Subtle Mastery

Privacy Policy

We only process the data you send us, and only to reply to you.

1. Controller

Subtle Mastery, Lda., VAT PT519357914. Contact: hello@subtlemastery.com. We have not appointed a data protection officer, as it is not required for our activity.

2. What data we process

This site has no forms, uses no cookies and uses no analytics or advertising tools. Fonts are served by the site itself, with no requests to third parties.

We only process:

  • the data you send us by email: your name, email address and the content of your message;
  • technical access logs, such as IP address, browser and date, generated by the hosting service.
Purpose Legal basis (GDPR, Article 6(1))
Replying to you and preparing a proposal Steps taken at your request before a contract (point b) and our legitimate interest in replying (point f)
Protecting the site against abuse and attacks Legitimate interest in the security of the site (point f)
Meeting legal obligations, if we start a business relationship Legal obligation, for example tax (point c)

4. Who we share it with

We do not sell or pass on personal data. We use providers that process data on our behalf, bound by contract:

  • Google (Google Workspace), for email;
  • Cloudflare, for hosting the site and managing the domain.

5. Transfers outside the European Union

Google and Cloudflare may process data in the United States. Both are certified under the EU-US Data Privacy Framework, covered by the European Commission adequacy decision of 10 July 2023, and use standard contractual clauses. You can ask us for information about these safeguards.

6. How long we keep it

  • Contacts with no follow-up: up to 12 months after the last exchange.
  • Clients: for the duration of the business relationship and then for legal periods, such as the 10 years required for accounting records.
  • Technical logs: for the short period set by the hosting provider, for security only.

7. Your rights

You can request access, rectification, erasure, restriction of processing, portability, and object to processing based on legitimate interest, by writing to hello@subtlemastery.com. We reply within one month.

You can also lodge a complaint with the Portuguese data protection authority, CNPD (cnpd.pt).

8. Other information

  • Providing data is not mandatory. Without it, we simply cannot reply to you.
  • We do not make automated decisions or create profiles using your data.
  • Changes: if we change this policy, we publish the new version here, with its update date.

Last updated: 15 October 2026