Privacy Policy

Last updated: 2 April 2026

The Portugal Brief is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains what information we collect, how we use it, and your rights under the General Data Protection Regulation (GDPR) and Portuguese law.

1. Data Controller

Thrifty Explorations LLC
Publication: The Portugal Brief
Email: [email protected]
Website: https://theportugalbrief.pt

Thrifty Explorations LLC is the data controller responsible for your personal data collected through this website and newsletter.

2. What Data We Collect

Newsletter Subscribers

When you subscribe to our newsletter, we collect your email address, the date and time of subscription, and engagement data (whether you open emails or click links). This data is collected with your explicit consent and used solely to send you The Portugal Brief newsletter.

Website Visitors

When you visit our website, we may collect technical data such as your IP address, browser type, device type, pages visited, and referral source. This data is collected via Cloudflare and used for security and performance monitoring. It is not used to identify you personally.

We do not use Google Analytics or advertising cookies.

3. How We Use Your Data

• Sending the newsletter — Legal basis: Consent (Art. 6(1)(a) GDPR)
• Analysing newsletter engagement — Legal basis: Legitimate interest (Art. 6(1)(f) GDPR)
• Website security and performance — Legal basis: Legitimate interest (Art. 6(1)(f) GDPR)
• Complying with legal obligations — Legal basis: Legal obligation (Art. 6(1)(c) GDPR)

4. Third-Party Services

We use the following third-party services that may process your data:

• Ghost (ghost.org) — our publishing platform, which stores subscriber email addresses and manages newsletter delivery preferences.
• Mailgun (mailgun.com) — our email delivery provider, used to send newsletters to subscribers. Mailgun processes your email address for delivery purposes only.
• Cloudflare (cloudflare.com) — our CDN and security provider, which processes web traffic passing through our domain.

5. How Long We Keep Your Data

• Subscriber data: Retained for as long as you are subscribed. Deleted within 30 days of unsubscribing.
• Website traffic data: Aggregate data retained for up to 12 months.

6. Your Rights

Under GDPR, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data ("right to be forgotten")
• Restrict processing of your data
• Port your data to another service
• Object to processing based on legitimate interest
• Withdraw consent at any time

To unsubscribe from the newsletter, use the link at the bottom of any newsletter email. For other data requests, contact us at [email protected]. We will respond within 30 days.

You may also lodge a complaint with Portugal's data protection authority:
CNPD — Comissao Nacional de Protecao de Dados
Rua de Sao Bento, 148-3, 1200-821 Lisboa
https://www.cnpd.pt

7. Cookies

We use only essential cookies required for the website to function:

• Ghost session cookies — required for subscriber login and content access
• Cloudflare security cookies — required for DDoS protection and performance

We do not use marketing, advertising, or analytics cookies. Because we only use strictly necessary cookies, consent is not required under GDPR or the ePrivacy Directive.

8. Data Transfers

Your data may be processed outside the EEA by our service providers (Mailgun, Cloudflare). Where this occurs, appropriate safeguards including Standard Contractual Clauses (SCCs) are in place to ensure your data is protected to GDPR standards.

9. Children's Privacy

The Portugal Brief is not directed at children under 16. We do not knowingly collect personal data from children.

10. Changes to This Policy

We may update this policy periodically. The "Last updated" date at the top will reflect any changes. Significant changes will be communicated to subscribers by email.

11. Contact

Thrifty Explorations LLC
Email: [email protected]
Website: https://theportugalbrief.pt