Data protection
Personal data,
with a legal basis.
What data we process, on what legal basis, for how long and with whom. And how to exercise your rights, without having to chase us.
Data controller
JANELAMBICIOSA, UNIPESSOAL LDA is the controller for personal data collected through this website and in the course of client and supplier relationships. Privacy contact details are at the end of this page.
The company has not appointed a data protection officer, as the conditions in Article 37 GDPR are not met. A dedicated contact for these matters exists nonetheless.
What data, and on what basis
Contact and booking requests. Name, email, phone, company, country and the content of the message. Basis: pre-contractual steps at the data subject’s request, or consent where the request is not pre-contractual. Retention: 24 months from last contact.
Service delivery. Identification data for clients, their representatives and beneficial owners. Basis: performance of the contract and compliance with legal obligations, notably anti-money-laundering. Retention: for the applicable statutory periods, counted from the end of the relationship.
Invoicing and accounting. Tax data and supporting documents. Basis: legal obligation. Retention: ten years.
Website security. Technical server logs, including IP address, for abuse detection and rate limiting. Basis: legitimate interest in the security of the service. Retention: 30 days.
This website uses no non-essential cookies, has no third-party analytics and performs no profiling.
Who it is shared with
Data is shared only with processors necessary to operations — hosting, email, accounting — all bound by an agreement under Article 28 GDPR. We do not sell data, do not release it for third-party marketing and do not transfer it outside the European Economic Area without appropriate safeguards.
The current list of subprocessors is available on request.
Your rights
You have the right to access your data, to have it rectified or erased, to restrict or object to processing, and to data portability. Where the basis is consent, you may withdraw it at any time, without affecting the lawfulness of prior processing.
We respond within one month. If a request is complex, we tell you about the extension and the reason within that same month.
You may also lodge a complaint with the supervisory authority: the Portuguese Data Protection Authority (CNPD).
Record of processing activities
We maintain the record required by Article 30 GDPR, listing purposes, categories of data subjects and data, recipients and retention periods. It is provided to institutional clients who request it as part of due diligence.
Controls
The real status of each control in this area. A control "being implemented" is defined and pending approval; "planned" has a target date but is not yet written.
- In force
Privacy policy published
By purpose, with legal basis and retention.
- In force
Zero non-essential cookies
No external analytics, no profiling.
- In force
Retention periods defined
Concrete figures, not "as necessary".
- Being implemented
Record of processing (Art. 30)
Prepared; in final review.
- Being implemented
Processor agreements
Article 28 template in use; inventory to complete.
- Planned
Retention and deletion policy
To be formalised in a single document.
Documents in this area
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Privacy Policy
In forceWhat personal data we process, on what legal basis, for how long, with whom it is shared and how to exercise your rights.
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Record of Processing Activities
Being implementedThe record required by Article 30 GDPR, listing purposes, categories of data subjects and data, recipients and retention periods.
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Data Processing Agreement Template
Being implementedClauses for processing data on the client’s behalf under Article 28 GDPR, used in our service agreements.
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Retention and Deletion Policy
PlannedRetention periods by document type, including statutory tax and anti-money-laundering retention requirements.
Need documentation for a process?
We send the due diligence pack within 24 business hours, with the registry certificate, beneficial ownership, corporate structure and the applicable policies.