Privacy Policy
Last updated: May 12, 2026
1. Data Controller Identification
This website (thesharpway.studio) is jointly operated by: Andrea Valentina De Abreu Arias, resident in Portugal, acting as primary data controller under Portuguese law (GDPR). Gabriel Gonzalez Montañez, resident in Colombia, acting as co-controller under Colombian law (Law 1581 of 2012). Controller contact: [email protected]
2. Data Collected and Purposes
We collect the following personal data: - Contact form: name, email address, and message. Purpose: managing discovery requests and pre-contractual communication. - Anonymous analytics via Plausible Analytics: aggregated visit metrics with no cookies and no individual IP identification. Purpose: website improvement.
3. Legal Basis for Processing
- Consent (Art. 6.1.a GDPR): contact form when voluntarily submitting data. - Contract execution (Art. 6.1.b GDPR): managing pre-contractual requests. - Legitimate interest (Art. 6.1.f GDPR): aggregated anonymous analytics (no impact on individual rights).
4. Data Retention
Contact form data is retained for 5 years from the last communication, in compliance with applicable fiscal and accounting obligations in Portugal and Colombia. Analytics data is aggregated and anonymous; no individual data is retained.
5. Your Rights
You may exercise the following rights by contacting [email protected]: - Access: know what personal data we process. - Rectification: correct inaccurate data. - Erasure: request deletion of your data. - Objection: object to processing on legitimate grounds. - Portability: receive your data in a structured format. - Restriction: request limitation of processing. We will respond within 30 days.
6. International Transfers
We use Plausible Analytics (EU-hosted server) - no transfers outside the EEA for analytics. The dual Colombia/Portugal processing is based on the European Commission Standard Contractual Clauses (Decision 2021/914) as the legal basis for international transfers.
7. Cookies
This site does NOT use tracking cookies or third-party cookies. Plausible Analytics operates cookieless - no cookies are installed on your device.
8. Image Disclosure
Partner images are real portraits with digital retouching. Original unretouched files are retained for verification. Complies with EU AI Act Art. 50 (effective August 2, 2026).
9. Changes to This Policy
We will notify material changes to this policy with at least 30 days' notice by email or website announcement.
10. Jurisdiction and Supervisory Authority
- Portugal (Andrea De Abreu Arias): CNPD - Comissão Nacional de Proteção de Dados (www.cnpd.pt). - Colombia (Gabriel Gonzalez Montañez): SIC - Superintendencia de Industria y Comercio (www.sic.gov.co).