GDPR Statement
Last updated: October 4, 2026
1. Data Controller
Centelha D'Êxito Unipessoal Lda, a company registered in Portugal, registered address: Caminho das Searas 50, Vilamoura, 8125-417, Portugal ("the Controller").
Contact for all data protection matters: hello@keelycapel.com.
2. Categories of Personal Data Processed
| Category | Examples |
|---|---|
| Identity data | Name |
| Contact data | Email address |
| Transaction data | Payment and booking details (processed by Stripe/Calendly, not stored directly by us) |
| Usage data | Website analytics via Google Analytics (cookies, IP address, browsing behaviour) |
3. Legal Basis for Processing
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Email capture / early access signup | Consent |
| Consulting booking and payment | Performance of a contract |
| Website analytics | Consent (via cookie banner) |
| Legal/accounting compliance | Legal obligation |
4. Data Retention
Personal data is retained only for as long as necessary for the purpose it was collected for, or as required under Portuguese and EU law (including accounting record retention requirements). Email list data is retained until you unsubscribe or request deletion.
5. International Data Transfers
Google Analytics may transfer data outside the European Economic Area (EEA), including to the United States. Where this occurs, it is conducted under legally recognised safeguards, including the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses, as applicable.
6. Data Subject Rights
Under the GDPR, you have the right to:
- Access the personal data we hold about you
- Rectify inaccurate or incomplete data
- Erasure ("right to be forgotten"), subject to legal retention requirements
- Restrict processing in certain circumstances
- Object to processing based on legitimate interests or for direct marketing
- Data portability — receive your data in a structured, commonly used format
- Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal
To exercise any of these rights, contact hello@keelycapel.com. We will respond within one month, as required under GDPR Article 12.
7. Supervisory Authority
If you believe your data protection rights have been infringed, you have the right to lodge a complaint with:
Comissão Nacional de Proteção de Dados (CNPD)
Portugal's national data protection authority
www.cnpd.pt
8. Data Processors
This site uses the following third-party processors, each operating under their own privacy policies and, where applicable, GDPR-compliant Data Processing Agreements: Stripe (payments), Calendly (scheduling), Sender (email), Google Analytics (analytics), Vercel (hosting).
9. Related Policies
See also our Privacy Policy and Terms & Cookie Notice for further detail on how this site is used.