Privacy Policy

Last updated: 27 July 2026 · Version 1.1

1. Data controller

The controller of your personal data is [REGISTERED COMPANY NAME], [type], with registered office at Avenida da Liberdade 129, 5ºD, 1250-140 Lisbon, Portugal, tax number (NIPC) [NIPC]. For any data-protection matter, contact us at geral@harborpartners.pt.

2. What we collect and why

We only process data you voluntarily provide through the site's forms:

• Contact form: name, email and message, to respond to your enquiry. Legal basis: pre-contractual steps / legitimate interest (Art. 6(1)(b) and (f) GDPR).
• Refer a business: the data you submit, including any third-party data you provide, to assess the opportunity. Legal basis: legitimate interest (Art. 6(1)(f)).
• Careers / applications: name, email, CV and application details, to manage recruitment. Legal basis: pre-contractual steps and legal equal-treatment duty (Art. 6(1)(b) and (c)).

Site usage statistics: we measure page visits with a self-hosted solution running on our own servers, without cookies and without third-party analytics services. Each page view creates a record containing the page visited, the date and time, the referring site (where there is one), the language and device type, and the browser family. Your IP address is not retained: it is used only at the moment of recording, to derive a same-day visitor code via a key that is replaced daily and whose previous version is destroyed, so that from the following day onwards that code can no longer be recomputed, including by us. The code serves only to distinguish visitors within the same day and is not linked to any other information about you. Legal basis: our legitimate interest in understanding how the site is used (Art. 6(1)(f) GDPR). Browser privacy signals (Global Privacy Control and Do Not Track) are honoured and automated traffic is excluded.

We do not carry out automated decision-making or profiling.

3. Recipients and processors

Your data may be processed on our behalf by providers that support the site and the delivery of form submissions (in particular the hosting provider and the form-forwarding service), acting as processors under Art. 28 GDPR. We do not sell or share your data with third parties for marketing.

Forms on this site are processed by an external form-service provider whose infrastructure may operate outside the European Union. We are evaluating a move to an EU-based provider; in the meantime, submitted data is limited to what is strictly necessary to respond to your enquiry.

4. International transfers

Where a processor handles data outside the European Economic Area, we ensure an adequacy decision or appropriate safeguards (e.g. Standard Contractual Clauses) under Chapter V GDPR. You may request a copy of those safeguards.

5. Retention

• Contact enquiries and referrals: for as long as needed to handle them and any resulting relationship.
• Site usage statistics: records are deleted automatically after 25 months (allowing year-on-year comparison). The visitor code ceases to be recomputable the day after it is recorded.
• Applications: CVs are generally kept for a maximum of 1 year, unless you consent to a talent pool; recruitment records are kept for 5 years to evidence equal treatment (Law 105/2009).

6. Your rights

You have the right of access, rectification, erasure, restriction, portability and objection, and the right to withdraw consent at any time (without affecting prior lawful processing). To exercise these rights, contact geral@harborpartners.pt.

7. Complaints

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

8. Minors

Our services are aimed at professionals and adults. We do not knowingly collect data from children under 13 without the consent of their legal representative (Art. 16 of Law 58/2019).

9. Cookies

Our use of cookies and similar technologies is described in our Cookie Policy.

10. Changes

This policy may be updated. The version in force is always the one published on this page, with its date.