1. Introduction
Friary WBWR ("we," "our," or "us") operates Pugdko (pugdko.world), an editorial platform focused on marketing analysis and professional education. This Privacy Policy explains how we collect, use, disclose, and protect your personal information in accordance with the General Data Protection Regulation (GDPR) and Portuguese data protection laws.
2. Data Controller
Friary WBWR
Avenida da Liberdade 245
1250-096 Lisbon, Portugal
Email: [email protected]
Phone: +351 21 555 2740
3. Information We Collect
3.1 Information You Provide
- Contact Forms: Name, email address, inquiry subject, and message content
- Newsletter Subscription: Email address
- Correspondence: Information you provide when contacting us via email
3.2 Automatically Collected Information
- Usage Data: Pages visited, time spent, referral sources
- Device Information: Browser type, operating system, IP address
- Cookies: See our Cookie Policy for details
4. How We Use Your Information
We process your personal data for the following purposes:
- Responding to Inquiries: To address your questions and provide customer service
- Newsletter Delivery: To send editorial updates and marketing insights (with your consent)
- Website Improvement: To analyze usage patterns and enhance user experience
- Legal Compliance: To comply with applicable laws and regulations
- Security: To protect against fraudulent or unauthorized activity
5. Legal Basis for Processing
We process your personal data based on:
- Consent: For newsletter subscriptions and optional communications
- Legitimate Interests: For website analytics, security, and service improvement
- Contractual Necessity: To respond to your inquiries and provide requested services
- Legal Obligation: To comply with applicable laws
6. Data Sharing and Disclosure
We do not sell your personal information. We may share data with:
- Service Providers: Third-party vendors assisting with email delivery, analytics, and hosting
- Legal Requirements: When required by law, court order, or governmental authority
- Business Transfers: In connection with merger, acquisition, or asset sale
7. International Data Transfers
Your data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure adequate protection through:
- EU Commission approved Standard Contractual Clauses
- Data Processing Agreements with service providers
- Adequacy decisions by the European Commission
8. Data Retention
We retain personal data only as long as necessary:
- Contact Form Inquiries: 2 years from last contact
- Newsletter Subscriptions: Until you unsubscribe
- Analytics Data: 26 months (anonymized after 14 months)
- Legal Compliance: As required by applicable law
9. Your Rights Under GDPR
You have the following rights regarding your personal data:
- Access: Request copies of your personal data
- Rectification: Request correction of inaccurate data
- Erasure: Request deletion of your data ("right to be forgotten")
- Restriction: Request limitation of processing
- Data Portability: Receive your data in structured, machine-readable format
- Object: Object to processing based on legitimate interests
- Withdraw Consent: Withdraw previously given consent at any time
To exercise your rights, contact us at [email protected]. We will respond within 30 days.
10. Security Measures
We implement appropriate technical and organizational security measures:
- SSL/TLS encryption for data transmission
- Access controls and authentication
- Regular security assessments
- Employee training on data protection
- Incident response procedures
11. Cookies and Tracking
We use cookies and similar technologies. For detailed information, please review our Cookie Policy.
12. Children's Privacy
Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.
13. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated through:
- Prominent notice on our website
- Email notification to newsletter subscribers
- Updated "Last modified" date at the top of this policy
14. Supervisory Authority
You have the right to lodge a complaint with the Portuguese Data Protection Authority (CNPD):
Comissão Nacional de Proteção de Dados (CNPD)
Avenida D. Carlos I, 134, 1.º
1200-651 Lisbon, Portugal
Website: www.cnpd.pt
15. Contact Us
For privacy-related questions or to exercise your rights:
Privacy Team
Email: [email protected]
Address: Avenida da Liberdade 245, 1250-096 Lisbon, Portugal
Phone: +351 21 555 2740