Privacy Policy

Last updated: 14 September 2026

FHH respects the privacy of its clients, prospective clients, partners, candidates, subscribers and other Website users and is committed to processing personal data lawfully, fairly, transparently and securely.

This Privacy Policy explains how we collect, use, store and protect personal data provided through the FHH Website, as well as the rights of the respective data subjects.

The processing of personal data is carried out in accordance with Regulation (EU) 2016/679 of 27 April 2016, the General Data Protection Regulation, hereinafter referred to as the “GDPR”, Law No. 58/2019 of 8 August, and other applicable Portuguese and European legislation relating to personal data protection and privacy.

1. Data Controller

The controller responsible for the processing of personal data collected through the Website is:

FHH Portugal Unipessoal Lda
Trading name: FHH
Tax ID / Company Registration Number (NIF/NIPC): 519 600 185
Address: Rua Comissão Iniciativa, Torre Brasil, Nr. 2A, E403, 4.º, 2410-098 Leiria, Portugal
Telephone: +351 244 024 781
Email: info@fhh-portugal.pt

For any matter relating to privacy, personal data protection or the exercise of your rights, you may contact FHH using the email address indicated above.

2. Scope of the Privacy Policy

This Privacy Policy applies to personal data processed through the FHH Website and its respective forms, including in connection with:

• contact requests;
• information requests;
• requests for proposals or support;
• meeting scheduling;
• newsletter subscriptions;
• job applications or recruitment-related contact;
• use and browsing of the Website;
• security mechanisms and prevention of automated or malicious access;
• communications initiated by the user through the contact methods made available on the Website.

This Policy applies exclusively to personal data processing carried out by FHH within the context described above.

3. What Is Personal Data

Personal data means any information relating to an identified or identifiable natural person.

Personal data may include, among other information:

• name;
• email address;
• telephone number;
• job title or professional role;
• company or organisation;
• tax identification number;
• IP address;
• browsing data;
• information contained in messages or forms;
• data contained in documents voluntarily submitted by the user;
• certain identifiers and technical information associated with the device or connection used.

4. Personal Data We May Collect

Depending on how the user interacts with the Website, FHH may collect different categories of personal data.

4.1. Contact forms

When you contact FHH through a form, we may collect:

• name;
• email address;
• company;
• telephone number, where requested;
• service or area of interest;
• message content;
• other information voluntarily provided by the user.

This data is used to analyse and respond to the request submitted.

4.2. Meeting scheduling

When requesting a meeting, data processed may include:

• name;
• email address;
• telephone number;
• company or project;
• company Tax ID, where requested;
• job title or role;
• sector of activity;
• number of employees;
• preferred date and time for the meeting;
• additional information provided through the form.

This data is used exclusively to organise, prepare and conduct the requested meeting and to follow up on the relevant commercial or professional contact.

4.3. Newsletter

When subscribing to the FHH newsletter, we may collect:

• email address;
• information relating to the subscription;
• technical information necessary to manage and confirm the subscription.

The email address will be used to send content relating to accounting, taxation, management, business consulting, incentives, legislation, FHH services and other professional content considered relevant.

Subscription is based on the user’s consent and may be cancelled at any time.

4.4. Recruitment and job applications

When submitting an application to FHH, we may process:

• name;
• contact details;
• curriculum vitae;
• professional experience;
• academic qualifications;
• professional skills;
• professional profile;
• other information voluntarily provided in connection with the application.

Candidates should not include personal data in their CV or application that is not necessary for professional assessment, particularly data of a particularly sensitive nature.

4.5. Technical and Website usage data

During use of the Website, certain technical data may also be processed, including:

• IP address;
• browser type;
• device used;
• operating system;
• date and time of access;
• pages visited;
• source of the visit;
• interactions carried out on the Website;
• identifiers associated with cookies or similar technologies, where applicable.

Some of this data is necessary to ensure the operation, security and stability of the Website. Other data is only processed with the user’s consent where legally required.

4.6. Cloudflare Turnstile and bot prevention

The FHH Website uses Cloudflare Turnstile, a service provided by Cloudflare, Inc., intended to protect websites against bots, spam, abuse and other forms of automated or malicious activity.

Turnstile makes it possible to distinguish, through the analysis of certain technical signals, interactions carried out by human users from potentially malicious automated interactions.

For this purpose, Cloudflare Turnstile may process certain technical signals associated with the visitor and the Website, including:

• IP address;
• TLS Fingerprint;
• information contained in the User-Agent header;
• information about the browser and device;
• Sitekey used by the Website;
• domain or origin associated with the Sitekey;
• other technical signals strictly related to bot detection and prevention.

This data is not collected by FHH through Turnstile for advertising, marketing or commercial profiling purposes.

According to information provided by Cloudflare, the signals processed by Turnstile are intended to enable the detection and blocking of automated traffic and to improve the service’s bot detection capabilities.

In the context of processing carried out to protect the FHH Website, Cloudflare acts as a service provider and processor of FHH in relation to data processed on its behalf and in accordance with its instructions.

Cloudflare also states that it processes certain signals as a data controller when those signals are used to develop and improve Turnstile’s bot detection capabilities.

Further information regarding this processing is available in the Cloudflare Turnstile Privacy Addendum:

https://www.cloudflare.com/en-gb/turnstile-privacy-policy

5. Purposes and Legal Bases

FHH processes personal data only where there is a defined purpose and a valid legal basis.

Responding to contact or information requests

Data is processed to respond to questions, information requests, requests for proposals or other communications initiated by the user.

The processing may be based on taking pre-contractual steps at the request of the data subject or on FHH’s legitimate interest in responding to communications addressed to it.

Scheduling and conducting meetings

Data is processed to manage the meeting request, confirm availability, prepare the meeting and follow up on the matter presented.

Depending on the context, the legal basis will be taking pre-contractual steps at the request of the data subject or FHH’s legitimate interest in managing its professional and commercial contacts.

Provision of services

Where there is a contractual relationship with FHH, the necessary data may be processed for the performance of the relevant contract and fulfilment of associated obligations.

Compliance with legal obligations

Certain data may be processed or retained where necessary to comply with legal, tax, accounting, regulatory or other obligations applicable to FHH.

Sending newsletters and marketing communications

The sending of newsletters and other promotional electronic communications is based on the consent of the data subject whenever legally required.

Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before its withdrawal.

Recruitment

Candidate data is processed to assess applications and carry out steps relating to potential recruitment.

Processing is generally based on taking pre-contractual steps at the request of the candidate.

Where FHH intends to retain an application for future opportunities beyond the recruitment process concerned, the candidate’s consent may be requested.

Website security and operation

Certain technical data may be processed on the basis of FHH’s legitimate interest in ensuring the availability, integrity, security and proper operation of the Website and its technological systems.

This processing may include the use of security mechanisms designed to prevent and detect bots, spam, abuse, unauthorised access attempts, cyberattacks and other potentially harmful activities.

For this purpose, FHH uses, among other security solutions, Cloudflare Turnstile.

6. Mandatory and Optional Data

Fields identified as mandatory in forms are required so that FHH can properly process the request submitted.

If the user does not provide the mandatory data, it may not be possible to submit the form, respond to the request, schedule a meeting or provide the requested service.

All remaining fields are optional.

Certain security controls implemented on the Website may also be necessary to allow the secure use of specific forms and functionalities.

7. Data Retention

FHH retains personal data only for the period necessary to fulfil the purpose for which it was collected, without prejudice to longer retention periods imposed by law.

As a general principle:

• data associated with contact requests and prospective commercial relationships will be retained for the period necessary to manage and follow up on the request;
• data associated with contractual relationships will be retained for the duration of the relationship and subsequently for the periods required to comply with legal obligations and defend legal rights;
• data used for newsletters will be processed while the subscription remains active or until consent is withdrawn;
• data associated with job applications will be retained for the period necessary for the recruitment process, unless consent has been provided for retention for an additional period;
• technical and security logs will be retained only for the period necessary to prevent, detect and investigate incidents.

Data processed by technology service providers, including Cloudflare, may be retained for the periods necessary to provide and secure the respective services and in accordance with the applicable contractual terms and privacy policies.

When data is no longer required, it will be deleted, anonymised or blocked, as applicable.

8. Sharing Data with Third Parties

FHH does not sell, rent or trade personal data.

Data may, however, be processed by service providers engaged by FHH where necessary for the operation of the Website or the provision of associated services.

These providers may include, in particular:

• Website hosting providers;
• technology infrastructure providers;
• email service providers;
• contact management system providers;
• scheduling platforms;
• analytics and statistics tool providers;
• cybersecurity and bot prevention services;
• newsletter sending and management platforms;
• Website maintenance and development providers;
• professional advisers, where necessary.

Technology providers used for Website security include Cloudflare, Inc., through the Cloudflare Turnstile service, which is used to identify and block potentially malicious automated traffic.

Whenever acting on behalf of FHH as processors, these providers are subject to the applicable data protection obligations, including confidentiality and security requirements.

Certain providers may also process data as independent data controllers for their own purposes, in which case their respective privacy policies will apply.

Data may also be disclosed to public, judicial, tax, regulatory or other authorities where required by law or pursuant to a valid order.

9. International Data Transfers

Some technology providers used by FHH may process personal data outside the European Economic Area.

This may include international technology infrastructure and security providers, including Cloudflare.

Whenever an international transfer of personal data takes place, FHH will seek to ensure that the safeguards legally required under the GDPR are used, including:

• adequacy decisions adopted by the European Commission;
• Standard Contractual Clauses approved by the European Commission;
• other transfer mechanisms recognised under applicable legislation.

Where necessary, additional measures will be adopted to ensure an adequate level of protection for personal data.

10. Cookies and Similar Technologies

The Website may use cookies and similar technologies to ensure its operation, improve the user experience, obtain statistical information and, where applicable, support communication and marketing activities.

Cookies strictly necessary for the operation and security of the Website may be used without consent where permitted by applicable legislation.

Analytics, advertising or other non-essential cookies should only be activated after obtaining the user’s consent where such consent is legally required.

Users may manage or withdraw their preferences through the cookie management mechanism available on the Website.

Further information should be made available in the FHH Cookie Policy.

10.1. Cloudflare Turnstile

The Website uses Cloudflare Turnstile as a security mechanism intended to prevent bots, spam and abusive use of forms and other protected functionalities.

Turnstile may use technical signals, cookies or similar technologies strictly necessary to verify whether an interaction has characteristics consistent with a legitimate user or automated traffic.

The use of Turnstile on the Website is intended for infrastructure security and protection and is not used by FHH to display personalised advertising or create commercial profiles of visitors.

According to Cloudflare, the signals processed by Turnstile are used for bot detection and blocking and to improve the service’s detection capabilities.

For further information regarding data processing associated with Turnstile, please consult:

Cloudflare Turnstile Privacy Addendum
https://www.cloudflare.com/en-gb/turnstile-privacy-policy/

11. Links to Third-Party Websites

The FHH Website may include links to websites, platforms or services managed by third parties.

FHH does not control the privacy practices of these third parties, and this Privacy Policy does not apply to data processing carried out through such websites or services.

We recommend that users review the relevant privacy policies before providing personal data.

12. Personal Data Security

FHH adopts appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;
• improper alteration;
• unauthorised disclosure;
• loss;
• destruction;
• misuse;
• unlawful or accidental processing;
• malicious automated traffic;
• spam and abuse of forms;
• attempts to compromise Website security.

To enhance Website security, specialised third-party services may be used, including Cloudflare Turnstile.

These measures are reviewed and adapted whenever necessary, taking into account the nature of the data, the risks associated with processing, the state of technology and implementation costs.

Despite the measures adopted, no data transmission or storage system can guarantee absolute security.

13. Confidentiality

Employees, service providers and other persons who may have access to personal data processed by FHH are subject to confidentiality obligations and should only access the data necessary to perform their respective duties.

14. Rights of Data Subjects

Under applicable legislation, data subjects may exercise, where applicable, the following rights:

Right of access

You may request confirmation as to whether your personal data is being processed and obtain access to that data.

Right to rectification

You may request the correction or updating of inaccurate or incomplete personal data.

Right to erasure

You may request the deletion of your personal data where the conditions established by law are met.

This right is not absolute and may not apply where retention of the data is necessary to comply with a legal obligation or for the establishment, exercise or defence of legal claims.

Right to restriction of processing

You may request, under the conditions established by law, that the processing of your personal data be temporarily restricted.

Right to object

You may object to the processing of personal data based on FHH’s legitimate interests on grounds relating to your particular situation.

Where data is used for direct marketing, you may object to such processing at any time.

Right to data portability

Where applicable, you may request the transmission of personal data that you provided to FHH in a structured, commonly used and machine-readable format.

Right to withdraw consent

Where processing depends on consent, that consent may be withdrawn at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

Right not to be subject solely to automated decisions

Where applicable, the data subject has the right not to be subject to a decision based solely on automated processing that produces legal effects or similarly significant effects.

15. How to Exercise Your Rights

To exercise any of the rights indicated above or to raise a question relating to the processing of your personal data, please contact:

Email: info@fhh-portugal.pt

The request should make it possible to adequately identify the data subject and the right they wish to exercise.

FHH may request additional information where strictly necessary to confirm the identity of the applicant and prevent unauthorised disclosure of personal data.

Requests will be reviewed and responded to within the time limits provided for under applicable legislation.

With regard to processing carried out independently by third parties acting as data controllers, including certain processing carried out by Cloudflare for the improvement of Turnstile, the data subject may also exercise their rights directly with the entity responsible for the relevant processing.

16. Complaints

Without prejudice to any other administrative or judicial remedy, the data subject has the right to lodge a complaint with the competent supervisory authority if they consider that the processing of their personal data infringes applicable legislation.

In Portugal, the supervisory authority is:

Comissão Nacional de Proteção de Dados — CNPD
Av. D. Carlos I, 134, 1.º
1200-651 Lisboa
Portugal

17. Data Relating to Minors

The services made available through the FHH Website are primarily intended for companies, entrepreneurs, professionals and individuals acting in a professional context.

FHH does not intend to knowingly collect personal data relating to minors through the Website.

Where improper processing of a minor’s data is identified, appropriate measures will be taken to delete or regularise such data where legally required.

18. Changes to the Privacy Policy

FHH may update this Privacy Policy whenever legal, regulatory, technological, operational or data processing-related changes occur.

The updated version will be made available on the Website and will indicate the relevant date of the latest update.

Where changes are materially significant, additional measures may be adopted to inform users.

19. Contact Details

For any questions relating to this Privacy Policy or the processing of your personal data:

FHH
FHH Portugal Unipessoal Lda
Tax ID / Company Registration Number (NIF/NIPC): 519 600 185
Address: Rua Comissão Iniciativa, Torre Brasil, Nr. 2A, E403, 4.º, 2410-098 Leiria, Portugal
Telephone: +351 244 024 781
Email: info@fhh-portugal.pt