Privacy Policy

Introduction

Upgraide, Lda ("we", "our", or "us") is committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at upgraide.pt (the "Website").

Data Controller

The data controller responsible for your personal data is:

Legal Basis for Processing

We process your data under the following legal bases as defined by the GDPR:

• Consent (Art. 6(1)(a)) — Analytics cookies and tracking technologies are only activated after you provide explicit consent via our cookie consent banner. You may withdraw your consent at any time.
• Legitimate Interest (Art. 6(1)(f)) — Essential website functionality, security measures, and storing your consent preference are processed under our legitimate interest in operating a functional and secure website.

What Data We Collect

When you consent to analytics, we collect the following categories of data:

Analytics Events

• Page views and navigation paths
• Scroll depth on pages
• Click interactions (buttons, links, CTAs)
• Section views and time spent on sections
• Booking form interactions

Device Information

• Browser type and version
• Screen resolution
• Operating system

Network Data

• Approximate location (country/city level, derived from IP address)
• Referrer URL (the page that linked you to our Website)

Marketing Attribution

• UTM parameters (source, medium, campaign, term, content)

We do not collect personally identifiable information (PII) unless you voluntarily provide it, such as when submitting a contact or booking form.

Cookies and Tracking Technologies

Our Website uses cookies and local storage to provide analytics and remember your preferences. Below is a detailed overview of the technologies we use:

PostHog data is sent to eu.i.posthog.com and stored on EU-based servers (Frankfurt, Germany).

Data Retention

We retain collected data for the following periods:

• PostHog analytics data — Retained according to PostHog's EU data retention policy
• Google Analytics data — 14 months
• Consent preferences — Stored indefinitely in your browser's local storage until you clear it

International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA):

• PostHog — Data is processed and stored within the EU (Frankfurt, Germany). No transfer outside the EEA occurs.
• Google Analytics — Data may be transferred to the United States. This transfer is protected by Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring an adequate level of data protection.

Your Rights Under the GDPR

As a data subject, you have the following rights under the GDPR:

• Right of Access — You may request a copy of the personal data we hold about you.
• Right to Rectification — You may request correction of inaccurate or incomplete data.
• Right to Erasure — You may request deletion of your personal data ("right to be forgotten").
• Right to Restriction of Processing — You may request that we limit how we process your data.
• Right to Data Portability — You may request your data in a structured, machine-readable format.
• Right to Object — You may object to processing based on legitimate interest.
• Right to Withdraw Consent — You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing performed before withdrawal.

To exercise any of these rights, please contact us at privacy@upgraide.ai. We will respond to your request within 30 days.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local supervisory authority. In Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados (CNPD).

How to Manage Cookies

You can manage your cookie preferences in several ways:

• Manage Cookies button — Click the "Manage Cookies" link in our website footer to change your consent preferences at any time.
• Browser settings — You can configure your browser to block or delete cookies. Please refer to your browser's help documentation for instructions.

If you reject analytics cookies or withdraw consent, no analytics data will be collected. The website will continue to function normally without analytics tracking.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will indicate the date of the latest revision at the top of this page. We encourage you to review this policy periodically.

Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at privacy@upgraide.ai.