Privacy Policy

1. Who We Are

TrueDatarium operates from R. Actor António Silva, 1600-404 Lisboa, Portugal. We provide bookkeeping organisation and financial record preparation services to freelancers, sole traders and micro-businesses in Portugal. You can contact us at [email protected] or +351 217 824 700.

TrueDatarium is the data controller for personal data collected through this website and in the course of providing our services.

2. Legal Basis

This Privacy Policy is prepared in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR"), Law No. 58/2019 of 8 August (which implements the GDPR in Portugal), and any applicable guidelines from the Comissão Nacional de Proteção de Dados (CNPD), Portugal's national data protection authority.

3. What Personal Data We Collect

We collect personal data in the following contexts:

3.1 Website Enquiries

When you submit our contact form, we collect your name, email address, telephone number and the content of your message. The legal basis for this processing is your consent (Article 6(1)(a) GDPR) and our legitimate interest in responding to business enquiries (Article 6(1)(f) GDPR).

3.2 Service Delivery

When you engage TrueDatarium as a client, we process financial documents and records you provide to us. These may include receipts, bank statements, invoices and related business documents. The legal basis is performance of a contract (Article 6(1)(b) GDPR). Financial documents may contain personal data about third parties (suppliers, customers); we process this data only to the extent necessary to perform our organisational services.

3.3 Website Cookies

We use cookies on this website. Please see our Cookie Policy for full details. The legal basis for non-essential cookies is your consent (Article 6(1)(a) GDPR).

4. How We Use Your Data

We use personal data collected through this website to:

• Respond to your enquiries about our services
• Assess whether our services are suitable for your needs
• Communicate with you about your enquiry or engagement
• Improve our website and services based on usage patterns (where analytics cookies are accepted)

We use personal data collected in the course of service delivery to:

• Organise, categorise and reconcile your financial records
• Prepare monthly files for delivery to your contabilista
• Communicate with you about your records and any queries arising
• Comply with our legal obligations

We do not use your personal data for marketing purposes without your explicit consent. We do not sell, rent or share your personal data with third parties for their own marketing purposes.

5. Data Sharing

We share your personal data only in the following circumstances:

• Your contabilista: With your instruction and as part of our service, we deliver organised financial files to your designated contabilista certificado.
• Service providers: We use trusted third-party services for cloud file storage and email. These providers process data on our behalf under data processing agreements and are required to maintain appropriate security measures.
• Legal obligation: We may disclose data if required to do so by law or by a competent authority, including Portuguese courts or the Autoridade Tributária.

We do not transfer personal data outside the European Economic Area (EEA) unless appropriate safeguards are in place under Chapter V of the GDPR.

6. Data Retention

We retain personal data for the following periods:

• Enquiry data (non-clients): Up to 12 months from the date of enquiry, unless you become a client.
• Client financial records: For the duration of our engagement plus a minimum of 10 years, in accordance with Portuguese commercial and tax record-keeping obligations.
• Cookie and analytics data: As specified in our Cookie Policy.

After the applicable retention period, personal data is securely deleted or anonymised.

7. Your Rights Under GDPR

Under the GDPR and Portuguese law, you have the following rights regarding your personal data:

• Right of access (Article 15): You may request a copy of the personal data we hold about you.
• Right to rectification (Article 16): You may request correction of inaccurate or incomplete data.
• Right to erasure (Article 17): You may request deletion of your data, subject to legal retention obligations.
• Right to restriction of processing (Article 18): You may request that we limit how we use your data in certain circumstances.
• Right to data portability (Article 20): You may request your data in a structured, machine-readable format.
• Right to object (Article 21): You may object to processing based on legitimate interests.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the CNPD (Comissão Nacional de Proteção de Dados) at www.cnpd.pt.

8. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or alteration. Financial documents are stored in encrypted cloud storage with access controls. Physical documents received by post are kept in a secure environment and handled only by authorised personnel.

9. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this page reflects the most recent revision. Significant changes will be communicated to existing clients directly.

10. Contact

For any questions about this Privacy Policy or how we handle your data, contact us at: