Privacy Policy
Version of . The Portuguese version is the reference text; this is a faithful translation.
This policy explains what personal data we process, why, for how long and what your rights are under the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and, for people in Brazil, the Lei Geral de Proteção de Dados (LGPD, Law 13.709/2018).
1. Data controller
Fábio Magalhães
Portugal
Email: [email protected]
2. What data we process
a) Email update list
When you sign up we store your email, the site language, the page where you signed up, the date and time, the version of the consent text you accepted and your approximate country (a two-letter code such as “BR”, derived automatically by Cloudflare). We do not store your IP address in this list.
b) Pre-sale purchases
Payment happens on Lemon Squeezy, which acts as reseller (merchant of record) and is responsible for payment data. We never receive your card details. Lemon Squeezy shares with us what we need to deliver the product and support you: name, email, country and order details.
c) Anonymous counts
We may count, per day, how many times someone starts or finishes the practice test and clicks the pre-sale button. These are aggregated numbers only, with no cookies and no personal identifier.
d) Technical logs
Like any website, our hosting provider (Cloudflare) processes technical connection data, such as IP addresses, to serve pages and protect the site from abuse.
e) Practice-test progress
Your practice-test progress is stored only in your browser (local storage) and is never sent to us. You can delete it by clearing this site's data in your browser.
3. Purposes and legal bases
| Purpose | Legal basis (GDPR / LGPD) |
|---|---|
| Sending updates about the test regulation and the product launch | Consent — Art. 6(1)(a) GDPR; Art. 7(I) LGPD. You can withdraw it at any time. |
| Delivering purchased products, support and refunds | Performance of a contract and legal obligations — Art. 6(1)(b) and (c) GDPR; Art. 7(II) and (V) LGPD. |
| Site security and anonymous aggregated statistics | Legitimate interests — Art. 6(1)(f) GDPR; Art. 7(IX) LGPD. |
4. Cookies
We do not use advertising, tracking or analytics cookies, which is why there is no cookie banner. The practice test's local storage only keeps your progress, at your request.
5. Who we share data with
- Cloudflare, Inc. — website hosting and storage of the email list (processor). Data may be stored or processed in the EU and the US.
- Lemon Squeezy — payment processing, as reseller and independent controller of payment data.
- Email delivery provider — before we send the first email we will update this policy with the provider's name.
International transfers: transfers outside the European Economic Area (e.g. to the US) are covered by the EU-US Data Privacy Framework and/or standard contractual clauses. For people in Brazil, international transfer (LGPD Art. 33) relies on the standard contractual clauses approved by Brazil’s data protection authority, ANPD (Resolution CD/ANPD No. 19/2024), or another basis in LGPD Art. 33.
We do not sell personal data and do not use it for advertising.
6. How long we keep data
- Update list: until you unsubscribe or withdraw consent; or 24 months after sign-up if we never send any email; or 24 months after the last email we send — whichever comes first.
- Confirmation: our first email will ask you to confirm your sign-up (double opt-in). Addresses not confirmed within 30 days will be deleted.
- Purchase data: for the period required by applicable tax and accounting law.
- Statistics: aggregated numbers, no personal data.
7. Your rights and how to unsubscribe
You can ask for access, rectification, erasure, restriction, portability and object to processing, and withdraw consent at any time (without affecting processing already done). Just email [email protected]. Every email we send will include an unsubscribe link.
Unsubscribe now: enter your email below and it will be deleted from the list.
If you believe your data is not being handled properly, you can complain to the CNPD (Portugal's data protection authority), to your local EU authority or, in Brazil, to the ANPD.
8. Children
This site is not intended for children under 16, and we do not ask for children's data.
9. Changes
If we change this policy, the new version will be published here with a new date. Significant changes will be emailed to subscribers.
See also the Terms & legal notice.