Privacy Policy
Last updated: July 2026 · Version 1.0
This Privacy Policy describes how cdnCore, Lda. (“cdnCore”, “we”, “us”) collects and processes personal data through the website cdncore.eu. It is issued under Regulation (EU) 2016/679 (GDPR), Directive 2002/58/EC (ePrivacy), Portuguese Law 58/2019, and the Brazilian General Data Protection Law — Lei n.º 13.709/2018 (LGPD).
In short: we process the data you send us when you contact us by email, we keep short-lived server logs for security, and we use our own first-party, privacy-focused analytics that sets no advertising cookies and shares nothing with advertising networks.
1. Controller & contact
Data controller: cdnCore, Lda.
Address: CIEC — Centro de Inovação Empresarial da Covilhã, R. António Augusto de Aguiar 60, 6200-053 Covilhã, Portugal
Email: [email protected]
Phone: +351 275 959 168
Data protection contact: [email protected] (subject: “GDPR / LGPD request”). A formal Data Protection Officer (Encarregado) will be appointed and named here once our scale triggers the legal requirement.
2. Categories of personal data we process
We only process the categories listed below. We do not collect special-category data (Art. 9 GDPR / Art. 11 LGPD) on this website and we do not knowingly collect data from children under 16.
| What | When | Purpose | Legal basis | Retention |
|---|---|---|---|---|
| First and last name, email address, company (optional), phone (optional), the subject and the content of your message, plus your consent record (timestamp) | You submit the contact form with the consent box ticked, or email us directly | Reply to your enquiry; pre-contractual steps; keep a record of our correspondence | Your consent (Art. 6(1)(a) GDPR / Art. 7, I LGPD), recorded with a timestamp | 24 months after the last interaction, then deleted; earlier erasure on request |
| IP address, User-Agent, timestamp, requested URL, response status | Each HTTP request to the site | Network and information security, abuse detection, operational debugging | Legitimate interest (Art. 6(1)(f) GDPR — Recital 49; Art. 7, IX LGPD) | 30 days, then deleted or pseudonymised |
Browser localStorage entries (theme, cdncore-consent) | You change theme or dismiss the cookie notice | Remember your display preference and that you have seen the cookie notice | Strictly necessary (Art. 5(3) ePrivacy exemption — explicitly requested by user) | Until you clear your browser storage |
| Usage signals via our self-hosted AtlasEye analytics (page URL, referrer, approximate location, device / browser type, and a first-party analytics identifier) | Only after you opt in to analytics via the cookie banner | Measure traffic and understand which content is useful | Your prior consent (Art. 6(1)(a) GDPR / Art. 5(3) ePrivacy / Art. 7, I LGPD) | Until you withdraw consent or clear your browser storage; no cross-site or advertising profiling |
3. Cookies and analytics
By default this website sets only the strictly-necessary localStorage entries described above. Audience measurement is provided by AtlasEye, our own first-party analytics product self-hosted at app.atlaseye.eu. It is loaded only after you opt in through the cookie banner and is blocked until then; it sets no advertising cookies, builds no cross-site profiles, and shares no data with advertising networks. You can withdraw consent at any time. Full details are in the Cookie Policy.
4. Recipients and sub-processors
Your personal data may be shared, under contractual safeguards, with:
- Hosting and infrastructure providers in the European Union that run the servers delivering this website.
- Email providers that relay and store the correspondence you send us.
- Professional advisers (lawyers, accountants) where strictly necessary to defend a legal claim or comply with a legal obligation.
- Competent public authorities when legally compelled.
We do not sell or rent your personal data, and we do not use it for advertising or to train AI models. An up-to-date list of sub-processors is available on request via [email protected].
5. International transfers
Personal data collected through this website is stored on servers located in the European Union. If any sub-processor is ever located outside the European Economic Area, transfers will rely on a safeguard permitted by Chapter V GDPR — typically the Standard Contractual Clauses (Commission Decision (EU) 2021/914) with appropriate technical and organisational measures. For LGPD purposes, transfers rely on the mechanisms set out in Articles 33–35 LGPD.
6. Your rights as a data subject
Under GDPR (Articles 15–22) and LGPD (Article 18) you can, free of charge:
- Access — obtain confirmation that we process your data and a copy of it.
- Rectification — correct inaccurate or incomplete data.
- Erasure — have your data deleted, subject to legal retention obligations.
- Restriction — limit how we use your data in specific situations.
- Portability — receive your data in a structured, machine-readable format.
- Objection — object to processing based on legitimate interest.
- Withdraw consent at any time, without affecting prior lawful processing.
- Not be subject to solely automated decisions with legal or similarly significant effects (GDPR Art. 22; LGPD Art. 20). This website performs no such decision-making.
To exercise any right, email [email protected] with the subject “GDPR / LGPD request”. We answer within 30 days (extendable by a further 60 days where strictly necessary, with notice). You may also lodge a complaint with a supervisory authority — details are in the Legal Notice.
7. Security
We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access (Art. 32 GDPR / Art. 46 LGPD): encryption in transit (TLS), least-privilege access, audit logging, periodic backups, and incident response procedures. Where a personal data breach is likely to result in a risk to your rights, we notify the competent supervisory authority within 72 hours and, where required, inform you directly.
8. Children
This site is not directed to children under 16 and we do not knowingly collect their data. If you believe we may have done so, contact [email protected] and we will delete it.
9. Changes to this policy
We update this policy when our processing changes. Material changes are announced on the website. The version and last-updated date at the top always reflect the current version.
10. Contact
For any privacy-related question or to exercise your rights:
Email: [email protected] (subject: “GDPR / LGPD request”)
Postal: cdnCore, Lda., CIEC — Centro de Inovação Empresarial da Covilhã, R. António Augusto de Aguiar 60, 6200-053 Covilhã, Portugal