On this page
The short version
We are a small Portuguese agency. This site uses statistics only if you agree: our own, and Google Analytics. If you choose only necessary, a page load is counted with nothing kept about you, and nothing goes to Google. The site shows no ads. We receive personal data when you choose to contact us or book a call, and we use it to answer you and to run your engagement. We never sell it. Ask us at any time what we hold about you and the founder will answer personally.
01 Who we are
Admosphere Agency is a brand of Fronteira Sapiente, LDA, a company registered in Portugal with VAT number PT518349721 and registered office at Rua César de Oliveira 4, Amora, 2845-233 Portugal. In this policy we call ourselves Admosphere, we or us. For personal data handled as described here, we are the controller.
The person responsible is the founder, Francisco Sezões. You can reach him directly at francisco.m.sezoes@admosphereagency.com. We have not appointed a Data Protection Officer because the scale of our processing does not require one; privacy requests go straight to the founder.
02 What this policy covers
This policy explains how we handle personal data when you visit admosphereagency.com and its subpages, including the preview pages we prepare for prospects, when you contact us, and when you become a client. It follows the EU General Data Protection Regulation (GDPR) and Portuguese data protection law (Law 58/2019).
The campaigns we run for clients inside advertising platforms are a different activity, explained in section 09.
03 The data we collect
- Data you give us. Your name, email address, phone number, company and whatever you write to us when you email us, message us on WhatsApp or Telegram, connect on LinkedIn or book a call. Booking runs through Calendly, which asks for your name, email and preferred time.
- Statistics, only with your agreement. If you accept in the banner, our own statistics tool records how you use our pages: pages viewed, time on page, how far you scroll, clicks on links and buttons (their label), form starts and sends (field names only, never what you type), video plays, page speed, device type, browser, screen size, language, the country taken from your device's time zone (never your city) and where the visit came from. Visits are grouped with a key that changes every day, and your IP address is never stored. Google Analytics and the Google Ads tag load, and set their cookies, only after you accept.
- Without your agreement. Each page load is counted, as totals only: the page, where the visit came from (a link or campaign tags), the hour, and what every browser sends with a request anyway: the type of device, browser and system, the language, and the country, looked up from your address, which is never kept (country data: IP Geolocation by DB-IP). Visits from bots and from our own network are counted apart. No identifier, and nothing stored on your device.
- Preview pages. On a preview we prepare for you, if you accept statistics, our team sees when the preview was opened and how it was used, so we can follow up on the proposal.
- Server logs. Our hosting provider keeps standard server logs, such as IP address, browser type, pages requested and timestamps, to keep the site secure and running. We do not use them to identify visitors.
- Client data. If you become a client, the contract, billing and campaign account details needed to deliver the service and to meet our tax obligations.
- What we do not collect. No advertising pixels, no social media trackers, no session recordings, and nothing you type into a form before you send it.
04 Why we use it and our legal grounds
- To answer your enquiry and prepare a proposal. Steps taken at your request before a contract. Article 6(1)(b) GDPR.
- To deliver services, invoice and keep accounts. Performance of a contract and our legal obligations under Portuguese tax law. Article 6(1)(b) and 6(1)(c).
- To keep the website and our systems secure. Our legitimate interest in protecting our infrastructure. Article 6(1)(f).
- To understand how our pages are used and improve them, and to follow up on previews we prepared for you. Your consent, given in the banner and withdrawn just as easily at any time. Article 6(1)(a).
- To count our page loads and keep bots out of the numbers. Our legitimate interest in knowing how our pages are used and in preventing fraud; the totals hold nothing about you. Article 6(1)(f).
- To send you commercial updates. Only with your consent, which you can withdraw at any time. Article 6(1)(a).
07 International transfers
Some of the providers above process data outside the European Economic Area, mainly in the United States. Where that happens, the transfer relies on a European Commission adequacy decision, including the EU-US Data Privacy Framework, or on Standard Contractual Clauses approved by the Commission.
08 How long we keep data
- Enquiries that do not become an engagement. Up to 24 months after our last exchange, then deleted.
- Client contracts, invoices and accounting records. Up to 10 years, as Portuguese tax law requires.
- Statistics. Detail up to 13 months, then deleted. The page-load totals by hour, device, browser, language and country also go after 13 months; plain totals by page and source are kept. Google Analytics keeps its data for up to 14 months.
- Server logs. Kept briefly by our hosting provider on rolling cycles.
When a period ends, the data is deleted or anonymised.
09 Our advertising work for clients
Our business is running programmatic campaigns for clients. Inside advertising platforms we work with pseudonymous identifiers, such as advertising IDs and audience segments. That processing happens on our clients' behalf, under contracts that bind us to the GDPR, and under the policies of the platforms where the ads run.
We also measure the ads we run with our own tag inside the ad. It follows the consent you gave on the website showing the ad, through that site's consent tool. Without consent that covers us, the ad is only counted: served, seen, time in view, clicks and video progress, plus the type of device, browser and system, the country and checks for automated traffic, worked out on our server from what the browser sends with the request; the address is never kept. With it, we also check for automated traffic and record the device type, the browser, a daily device key made the same way as our site statistics, and the layout of the page around the ad. Raw records are deleted after 90 days and click records after 13 months, on our server in Portugal.
This site shows no ads and builds no advertising profiles.
10 Automated decisions and AI
We make no automated decisions that produce legal or similarly significant effects about you. Campaign optimisation uses automated bidding on pseudonymous data inside advertising platforms, as described in section 09.
When you write to us, a person reads and answers. You are never talking to a machine on our side. Where we use AI assisted tools internally, we do not feed them personal data collected through this website.
11 Your rights
Under the GDPR you can ask us, at any time and free of charge, to: access the data we hold about you, correct it, delete it, restrict how we use it, hand it over in a portable format, or object to processing based on legitimate interest. Where processing relies on consent, you can withdraw that consent at any time without affecting what was lawfully done before; for statistics, use the statistics choices. Because our statistics keep no identifier for more than a day, we usually cannot find past visits that belong to you; if you ask, we will check.
Write to francisco.m.sezoes@admosphereagency.com and we will answer within one month. If you are not satisfied, you can lodge a complaint with the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (cnpd.pt), or with the authority in your own country.
12 How we protect data
The site is served over HTTPS. We collect the minimum we need, restrict who can access it, and keep client records in access controlled systems. No method of transmission or storage is perfectly secure, but if a breach ever put your rights at risk we would notify you and the CNPD as the GDPR requires.
13 Children
Our website and services are aimed at businesses. They are not directed at anyone under 18 and we do not knowingly collect data from children. If you believe a child has sent us personal data, contact us and we will delete it.
14 Changes and how to reach us
When we change this policy we will publish the new version on this page with an updated effective date, and flag meaningful changes clearly.
Questions, requests or complaints: francisco.m.sezoes@admosphereagency.com, or by post to Fronteira Sapiente, LDA, Rua César de Oliveira 4, Amora, 2845-233 Portugal. A Portuguese version of this policy is available on request.