Privacy Policy

Introduction

VelvetFrontier Lda. ("we", "our", or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website and services. We are the data controller for the personal information we collect about you.

Data Controller Information

VelvetFrontier Lda.
Registration Number: 552021458
VAT Number: PT951475485
Address: Rua do Comércio 84, 3049-239 Coimbra, Portugal
Email: privacy@velvetfrontier.world

Data Collection

We collect personal data that you provide to us directly and information that is automatically collected when you use our website. The data we collect includes:

• Contact Information: Name, email address, phone number, and postal address when you contact us or request our services
• Communication Data: Information contained in any communications you send to us, including consultation requests and support inquiries
• Technical Data: IP address, browser type, operating system, referring website, pages visited, and time spent on our website
• Usage Data: Information about how you interact with our website and services
• Marketing Data: Your preferences for receiving marketing communications and your communication preferences

How We Use Your Information

We use of your data is based on legitimate business interests, contractual necessity, legal obligations, and your consent where required. We use your personal information to:

• Provide investment education services and respond to your inquiries
• Process and manage consultation bookings and service delivery
• Communicate with you about our services, including appointment confirmations and follow-ups
• Improve our website functionality and user experience
• Send you marketing communications (with your consent) about our services and educational resources
• Comply with legal and regulatory obligations
• Protect against fraud and ensure website security

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please see our Cookie Policy.

Data Sharing

We do not sell your personal information to third parties. We may share your information in the following circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our website and delivering our services
• Legal Requirements: When required by law or to protect our rights, property, or safety
• Business Transfers: In connection with any merger, sale of assets, or acquisition of our business
• Consent: With your explicit consent for specific purposes

Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, and resolve disputes. Contact information and communication records are typically retained for 7 years after our last interaction with you. Website analytics data is retained for 26 months. You may request deletion of your personal data at any time, subject to our legal obligations.

Your Rights

Under the General Data Protection Regulation (GDPR), you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal information we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete personal information
• Right to Erasure: Request deletion of your personal information in certain circumstances
• Right to Restrict Processing: Request that we limit how we use your personal information
• Right to Data Portability: Request a copy of your personal information in a structured, machine-readable format
• Right to Object: Object to our processing of your personal information for direct marketing purposes
• Right to Withdraw Consent: Withdraw your consent at any time where we rely on consent to process your personal information

Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. This includes encryption of data in transit, secure storage systems, access controls, and regular security assessments. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

International Data Transfers

As we operate within the European Union, your personal data is primarily processed within the EU/EEA. If we transfer your data outside the EU/EEA, we ensure appropriate safeguards are in place, such as adequacy decisions by the European Commission or standard contractual clauses.

Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

Contact Information

If you have any questions about this Privacy Policy, wish to exercise your rights, or need to contact us regarding your personal data, please reach out to us:

Complaints

If you believe we have not handled your personal information in accordance with this Privacy Policy or applicable data protection laws, you have the right to lodge a complaint with the relevant supervisory authority. In Portugal, this is the Comissão Nacional de Proteção de Dados (CNPD).

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR: (a) Consent - where you have given clear consent for us to process your personal data for specific purposes; (b) Contract - where processing is necessary for the performance of a contract with you; (c) Legal obligation - where processing is necessary to comply with legal obligations; (d) Legitimate interests - where processing is necessary for our legitimate business interests, provided these do not override your fundamental rights and freedoms.