Data controller
[NOMBRE Y APELLIDOS], a self-employed professional resident in Portugal trading as Pontro, Portuguese tax ID [NIF], address [DOMICILIO]. For any privacy question: [EMAIL-PRIVACIDAD].
What data we process, why, and on what basis
Browsing. When you visit the website, the hosting provider logs technical data (IP address, browser, requested page and time) to serve the site and protect it against abuse. Legal basis: our legitimate interest in running a secure website (Art. 6(1)(f) GDPR). Retention: [PLAZO-REGISTROS].
Contact and meetings. If you write to us through the form or book a meeting, we process the data you give us (name, email, company, job title, approximate volume of your operation, message, and meeting date and time) to reply and prepare the conversation. With each form message we also receive the campaign that brought you to the page, if its address included it (UTM parameters or Google Ads click identifier), and how long you took to send it, which we use to filter automated submissions. When we receive your message we send a confirmation email to the address you gave us. Legal basis: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR) and our legitimate interest in handling business enquiries (Art. 6(1)(f) GDPR). Retention: for as long as the business relationship lasts and, afterwards, for the statutory limitation periods.
Campaign measurement. If Google Ads measurement is enabled, browsing data will only be processed for advertising purposes with your consent (Art. 6(1)(a) GDPR). You can withdraw consent at any time. This measurement is not active today.
We do not make automated decisions or build profiles that have legal effects on you.
Recipients
We do not share your data with third parties unless required by law. We use these providers, which process data on our behalf under a data processing agreement:
- Hosting and CDN: BunnyWay d.o.o. (Slovenia, EU).
- Delivery of form messages: Lettermint B.V. (Netherlands, EU).
- Email: Heinlein Hosting GmbH, mailbox.org (Germany, EU).
- Meeting scheduling: [PROVEEDOR-AGENDA] (EU).
- Advertising, only with consent and once enabled: Google Ireland Ltd. (Ireland). This may involve transfers to the US covered by the EU-US Data Privacy Framework.
Your rights
You can exercise your rights of access, rectification, erasure, objection, restriction and portability, and withdraw your consent, by writing to [EMAIL-PRIVACIDAD]. If you believe we have not handled your data properly, you can lodge a complaint with the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (cnpd.pt), or with the supervisory authority of your country.