Privacy
Privacy policy
Last updated: 24 September 2026
This website collects as little as it possibly can. There are no cookies, no analytics, no tracking and no requests to third parties. This page explains, under Article 13 of the GDPR, the little that is unavoidable.
1. Who is responsible
The controller for the processing described here is:
- Controller
- Facing Impulse - Lda
- Registered office
- Rua da Quinta do Sobreiro, n.º 25, Quinta Vale do Espinhal, Espinhal, 3230-343 Penela
- Tax and legal person number (NIPC)
- 518941710
- Contact
- geral@facingimpulse.pt
No Data Protection Officer has been appointed. Under Article 37(1) of the GDPR the appointment is not mandatory here: Facing Impulse is not a public authority, its core activities do not consist of regular and systematic monitoring of data subjects on a large scale, and it does not process special categories of data on a large scale. Data protection matters are handled through the contact address above.
2. What we process, and why
2.1 Web server logs
Like any web server, the one serving this site records each request. The log line contains the IP address, date and time, the address requested, the HTTP status code, the number of bytes sent, the referring address and the browser identification (user agent). The IP address is personal data.
Purpose: keeping the service running and secure — diagnosing faults and detecting abuse. Lawful basis: legitimate interests, Article 6(1)(f) of the GDPR. These logs are not used to build profiles, are not cross-referenced with any other source and are not used for statistics or marketing.
2.2 Messages you send us
This site has no forms. The only way to reach us from here is the published email address. If you write to us, we process what you choose to send: your email address, your name if you give it, and the content of the message.
Purpose: replying to you and, where applicable, preparing or performing a contract. Lawful basis: pre-contractual steps and performance of a contract, Article 6(1)(b) of the GDPR, or our legitimate interest in replying to what we are asked, Article 6(1)(f).
3. How long we keep it
| Data | Retention |
|---|---|
| Web server logs | 14 days. Log files rotate daily and the fifteenth rotation deletes the oldest — there is no long-term archive and no backup of them. |
| Email correspondence | For as long as the contact or business relationship requires, and afterwards only where a legal obligation requires it — in particular the tax and accounting retention periods. |
4. Who else is involved
We do not sell, rent or trade personal data, and we do not share it with anyone except the service providers strictly needed to run the site and the mailbox, acting as processors on our instructions:
| Processor | Role and location |
|---|---|
| DigitalOcean | Hosting of the server that serves this website. The machine is physically located in Amsterdam, the Netherlands — inside the European Union. The web server logs described above live here. |
| Google Workspace | The geral@facingimpulse.pt mailbox. The service is contracted with Google Ireland Limited, established in the European Union. See the following section on international transfers. |
Personal data may also be disclosed to public authorities where a legal obligation requires it.
5. International transfers
The website itself transfers nothing outside the European Union: the server is in the Netherlands and the page makes no requests to third parties.
Email is the exception. Google Workspace is provided by Google Ireland Limited, but operating the service may involve access by Google LLC in the United States. Those transfers take place under the European Commission adequacy decision for the EU-US Data Privacy Framework, adopted on 10 July 2023, and under standard contractual clauses as an additional safeguard. If you prefer not to use email, you can contact us by post at the registered office above.
6. Cookies and storage on your device
This site sets no cookies, does not use your browser local storage and does no tracking: it writes nothing to your device. The language is chosen by address — the English version lives under /en/ — so there is no preference to remember.
Article 5 of Law 41/2004 of 18 August makes storing information on a user terminal, or accessing it, subject to prior consent. As this site does neither, there is no consent to ask for and no banner to show.
7. Your rights
Under Articles 15 to 22 of the GDPR you have the right to request access to your personal data, their rectification or erasure, restriction of processing, data portability, and to object to processing based on legitimate interests.
To exercise any of these rights, write to geral@facingimpulse.pt. We reply within one month of receiving the request, as required by Article 12(3) of the GDPR. Bear in mind that server logs are kept for fourteen days and are not indexed by person: after that period there is nothing left to give you.
You also have the right to lodge a complaint with the supervisory authority, under Article 77 of the GDPR. In Portugal this is the Comissao Nacional de Protecao de Dados (CNPD), Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, www.cnpd.pt.
8. Security
The site is served only over HTTPS, with a redirect from plain HTTP, and declares a content security policy that restricts every resource to this domain. It loads no external scripts, no external fonts and no external images. Access to the server is limited to named accounts with key-based authentication.
9. Changes to this policy
If what we do with personal data changes, this page changes with it and the date at the top is updated. There is no mailing list to notify, precisely because we keep none.