1. Introduction and Scope

This Privacy Policy ("Policy") constitutes a legally binding agreement between you ("User," "you," or "your") and Skillful Sardine - Unipessoal Lda. ("we," "us," "our," or "Company"), governing the collection, use, and disclosure of information through the Ligaro website (the "Website").

By accessing or using this Website, you expressly consent to the data practices described in this Policy. If you do not agree with this Policy, you must immediately cease using this Website.

Governing Law: This Policy is governed by and construed in accordance with the laws of Portugal, without regard to its conflict of law provisions.

2. Data Controller

The data controller responsible for your personal data is:

Skillful Sardine - Unipessoal Lda.
Email: legal@skillfulsardine.com

3. Information We Collect

3.1 Email Subscription (Waitlist)

When you subscribe to our waitlist, we collect the following information:

  • Name
  • Email address

Purpose: This information is collected solely to notify you about Ligaro's launch and product updates.

3.2 Website Analytics

We use Umami, a privacy-focused, open-source analytics tool hosted on our own infrastructure. Umami collects:

  • Page views (which pages are visited)
  • Referrer information (where visitors come from)
  • Browser and device type (aggregated, not individual)
  • Country of origin (derived from IP, IP is never stored)

Umami does NOT use cookies, does NOT track individuals across sessions, and does NOT collect personal data. All data is aggregated and anonymous. Umami is GDPR-compliant by design.

3.3 Information We DO NOT Collect

We explicitly DO NOT collect, store, or process any of the following:

  • Payment information
  • IP addresses in identifiable form
  • Device identifiers or advertising IDs
  • Cross-site tracking data

4. Legal Basis for Processing (GDPR)

Under the EU General Data Protection Regulation (GDPR), we process data under the following legal bases:

  • Consent (Article 6(1)(a) GDPR): When you subscribe to our waitlist, you provide explicit consent for us to process your personal data to send you product updates.

5. Purpose and Use of Data

We use collected data exclusively for the following purposes:

  • Sending product launch notifications
  • Communicating product updates and news about Ligaro

We will never use data for:

  • Unsolicited marketing or advertising
  • Selling or sharing data with third parties
  • Profiling or behavioral targeting
  • Any purpose not explicitly stated above

6. Data Sharing and Third Parties

We do not sell, rent, or share your personal data with any third parties for marketing purposes.

Legal Disclosure: We may disclose information if required by law, court order, or governmental authority, or to protect our legal rights, safety, or property.

7. Data Retention

Email Subscriptions: Your subscription data is retained until you unsubscribe. You may unsubscribe at any time using the link provided in our emails or by contacting us directly.

8. Your Rights Under GDPR and CCPA

8.1 GDPR Rights (EU/EEA Users)

  • Right to Access: You have the right to access the personal data we hold about you.
  • Right to Rectification: You may request correction of inaccurate data.
  • Right to Erasure: You may request deletion of your personal data ("right to be forgotten").
  • Right to Restrict Processing: You may request limitation of how we use your data.
  • Right to Data Portability: You may request a copy of your data in a structured format.
  • Right to Object: You may object to data processing.
  • Right to Lodge a Complaint: You may file a complaint with your local data protection authority.

8.2 CCPA Rights (California Users)

Under the California Consumer Privacy Act (CCPA), you have the right to:

  • Know what personal information is collected
  • Know whether your personal information is sold or disclosed (we do not sell data)
  • Request deletion of your personal information
  • Non-discrimination for exercising your rights

8.3 Exercising Your Rights

To exercise your rights or ask questions, contact us at legal@skillfulsardine.com. We will respond within 30 days.

9. Data Security

We implement industry-standard security measures to protect data integrity and prevent unauthorized access:

  • HTTPS encryption (TLS 1.3) for all Website traffic
  • Content Security Policy (CSP) to prevent XSS attacks
  • Regular security updates and server hardening
  • Database encryption and secure credential management

Limitation of Liability: While we strive to protect data, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

10. Children's Privacy

This Website is not directed at individuals under the age of 16. We do not knowingly collect data from children. If we become aware that a child under 16 has provided personal information, we will take steps to delete such data immediately.

11. Changes to This Privacy Policy

We reserve the right to modify this Policy at any time. Changes will be effective immediately upon posting. The "Effective Date" at the top of this page will reflect the date of the most recent revision.

Continued use of the Website after changes constitutes your acceptance of the revised Policy.

12. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or your data, contact us at:

Email: legal@skillfulsardine.com

We will respond to all inquiries within 30 days.

13. Severability

If any provision of this Policy is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.