Privacy Policy
Last updated:
This policy explains what personal data HLM handles when you visit our UK pages, contact us or are contacted by us as a business, why, who we share it with and how to use your rights.
1. Who we are
The controller is Vinicius de Oliveira da Silva, a sole trader with Portuguese tax number 334386349, trading as HLM — High Level Marketing ("HLM"). We are established in Portugal, so the EU GDPR applies to us; for people in the United Kingdom, the UK GDPR also applies.
For anything about your data, write to geral@highlevelmkt.com. We have not appointed a data protection officer, because the law does not require one for our activity.
2. What we process and why
- Enquiries and quotes (form, WhatsApp, phone or email): your name, contact details and what you write to us, to reply and prepare a quote. Legal basis: steps taken at your request before a contract.
- Clients: billing and project communication. Legal basis: performance of the contract and legal obligations (invoicing and accounting).
- Website measurement: pages viewed, where the visit came from and clicks on contact links, without your name or message content. Only if you accept in the cookie banner. Legal basis: consent.
- Advertising: measuring Google Ads and Meta campaigns, only if you choose "Accept all". Legal basis: consent.
3. Contacting UK businesses
We may contact businesses in the United Kingdom whose details are publicly listed, for example on Google Maps, their own website or Companies House, to offer our website and marketing services. We use the business name, the published phone number or email, the trade and the area, and, where it is part of the published details, the name of the person running the business.
Legal basis: our legitimate interest in offering relevant services to businesses (UK GDPR Article 6(1)(f)). Before calling, we check numbers against the Telephone Preference Service and the Corporate Telephone Preference Service. We only send marketing emails without prior consent to limited companies and LLPs, never to sole traders.
You can object at any time by telling us on the call, replying "stop" or writing to geral@highlevelmkt.com. We then add you to our do-not-contact list and stop. We keep prospecting records for up to 12 months after our last contact; the do-not-contact list is kept so that we don't contact you again.
4. Providers we use
- Vercel Inc.: website hosting, in the United States, with the European Commission's standard contractual clauses.
- Google (Google Analytics 4 and Google Ads): website and campaign measurement. Transfers to the US under the EU-U.S. Data Privacy Framework (and its UK Extension), with standard contractual clauses as a fallback.
- Microsoft (Microsoft Clarity): website usage analysis, only with analytics consent.
- Meta Platforms Ireland (Meta Pixel): Facebook and Instagram campaign measurement, only with "Accept all".
- Resend (Plus Five Five, Inc., US): sending website form enquiries to us by email. Standard contractual clauses and the EU-U.S. Data Privacy Framework.
- Zoho (Zoho Mail, EU data centre): our mailbox.
- WhatsApp (Meta): if you message us on WhatsApp, the conversation takes place under Meta's terms and privacy policy.
- HLM internal dashboard (hosted on Vercel): with consent, records each click on a contact link with where the visit came from, without your name, number or message.
5. How long we keep it
- Enquiries that don't become a project: up to 12 months after our last contact.
- Clients: for the project and then invoicing records for the legal retention period (10 years in Portugal).
- UK prospecting records: up to 12 months after our last contact.
- Measurement data: as configured in each tool and, in your browser, as listed in our Cookie Policy.
6. Your rights
You can ask for access, correction, deletion, restriction or portability, and you can object to processing, by writing to geral@highlevelmkt.com. Your right to object to direct marketing is absolute. You can withdraw cookie consent at any time under "Cookie preferences" in the footer.
If you think we are not handling your data properly, you can complain to the UK data protection regulator (ico.org.uk) if you are in the UK, or to Portugal's Comissão Nacional de Proteção de Dados (www.cnpd.pt).
7. What we don't do
- We don't sell personal data or share it for other companies' marketing.
- We don't make automated decisions that affect you.
- We don't send newsletters unless you ask for them.
8. Changes
If this policy changes, the date at the top changes with it, and significant changes are flagged on this page.
Controller: Vinicius de Oliveira da Silva, sole trader, tax number 334386349, trading as HLM — High Level Marketing. Contact: geral@highlevelmkt.com.