Cookie Policy

1. What cookies are

Cookies and equivalent technologies (localStorage, sessionStorage) are small files saved on your device that allow the site to recognise your browser, remember preferences and operate securely.

2. Categories used

We adopt the categorisation recommended by European authorities (CNIL/EDPB). Only the 'Strictly necessary' category is currently active on this site.

• Strictly necessary: Indispensable for site operation (auth session, language, consent record). Legal basis: legitimate interest / performance of a service requested by the user (Recital 66 of Directive 2002/58/EC).
• Preferences (not active): Reserved for future personalisation options. When activated, will require explicit consent.
• Statistics (not active): Reserved for aggregated usage analysis (e.g. Plausible Analytics or a privacy-friendly equivalent). When activated, will require explicit consent.
• Marketing (not active): We do not use advertising, retargeting, behavioural profiling cookies, or embedded external social network content.

3. Consent model

In line with the Planet49 ruling (CJEU C-673/17) and EDPB Guidelines 03/2022 on dark patterns, our banner offers 'Accept', 'Reject' and 'Customise' with equal visual weight and no pre-selection. You can change your mind at any time by clearing local storage in your browser, which will display the banner again.

5. Storage technologies used

The site currently uses only the browser's localStorage to keep (a) the chosen language and (b) the record of your cookie consent (including timestamp and policy version). We do not use HTTP tracking cookies.

6. Third-party cookies

The site does not embed third-party content that sets cookies without your prior consent. Should external services (e.g. maps, embedded video) be integrated in the future, they will be assigned to the appropriate category and depend on your consent.

7. Consent record

When you confirm your choice, we save in your browser a record with (i) the decision taken, (ii) the categories authorised, (iii) date/time and (iv) policy version in force — so we can demonstrate consent in line with Art. 7(1) GDPR.

8. Withdrawal of consent

You can withdraw consent at any time by clearing site data in your browser. Withdrawal takes effect for the future and does not affect the lawfulness of processing based on consent given previously.

9. Retention

The consent record is kept until withdrawal or until a new policy version, at which point it is requested again. When a new version is published, previous consent is automatically invalidated.

10. Changes to this policy

This policy may be revised. Whenever there is a material change to the policy or to the categories used, the version is incremented and the banner is shown again for a fresh decision.

11. Supervisory authority

You can lodge a complaint with the Portuguese Data Protection Authority (CNPD), Av. D. Carlos I, 134 - 1.º, 1200-651 Lisbon, geral@cnpd.pt, www.cnpd.pt.

12. Contact

For questions about cookies or to exercise GDPR rights, please contact us at organizacao@saojoaodesobrado.pt.