Privacy Policy

Last updated: August 28, 2026

1. Who we are

This Privacy Policy applies to the website holypassword.pt, operated by:

HOLYPASSWORD - UNIPESSOAL LDA
Tax ID (NIF): 519 046 862
Address: Praceta Ayrton Senna, 100, R/C C, 2750-103, Portugal
Contact: contact@holypassword.pt

HOLYPASSWORD - UNIPESSOAL LDA is the controller responsible for the personal data collected through this website, under the General Data Protection Regulation (GDPR).

2. What data we collect

We collect personal data in the following situations:

• Contact form: name, work email, company (optional), project type, and the content of the message you send us.
• Analytics (only with your consent): usage data — pages visited, visit duration, device type, and traffic source — via Google Analytics (Firebase Analytics).

3. Purposes and legal basis

• Responding to your enquiry: data submitted through the contact form is used solely to reply to you and assess your request. Legal basis: pre-contractual steps taken at your request (GDPR art. 6(1)(b)).
• Analytics: we use Google Analytics to understand how the site is used and to improve it. Legal basis: your consent (GDPR art. 6(1)(a)), given through the cookie banner. You can withdraw consent at any time (see section 4).

4. Cookies and Google Analytics

This site only loads analytics cookies after you accept the cookie banner shown on your first visit. You can change your choice at any time via the "Cookie Preferences" link in the site footer.

If you reject cookies, they are not loaded, and any existing analytics cookies are removed from your browser.

5. Data recipients

• Google Ireland Ltd. / Google LLC — provides Google Analytics (Firebase Analytics) and Google Fonts, used to load this site's typefaces (this means your device's IP address is sent to Google on every visit).
• Email provider (SMTP) — used only to relay contact-form messages to the company's email inbox.

We do not sell or share your personal data with third parties for marketing purposes.

6. International transfers

Some of the providers above (Google) may process data outside the European Economic Area, including in the US. Such transfers rely on the European Commission's Standard Contractual Clauses and/or the EU-U.S. Data Privacy Framework, as applicable under Google's own arrangements.

7. Retention periods

Messages received through the contact form are kept only for as long as necessary to respond to the request, and at most for the legal periods applicable to any subsequent contractual relationship. Analytics data is retained according to the retention period configured in our Google Analytics account.

8. Your rights

Under the GDPR, you have the right to:

• Access the personal data we hold about you;
• Request rectification of inaccurate or incomplete data;
• Request erasure of your data;
• Request restriction of processing;
• Object to processing;
• Request data portability;
• Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
• Lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD), Portugal's data protection authority — www.cnpd.pt.

To exercise any of these rights, contact us at contact@holypassword.pt.

9. Security

We adopt reasonable technical and organizational measures to protect your personal data against unauthorized access, loss, or alteration.

10. Changes to this policy

This policy may be updated from time to time. The date of the last update is shown at the top of this page.

11. Contact

For questions about this Privacy Policy or about the processing of your personal data, contact us at contact@holypassword.pt.