Privacy Policy

1. Who is responsible

The controller for this website is ALMA DESFOLHADA, LDA, trading under the Aurelia brands.

Aurelia Group is a brand designation. The legal operator is the company identified above until a legal name change is completed.

2. Scope of this policy

This website introduces Aurelia AI, the Aurelia AI Readiness Compass and IACOMO by Aurelia. It does not itself create IACOMO accounts, process payments, run assessments or accept AI prompts or document uploads.

When you follow a link to the Aurelia Shop, IACOMO MVP or another service, the privacy information of that service applies to the processing there. Please review it before entering personal data.

3. Visiting the website

Our hosting provider, Vercel, processes technical request information needed to deliver and protect the site. This may include IP addresses, requested URLs, timestamps, browser information and error or security logs. The purposes are reliable delivery, troubleshooting and prevention of abuse. The legal basis is our legitimate interest in operating a secure website under Article 6(1)(f) GDPR.

We do not use the newsletter form contents as analytics events. Avoid putting personal or confidential information in URLs.

4. Newsletter

If you choose to subscribe, we send your email address, submission time, originating page and the consent wording you accepted to HubSpot, our newsletter and contact management provider. We use these details to manage your subscription and send AI and leadership insights, product updates and learning opportunities.

The legal basis is your consent under Article 6(1)(a) GDPR. Subscription is optional and is not a condition of browsing this website or buying a product. We do not automatically subscribe you when you follow a product link or contact us.

You can withdraw consent through the unsubscribe link in a newsletter or by contacting support@aurelia-academy.com. Withdrawal does not affect processing already carried out lawfully. We may retain a limited record of your consent or unsubscribe request to demonstrate compliance and prevent further unwanted mail, based on legal obligations or our legitimate interest in documenting compliance.

This website uses its own form and does not embed the HubSpot tracking script. The form does not send a HubSpot tracking cookie or your browser IP address as a form field. HubSpot and Vercel still process technical connection information when providing their services. See HubSpot's privacy information.

5. Contacting us

If you email us, we process your email address and the contents of your message to respond and handle your request. Depending on its nature, this is necessary for steps at your request before entering a contract, performance of a contract under Article 6(1)(b) GDPR, or our legitimate interest in responding to enquiries under Article 6(1)(f).

Please do not send sensitive personal data, confidential employer information or passwords unless we have agreed on an appropriate secure channel.

6. Cookies, browser storage and analytics

We store your privacy preference locally in your browser under aurelia-privacy-v1. It records whether you allow analytics and when you made the choice. The preference expires after 180 days; it is not used for advertising. This storage is necessary to remember the choice you requested.

Vercel Web Analytics is loaded only when you accept optional analytics. We rely on consent under Article 6(1)(a) GDPR. It provides aggregate information such as page views, referring websites, approximate location, device and browser type. Vercel describes the service as cookie free and uses a request-derived visitor identifier that expires after 24 hours. This does not mean aggregate reports are deleted after 24 hours.

We remove query strings and URL fragments from page URLs before submitting analytics events. We do not send newsletter email addresses or form text as custom analytics events, and we do not embed advertising pixels.

You can reject optional analytics without losing access to this website. To withdraw consent, open the settings below and reject optional analytics. The page reloads to remove the analytics integration. Your browser choice does not change the separate privacy choices on the shop or IACOMO.

Further information: Vercel Web Analytics privacy documentation.

7. Recipients and international processing

Data is accessed by authorised personnel and service providers only as needed for the purposes described here. Relevant service providers include Vercel for website hosting and optional analytics, HubSpot for newsletter and contact management, and the email service used to receive and answer enquiries. Authorities or professional advisers may receive information where legally required or necessary to establish or defend legal claims.

Vercel and HubSpot operate internationally, so processing may take place outside the European Economic Area. Where GDPR transfer restrictions apply, transfers must be covered by an applicable adequacy decision or appropriate safeguards, such as the European Commission's Standard Contractual Clauses, with supplementary measures where required. Contact us for information on safeguards relevant to your data. Provider terms are available in the Vercel Data Processing Addendum and HubSpot Data Processing Agreement.

We do not sell your personal data.

8. How long we keep data

We retain data only for as long as needed for its purpose, subject to legal retention requirements and the establishment or defence of legal claims.

• Newsletter contact details are kept while your subscription is active. After withdrawal, marketing use stops; limited suppression and consent records may remain as described above.
• Enquiries are retained until handled and for any follow-up or legal recordkeeping reasonably required by their subject matter.
• Technical and security records are retained according to operational need, incident investigation requirements and applicable hosting service settings.
• The browser privacy preference expires after 180 days. Optional analytics reports follow the retention available under our Vercel service settings.

You can ask us for the retention criteria relevant to a particular record.

9. Your rights

Subject to the applicable legal conditions, you may request access, correction, erasure, restriction of processing and data portability. You may object to processing based on legitimate interests, and you may object to direct marketing at any time. You may withdraw consent at any time.

Contact support@aurelia-academy.com to exercise your rights. We may need proportionate information to verify your identity. You may lodge a complaint with a supervisory authority, including Portugal's Comissão Nacional de Proteção de Dados (CNPD), or the authority where you live or work.

10. Security, children and automated decisions

We use access controls, encrypted connections and data minimisation appropriate to this website. No internet service can guarantee absolute security. This website is intended for a professional adult audience and is not directed at children. Contact us if you believe a child has submitted personal data.

This informational website does not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

11. Changes and questions

We will update this policy when our services or processing change. The date above identifies the current version. Material changes requiring new consent will not be treated as covered by an old consent. For questions, contact support@aurelia-academy.com.