4.14. Where the legal basis is legitimate interest, you can object at any time (section 8). If you ask, we'll explain why that interest doesn't override your rights.

4.15. We don't take decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (Article 22 of the GDPR).

5. Who sees your data

5.1. The house. People who work for the house see your full record, with access set by the role they have in the app.

5.2. The door. People working the door see your name when they scan the code, and whether your member card gets in. So it works without a connection, the door phone may keep the night's list of members (name, number and member card status), and deletes it —.

5.3. The person who invited you. If you joined through a member's link, that member sees your name, your member number, the date you joined and where your membership stands: up to date, behind or ended. They never see amounts, the payment method, or why a membership ended or was revoked.

5.4. Anyone who opens your invite link. Your invite page shows your first name. The membership page that opens from it also shows your member number.

5.5. Other members and the public. They only see totals: how many members, how many are going, how many came. Never names.

5.6. Our suppliers, who process data for us, under contract and only for what we ask them to do:

• Stripe (Stripe Payments Europe, Limited, Ireland): payments;
• Resend (USA): sending emails;
• Meta (Meta Platforms Ireland Limited, Ireland): sending WhatsApp messages, if you ticked the box (4.8);
• your browser's notification service (Google's, Apple's, Mozilla's or Microsoft's, depending on your phone): delivering the app's notifications, if you turned them on (4.8). Each notification is encrypted: only your device can read it;
• Vercel Inc. (EUA): hosting the app, in UE (Frankfurt);
• Neon, Inc. (EUA): database, in UE (Frankfurt);
• —: invoicing;
• —: accounting.

5.7. Stripe as a controller in its own right. Stripe also processes payment data on its own account, to prevent fraud and meet its own legal obligations. See Stripe's privacy policy.

5.8. WhatsApp. If you use the members' community or the channel, WhatsApp (WhatsApp Ireland Limited) processes your data under its own policy.

5.9. The authorities, when the law obliges us.

5.10. We don't sell your data. We only share it for advertising with Meta, and only if you accept its cookies (5.11).

5.11. Meta. If you accept Meta's cookies, Meta (Meta Platforms Ireland Limited, Ireland) receives the data in 2.11. For collecting and sending that data, the house and Meta are joint controllers (Article 26 of the GDPR), under an agreement Meta publishes in its Business Tools Terms. What Meta does afterwards, it does as a controller in its own right, under Meta's privacy policy. You can exercise your rights over that data with us or with Meta.

6. Data outside the European Economic Area

6.1. Some suppliers are outside the European Economic Area, or have group companies there, in particular in the USA (Stripe, Resend and Meta, if you accept its cookies or tick the WhatsApp box; and Google's and Apple's notification services, if you turn on the app's notifications).

6.2. In those cases, the transfer relies on:

• the European Commission's adequacy decision on the EU-US Data Privacy Framework, for certified companies; or
• the standard contractual clauses approved by the European Commission.

6.3. You can ask us for a copy of these safeguards at ola@innerlabel.pt.

7. How long we keep the data

7.1. We keep each kind of data for the time below.

• Member record and membership: while you're a member, and for — after your membership ends. During that time we also keep your member number, so you come back with it if you join again (Terms, clause 6.4).
• Invoices and payment records: 10 calendar years after the year of payment, as tax law requires (Article 52 of the VAT Code and Article 123 of the Corporate Income Tax (IRC) Code).
• Payment method fingerprint: as long as the member record.
• Who invited you: as long as the member record. If you delete your account, the link to the members you brought stays, without your name.
• Entries at the door and "I'm going": while you're a member, and for — after. If you ask us to delete your account, we delete them.
• Temporary guest list card (your name, your email, who invited you, whether you got in and whether you became a member): up to 60 days after the night.
• Record of a revocation: —.
• Record of consent (when you said yes, confirmed or left, and from where; we keep only an encrypted version of your email): 3 anos depois de o consentimento acabar.
• Unconfirmed newsletter request: 30 dias.
• Suppression list: if you leave the list, we keep your email on a suppression list, only so we don't write to you again (if you delete your account, only the encrypted version stays, in the record of consent).
• A non-member's email: until you withdraw consent or ask us not to write again, and 2 anos depois de confirmares, se entretanto não aderires at most.
• Customers from earlier parties (your email, your name if we have it, and where it came from): until you leave the list, and 2 anos depois de o teu contacto entrar na lista ou do último email que te mandámos, o que for mais tarde, se entretanto não aderires at most. If you leave, or the email bounces or you mark it as spam, it stays only on the suppression list.
• The relationship emails we sent you (which one and when): 2 anos.
• Sign-in links and codes: they last 15 minutes and work once. Each new request deletes the earlier ones; the encrypted record of the last one is deleted —.
• IP address for limiting tries: 10 minutes at most, only in the server's memory.
• Your cookie choice (the il_cookies cookie): 6 months; then we ask again.
• Ad measurement: we don't keep it; it goes to Meta, which keeps it under its own policy. Your payment keeps, with its data at Stripe, the IP, browser and Meta cookies from when you opened it, to send to Meta once the payment goes through.
• Hosting technical logs: —.
• Photos in the archive: —, or until you ask us to take down one you're in.
• Backups: —.

7.2. When the law doesn't set a period, we keep data only as long as the purpose needs it. When we need it to prove we performed the contract, we may keep it until the rights it relates to are time-barred (Article 21 of Law no. 58/2019).

7.3. Once those periods are over, we delete the data or make it anonymous. App notifications without an account (4.8) are deleted when you turn them off, or after 6 months without you opening the app.

7.4. If you delete your account. You ask in the app, under Profile › Delete your account, or by email, and the house deletes it. We delete your name, your email, your WhatsApp number, the devices for the app's notifications, your entries at the door, your "I'm going" taps, the sign-in links and codes, the newsletter request, your place in the pressing (its number stays counted, without you) and the house's notes about you. We keep your member number, your membership and the invoices, and the commission, for the 10 years tax law requires (7.1). We also keep, for the same time, your withdrawals, with the details you gave us for the transfer: the IBAN and the account holder, and the NIF and the receipt, if you gave them. The record of consent keeps only the encrypted version of your email. Before we delete it, your membership has to be cancelled. If you have confirmed commission, you give us the IBAN and the account holder when you ask, and the house transfers it to you, whatever the amount. Commission still waiting to be confirmed also holds the account: once it's confirmed, you ask for its transfer the same way. If your member card was revoked, the account is only deleted once the period for the revocation record is over (7.1).

8. Your rights

8.1. You have the right to:

• access: know what data we hold about you and get a copy;
• rectification: correct data that's wrong or incomplete;
• erasure: ask us to delete your data, except what the law makes us keep (invoices, for example). You ask in the app, under Profile › Delete your account, or by email (7.4);
• restriction: ask us to stop using certain data for a while;
• portability: get the data you gave us in a commonly used format;
• objection: object to use based on legitimate interest. You can always object to advertising and to email notices, without giving a reason;
• withdraw consent at any time, without affecting what was done before.

8.2. How. Write to ola@innerlabel.pt from your membership email. If you can't, we may ask you for another way to confirm who you are.

8.3. We reply within one month. For complex requests, that can be extended by two more months; if so, we tell you within the first month. You pay nothing, unless a request is manifestly unfounded or excessive.

8.4. Complaints. You can complain to the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD): www.cnpd.pt.

9. Cookies and what stays on your phone

9.1. The session cookie. We use the cookie ic_sessao, which keeps you signed in:

• it's essential: without it you can't use the app with your account;
• it lasts 180 days;
• it's HttpOnly (the pages' code can't read it) and only travels over a secure connection;
• it holds who you are and since when you've been signed in, signed so it can't be changed.

Because it's essential, it doesn't need your consent (Article 5(2) of Law no. 41/2004).

9.2. The cookie for your choice. The il_cookies cookie only keeps whether you accepted or declined Meta's cookies, for 6 months. It's essential so we can respect your choice, and doesn't need consent.

9.3. Meta's cookies, only if you accept. On the club's public pages (home, invites and joining), we ask whether you accept Meta's cookies. If you do, Meta's pixel sets the _fbp cookie and, if you came from an ad, _fbc (90 days each), and measures our ads (4.11). If you decline, or don't answer, we load nothing from Meta. Change your mind whenever you like, under "Cookies" in the footer; if you decline after accepting, we delete those cookies. The members' app, the door and the house have no Meta cookies. We don't use analytics cookies.

9.4. Stripe. When you pay, you're on Stripe's payment pages. Stripe uses its own cookies there, under Stripe's cookie policy.

9.5. The installed app. If you add the app to your home screen, your phone keeps the Home and Code screens (with your name, your number and the code for the door), so your member card opens without an internet connection. This stays on your phone, not on our servers. Signing out of the app deletes it. So does clearing the site's data in your browser.

10. Security

10.1. We protect the data with appropriate technical and organisational measures. For example: encrypted connections; sign-in links and codes kept only in encrypted form, lasting 15 minutes and working once; a signed session cookie; and access to members' records only for people with the house role, checked on every request.

10.2. If there's a data breach that puts you at high risk, we tell you, as the law requires.

11. Age

11.1. Membership is for people aged — or over. We don't knowingly collect data from anyone younger. If we find out it's happened, we delete it.

12. Changes to this Policy

12.1. If we change this Policy in a way that matters, for example a new use of data or a new supplier, we email you before the change takes effect.

12.2. The date at the top tells you which version is in force.