Privacy Policy

1. Data Controller

The Data Controller responsible for the personal data collected through this site, the contacts made via the page and the services related to the Personal Financial Strategy Plan programme is Axelleworth Associates, NIPC 510977561, with its registered office at Brigantia Ecopark - Av Cidade de Leon 506, 5300-358 Bragança.

The Personal Financial Strategy Plan programme is developed and delivered by Luís Lourenço, within the scope of Axelleworth Associates' activity.

For any question related to this policy or to the processing of your data, please contact us at ask@ymwhub.net.

2. Scope of this policy

This Privacy Policy applies to the personal data processed in the context of the use of this landing page, contact requests, the scheduling of conversations, messages sent via WhatsApp or email and, where applicable, the suitability assessment, contracting and participation in the Personal Financial Strategy Plan programme.

This page does not include its own checkout, a diagnostic form, a reserved user area or account creation. Contacts are made through the channels provided on the page, namely online scheduling, WhatsApp and email.

The use of cookies and similar technologies is governed by the Cookie Policy.

3. Personal data collected

The personal data processed is that which you voluntarily provide when you interact with Axelleworth Associates or with Luís Lourenço through the channels available on the site.

It may include, as the case may be:

• name;
• email address;
• telephone number;
• data shared when scheduling a conversation;
• content of messages sent by email or WhatsApp;
• information you choose to share about your financial situation, objectives, doubts, priorities, family, professional or asset context;
• data necessary for any contracting, invoicing and delivery of the programme, should you become a client.

During the initial conversation or throughout the programme, you may choose to share more detailed financial or personal information. That information will be used only to assess the suitability of the programme, prepare the work, deliver the service and build your personal financial strategy.

In the initial contact, you should avoid sending excessive information or especially sensitive data that is not necessary for the specific purpose at hand.

4. Purposes of processing

Your personal data is processed for the following purposes:

• responding to your contact and clarifying questions about the programme;
• scheduling, preparing and holding initial conversations;
• assessing the suitability of the programme for your case before any admission;
• communicating with you by email, telephone or WhatsApp in connection with your request;
• preparing, delivering and following up on the programme, should you choose to contract the service;
• organising sessions, preparation documents, consolidations, asynchronous follow-up and other elements necessary for the provision of the service;
• complying with applicable legal, tax, accounting or administrative obligations;
• handling requests related to data subjects' rights;
• maintaining records necessary as evidence of contacts, contracting, consents, legal obligations or defence of rights.

The data is not used for sale to third parties, marketing by third parties or sending communications unrelated to the contact made or the service requested, unless there is a legal basis or specific consent for that purpose.

5. Legal basis

The processing of your data may rely, depending on the specific purpose, on one or more of the following legal bases:

• Consent, when you decide to make contact voluntarily through the indicated channels, send a message or share information;
• Pre-contractual steps, when you request information, schedule a conversation or ask for a suitability assessment before any potential contracting;
• Performance of a contract, should you choose to contract the programme;
• Compliance with legal obligations, namely tax, accounting or administrative;
• Legitimate interest, when it is necessary to retain proportionate records for contact management, internal organisation, security, service improvement, evidence of interactions or defence of rights, without prejudice to your rights and freedoms.

Consent may be withdrawn at any time, without affecting the lawfulness of the processing carried out beforehand.

6. Retention period

Data is retained only for the period necessary to fulfil the purposes for which it was collected.

In general terms:

• data from contact requests or messages without commercial continuity may be deleted or anonymised when no longer necessary;
• data related to assessment conversations may be retained for the period necessary for contact management, reasonable follow-up and evidence of the request;
• client, contracting and invoicing data will be retained for the legally applicable periods;
• information worked on within the scope of the programme will be retained only for as long as necessary for delivery, follow-up, compliance with legal obligations or defence of rights.

Whenever there is no legitimate basis for retention, the data will be deleted or anonymised.

7. Third-party channels and services

Some contacts and features may be carried out through third-party services, namely:

• online scheduling / Google Calendar or equivalent booking service;
• WhatsApp;
• email;
• hosting, technical site management, security, technical analysis or tooling services necessary for the operation of the page.

When you use these channels, the data may also be processed by those providers, in accordance with their respective privacy policies, terms and settings.

The use of these channels results from your choice when clicking on the respective buttons or links. You are advised to consult the privacy policies of those services whenever you wish to understand how they process your data.

8. Internal access, confidentiality and security

Access to personal data will be limited to the people who need that information to ensure contact, organisation, preparation, delivery and follow-up of the programme.

Those people act under the responsibility of Axelleworth Associates, solely for the purposes set out in this policy and subject to duties of confidentiality and discretion.

Appropriate measures are taken to protect personal data against unauthorised access, loss, alteration, disclosure or misuse.

Information shared in the context of the assessment, contracting or delivery of the programme will be treated with discretion and only for the purposes related to the contact, suitability, contracting or provision of the service.

No communication system is absolutely secure. For that reason, in the initial contact you should avoid sharing excessive information, especially financial, family or personal information that is not yet necessary for the purpose at hand.

9. Data sharing

Your data is not sold, transferred or used for marketing by third parties.

Internal access to the data will be limited to Luís Lourenço and to people authorised by Axelleworth Associates who support the organisation, preparation, delivery and follow-up of the programme.

The data may also be processed or shared, only to the extent necessary, with:

• technical providers essential to the operation of the site, email, scheduling, communication or storage;
• providers of administrative, accounting, tax, legal or technological services;
• banking or payment entities, where applicable;
• public, judicial, tax or regulatory authorities, where there is a legal obligation;
• other providers necessary for the delivery of the service, where applicable and only to the extent necessary.

Whenever providers that process personal data on behalf of Axelleworth Associates are used, efforts will be made to ensure that those providers offer adequate data protection guarantees.

10. International transfers

Some of the technological services used, such as scheduling tools, email, messaging, hosting or other digital services, may involve the processing of data outside the European Economic Area.

Where this occurs, efforts will be made to use providers that adopt adequate data protection mechanisms, under the applicable terms of the General Data Protection Regulation.

11. Your rights

As a data subject, you have the right to:

• access the personal data concerning you;
• request the rectification of incorrect or incomplete data;
• request the erasure of your data, under the legally applicable terms;
• request the restriction of processing;
• object to the processing, where applicable;
• withdraw consent at any time, where the processing is based on that consent;
• request data portability, where applicable;
• lodge a complaint with the competent supervisory authority.

To exercise these rights, please contact us at ask@ymwhub.net.

In Portugal, the competent supervisory authority is the Portuguese Data Protection Authority — Comissão Nacional de Proteção de Dados (CNPD).

12. Updates to this policy

This Privacy Policy may be updated whenever necessary, namely due to legal, technical, operational or site-functioning changes.

The date of the last update will be indicated at the beginning of the document.

13. Contacts

For any question related to this policy or to the processing of your data, please contact us at ask@ymwhub.net.