Privacy policy

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This privacy policy explains how personal data is handled when you visit miratorie.com and when you contact Miratorie through the channels offered on this website. It is written to meet the EU General Data Protection Regulation (GDPR), Portuguese Law 58/2019, the UK GDPR and the Swiss Federal Act on Data Protection (FADP).

1. Who is responsible for your data

The controller of your personal data is Gustavo Iha Rodrigues de Moraes, a sole trader operating under the name Miratorie.

You can use these same contacts for any question or request about your personal data.

2. When you visit the website

This website does not ask you for any personal information. However, like any website, it cannot be delivered to your browser without some technical data being processed.

What is processed: your IP address, approximate location derived from it (country or region), the browser and device information your browser sends (user agent), the page requested and the time of the request.

Why we collect it: to deliver the pages you request and to protect the website against abuse, such as denial-of-service attacks and malicious automated traffic. As part of this protection, a request that looks malicious may be automatically blocked.

Legal basis: our legitimate interest in operating a secure and available website (Article 6(1)(f) GDPR).

How long: this data is processed while your request is being served and checked. For security monitoring, AWS keeps a sample of recent requests, which can include your IP address and browser information, for up to 3 hours before it is deleted automatically. We do not keep access logs, and we do not use this data to identify, profile or track you.

3. When you contact us by WhatsApp or phone

If you choose to message us on WhatsApp or call us, we process the information that comes with that contact.

What is processed: your phone number, your name, WhatsApp profile name and profile picture (only what your WhatsApp privacy settings make visible to us), the content of your messages and any information you share about you or your business, and basic call details (number, date and duration).

Why we collect it: to answer your enquiry and, if you ask us to, to prepare a proposal for our services.

Legal basis: taking steps at your request before entering into a contract (Article 6(1)(b) GDPR). For general questions that are not about a possible engagement, our legitimate interest in responding to people who contact us (Article 6(1)(f) GDPR).

How long: we keep your messages and contact details for up to five years after our last exchange, unless you ask us to delete them sooner.

If you become a client, the data needed for our engagement is kept for as long as the engagement lasts and afterwards for the periods required by Portuguese tax and accounting law.

About WhatsApp: WhatsApp is operated by Meta (WhatsApp Ireland Limited for users in Europe), which processes your data as an independent controller under its own privacy policy. We recommend reading it before using WhatsApp to contact us.

4. Who receives your data

We do not sell your data and we do not use it for advertising.

The website links to our Instagram and LinkedIn pages. These are ordinary links: nothing from those platforms is loaded on this site, and once you follow a link, that platform's own privacy policy applies.

5. Transfers outside Europe

To deliver pages quickly, CloudFront serves them from the location closest to you, which for visitors in Europe is normally within Europe. Some processing by AWS may still take place outside the European Economic Area, the UK or Switzerland, including in the United States. Where this happens, it is covered by the EU–US Data Privacy Framework (including its UK and Swiss extensions) and/or the European Commission's Standard Contractual Clauses included in those providers' terms.

6. Your rights

You have the right to:

To exercise any of these rights, contact us by WhatsApp, phone or email (section 1). We will respond within one month, and we may ask for information to confirm your identity. Because we keep no website access logs, we have no website visit data that could be linked to you.

7. Complaints

If you believe your data has been handled unlawfully, you can complain to a data protection authority. Our lead authority is the Portuguese Comissão Nacional de Proteção de Dados (CNPD) — www.cnpd.pt. You can also contact the authority in the country where you live or work, including:

We would appreciate the chance to address your concern first.

8. Changes to this privacy policy

We will update this privacy policy if the way we handle personal data changes. The date at the top shows when it was last revised.