Privacy Policy

Last updated: August 2026

We operate in sensitive situations; we treat your data with the same discretion we apply to yours. This policy states, plainly, what we collect, why, and for how long.

Data controller

Shadowstep, Lda · Company no. (NIPC) 514507470 · Lisbon, Portugal. For any personal-data matter: [email protected].

Data we collect

Contact form: name, preferred contact channel and the corresponding contact detail — email or phone number, per your choice —, type of situation and preferred language. Only what you voluntarily submit in order to be contacted.

Briefing subscription: email address and preferred language.

Audience measurement: this site uses no cookies and no persistent identifiers. We record usage events (page, section, language, viewport size, referring domain) tied to an ephemeral random identifier that expires when the tab closes and cannot be linked to your identity. IP addresses are not stored.

Purposes and legal basis

Contact requests: responding to your request and preparing the engagement you ask of us (GDPR art. 6(1)(b) — pre-contractual steps at the data subject’s request).

Briefings: delivery of the executive briefings you subscribed to (art. 6(1)(a) — you may unsubscribe at any time by email).

Cookie-less audience measurement: legitimate interest in understanding, in aggregate and anonymously, how the site is used (art. 6(1)(f)).

Retention

Contact requests are automatically deleted 24 months after submission. If a request leads to an engagement, the data of that engagement is handled within its own scope; the form record is still deleted within the same period.

Briefing subscriptions are kept until cancelled by the subscriber (an email to [email protected] suffices).

Audience-measurement events are automatically deleted after 12 months.

Recipients

Data is neither sold nor shared with third parties for their own purposes. It is processed only by Shadowstep and by the hosting and email-delivery providers strictly necessary to operate the site, bound by data-protection obligations.

Your rights

You may at any time request access, rectification, erasure, restriction or portability of your data, or object to its processing, by writing to [email protected]. We reply within the statutory deadline. You also have the right to lodge a complaint with the Portuguese supervisory authority, CNPD (cnpd.pt).

Shadowstep, Lda · NIPC 514507470 · Lisbon · Portugal · [email protected]