Privacy Policy
Last updated: 17 August 2026
1. Who is responsible for your data
The controller of the personal data described in this policy is Arroba Harmoniosa, with its registered office at Rua Ana de Castro Osório, no 5, NO-/CA, Lisboa, Portugal, represented by Aleksandrs Zukovs.
Registration number: Not yet available — please request it by email. VAT number:
Not yet available — please request it by email.
You can reach us about anything in this policy at harmonioarrobalda@inbox.eu.
If you need to know whether a Data Protection Officer has been appointed under Article 37 GDPR, and how to contact one, please ask us by email and we will tell you.
2. What this website collects
This website is a static site. It contains no contact form, no login, no analytics, no advertising technology, no social media plug-ins and no embedded third-party content. It loads no fonts, scripts, images or other resources from any external server.
In practical terms, this means that simply reading this website does not cause us to collect any personal data about you, and does not disclose your IP address to any third party for our purposes.
Server logs
The site is hosted on Cloudflare Pages. Like any web host, Cloudflare processes technical connection data — including your IP address, the time of the request, the page requested, and your browser's user agent string — in order to deliver the page to you and to protect the service against attack and abuse. This processing is carried out by Cloudflare as our processor, under Article 28 GDPR.
Legal basis: our legitimate interest in operating and securing the website (Article 6(1)(f) GDPR).
Cloudflare's own privacy documentation is available at cloudflare.com/privacypolicy.
Local storage
If you make a choice in the cookie notice, that choice is recorded in your browser's local
storage under the key ah-consent. It stays on your device, is never transmitted to
us, and can be cleared at any time through your browser settings. See the
Cookie Policy for detail.
3. If you email us
When you write to us, we receive whatever you put in your message: your email address, your name if you give it, and the content of the enquiry itself.
| Purpose | Legal basis | Retention |
|---|---|---|
| Answering your enquiry and discussing possible work | Steps prior to entering a contract, Article 6(1)(b) GDPR | For as long as the enquiry is live, and no longer than is necessary for it. Ask us by email for the current period. |
| Performing a contract once one exists | Contract, Article 6(1)(b) GDPR | For the duration of the contract |
| Meeting statutory accounting and tax obligations | Legal obligation, Article 6(1)(c) GDPR | As required by Portuguese law |
Our email is handled by the provider of the inbox.eu service, who processes it on
our behalf in order to deliver and store messages.
4. Who we share data with
We do not sell personal data and we do not share it for advertising. We disclose it only to:
- service providers who process it on our instructions, such as our hosting and email providers;
- professional advisers, where necessary and under a duty of confidentiality;
- public authorities, where we are legally required to do so.
5. Transfers outside the EEA
Our hosting provider operates a global network, so serving this website may involve processing in countries outside the European Economic Area. Where that happens, transfers are covered by the European Commission's Standard Contractual Clauses together with supplementary technical measures, as described in the provider's own documentation.
6. Your rights
Under the GDPR you have the right to:
- obtain confirmation of whether we process your data, and a copy of it (Article 15);
- have inaccurate data corrected (Article 16);
- have data erased where the conditions are met (Article 17);
- have processing restricted in certain circumstances (Article 18);
- receive your data in a portable format (Article 20);
- object to processing carried out on the basis of legitimate interest, on grounds relating to your particular situation (Article 21);
- withdraw consent at any time, where processing is based on consent (Article 7(3)).
Write to harmonioarrobalda@inbox.eu to exercise any of these. We will respond within one month, as required by Article 12(3) GDPR.
7. Complaints
If you believe we have handled your data unlawfully, you may lodge a complaint with the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD), cnpd.pt, or with the supervisory authority of the EU country where you live or work.
8. Security
The site is served exclusively over HTTPS. We apply access controls and confidentiality obligations to the accounts and systems that hold client correspondence. No system is immune to compromise, and we make no claim otherwise.
9. Changes
If this policy changes, the revised version will be published on this page with a new "last updated" date. Material changes affecting people we already correspond with will be communicated directly.