Privacy and Data Protection Policy

1. Introduction

EDGEWISE, Lda, a private limited company duly registered in Portugal, provides accounting services, business consultancy, payroll processing, and other corporate support services. The protection of the privacy and personal data of our clients, employees, suppliers, website users, and all other data subjects is an absolute priority. This Privacy and Data Protection Policy describe, in a clear and transparent manner, the principles and practices adopted by EDGEWISE, Lda in the processing of personal data, in accordance with Regulation (EU) 2016/679 – General Data Protection Regulation (GDPR) and the applicable national legislation.

2. Data Controller

The data controller is:
EDGEWISE, Lda
Torre de Monsanto
Rua Afonso Praça, n.º 30 – 7º
1495-061 Algés (Oeiras)
Tax ID No. 516244949
Email: hello@edgewise.pt
Telephone: +351 210 963 562

3. Categories of Personal Data Processed

During its activity, EDGEWISE, Lda may collect and process the following categories of personal data:

  • Identification data: name, tax identification number, date of birth, address, ID card number, telephone numbers, and email addresses.
  • Professional and financial data: IBAN, salaries, mandatory deductions, accounting records, tax and social security information.
  • Authentication and access data: login details for official platforms (Tax Authority, Social Security, ACT, among others), when expressly mandated by the client.
  • Data provided through the website: Information submitted via contact forms (name, email, telephone, subject, message). Browsing data automatically collected through cookies.

4. Purposes of Processing

Personal data collected by EDGEWISE, Lda are processed exclusively for legitimate purposes, namely:

  • Provision of accounting, consultancy, and payroll services.
  • Compliance with legal and regulatory obligations, particularly in tax, accounting, labour, and social security matters.
  • Management of contractual relationships with clients, suppliers, and employees.
  • Responding to contact requests submitted via the website.
  • Improving the browsing experience on the website and carrying out statistical analysis of usage.
  • Exercising or defending rights in legal or administrative proceedings.

5. Lawful Basis for Processing

EDGEWISE, Lda processes personal data on the following lawful bases:

  • Performance of a contract or pre-contractual measures at the request of the data subject.
  • Compliance with legal obligations to which EDGEWISE, Lda is subject.
  • Legitimate interests pursued by EDGEWISE, Lda, provided that such interests are not overridden by the rights or interests of the data subject.
  • Consent of the data subject, where applicable (e.g. newsletter subscription, non-essential cookies).

6. Data Retention

Personal data will be retained only for the period strictly necessary for the purposes for which they were collected, including:

  • 10 years for accounting and tax data.
  • 5 years for payroll and social security data, unless longer periods are legally required.
  • Until the request is processed for data submitted through contact forms.
  • In accordance with the cookie policy for browsing data collected automatically.

7. Cookies

The EDGEWISE, Lda website uses cookies, which are small text files stored on the user’s device, to:

  • Ensure the correct functioning of the website;
  • Improve browsing experience and functionalities;
  • Analyze website usage statistics (analytical cookies);
  • Personalize content, where applicable.
  • Users may configure their browser settings to block or delete cookies at any time. However, doing so may affect some website functionalities.

8. Contact Forms

Personal data provided through contact forms on the website will be used exclusively to respond to the request submitted by the user.

  • Data will not be used for marketing purposes without prior and explicit consent.
  • After the request has been handled, the data may be retained only for the period necessary for its management or as evidence in the event of a dispute.

9. Data Sharing with Third Parties

EDGEWISE, Lda may disclose personal data to third parties in the following circumstances:

  • To comply with legal obligations (e.g. Tax Authority, Social Security, ACT).
  • To banks and insurance providers, when strictly necessary.
  • To subcontractors providing technical or administrative support services, who will always be bound by confidentiality and security obligations.
    Under no circumstances will personal data be sold or disclosed for commercial purposes.

10. Rights of Data Subjects

Under the applicable law, data subjects may exercise the following rights at any time:

  • Right of access to their personal data;
  • Right to rectify inaccurate or outdated data;
  • Right to erasure of data (“right to be forgotten”), where legally permissible;
  • Right to restriction of processing;
  • Right to object to processing;
  • Right to data portability, where applicable;
  • Right to withdraw consent, without affecting the lawfulness of processing carried out prior to withdrawal. Requests to exercise these rights must be submitted in writing to: hello@edgewise.pt

11. Security Measures

EDGEWISE, Lda adopts appropriate technical and organizational measures to ensure the confidentiality, integrity, and availability of personal data, including:

  • Restricted access control and secure authentication;
  • Encryption and system protection;
  • Regular backups and incident monitoring;
  • Ongoing training of staff on data protection;
  • Internal procedures for incident response.

12. Data Protection Officer

EDGEWISE, Lda is not legally required to appoint a Data Protection Officer (DPO) under the GDPR, as the processing of data does not take place on a large scale, nor does it involve systematic monitoring of special categories of data. Nevertheless, EDGEWISE, Lda has designated a dedicated internal contact point for all matters relating to data protection: Email: hello@edgewise.pt

13. Changes to this Policy

EDGEWISE, Lda reserves the right to amend this Privacy and Data Protection Policy at any time, ensuring its continuous alignment with applicable legal and regulatory requirements. The updated version will always be published on the EDGEWISE, Lda website and will take effect from the date of its publication.

14. Complaints

Without prejudice to the right to contact EDGEWISE, Lda to resolve any issues relating to the protection of personal data, data subjects also have the right to lodge a complaint with the Portuguese Data Protection Authority (CNPD): website www.cnpd.pt.

Lisbon, 25th september 2025