Privacy policy

1. Data controller

The controller of the personal data collected through this website is ClearPath Solutions, reachable at [email protected].

2. What data we collect

This is a static website with no forms connected to servers of our own. The data we process is only what you give us voluntarily:

• Contact details — name, email, company, indicative budget and the content of your message, when you write to us by email or through the contact form.
• Technical browsing data — IP address and access logs kept by our hosting provider for the security and operation of the service.

We do not collect special categories of data or data from minors. We do not use analytics, advertising or social media cookies.

3. Purposes and legal bases

• Answering contact and proposal requests — legitimate interest in replying to those who contact us and, where applicable, steps prior to entering into a contract (Article 6(1)(b) and (f) GDPR).
• Website security and availability — legitimate interest in protecting the infrastructure (Article 6(1)(f)).
• Legal obligations — retention of commercial and tax records where a contractual relationship exists (Article 6(1)(c)).

4. How long we keep it

Contact requests are kept for 24 months after the last interaction, unless they lead to a contractual relationship. In that case, data is kept for the applicable legal periods, including tax ones. Technical logs at the hosting provider follow the period set by that provider, usually no longer than 12 months.

5. Who it may be shared with

We do not sell or share personal data for marketing purposes. We may use processors that provide services strictly necessary to operate:

• Web hosting and email provider, with servers in the European Union.
• Professional service providers (accounting, legal counsel), bound by confidentiality.

Wherever data is transferred outside the European Economic Area, we apply the safeguards set out in the GDPR, such as standard contractual clauses.

6. Cookies and similar technologies

This website sets no first-party cookies and uses no analytics or advertising tools. Fonts are served from this domain, so your browser does not contact third-party services to load them.

7. Your rights

Under the GDPR you may, at any time:

• Request access to the data we hold about you.
• Request rectification of inaccurate or incomplete data.
• Request erasure, where there is no legal obligation to keep it.
• Restrict or object to processing, including on grounds relating to your particular situation.
• Request portability of the data you provided to us.
• Withdraw consent, where processing is based on it.

To exercise these rights, write to [email protected]. We reply within one month, extendable where the complexity justifies it.

You also have the right to lodge a complaint with the Portuguese Data Protection Authority (CNPD), at cnpd.pt.

8. Security

We adopt technical and organisational measures appropriate to the risk: encrypted connections (HTTPS), restricted access to mailboxes and data minimisation when collecting. No system is infallible; in the event of a data breach likely to affect your rights, we notify the CNPD and the affected data subjects within the legal deadlines.

9. Changes to this policy

We may update this policy to reflect legal or operational changes. The last update date always appears at the top. Relevant changes are communicated to clients with an active contract.

10. Contact

Privacy questions: [email protected].