Privacy Policy

Last updated: 29, September, 2025

1. Introduction

Emanuel Balsa ("we," "us," or "our") operates www.emanuelbalsa.com (the "Website"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Website and use our services.

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Website.

2. Information We Collect

2.1 Personal Information

We may collect personally identifiable information that you voluntarily provide, including:

  • Name and email address (newsletter subscriptions)

  • Contact information (customer support inquiries)

  • Payment information (course purchases)

  • Profile information (account creation)

  • Communication preferences

2.2 Automatically Collected Information

When you visit our Website, we may automatically collect:

  • IP address and location data

  • Browser type and version

  • Operating system information

  • Referring website addresses

  • Pages viewed and time spent on pages

  • Device information and screen resolution

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

  • Remember your preferences and settings

  • Analyze Website traffic and user behavior

  • Provide personalized content and advertisements

  • Improve Website functionality and user experience

Types of cookies we use:

  • Essential cookies (necessary for Website operation)

  • Analytics cookies (Google Analytics, etc.)

  • Marketing cookies (social media pixels, advertising)

  • Preference cookies (language, region settings)

Cookie Consent and Control:

By using our Website, you consent to our use of essential cookies necessary for site functionality. For non-essential cookies (analytics, marketing), we will request your explicit consent through a cookie banner on your first visit.

You can withdraw cookie consent at any time by:

- Adjusting your browser settings to block or delete cookies

- Using our cookie preference center [if you implement one]

- Contacting us at happyhelp@emanuelbalsa.com

Note: Blocking essential cookies may prevent certain Website features from functioning properly.

3. How We Use Your Information

3.1 Primary Uses

We use collected information to:

  • Provide and maintain our services

  • Process transactions and send confirmations

  • Send newsletters and educational content

  • Respond to customer service inquiries

  • Improve Website functionality and user experience

  • Analyze usage patterns and trends

3.2 Communication

We will send you marketing communications only if:

- You have explicitly subscribed to our newsletter, OR

- You have purchased a product/service and have not opted out, AND

- You have not subsequently unsubscribed

Types of communications:

- Educational newsletters: Weekly behavioral finance/AI insights

- Course/product announcements: New offerings and updates

- Service announcements: Critical platform updates (cannot opt out)

- Customer support: Responses to your inquiries

Right to Opt-Out:

Every marketing email includes an unsubscribe link. You may also:

- Email happyhelp@emanuelbalsa.com with "UNSUBSCRIBE" in subject

- Adjust preferences in your account settings

- Opt out during account creation

We will process unsubscribe requests within 48 hours.

3.3 Legal Compliance

We may use information to:

  • Comply with applicable laws and regulations

  • Respond to legal requests and prevent fraud

  • Protect our rights and property

  • Ensure user safety and security

4. Information Sharing and Disclosure

4.1 Third-Party Service Providers

We may share information with trusted third-party service providers who assist us in:

  • Payment processing (Stripe, PayPal)

  • Email marketing (ConvertKit, Mailchimp)

  • Website analytics (Google Analytics)

  • Customer support tools

  • Content delivery networks

4.2 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

4.3 Legal Requirements

We may disclose information when required by law or to:

  • Comply with court orders or legal processes

  • Protect our rights and property

  • Investigate potential violations

  • Ensure user and public safety

4.4 Consent-Based Sharing

We will not sell, rent, or share your personal information with third parties for their marketing purposes without your explicit consent.

5. Data Security

5.1 Security Measures

We implement appropriate technical and organizational measures to protect your information, including:

  • SSL encryption for data transmission

  • Secure payment processing systems

  • Regular security audits and updates

  • Access controls and authentication

  • Data backup and recovery procedures

5.2 Limitation of Security

While we implement industry-standard security measures, no method of internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security against unauthorized access, hardware/software failure, or other factors beyond our control.

Data Breach Notification:

In the event of a data breach that compromises your personal information, we will:

- Notify affected users within 96 hours of discovering the breach

- Report the breach to relevant data protection authorities as required by law

- Provide details about the nature of the breach and affected data

- Advise on protective measures you should take

- Outline steps we are taking to address the breach

You may report security concerns to: happyhelp@emanuelbalsa.com

6. Your Rights and Choices

6.1 Access and Correction

You have the right to:

  • Access your personal information we hold

  • Request correction of inaccurate information

  • Update your account details and preferences

  • Request information about our data practices

6.2 Data Portability and Deletion

You may request to:

  • Export your personal data in a portable format

  • Delete your personal information (subject to legal requirements)

  • Restrict processing of your information

  • Object to certain uses of your data

Data Deletion Exceptions:

We may retain certain information even after deletion request if required for:

- Legal compliance (tax records: 7 years)

- Dispute resolution (transaction records: duration of applicable limitation period)

- Fraud prevention (payment information: as required by financial regulations)

- Enforcing agreements (contract-related data: duration of contract + 3 years)

When we cannot fully delete your data due to legal obligations, we will:

- Restrict processing to only legally required purposes

- Notify you of the specific retention requirement

- Delete the data once the retention period expires

6.3 Communication Preferences

You can:

  • Unsubscribe from marketing emails using provided links

  • Update your communication preferences in your account

  • Contact us to modify your subscription settings

  • Opt out of non-essential cookies

6.4 GDPR Rights (EU Residents)

If you are located in the European Union, you have additional rights under GDPR, including:

  • Right to be informed about data processing

  • Right of access to your personal data

  • Right to rectification of inaccurate data

  • Right to erasure ("right to be forgotten")

  • Right to restrict processing

  • Right to data portability

  • Right to object to processing

  • Rights related to automated decision-making

Right to Lodge a Complaint:

If you believe we have violated your data protection rights, you may:

1. Contact us first: happyhelp@emanuelbalsa.com

We will investigate and respond within 30 days.

2. Lodge a complaint with your supervisory authority:

- Portugal: Comissão Nacional de Proteção de Dados (CNPD)

Website: www.cnpd.pt

Email: geral@cnpd.pt

- EU residents: Contact your local Data Protection Authority

Find your authority: https://edpb.europa.eu/about-edpb/board/members_en

You have the right to lodge a complaint at any time, though we appreciate

the opportunity to address concerns directly first.

7. Children's Privacy

Our Website is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected such information, we will take steps to delete it promptly.

8. International Data Transfers

8.1 Primary Data Location

Your information is primarily processed and stored in [specify: Portugal/EU/USA - you need to clarify this].

8.2 Transfers Outside the EU

If you are in the EU and your data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards through:

Standard Contractual Clauses (SCCs): EU-approved contracts with service providers

Adequacy Decisions: Transfers only to countries with EU-recognized adequate protection

Privacy Shield (if applicable): For certified US service providers [NOTE: Verify current status]

8.3 Your Rights Regarding Transfers

You may request:

- Information about which countries your data is transferred to

- Copies of safeguards in place for such transfers

- Objection to specific transfers (subject to service impact)

Contact happyhelp@emanuelbalsa.com for transfer-related inquiries.

9. Data Retention

9.1 Retention Periods

We retain personal information for as long as necessary to:

  • Provide our services to you

  • Comply with legal obligations

  • Resolve disputes and enforce agreements

  • Fulfill legitimate business purposes

9.2 Specific Retention Periods

  • Account information: Retained while account is active plus 3 years

  • Transaction records: 7 years for tax and legal compliance

  • Marketing communications: Until you unsubscribe plus 2 years

  • Website analytics: 26 months (Google Analytics default)

Data Anonymization:

After retention periods expire, we may anonymize your data (removing all identifiable information) for:

- Statistical analysis and research

- Service improvement and development

- Industry insights and trends

Anonymized data cannot be linked back to you and is not subject to data protection regulations. We may retain anonymized data indefinitely.

If you object to anonymization of your data, you must notify us before the retention period expires.

10. Third-Party Websites

Our Website may contain links to third-party websites. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party websites you visit.

11. Updates to This Privacy Policy

11.1 Change Notification

We reserve the right to modify this Privacy Policy at any time. When we make changes:

Minor changes: Updated effective date only

Material changes:

- Email notification to active subscribers (30 days advance notice)

- Prominent banner on Website

- Summary of key changes provided

11.2 Version History

Previous versions: [Link to archive or state "Available upon request at happyhelp@emanuelbalsa.com"]

Current version: 29th September, 2025

11.3 Continued Use

Your continued use of our services after changes become effective constitutes

acceptance of the revised Privacy Policy. If you do not agree to changes,

you must discontinue use and may request account deletion.

12. Contact Information

12.1 Data Controller

Emanuel Balsa is the data controller for your personal information collected through this Website.

12.2 Contact Details

If you have questions about this Privacy Policy or our data practices, please contact us:

Email: happyhelp@emanuelbalsa.com

Website: www.emanuelbalsa.com

12.3 Supervisory Authority

Portugal (Primary Authority):

Comissão Nacional de Proteção de Dados (CNPD)

Address: Av. D. Carlos I, 134, 1º, 1200-651 Lisboa, Portugal

Phone: +351 213 928 400

Email: geral@cnpd.pt

Website: www.cnpd.pt

Other EU Residents:

You have the right to lodge a complaint with the supervisory authority

in your country of residence, place of work, or place of alleged infringement.

Dispute Resolution Process:

1. Internal resolution: Contact happyhelp@emanuelbalsa.com (response within 30 days)

2. Supervisory authority: File complaint with CNPD or your local authority

3. Judicial remedy: Seek legal redress through courts if unsatisfied with outcomes

We commit to cooperating with supervisory authorities in resolving complaints.