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Privacy Policy

Last updated: 6 October 2026

1. Who we are (Data controller)

TMI Agency is a brand operated by Miguel Pudivitr, sole trader (empresário em nome individual), Portuguese tax ID 276432967, with fiscal domicile at Alameda D. Pedro V, 39, 4400-115 Vila Nova de Gaia, Portugal. He is the controller of personal data collected through this site and in the business prospecting described below.

Contact for privacy matters: geral@tmiagency.pt · +351 919 648 286. We have not appointed a Data Protection Officer (DPO) as it is not legally required in our case.

2. What data we collect

  • Data you provide: name, email, company, message and any other information you choose to share in the contact form.
  • Meeting booking: on the booking page (agenda.tmiagency.pt) we collect your name, email, company, phone (if you give it) and the time you choose.
  • Direct contact: content of communications by email, phone or social networks.
  • Browsing data: technical data (IP address, device, browser, pages visited) via cookies.
  • Campaigns: data you provide via ad forms (Meta/Instagram/Facebook).
  • Business prospecting: when a company may be interested in our services, we collect the company name, sector, address and business contact details (phone, general email and, where available, the name, role, business email, phone and LinkedIn profile of the decision maker), and notes from our calls. This data comes from the company's own website, its public Google profile, the business contact tool Hunter or a phone call with us.

3. Why we use your data

  • Respond to contact, quote or diagnosis requests.
  • Book and hold meetings: an email for you to confirm the request, a confirmation with a calendar invite, a reminder 15 minutes before, and talking with you about what we agree.
  • Provide and manage our services.
  • Contact companies by phone and email to present our services (business prospecting). By email, only in these cases: when you asked us for the information or gave your consent, for example on a call; or, without a request, only to the general email published by a company (legal person), provided it is not on the opt-out list kept by the Portuguese Directorate-General for Consumers (DGC), and which we stop using as soon as the company objects. Without a request or consent, we never email sole traders (or companies whose legal form we have not yet confirmed), named individuals' email addresses, or contacts obtained from tools such as Hunter.
  • Prepare conversations with the help of artificial intelligence (company analysis and drafts of messages and proposals), always reviewed by a team member. The AI does not make decisions about you.
  • Measure and improve the site and campaigns.
  • Comply with legal obligations.

4. Legal basis

Pre-contractual steps at your request (meeting booking, replies to contact requests and sending the information or presentation you ask for) and contract performance; consent (commercial emails you agreed to receive and optional cookies); legitimate interest (security and improvement of the site, business prospecting to companies and preparing conversations, always with the right to object described in section 8); legal obligation.

5. Cookies and tracking technologies

We use cookies and local storage technologies (localStorage) for the following purposes:

  • Strictly necessary: stores your consent preference (localStorage, key tmi-cookie-consent). Does not require consent.
  • Analytics (optional): Google Analytics 4 (ID G-HTYRP0N659), with IP anonymisation. Only enabled with your consent.
  • Marketing (optional): Meta Pixel (ID 4309035312697781), to measure conversions and remarketing. Only enabled with your consent.
  • Booking page: uses Cloudflare Turnstile to stop bots. It is strictly necessary and is not used for advertising.

You can change your choice at any time by clicking Cookie settings in the footer. For details on each cookie, see our Cookie Policy.

6. Subprocessors and international transfers

We do not sell your data. To deliver the service, we rely on carefully selected subprocessors. Where applicable, transfers outside the European Economic Area are made under Standard Contractual Clauses (SCCs) approved by the European Commission.

  • Netlify, Inc. (USA): website hosting and contact form submission processing; submissions are also sent to our contact database. Under SCCs. Netlify Policy.
  • Supabase, Inc. (EU servers, Frankfurt): database where we keep contacts and meetings. Under SCCs. Supabase Policy.
  • Vercel Inc. (USA): hosting of the booking page and of our internal contact management system, with cookie-free visit statistics. Under SCCs. Vercel Policy.
  • Resend, Inc. (USA): sending the confirmation, invite and reminder emails, and the commercial emails. Under SCCs. Resend Policy.
  • OpenRouter, Inc. (USA), which routes the request to the provider of the artificial intelligence model (currently Anthropic, PBC, USA): analysis of the company to prepare the conversation (company name, website and its public text, service of interest, team notes and contact person's name). Under SCCs. OpenRouter Policy.
  • Apify Technologies s.r.o. (Czech Republic, EU): collection of public company data from their website and Google Maps. Apify Policy.
  • Hunter Web Services, Inc. (USA): business contact tool. Under SCCs. Hunter Policy.
  • Apple Distribution International (Ireland + USA): calendar where the meeting is kept (only the company name and an internal reference), under Apple's privacy policy. Apple Policy.
  • Cloudflare, Inc. (USA): bot protection on the booking page (processes the IP address). Under SCCs. Cloudflare Policy.
  • Zoom Video Communications, Inc. (USA): the meeting's video call. Under SCCs. Zoom Policy.
  • Google Ireland Ltd. / Google LLC (Ireland + USA): Google Analytics 4 (only with your consent). Under SCCs. Google Policy.
  • Meta Platforms Ireland Ltd. / Meta Platforms Inc. (Ireland + USA): Meta Pixel (only with your consent). Under SCCs. Meta Policy.
  • WhatsApp Ireland Ltd. (Meta): when you start a conversation with us via the "WhatsApp" button, the communication is subject to the WhatsApp privacy policy. WhatsApp Policy.

The typefaces used on the site (Montserrat) are self-hosted on our servers, which means we do not make calls to Google Fonts servers.

7. How long we keep your data

  • Contact form submissions: stored in the Netlify Forms panel as long as useful for commercial follow-up. Unanswered requests are deleted, as a rule, within 24 months.
  • Contacts and meetings in our database: kept while useful for commercial follow-up. A contact archived for more than 24 months, with no activity since then and that did not become a client, is anonymised automatically: we delete the name, email, phone, website, notes, decision-makers and the text of messages. Only information that identifies no one remains (dates, stage and contact channel), for our statistics.
  • Unconfirmed booking requests: deleted within 3 days after the link expires.
  • Log of commercial emails sent (to whom, when, the text, the basis for sending and delivery status): while the contact is in our database. When the contact is anonymised, after the 24 months, the log is left without recipient and without text. If the contact is deleted on request, the log is deleted with it.
  • Exclusion list (people who asked to leave, bounced emails and spam complaints): we keep a fingerprint of the email (a code from which the address cannot be read), the reason and the date. While the contact is in our database it stays linked to it; if the contact is deleted, only the fingerprint remains, with no time limit, so we never write again to anyone who asked to leave.
  • Email communications: kept while the relationship lasts, or until deletion is requested.
  • Analytics data (GA4): 14 months (default GA4 configuration).
  • Consent preference (localStorage): indefinitely until the user clears browser storage or changes the preference.
  • Invoicing and tax obligations: 10 years, under applicable Portuguese law.

8. Your rights

You have the right to access, rectify, erase, restrict and object to processing, to portability and to withdraw consent at any time. To exercise these rights, write to geral@tmiagency.pt.

You can object to direct marketing at any time, without giving a reason: click "Unsubscribe" ("Sair da lista") in any of our emails or write to geral@tmiagency.pt. We will stop contacting you for that purpose. If your data came from a source other than you, you can ask us for the exact source.

You can also lodge a complaint with the Portuguese supervisory authority, CNPD.

9. Security

We adopt reasonable technical and organizational measures to protect your data.

10. Changes

We may update this policy. The version in force is the one published on this page, with the corresponding date.

11. Contact

geral@tmiagency.pt · +351 919 648 286.