1. Introduction
Cabomasy Lda (“we”, “our”, “us”) is committed to protecting the privacy of its users (“you”, “user”, “data subject”) in accordance with the laws of the Republic of Cape Verde (Law No. 133-V-2001 and its amendments) on personal data protection and under the supervision of the Comissão Nacional de Proteção de Dados Pessoais (CNPD).

2. Scope
This policy applies to all personal data that we collect or receive through the website, services, video platform, newsletter, or any other digital/offline channel connected to our business, when the user is a resident of or holds data in Cape Verde.

3. Data We Collect

• Identification data: name, surname, address, email, phone number.
• Access and usage data: how you access the services, IP address, device type, activity history on the platform.
• Payment data, if applicable: card numbers, banking details (processed securely).
• Sensitive data, only if necessary and with explicit consent (e.g., health, political opinions, etc.), always in compliance with applicable law.

4. Legal Basis for Processing
We process personal data only if:

• you have provided explicit consent for one or more specific purposes;
• it is necessary for the performance of a contract to which you are a party;
• it is necessary to comply with a legal obligation;
• it is in our legitimate interest, provided that your fundamental rights and freedoms do not prevail;
• other purposes permitted by law (public interest, protection of the individual, etc.).

5. Purposes of Processing
Data may be used to:

• provide requested services (access, videos, support, etc.);
• manage user registration and profile;
• billing and payments;
• send newsletters, promotions, updates, if authorized;
• improve services, statistical analysis;
• ensure security, fraud prevention, legal compliance.

6. Data Retention
We retain personal data only for as long as strictly necessary for the purposes for which it was collected, in accordance with applicable laws. After that period, data will be deleted or anonymized.

7. Data Subject Rights
You have, among others, the following rights:

• to be informed if your data is processed;
• access to your data;
• rectification, update, deletion (“right to be forgotten”) of your data if no longer necessary or unlawfully processed;
• objection to processing on legitimate grounds;
• objection to processing for marketing purposes;
• not to be subject to automated decisions that produce legal effects or significantly affect you;
• where applicable, data portability.

8. International Data Transfers
If we transfer personal data outside Cape Verde, we ensure that the destination country provides an adequate level of protection or that appropriate safeguards are adopted (contracts, protective clauses, explicit consent, etc.).

9. Data Security
We implement appropriate technical and organizational measures to protect data from unauthorized access, loss, destruction, alteration, or improper disclosure. We use secure protocols, encryption where necessary, internal controls, and staff training.

10. Data Breach Notification
In case of a data breach that may pose a risk to the rights and freedoms of individuals, we will notify the CNPD within 72 hours of becoming aware of it, and all affected individuals will be informed “without undue delay” as required by law.

11. Use of Cookies and Similar Technologies

• We explain which cookies we use, why (functional, analytical, marketing), and how you can accept or refuse them.
• If cookies collect personal data or track activities, we will request explicit consent where required by law.

12. Data Controller / DPO
Where required by law, we will appoint a Data Protection Officer (DPO) or equivalent person. Contact details (name, email, address) will be provided for any questions or requests regarding your data.

13. Changes to this Privacy Policy
We may update this Privacy Policy for legal, operational, or regulatory reasons. You will be informed of substantial changes via the website or other means, and the updated version will display the revision date.

14. Contact
If you have any questions, concerns, or wish to exercise your rights, you can contact us at:
Email: cabomasi@cabomasi.com