Privacy Policy
Last updated Oct 1, 2026
This policy explains what personal data EasyPortugalNow handles, why, who else sees it, how long we keep it and what you can ask us to do with it. It covers easyportugalnow.com, the newsletter and the Portugal Navigator. It follows the EU General Data Protection Regulation (GDPR) and French data protection law.
Who is responsible for your data
TWENTY M, SAS, 229 rue Saint-Honoré, 75001 Paris, France (RCS Paris 990 370 603), the company that publishes EasyPortugalNow, is the controller of your data. We have not appointed a data protection officer. For any question or request about your data, write to contact@easyportugalnow.com, or use the contact page and choose “My personal data, or a legal question”.
In short
- Reading the articles needs no account, and we ask you for nothing.
- We collect what you type into a form, what you send us, and what a payment needs.
- You never have to give us data, but some is needed for what you ask: your email for the newsletter, your name and email to get an answer, the email you pay with for the Portugal Navigator, and the documents listed for a paid service. Without them we cannot send the emails, answer you, give you access or perform the service.
- What you enter in the Portugal Navigator stays in your own browser. We never receive it.
- Audience measurement runs only if you accept it.
- We do not sell or rent your data, and we do not use it for advertising.
What we collect, why, and for how long
Reading the site
We ask you for nothing and set no cookie while you read, unless you accept audience measurement. Like any web host, Netlify receives the technical data that comes with each request (IP address, date and time, page requested, browser) to deliver the page and protect the site against attacks, and records it in its server logs.
- Legal basis: our legitimate interest in running a secure site (GDPR article 6(1)(f)).
- Processor: Netlify, Inc., United States.
- How long: Netlify processes these logs for us under its data processing agreement, which sets no fixed period for them. We never download or copy them. The only logs we can read ourselves are those of the small function that passes sign-ups to Mailchimp: they hold no email address, and Netlify’s documentation says it keeps them for at least 24 hours, or 7 days on some plans.
Audience measurement, only with your consent
When audience measurement is switched on and you click Accept in the banner, Google Analytics 4 records the pages you view, how you arrived, your type of device and browser and your approximate location, under a random identifier kept in a cookie. We use it only to count visits and see which articles help.
- Legal basis: your consent (article 6(1)(a)). You can withdraw it at any time with the “Cookie settings” link in the footer.
- Recipients: Google Ireland Limited (Ireland) and Google LLC (United States).
- How long: Google keeps the data tied to a browser for the retention period set in our Analytics account, which is 14 months at most; the aggregated reports it produces do not identify anyone. The cookies last 2 years. The cookie policy has the details.
- If you refuse or ignore the banner, the Google script is never loaded and nothing is sent to Google.
Newsletter and Portugal Navigator waitlist
- Data: your email address, the form you used (newsletter or waitlist), the date you signed up, and whether each email reached you. We have turned off Mailchimp’s open and click tracking, so we do not know whether you open our emails or click their links. Mailchimp may still pass links through its own servers to protect readers against malicious links.
- Purpose: to send you the newsletter; for the waitlist, one email when the Portugal Navigator opens for sale.
- How it works: you are subscribed as soon as you send the form, with no confirmation email. If you had unsubscribed before, Mailchimp sends you one email to confirm before adding you back. Every email we send has an unsubscribe link.
- Legal basis: your consent (article 6(1)(a)).
- Processor: The Rocket Science Group d/b/a Mailchimp, part of Intuit Inc., United States. The site passes your address to Mailchimp through a small function hosted by Netlify.
- How long: until you unsubscribe, and at most 3 years after you signed up, unless you confirm within that time that you still want our emails. Once you unsubscribe, Mailchimp keeps your address marked “unsubscribed” so that we never write to you again by mistake; ask us and we delete it completely. For the waitlist, once the opening email is sent, we keep your address only if you also subscribed to the newsletter.
Messages you send us
This covers the contact form and emails you send to contact@easyportugalnow.com or partners@easyportugalnow.com.
- Data: your name and email, the topic and answers you choose, your message and the page you wrote from. Anything else you decide to tell us.
- Purpose: to answer you.
- Legal basis: steps you ask us to take before a contract, such as a question about the Portugal Navigator before you buy (article 6(1)(b)); otherwise our legitimate interest in answering the messages we receive (article 6(1)(f)).
- Processors: Web3Forms, a service of Web3Creative, a business registered in Kerala, India, delivers form messages to our mailbox. Its privacy policy says it keeps a copy of each message, encrypted, on Amazon Web Services servers, for the retention period set on the form, and that its spam filters, CleanTalk and Akismet, receive the sender’s IP address and email address. Our mailbox runs on Google Workspace (Google).
- How long: 3 years from our last exchange. Web3Forms keeps its copy for the period set on our forms, never more than 3 years. If the exchange leads to an order, the rules for the Portugal Navigator below apply.
Spam filters sometimes block a genuine message. If you get no reply within two business days, email us directly.
Portugal Navigator
What stays with you. Everything you enter in the Navigator, such as your income, documents, household and progress, is saved in your own browser, and the calculations run there. None of it is sent to us or to our providers, so we cannot see it, use it or restore it, and we are not a controller of that data. Clearing your browsing data erases it. You can export a copy as a file from your account page and import it on another device.
What we hold.
- Data: your account, which is your email address and, if you give it, your name; your purchase and any refund, with the Stripe references of the payment and the dates. To protect sign-in, we also keep short-lived sign-in codes and counters of attempts, tied to a coded (hashed) form of your email address and IP address, and delete them automatically once they expire.
- Purpose: to give you access, sign you in, handle refunds and answer your questions.
- Legal basis: performance of the contract (article 6(1)(b)); for the sign-in records, our legitimate interest in protecting accounts (article 6(1)(f)).
- Processors: Netlify (the app and the account records), Stripe (payment), and Mailchimp Transactional from Intuit (sign-in codes and account emails).
- How long: as long as your account exists. You can delete it from your account page or by writing to us, and we delete the account record within one month. We then keep only proof of the purchase for 5 years, and invoices and accounting records for 10 years.
Payments
The Portugal Navigator is paid on Stripe’s own checkout pages. Stripe receives your card details directly: we never see or store your full card number. We receive the name and email you gave at checkout, what you bought, the amount and the date.
- Legal basis: performance of the contract (article 6(1)(b)), and our legal obligation to keep accounting records (article 6(1)(c)).
- Recipient: Stripe Payments Europe, Limited (Ireland), with its affiliate Stripe, LLC (United States). Stripe also processes payment data for its own purposes, such as preventing fraud and meeting its legal duties, under its own privacy policy.
- How long: 10 years for invoices and accounting records.
Who else sees your data
Beyond the two founders, only these providers process your data, each for the purpose described above:
- Netlify, Inc. (United States): hosting, the site’s functions, and the Portugal Navigator.
- Google (Ireland and United States): our Google Workspace mailbox and, only with your consent, Google Analytics.
- The Rocket Science Group d/b/a Mailchimp, Intuit Inc. (United States): newsletter, waitlist and Navigator emails.
- Stripe Payments Europe, Limited (Ireland), our payment provider, and its affiliate Stripe, LLC (United States): payments.
- Web3Creative, for Web3Forms (India, with servers in several regions): delivery of form messages, with its own providers Amazon Web Services, Cloudflare, Hetzner, CleanTalk and Akismet.
We also disclose data to an authority when the law requires us to answer its lawful request. We do not sell or rent your data, and we do not share it for advertising.
Transfers outside the European Union
- Netlify, Google, Mailchimp and Stripe: these transfers to the United States rely on the EU-U.S. Data Privacy Framework, which the European Commission found adequate in Implementing Decision (EU) 2023/1795. On September 28, 2026, each company held an active certification on the official list: Netlify, Inc, Intuit Inc., whose certification covers Mailchimp, Google LLC and Stripe, LLC. Netlify’s data processing agreement falls back on the European Commission’s standard contractual clauses if the Framework ever stops applying.
- Web3Forms: Web3Creative works from India and may process data in several regions. Its data processing agreement incorporates the standard contractual clauses of Implementing Decision (EU) 2021/914.
Write to us for a copy of the safeguards that apply to a transfer.
Your rights
You can ask us at any time to:
- give you a copy of the data we hold about you (access);
- correct it (rectification);
- delete it (erasure);
- limit what we do with it while a question is settled (restriction);
- send you, or another company, the data you gave us in a usable file (portability);
- stop using it where we rely on our legitimate interest (objection);
- stop using it where we rely on your consent, which you can withdraw as easily as you gave it.
Under French law you can also tell us what should happen to your data after your death.
Write to contact@easyportugalnow.com or use the contact page. It is free. We answer within one month; for a complex request we can take two more months, and if so we tell you why within the first month. If we have a reasonable doubt about who is asking, we may ask you to confirm your identity.
Complaints
If you think we have not respected your rights, you can complain to the French data protection authority, the CNIL: online or by mail to CNIL, Service des plaintes, 3 Place de Fontenoy, 75007 Paris, France. You can also complain to the authority of the EU country where you live or work. We would rather you wrote to us first, so we can put it right.
No automated decisions
We make no decision about you based solely on automated processing, and we do not profile you. The only automated step is the spam filter on our forms, which may hold back a message: if that happens, email us directly.
Children
EasyPortugalNow is written for adults. You must be 18 or older to buy the Portugal Navigator, and we do not knowingly collect data from children through the site. If you believe a child has sent us personal data, tell us and we delete it.
Security
The whole site runs over an encrypted connection. Only the people who work on your request can read your messages and documents. Card details stay with Stripe, and what you enter in the Portugal Navigator never leaves your device.
Changes to this policy
We update this policy when what we do with your data changes, and the date at the top shows the current version. If a change affects the data of Portugal Navigator account holders, we tell them by email before it applies.