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Privacy notice

This privacy notice explains how ALGORITMO DA SORTE — UNIPESSOAL LDA (“we”, “us”, “our”) processes personal data when you visit algoritmodasorte.com or contact us, in line with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable EU and Portuguese law, including rules on cookies and similar technologies. This page is for transparency; it does not replace legal advice.

1. Who is responsible for your data?

We are the data controller for the processing described here.

For questions about this notice or your privacy rights, contact us at the email above. We will respond within a reasonable time and, where GDPR applies, within one month in principle (that period may be extended by two further months where necessary, as permitted by GDPR).

2. What personal data do we process?

Depending on how you interact with us, we may process the following categories of data:

  • Website usage data: pages viewed, approximate time on site, referrer/exit pages, browser type and version, device type, operating system, language preferences, and similar technical information collected through server logs or essential cookies.
  • Cookie / storage data: data stored or read from your device when we use cookies or local storage (for example to remember your cookie choices).
  • Communications data: if you email us, we process your email address, the content of your message, attachments you send, and technical metadata generated in the course of delivery (such as timestamps and routing information).

We do not ask you to create an account on this website solely to browse it, and we do not intentionally collect special categories of data (such as health data) through the site.

3. For what purposes and on what legal bases do we process data?

Under GDPR, we must identify a lawful basis for each purpose. In summary:

  • Operating and securing the website (delivering pages, preventing abuse, debugging, maintaining availability) — legitimate interests (Art. 6(1)(f) GDPR) to run a secure, functional site, balanced against your rights; where strictly necessary cookies or storage are used, this may also align with legitimate interests or, where required by EU/Portuguese rules, another applicable basis.
  • Responding to enquiries and managing pre-contractual steps when you contact us — legitimate interests (Art. 6(1)(f)) and/or performance of a contract or steps at your request prior to entering a contract (Art. 6(1)(b)), depending on the nature of your request.
  • Storing your cookie preference (e.g. “Accept all” / “Essential only”) — typically consent (Art. 6(1)(a)) where non-essential cookies or similar tools are involved, and/or compliance with the ePrivacy framework as transposed in Portugal.
  • Compliance with legal obligations (for example tax, accounting, or responding to lawful requests from public authorities) — legal obligation (Art. 6(1)(c)).
  • Analytics or improvement of the site (only if we use optional analytics tools and you have consented) — consent (Art. 6(1)(a)); if you refuse or withdraw consent, we will not rely on consent for that processing.

Where we rely on legitimate interests, you have the right to object on grounds relating to your particular situation (see section 8). We will assess your objection as required by GDPR.

4. Cookies and similar technologies

We may use cookies (small text files placed on your device) and similar technologies (such as local storage) in line with EU rules on electronic communications and the GDPR.

  • Strictly necessary cookies or storage are used where required for core functions (for example remembering a choice you have already made in our cookie banner, or keeping the site secure).
  • Optional cookies (for example analytics) are used only if you give us consent through our cookie controls. You can change your mind at any time by clearing site data for our domain and revisiting the site, or by contacting us.

Browser settings may also let you block or delete cookies; blocking strictly necessary cookies may affect how the site works.

5. Who receives your data?

We do not sell your personal data. We may share data with:

  • Service providers (processors) who assist us with hosting, email, security, or analytics, bound by written agreements that require them to protect personal data and process it only on our instructions (Art. 28 GDPR).
  • Professional advisers (for example lawyers or accountants) where legally necessary.
  • Public authorities when we are legally required to disclose information.

6. Transfers outside the European Economic Area (EEA)

Our processing is generally carried out within the EEA (Portugal / EU providers). If we ever use a provider in a country not covered by an adequacy decision of the European Commission, we will ensure appropriate safeguards under GDPR (for example the EU Commission’s Standard Contractual Clauses) unless another valid transfer mechanism applies.

7. How long do we keep personal data?

We keep data only for as long as necessary for the purposes set out in this notice, unless a longer period is required or permitted by law. Indicatively:

  • Server logs — typically retained for a limited period needed for security and troubleshooting, then deleted or aggregated.
  • Email correspondence — kept for as long as needed to handle your enquiry and any follow‑on relationship, and thereafter according to legal, tax, or limitation rules.
  • Cookie preferences — stored locally on your device according to the lifespan of the relevant cookie or storage key (you can remove it via browser settings).

8. Your rights under the GDPR

If GDPR applies to our processing of your personal data, you have the following rights (subject to conditions and exemptions in the GDPR):

  • Right of access (Art. 15) — to obtain confirmation whether we process your data and a copy of certain information.
  • Right to rectification (Art. 16) — to have inaccurate data corrected.
  • Right to erasure (“right to be forgotten”) (Art. 17) — in specific circumstances.
  • Right to restriction of processing (Art. 18) — in specific circumstances.
  • Right to data portability (Art. 20) — where processing is based on consent or contract and is automated.
  • Right to object (Art. 21) — to processing based on legitimate interests, and to direct marketing (we do not send marketing solely from browsing this site unless you separately opt in).
  • Right to withdraw consent at any time, where processing is based on consent — without affecting the lawfulness of processing before withdrawal.
  • Right to lodge a complaint with a supervisory authority (Art. 77), in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement.

To exercise your rights, email info@algoritmodasorte.com. You may also contact the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD): www.cnpd.pt.

9. Automated decision-making and profiling

We do not use your personal data for solely automated decisions that produce legal or similarly significant effects on you, and we do not carry out profiling as defined in Art. 22 GDPR in connection with this website.

10. Children

This website is aimed at businesses and professionals. We do not knowingly collect personal data from children below the age at which consent is valid under local law without appropriate parental authority. If you believe we have collected such data, please contact us and we will take steps to delete it where appropriate.

11. Security

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access (Art. 32 GDPR). No method of transmission over the Internet is completely secure; we encourage you to use secure channels when sending sensitive information.

12. Changes to this notice

We may update this privacy notice to reflect changes in our practices, services, or legal requirements. The revised version will be published on this page. Where changes are material and we rely on consent, we will seek fresh consent where required by law.