Privacy notice
This notice covers three groups of people: businesses I email first, people who email me, and visitors to this site. In short: I hold very little, I don't use cookies or tracking pixels, I never sell data, and replying "no" to any email from me stops all further contact.
Who is responsible
The controller is Paleta Dinâmica, Lda., a company registered in Portugal, through which Diogo Seca works. Contact for anything in this notice: [email protected]. There is no data protection officer.
If I emailed you first
What I hold. The company name, its website, a business email address, and, where the business publishes them, the name and role of a contact person. Nothing else: no personal social media, no home addresses, no sensitive data.
Where it came from. Public sources only: the business's own website, its Google Maps listing, and public company registers such as Companies House.
Why, and on what basis. To offer website and software work to businesses that might need it, one email at a time, written by me. The lawful basis is legitimate interests (Article 6(1)(f) of the GDPR and the UK GDPR): my interest is finding clients, and the email is relevant to your business, sent to a business address, and easy to refuse.
How long. If I never contact you, I delete your details within 90 days. If I do, I keep them for 24 months after the last email, then delete them. If you say no, I keep only your email address and the date on a do-not-contact list, for as long as I do any outreach, so you are never contacted again. That list is the one thing I keep after an erasure request, because deleting it would let you be emailed again.
If you email me
I keep your message and contact details to answer you and, if we work together, to quote, contract and invoice. The lawful basis is taking steps at your request before a contract (Article 6(1)(b)). If nothing comes of it, I delete the conversation within 24 months. If you become a client, invoices and the records behind them are kept for 10 years, because Portuguese tax law requires it (Article 6(1)(c)).
If you visit this site
This site sets no cookies and stores nothing on your device, so there is no cookie banner. Two privacy-focused analytics tools count visits:
- Cloudflare Web Analytics, which counts page views without cookies or identifiers.
- PostHog, hosted in the EU, which records the page you view, the site that sent you there, any campaign tags in the link, and a few clicks (opening the hire page, copying my email address). Each page load gets a random ID that lives only in memory and is forgotten when you leave, so visits are not linked to you or to each other. If your browser sends Do Not Track, PostHog gets nothing at all.
The lawful basis is legitimate interests: knowing which pages and links bring in work. Your IP address reaches these services as part of any web request; I don't use it to identify anyone.
Who else handles it
A few service providers process data for me, under contract and only on my instructions: my email provider, Cloudflare (hosting and analytics), PostHog (analytics), and the spreadsheet or tool I keep outreach records in. Some of them are based in, or may access data from, the United States. Those transfers rely on the EU-US Data Privacy Framework and its UK extension, or on standard contractual clauses. I don't sell, rent or share data with anyone else.
Your rights
You can ask for a copy of what I hold about you, ask me to correct it, delete it, or restrict how I use it, and object to how I use it. An objection to direct marketing always wins: reply "no" to any email from me, or write to [email protected], and I stop. I answer every request within a month. No decisions about you are made automatically.
If you are unhappy with how I handle your data, you can complain to the data protection authority where you live or work: the CNPD in Portugal (cnpd.pt), the ICO in the UK (ico.org.uk), or the Data Protection Commission in Ireland (dataprotection.ie). I'd appreciate the chance to fix it first.
Changes
If this notice changes, the date below changes with it.
Last updated: 26 October 2026