Privacy Policy

1. Introduction

EmberPlanet Lda. ("we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us in any way. By using our services, you consent to the data collection and use practices described in this policy.

2. Data Controller Information

The data controller for your personal information is:

3. Data We Collect

We collect various types of information in connection with the services we provide, including data collection through our website, contact forms, and business interactions. The personal data we collect may include:

• Contact Information: Name, email address, phone number, postal address, and company details
• Professional Information: Business details, industry, company size, financial information relevant to our services
• Communication Data: Records of communications, enquiries, and correspondence with us
• Website Usage Data: IP address, browser type, device information, pages visited, and time spent on our website
• Technical Data: Cookies, log files, and other tracking technologies as described in our cookie policy
• Marketing Data: Preferences for receiving marketing communications and participation in surveys or promotions

4. How We Use Your Information

We use the personal data we collect for various purposes related to our business operations and service delivery. We use of your data includes the following purposes, based on legitimate business interests and legal obligations:

• Providing financial advisory services and business consultations
• Responding to enquiries and communicating with clients and prospects
• Processing service applications and managing client relationships
• Conducting risk assessments and compliance checks as required by financial regulations
• Improving our website, services, and customer experience
• Sending relevant marketing communications (with your consent)
• Complying with legal and regulatory obligations
• Protecting against fraud and ensuring the security of our services

5. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Contract Performance: To provide our financial advisory services and fulfil contractual obligations
• Legitimate Interest: To operate our business, improve our services, and maintain client relationships
• Legal Obligation: To comply with financial regulations, anti-money laundering requirements, and other legal duties
• Consent: For marketing communications and non-essential cookies (which you can withdraw at any time)

6. 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 refer to our Cookie Policy.

7. Data Sharing and Disclosure

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

• With professional service providers (lawyers, accountants, auditors) when necessary for service delivery
• With regulatory authorities when required by law or regulation
• With technology service providers who assist in website operation and data processing (under strict confidentiality agreements)
• In connection with a business transfer, merger, or acquisition (with appropriate safeguards)
• To protect our legal rights or prevent fraud

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, and resolve disputes. Generally, we retain client data for seven years after the end of our business relationship, in accordance with financial services regulations. Website usage data and cookies are retained for shorter periods as specified in our Cookie Policy. You may request deletion of your data subject to our legal and regulatory obligations.

9. Your Rights

Under GDPR and Portuguese data protection law, your rights regarding your personal data include:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data (subject to legal obligations)
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing based on legitimate interests or for marketing purposes
• Right to Withdraw Consent: Withdraw consent for processing where consent is the legal basis

10. Data Security

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

11. International Data Transfers

As a Portugal-based company operating within the European Union, we primarily process data within the EU/EEA. If we transfer data outside the EU/EEA, we ensure appropriate safeguards are in place, such as adequacy decisions, standard contractual clauses, or other approved transfer mechanisms under GDPR.

12. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete such information promptly.

13. 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. Your continued use of our services after such changes constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy, wish to exercise your rights, or need to contact us regarding data protection matters, please contact information is available through the following channels:

15. Supervisory Authority

If you believe we have not handled your personal data in accordance with this policy or applicable law, you have the right to lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados - CNPD) or your local supervisory authority in the EU.