Privacy Policy

1. Data Controller

• Identity: Pedro Murinelo.
• Contact: [pedro.murinelo@protonmail.com].
• Data Protection Officer (DPO): [pedro.murinelo@protonmail.com].

2. Personal Data Collected

We collect personal data when you:

• Browse our website (navigation data like IP address, browser type, via cookies – see Cookies Policy).
• Fill out contact forms, scheduling, or registration forms (name, email, phone, if relevant).
• Use our services (sensitive information relevant to the engagement, with explicit consent).

Data types:

• Identification: name, email, phone.
• Sensitive data (as applicable).
• Automated data: cookies, access logs.

3. Purposes of Processing

Data is processed to:

• Provide services (legal basis: contract execution or consent).
• Respond to inquiries and schedules (legal basis: legitimate interest or consent).
• Improve the website and services (legal basis: legitimate interest).
• Comply with legal obligations (e.g., tax or regulatory requirements).

We do not use data for direct marketing without prior consent.

4. Data Sharing

Data may be shared with:

• Service providers (e.g., video conferencing platforms like Zoom, with GDPR-compliant subprocessing agreements).
• Competent authorities (if required by law).
• We do not transfer data outside the EEA without adequate safeguards (standard contractual clauses or adequacy decisions).

5. Data Subject Rights

You can exercise the following rights by contacting us:

• Access: to know what data we hold about you.
• Rectification: to correct inaccurate data.
• Erasure ("right to be forgotten"): to delete data when no longer necessary.
• Restriction: to restrict processing in certain cases.
• Portability: to receive data in a structured format.
• Objection: to object to processing based on legitimate interest.
• Withdrawal of consent: at any time, without affecting prior processing.

To exercise your rights, email [insert email]. We will respond within 1 month (extendable if complex).

You may complain to the National Data Protection Commission (CNPD): www.cnpd.pt.

6. Data Security

We implement technical and organizational measures to protect data (e.g., encryption, controlled access, secure backups). In case of a breach, we notify the CNPD and affected individuals if necessary.

7. Retention Period

We retain data for as long as necessary:

• Contact data: up to 1 year after the last interaction.
• Service data: up to 5 years after the end of the engagement (legal obligation).
• Thereafter, data is anonymized or deleted.

8. Policy Changes

We may update this policy. Changes will be published on the website with a revision date. Last updated: 11.05.2026.