Privacy Policy

1. Who is responsible for your data

This website is operated by True North — Business Decision Architecture, under the responsibility of Manuel Pinheiro.

Legal entity: [NIF / Company registration — to be completed]
Address: [Address — to be completed]
Contact: manuel@truenorthbda.com

2. What data we collect and why

We collect personal data only when you voluntarily provide it — for example, when you fill out the contact form or send an email.

• Contact data (name, email, message) — to respond to your enquiry and assess whether there is a fit for collaboration.
• Navigation data — if analytics tools are active, we may collect anonymised data about how you use the site (pages visited, time spent, device type). This data does not identify you individually.

We do not collect sensitive data and we do not use your data for automated profiling or decisions.

3. Legal basis for processing

• Legitimate interest — to respond to contact requests and manage potential client relationships.
• Consent — for analytics cookies, where applicable, collected via the cookie banner.

4. How long we keep your data

Contact data is retained for as long as necessary to manage the communication or potential collaboration — generally no longer than 2 years after the last interaction, unless there is an ongoing contractual relationship.

Analytics data, where collected, is aggregated and anonymised and does not allow individual identification.

5. Who we share your data with

We do not sell or share your personal data with third parties for commercial purposes. We may use the following service providers, who process data on our behalf under appropriate data protection agreements:

• Typeform — contact form processing (if active). Typeform GDPR information.
• Google Analytics — anonymised site usage analytics (if active). Google Privacy Policy.
• Netlify — website hosting. Netlify Privacy Policy.

All providers are based in the EU or operate under standard contractual clauses in accordance with GDPR.

6. Your rights

Under the GDPR, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request erasure of your data
• Object to or restrict processing
• Request data portability
• Withdraw consent at any time (where processing is based on consent)

To exercise any of these rights, contact us at manuel@truenorthbda.com. We will respond within 30 days.

You also have the right to lodge a complaint with the Portuguese data protection authority: CNPD — Comissão Nacional de Proteção de Dados.

7. Cookies

This website may use cookies. For full details on what cookies are used and how to manage them, see our Cookie Policy.

8. Changes to this policy

We may update this policy from time to time. The date at the top of this page will always reflect the most recent version. We encourage you to review it periodically.