Last update: September 2025.

This Policy describes how Fernando Lucena Unipessoal Lda., NIF 516230840, headquartered in Guilhadeses, 4970-786 Arcos de Valdevez (“True Brands,” “we”), processes personal data in accordance with Regulation (EU) 2016/679 (GDPR), Law No. 58/2019, and Law No. 41/2004.

1. Data Controller

Controller: Fernando Lucena Unipessoal Lda.

Tax ID: 516230840

Headquarters: Guilhadeses, 4970-786 Arcos de Valdevez

Contact email: info@truebrands.pt

Data Protection Officer (DPO): Fernando Ribeiro – fernando.ribeiro@truebrands.pt

2. What data we collect

Identification and contact details: name, email, telephone number, company, position.

Website usage: IP, logs, pages visited, cookie identifiers.

Contractual and billing data: only for customers (tax ID, address, payments).

Marketing preferences and consents: subscriptions, opt-ins.

Data is collected directly (forms, emails, meetings) and indirectly (cookies/analytics – see Cookie Policy).

3. Purposes and legal bases
We process data for:

Responding to requests and providing services (e.g., free audit, proposals).
Basis: performance of pre-contractual steps/contract (Article 6(1)(b) GDPR).

Marketing and communication (sending content, newsletters, campaigns).
Basis: consent (Art. 6(1)(a)) or legitimate interest.

Website management and security (cookies, monitoring, protection against abuse).
Basis: legitimate interest (Art. 6(1)(f)) + consent in the case of analytical/remarketing cookies.

Compliance with legal obligations (billing, tax).
Basis: legal obligation (Art. 6(1)(c)).

4. Retention periods

Leads/contacts: 24 months without interaction.

Customers/billing: 10 years (tax periods).

Other data: retained only for the period required by law or until consent is withdrawn.

5. Data sharing
Data may be shared with subcontractors providing services to True Brands, including:

Hosting: Wix (US/EU, with Standard Contractual Clauses).

CRM: HubSpot (international transfers with adequate safeguards).

Analytics and digital marketing: Google Analytics, Google Ads, Meta Ads.

Productivity/email: Microsoft 365.

These providers process data on our instructions and in accordance with the GDPR.
We may also share data with public authorities when required by law.

6. Data subject rights
Data subjects may, at any time:

Access their personal data;

Correct incorrect or outdated data;

Request erasure (“right to be forgotten”);

Restrict or object to processing, including marketing;

Request portability of the data provided;

Withdraw consent previously given.

To exercise these rights, contact: info@truebrands.pt or the DPO at fernando.ribeiro@truebrands.pt.
Data subjects also have the right to lodge a complaint with the Portuguese Data Protection Authority (CNPD): www.cnpd.pt.

7. Cookies and similar technologies
Our website uses cookies:

Essential: necessary for the functioning of the site (do not require consent).

Analytics: used to measure site usage (Google Analytics).

Marketing/remarketing: used for digital campaigns (Google Ads, Meta Ads).

The user can manage preferences via the cookie banner and browser. For more details, see our Cookie Policy.

8. Security
We implement technical and organizational measures to protect data against loss, alteration, unauthorized access or improper disclosure, including encryption in transit and restricted access controls.

9. Minors
Our services are not intended for minors. If we detect inadvertent collection of minors’ data, we will proceed with immediate deletion, unless valid consent has been obtained from holders of parental responsibility.

10. Changes to this policy
This Policy may be updated to reflect legal or operational changes. The most recent version will always be available at www.truebrands.pt.

11. Contacts

True Brands / Fernando Lucena Unipessoal Lda.

Email: info@truebrands.pt

DPO: Fernando Ribeiro – fernando.ribeiro@truebrands.pt

Headquarters: Guilhadeses, 4970-786 Arcos de Valdevez

Supervisory authority: CNPD – www.cnpd.pt

Cookie Policy

Last update: September 2025

This Policy explains how Fernando Lucena Unipessoal Lda. (“True Brands,” “we”) uses cookies and similar technologies on the website www.truebrands.pt.

1. What are cookies

Cookies are small text files stored on the user’s device when visiting a website. They serve to recognize the user, remember preferences, improve browsing experience, and collect information for statistics and marketing.

2. Types of cookies used

Strictly necessary cookies
Ensure the basic functioning of the site (e.g., navigation, forms).
They cannot be disabled in our systems.
Legal basis: legitimate interest.

Performance/analytics cookies
Allow measurement and improvement of site performance (e.g., Google Analytics).
Collect data in an aggregated and anonymous way (number of visits, most viewed pages).
Require user consent.

Marketing/remarketing cookies
Used by platforms such as Google Ads, Meta Ads and HubSpot to personalize advertising and measure campaign effectiveness.
Require user consent.

3. Third-party cookies

We may allow third parties (Google, Meta, HubSpot, Wix) to place cookies on the user’s device for:

Traffic and performance analysis (Google Analytics).
Remarketing and personalized advertising (Google Ads, Meta Ads).
Lead management and marketing automation (HubSpot).

These third parties are responsible for processing the data collected through their cookies. We recommend reading their respective privacy policies.

4. Cookie management

The user may:

Set preferences via the cookie banner on the site.
Change browser settings to block or delete cookies.

Attention: disabling cookies may affect browsing experience and some site features.

5. Retention

Session cookies: expire when the user closes the browser.
Persistent cookies: remain on the device until the defined period or until deleted by the user.

6. Example cookie table

Name – Provider – Purpose – Duration – Type

_ga – Google – Distinguish users (Analytics) – 2 years – Analytics

_gid – Google – Browsing statistics – 24 hours – Analytics

_gat – Google – Limit request rate – 1 minute – Analytics

hubspotutk – HubSpot – Contact/lead identification – 13 months – Marketing

IDE / ANID – Google – Personalized Ads – up to 2 years – Marketing

fr – Meta (Facebook) – Remarketing and tracking – 90 days – Marketing

XSRF-TOKEN, hs, svSession – Wix – Site security and functioning – Session / 2 years – Necessary

(The list may vary depending on the configuration active on Wix and integrations; it should be reviewed periodically.)

7. Changes
We may update this Policy to reflect legal or operational changes. The most recent version will always be available at www.truebrands.pt.

8. Contacts