Privacy Policy
Last updated: 16 July 2026
1. Who is the data controller
The controller responsible for processing your personal data is:
- Rúben Gonçalves, trading as PrimeRSG
- VAT number: 256189544
- Address: Avenida de S. Paulo, 43, 2565-001 Cabeça Gorda, Portugal
- Email: ruben@primersg.co
2. What data we collect and why
This site has no forms of its own. Personal data is only collected in the situations below.
| Situation | Data | Purpose | Legal basis (GDPR) |
|---|---|---|---|
| Booking a call (via Cal.com) | Name, email, time zone, answers to the booking form questions and any notes you provide | To schedule, prepare and hold the meeting with you | Art. 6(1)(b) — pre-contractual steps taken at your request |
| Contacting us by email or Instagram | Name, email or username, and the content of your message | To reply to you | Art. 6(1)(b) and (f) — legitimate interest in responding |
| Language preference | Your choice (PT or EN), stored only in your browser | So we don't ask you for your language again in the same session | Strictly necessary — no consent required |
3. Cookies and similar technologies
This site uses no advertising, analytics or tracking cookies. There is no Google Analytics, no Meta Pixel and no equivalent tool.
The only information stored on your device is your language choice, kept in your browser's
sessionStorage. It is deleted as soon as you close the tab and cannot identify you.
Because it is strictly necessary for the service you requested, no consent is required.
Fonts are loaded from Google Fonts (Google LLC) via its content delivery network. When a page loads, your browser requests the font files from Google, which may receive your IP address for that purpose. No cookies are set by this and no font data is used to identify you.
4. Third-party services
The booking calendar is provided by Cal.com, Inc. The Cal.com script only loads after you click a booking button. Until then, none of your data (including your IP address) is sent to Cal.com.
If you go ahead with a booking, Cal.com processes your data as our processor. Cal.com may transfer data outside the European Economic Area under the Standard Contractual Clauses approved by the European Commission. See Cal.com's privacy policy at cal.com/privacy.
The site also links to Instagram. If you follow that link, Meta's privacy policy applies. We do not share any data with Meta from this site.
The site is hosted on Netlify, which logs technical access data (such as your IP address) for security and server operation purposes, based on our legitimate interest (Art. 6(1)(f)).
5. How long we keep your data
- Booking and enquiry data: up to 2 years after our last contact, if we don't go on to work together.
- Client data: for the applicable legal period, including tax and accounting obligations (10 years under Portuguese law).
- Language preference: deleted when you close the tab.
6. Who we share your data with
Your data is never sold or passed to third parties for marketing. It is only accessed by:
- Cal.com — meeting scheduling
- Netlify — website hosting
- Google Workspace — email communication
- Our accountant and the tax authorities, where required by law
7. Your rights
Under the GDPR, you have the right to:
- Access the data we hold about you
- Correct inaccurate or incomplete data
- Request erasure of your data
- Restrict or object to processing
- Request data portability
- Withdraw consent, where processing is based on it
To exercise any of these rights, email ruben@primersg.co. We reply within one month at the latest.
If you believe your data is not being handled properly, you can lodge a complaint with the Portuguese data protection authority, Comissão Nacional de Proteção de Dados (CNPD) — www.cnpd.pt — or with the supervisory authority in your own country.
8. Security
The site is served exclusively over an encrypted connection (HTTPS). Access to the accounts where data is processed is protected by two-factor authentication.
9. Changes to this policy
This policy may be updated whenever our services or legal obligations change. The date of the last update is shown at the top of this page.