A personal data leak costs fines, contracts and reputation. The privacy and GDPR policy of DataRoad - IT Services and Consulting exists so that this never happens to those who entrust us with information. It tells you, plainly, what data we collect, why, for how long, who it flows to and how you control it. Revision in force: May 2026.
It covers the website, commercial enquiries, clients, suppliers, candidates and the managed IT services we operate. The framework is the GDPR (EU Regulation 2016/679) and Law 58/2019, which implements it in Portugal.
DataRoad is a Portuguese MSP (Managed Service Provider). We operate networks, systems and managed cybersecurity for national and international organisations that do not tolerate failure. Protecting data is part of the service we sell, not a legal appendix.
| Item | Information |
|---|
| Company name | DATAROAD IT SERVICES AND CONSULTING LDA, trading as DataRoad |
| Tax ID (NIPC) and registration | 513368078, Lisbon Commercial Registry |
| Address | Av. dos Moinhos, 12 B, Quinta Grande — 2610-119 Alfragide, Portugal |
| Main line | +351 211 459 950 |
| Sales | sales@dataroad.pt |
| DPO (data protection) | DPO@DATAROAD.PT |
In what capacity do we act?
Controller whenever we are the ones collecting the data: website, forms, sales process and human resources.
Processor when we manage a client's networks, monitoring or infrastructure and therefore handle data that belongs to them. In that case we follow their written instructions, under a data processing agreement (DPA) and Article 28 of the GDPR.
What terms do we use?
- Data subject The natural person the information relates to.
- Personal data Anything that identifies, or makes it possible to identify, that person.
- Processing Any action on that data: collecting, storing, consulting, organising, sharing or erasing.
- Controller Whoever decides what the data is for and by what means it is processed.
- Processor Whoever processes data on behalf of, and on the instructions of, the controller.
Which core rules do we follow?
Article 5 of the GDPR sets seven principles. In practice, they translate as follows:
- Transparency — we explain what we do, lawfully and fairly.
- Purpose — each item of data serves a specific, explicit and legitimate purpose.
- Minimisation — we ask only for what is essential.
- Accuracy — we correct whatever is wrong or out of date.
- Storage limitation — nothing is kept beyond the justified period.
- Security — integrity and confidentiality ensured by technical and organisational controls.
- Accountability — we can demonstrate, with documents, that we comply with all of this.
What data do we collect, depending on the relationship?
| Relationship | Data |
|---|
| Website visitor | IP, browser, operating system, language, screen resolution, pages viewed, visit duration, originating page (referrer) and cookies, described in the Cookie Policy |
| Information or proposal request | Name, company, job title, email, telephone, the message sent and anything the person chooses to add |
| Client | Identification of the company and its legal representatives; commercial and technical contacts; tax ID, registered address and commercial terms; proposals, contracts, invoices, communications, tickets, interventions and reports; technical data on systems and users |
| Supplier or partner | Contacts for the company and its representatives, billing, transactions and correspondence |
| Candidate | CV, cover letter, experience, education, references and any other data they choose to send |
What about users of the networks we manage?
When we operate a client's infrastructure, we may access data on that organisation's employees or users:
- Accounts — user name, username and company email.
- Technical credentials — tokens and certificates. Plain-text passwords, never.
- Logs — records from devices, applications and the network.
- Managed devices — configurations of personal and business devices.
- Telemetry — IP addresses, technical location and monitoring metrics.
In these cases we act solely as processor: we process this data on the client's behalf, with documented instructions and a signed DPA (Article 28).
What is the data used for, and on what legal basis?
| Legal basis (Article 6(1) GDPR) | Purpose | Data |
|---|
| Consent — point (a) | Website statistics and optimisation; newsletter and marketing | Cookies, browsing, name and email |
| Pre-contractual steps — point (b) | Answering enquiries and preparing proposals; selecting candidates | Contacts and application data |
| Performance of the contract — point (b) | Managing clients, suppliers and partners | Client data, contacts and correspondence |
| Performance of the contract + DPA (Article 28) | Operating managed IT services | Technical and end-user data |
| Legal obligation — point (c) | Invoicing, tax and other legal requirements | Billing data and whatever the law requires |
| Legitimate interest — point (f) | Information security, fraud prevention and defence before the courts or authorities | Logs, technical data and only what is strictly necessary |
Where do we obtain the data?
Almost always from the data subject: through the website, a sales contact or over the course of the contract. There are three other possible sources:
- Public information — company registers, official websites and professional profiles such as LinkedIn, for B2B prospecting.
- Our clients — who give us user data so that we can provide the service.
- Manufacturers and technology partners — in the context of certifications, partnerships and distribution.
Does the data leave DataRoad?
Only when necessary and never for sale. DataRoad does not sell, rent or hand over personal data for commercial purposes. The possible recipients are:
- Our team Only those who need access to do their work (need-to-know), under a duty of confidentiality.
- Contracted providers Microsoft 365 and Google Workspace; the helpdesk, including the helpdesk.dataroad.pt portal; RMM (Remote Monitoring & Management) tools; monitoring and alerting, which is 24/7 only on the Premium 365 plan; backup and cloud storage; hosting; web analytics and marketing, such as Google Analytics; accounting, invoicing and legal support; telecommunications and post.
- Public bodies and courts If required by law or a court decision.
- Auditors and consultants Limited to the work they are asked to do.
- Insurers In claims or professional liability matters.
Each provider is selected for quality, security and GDPR compliance. All sign a written contract with confidentiality and data protection obligations, as Article 28 requires.
Are there transfers outside Europe?
We always prefer servers within the European Economic Area (EEA). Some services from global providers, such as Microsoft or Google, may take data outside the EEA, particularly to the United States.
In those cases we use the safeguards in Article 46 of the GDPR:
- Adequacy recognised by Brussels — for example, the EU-US Data Privacy Framework.
- Standard Contractual Clauses (SCCs) — on the European Commission model.
- Binding Corporate Rules (BCRs) — where the provider has them.
On request, the DPO will detail the transfers that apply to you.
How long is the data kept?
| Period | Data |
|---|
| 12 months | Contacts that did not proceed; access and security logs (or longer, if the law requires); unsuccessful applications, with consent and unless otherwise requested |
| Up to 26 months | Website logs and analytics, per the Google Analytics 4 default |
| 5 years | Proposals (from issue); tickets and technical reports (from closure); emails |
| 10 years | Contracts and invoicing, as required by tax law (Article 123 of the CIRC) |
| For the duration of the contract | Active clients |
| Until consent is withdrawn | Newsletter and marketing |
Once the period expires, we erase or anonymise the data securely and irreversibly. The exception is where the law requires us to keep it or it is needed to defend rights in court.
Managed cybersecurity is at the heart of what we offer. On our own systems we apply the standard we apply to client networks, to stop unauthorised access, loss, destruction or accidental disclosure.
Technical controls
- Encryption TLS 1.3 in transit, AES-256 at rest.
- MFA Multi-factor authentication mandatory on critical systems.
- Least privilege Nobody has more access than they need.
- Segmented network Protected by next-generation firewalls.
- Backups Redundant, with regular restore tests.
- SIEM/SOC Security event monitoring, continuous 24/7 only on the Premium 365 plan.
- Patching Methodical updating of systems and software.
- Vulnerabilities Managed and audited periodically.
- EDR and anti-malware Installed on every endpoint.
Organisational controls
- Written internal policy Reviewed regularly.
- Training Ongoing, in privacy and cybersecurity.
- NDAs Signed by employees and providers.
- Incident response plan With notification to the CNPD within 72 hours.
- DPIAs Impact assessments where warranted.
- Record of processing activities Kept up to date.
- Audits Internal and external, on a schedule.
What if there is a breach?
We notify the CNPD within 72 hours of becoming aware, where there is a risk to people's rights and freedoms (Article 33). Where the risk is high, we also inform the affected data subjects without undue delay (Article 34).
Do we use automated decisions or profiling?
No. No decision with legal effect or significant impact depends solely on automated processing, including profiling. Monitoring, firewalls and intrusion detection work on technical parameters, not on people.
What rights do you have and how do you exercise them?
- Access To know whether we process your data and obtain a copy.
- Rectification To correct whatever is wrong or out of date.
- Erasure The so-called right to be forgotten, in the cases the GDPR provides for.
- Restriction To freeze processing for a time.
- Objection To refuse processing, particularly for marketing.
- Portability To receive the data in a structured, machine-readable format, or have it sent to another organisation.
- Withdrawing consent At any time; what has already been done remains valid.
- Not being subject to solely automated decisions Including profiling, save for legal exceptions.
- Complaint To the supervisory authority.
Simply write to DPO@DATAROAD.PT or send a letter for the attention of the Data Protection Officer at the head office address. We may ask for proof of identity, so as not to release data to anyone other than the data subject.
Response time: 30 days. For complex or numerous requests it may be extended by a further two months, and we will inform the data subject of this.
Where can I complain?
Without prejudice to other administrative or judicial remedies, the competent authority is the CNPD — Comissão Nacional de Proteção de Dados (the Portuguese data protection authority):
- Online — www.cnpd.pt · geral@cnpd.pt
- Address — Avenida D. Carlos I, 134, 1.º — 1200-651 Lisboa
- Telephone — +351 213 928 400
What else do you need to know?
- Cookies Governed by the Cookie Policy, which forms part of this document.
- Minors The website and services are intended for people aged 18 or over. We do not knowingly collect data from minors; if this happens without parental authorisation, we erase it immediately.
- DPO Appointed to oversee compliance and liaise with data subjects and the CNPD, at DPO@DATAROAD.PT or by letter to the head office.
- Revisions We update the policy when the law, case law, regulation or best practice changes. The current version is kept on the website with its date. Significant changes are communicated by email or a prominent notice.
Which legislation applies?
- GDPR — Regulation (EU) 2016/679, adopted on 27 April 2016 by the European Parliament and the Council.
- Law 58/2019 (8 August) — implementation of the GDPR in Portugal.
- Law 41/2004 (18 August) — privacy in electronic communications.
- Decree-Law 7/2004 (7 January) — electronic commerce.
- Law 46/2018 (13 August) — cybersecurity legal framework.
- Law 48/2024 (21 November) — transposes the NIS2 Directive.
- Guidance — CNPD and the European Data Protection Board (EDPB).
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