Privacy Policy

1. Data Controller

The data controller responsible for your personal data is Dawn Pro Partners, an immigration consultancy registered in Portugal.

Dawn Pro Partners is not a law firm and does not provide legal advice as defined by Portuguese law. Legal services, when required, are provided by lawyers licensed to practise in Portugal and engaged separately on your behalf.

For all privacy-related inquiries, you may contact us at privacy@dawnpropartners.com.

2. What Data We Collect

We collect the following categories of personal data:

Assessment data: nationality, country of residence, employment type, income range, family composition (number of dependents, ages), and other information you provide through our online assessment tool.

Contact data: email address, name (if provided), phone number or WhatsApp contact (if provided), and the content of messages you send us.

Booking and payment data: consultation date and time, timezone, booking references from Cal.eu (the European-region service operated by Cal.com), and payment information processed securely through Stripe for paid strategy sessions. We do not store your full card details on our servers.

Technical data: IP address, browser type and version, device type, operating system, referring URL, pages visited, and timestamps. This data is collected through self-hosted Plausible Analytics (Community Edition) on infrastructure we control in the European Union. Our analytics configuration is designed to avoid personally identifiable tracking in analytics payloads.

Communication data: records of correspondence between you and Dawn Pro Partners via email, WhatsApp, or other channels, including consultation notes created during your strategy sessions.

Providing your personal data is not a statutory requirement. However, certain data is necessary for us to deliver our services. If you choose not to provide assessment data, we will be unable to generate your visa pathway analysis. If you choose not to provide contact data, we will be unable to deliver your PDF report or schedule consultations.

3. How We Use Your Data

We use your personal data for the following purposes:

•  To generate your personalized visa pathway assessment based on the information you provide
•  To deliver your PDF assessment report to the email address you provide
•  To process and manage consultation bookings and payments
•  To prepare for your strategy session by reviewing your assessment results in advance
•  To respond to your inquiries via email or WhatsApp
•  To send transactional emails related to your booking or assessment (confirmations, reminders, follow-ups)
•  To improve our services through anonymized, aggregated analytics that do not identify individual users
•  To comply with legal obligations, including Portuguese tax and commercial record-keeping requirements

To view your free online assessment results and receive the assessment PDF by email, you must agree to subscribe to Dawn Pro Partners email updates about Portugal immigration, service news, reminders, and promotional offers. This subscription is required at lead capture and is recorded with consent text version, policy version, timestamp, and email hash. You may withdraw marketing consent at any time using the unsubscribe link in any promotional email or our unsubscribe page. Withdrawal does not affect transactional emails about your assessment, bookings, or services where we must deliver them.

We do not build advertising profiles or sell your data. After you unsubscribe or exercise erasure rights, we may retain a minimal email-hash suppression record to prevent promotional re-adds; that record does not include your name, raw email, or quiz answers.

4. Legal Basis for Processing

Under GDPR Article 6(1), we process your personal data on the following legal bases:

Contract performance (Article 6(1)(b)): processing your assessment data to generate visa pathway results, delivering your PDF report, processing bookings, managing payments, and preparing for and conducting your strategy session.

Consent (Article 6(1)(a)): the mandatory marketing subscription agreed at lead capture to access the free assessment and PDF, optional analytics cookies where enabled, and any other processing that requires consent under applicable law. You may withdraw marketing consent at any time via unsubscribe without affecting transactional messages we must send for your assessment or bookings.

Legitimate interests (Article 6(1)(f)): improving our services through anonymized analytics, preventing fraud, and ensuring the security of our platform. Our legitimate interests do not override your fundamental rights and freedoms.

Legal obligation (Article 6(1)(c)): retaining payment records and commercial documentation as required by Portuguese tax law and commercial regulations.

5. Automated Decision-Making

Our online assessment tool uses automated processing to generate visa pathway recommendations based on the information you provide. The tool compares your inputs (such as nationality, employment type, income range, and family composition) against publicly available Portuguese immigration requirements to identify which visa categories may be applicable to your situation.

These automated results are informational and for guidance purposes only. They do not constitute a binding decision, legal advice, or a guarantee of eligibility. The assessment output is designed to inform your subsequent consultation with a qualified professional, not to replace it.

You have the right to request human review of the automated assessment output at any time by contacting us at hello@dawnpropartners.com or during your strategy session.

6. Data Sharing & Third Parties

We share your personal data only with third-party service providers that are necessary for the delivery of our services. A provider's role may be a data processor or an independent controller, depending on the service. Where a provider processes personal data on our behalf, that processing is governed by applicable data-processing terms and GDPR Article 28 requirements.

Website and application hosting: our production website and application run on virtual private servers in the European Union operated under our control (not a third-party edge hosting platform). Pages are served to your browser from that infrastructure.

Assessment and booking data storage: Convex (self-hosted deployment on our EU VPS infrastructure). Stores encrypted assessment submissions, booking correlation metadata, and related operational records needed to deliver our services. Raw quiz answers and contact details are encrypted before storage.

Consultation scheduling:Cal.eu, the European-region service operated by Cal.com, Inc. (United States). Dawn's booking configuration uses Cal.eu website, embed, and API endpoints. Cal advertises EU hosting for accounts configured to its EU data region. This is not a representation that every Cal.com operation or service provider is confined to the EEA. Cal.com remains the service operator and booking system of record, and its privacy notice explains that certain personal data may also be processed outside the EEA or by its service providers. Cal may process attendee contact details and other information you provide when booking. Paid sessions are completed through Stripe; we store booking correlation references, not your full payment card data.

Payment processing: Stripe, Inc. (United States, with EU data processing options). Stripe processes payment card information under PCI-DSS Level 1 certification as the payment system of record for paid bookings. We do not receive or store your full card details.

Transactional email: Resend, Inc. (United States). Used to deliver your PDF assessment report, booking confirmations, and session-related communications to the email address you provide.

Analytics: self-hosted Plausible Analytics (Community Edition) on our EU VPS. Privacy-respecting analytics that does not use marketing or advertising cookies by default and is configured to avoid personally identifiable information in our analytics payloads.

External machine translation:when you choose to open a translated version of a public reading page, the page URL is sent to Google Translate or the relevant external translation provider so that the provider can generate the translated page. Do not use machine translation for forms, payments, booking flows, assessment results, account actions, or pages where you intend to submit personal information. Your use of the external translation provider is governed by that provider's own terms and privacy policy.

Where a provider publishes GDPR-related documentation, data processing agreements, or international transfer mechanisms, those materials describe the provider's own compliance posture. They are not a guarantee by Dawn Pro Partners that any particular provider or transfer meets your expectations or legal requirements.

We do not sell your personal data. We do not share your personal data with third parties for their own marketing or advertising purposes. We do not use your data for profiling beyond the scope of our assessment tool as described in Section 5.

If your engagement requires coordination with lawyers licensed to practise in Portugal for legal services, relevant case information will be shared under a separate data processing relationship. You will be informed before any such sharing takes place.

7. International Data Transfers

Some of our third-party service providers (including Stripe, Resend, and Cal.com, Inc.) are based in the United States or may process data outside the European Economic Area (EEA). Our consultation-scheduling configuration uses Cal.eu's EU-region endpoints. Cal advertises EU hosting for accounts configured to its EU data region, but regional hosting does not mean that every support, communications, analytics, integration, or subprocessor operation is necessarily confined to the EEA. Cal.com's privacy notice states that personal data may also be transferred to or processed in other countries, including the United States.

We do not infer a valid international-transfer safeguard solely from a provider's regional hosting claim. Where GDPR Chapter V requires a transfer mechanism, the applicable basis depends on the provider's current contractual terms, the recipient, the destination, and the processing activity. You may request current provider-specific transfer information by contacting privacy@dawnpropartners.com.

8. Data Retention

We retain your personal data only for as long as necessary for the purposes described in this policy, or as required by applicable law.

Assessment data: retained for 24 months from the date of completion, after which it is permanently deleted unless you have entered into an engagement with us.

Client engagement data: retained for the duration of the engagement plus 24 months, to allow for follow-up support and continuity of service.

Payment and financial records: retained for 7 years as required by Portuguese tax law (Código do IRC, Article 123; Lei Geral Tributária, Article 78).

Email addresses: retained until you unsubscribe or request deletion, whichever comes first.

Technical and analytics data:anonymized and aggregated; individual records are not retained beyond the analytics provider's standard retention period.

You may request deletion of your personal data at any time, subject to our legal obligation to retain certain records as described above.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

•  Encryption of data in transit using TLS/HTTPS across all pages and endpoints
•  Payment processing delegated entirely to PCI-DSS Level 1 certified Stripe infrastructure
•  Access to personal data restricted to authorized personnel on a need-to-know basis
•  Regular review of third-party processor security practices and certifications
•  No storage of payment card details on our own servers or systems

While we take reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security but are committed to promptly addressing any breach in accordance with GDPR Article 33 and Article 34.

10. Children's Data

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data directly from children. Our assessment tool may collect information about the number and ages of dependents as part of a family's relocation assessment; this information is provided by the adult user and is processed solely for the purpose of generating visa pathway recommendations that account for family composition.

If we become aware that personal data has been collected directly from a child without appropriate parental consent, we will take steps to delete that data promptly. If you believe a child's data has been submitted to us in error, please contact privacy@dawnpropartners.com.

11. Your Rights

Under the General Data Protection Regulation (GDPR), you have the following rights regarding your personal data:

Right of access (Article 15): you may request a copy of the personal data we hold about you.

Right to rectification (Article 16): you may request correction of inaccurate or incomplete personal data.

Right to erasure (Article 17): you may request deletion of your personal data, subject to our legal obligations to retain certain records.

Right to restriction of processing (Article 18): you may request that we limit the processing of your personal data in certain circumstances.

Right to data portability (Article 20): you may request a machine-readable copy of personal data you have provided to us.

Right to object (Article 21): you may object to the processing of your personal data where the legal basis is legitimate interest.

Right to withdraw consent (Article 7(3)): where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, contact us at privacy@dawnpropartners.com. We will respond within 30 days as required by GDPR Article 12(3). If we need additional time, we will inform you of the extension and the reasons within the initial 30-day period.

You also have the right to lodge a complaint with the Portuguese National Data Protection Commission (Comissão Nacional de Proteção de Dados, CNPD): Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, Portugal. Website: www.cnpd.pt.

12. Cookies

In accordance with the ePrivacy Directive as transposed into Portuguese law (Lei n.º 41/2004), we use cookies and similar technologies as follows:

Strictly necessary cookies: these are required for the basic functionality of our website, such as session management and security. These cookies do not require your consent and cannot be disabled without affecting site functionality.

Analytics cookies: we use Plausible Analytics, which is designed to operate without cookies. If any optional analytics cookies are used in the future, they will require your explicit opt-in consent before being placed on your device.

Third-party cookies: Stripe may place cookies necessary for payment processing and fraud prevention when you proceed to checkout. These are strictly necessary for the completion of your transaction.

We do not use marketing cookies, advertising cookies, or social media tracking cookies. You can manage your cookie preferences at any time through the cookie settings accessible in the footer of our website. You may also configure your browser to reject cookies, although this may affect your ability to use certain features of our site.

13. Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. The “Last updated” date at the top of this page reflects the most recent revision.

For material changes that affect how your personal data is processed, we will make reasonable efforts to notify you by email (if you have provided one) or by placing a prominent notice on our website prior to the change taking effect. Your continued use of our services after such notification constitutes acceptance of the updated policy.