Privacy Policy

1. Information we handle

• Account and access: name, email, nationality, authentication information, account identifier, verification status, workspace memberships, roles and access-change records. The registration form also accepts a telephone number and optional passport number and expiry date. Do not provide optional identity information unless it is relevant to the service you request.
• Paid services: subscription and service entitlement information, and the customer, billing, tax, invoice and payment-status information necessary to administer your purchase. This concerns access to Fundraxis, rather than an investment in a fund. Payment data depends on the payment method used; any payment-provider notice presented during payment also applies.
• Use of the service: browser and connection information, technical request and error records, saved preferences, comparisons and information you enter into available tools or review forms. Some preferences, investor-tool inputs and drafts are saved in your browser.
• Communications and professional information: correspondence you send us, and professional names, roles and business contact information provided by organisations or found in regulatory filings, reports and other business sources.

Required registration fields are identified in the form. Without the information needed to create and secure an account, provide a purchased service or issue an invoice, we may be unable to complete that operation. Optional fields are not a requirement to buy an investment.

2. Why we use personal data

We use information needed to register and authenticate you, provide paid access, administer subscriptions and respond to service requests to perform our contract with you or take steps you request before entering it. Accounting, tax and legally required records are handled to meet legal obligations.

Protecting accounts, investigating misuse, maintaining service reliability and managing business correspondence serve our legitimate interests in operating a secure service. Maintaining relevant professional information in Portugal Funds serves our legitimate interest in providing accurate fund research. These interests must be balanced against the rights of the people concerned.

If we request consent for a separate optional purpose, the request will identify that purpose. You can withdraw that consent without affecting earlier lawful processing. Creating an account or paying for access is not, by itself, consent to unrelated marketing.

3. Access, service providers and external content

Access is limited to authorised personnel and service providers who need information to operate the service, manage accounts, support customers or meet legal requirements. Authentication uses Amazon Web Services Cognito; hosting and database infrastructure also use AWS. Billing, accounting and payment services may receive information necessary for the transaction or statutory records, according to the arrangement used for your purchase. Information may also be disclosed where legally required or necessary to establish or defend a legal claim.

Professional information included in Portugal Funds is available to authorised users of the database. Account credentials, private correspondence and customer billing information are not part of the fund research catalogue.

Some pages display external charts from TradingView. Loading embedded content connects your browser to that provider, which may receive connection and browser information and use its own browser storage. External services have their own privacy notices. Review the TradingView Privacy Policy before using that content.

Processing locations depend on the service provider. Where personal data is transferred outside the European Economic Area, an applicable legal transfer mechanism is required, such as an adequacy decision or appropriate contractual safeguards. Contact the privacy address above for details of the providers, locations and safeguards applicable to your service.

4. Browser storage and security

The application uses local storage and session storage for authentication sessions, verification steps, workspace selection, table preferences, comparisons and saved tool inputs or drafts. Session storage normally ends when its browser tab is closed; local storage can persist until removed. Clearing browser storage may sign you out or remove locally saved work, and does not delete records held by Nomera Capital. Use particular care on shared devices.

Access controls and authentication help protect personal information. No online service can guarantee absolute security. Keep your credentials private and report suspected unauthorised access to the privacy contact above.

5. How long information is kept

Retention depends on the purpose: account and access information is needed while the account or service relationship remains active; billing and accounting records are subject to applicable statutory periods; support and security records are kept for the period needed to resolve requests, investigate incidents or handle claims. Professional research information is assessed for continued relevance and accuracy. Records may need to be retained after an account closes where a legal obligation or an unresolved claim requires it.

You can ask for the retention period or criteria applicable to a particular record. A request to cancel a paid subscription and a request to erase personal data are separate requests: neither automatically completes the other.

6. Your choices and rights

Subject to the conditions in data-protection law, you may request access, correction, erasure, restriction or portability of your personal data, and object to processing based on legitimate interests. You may also withdraw consent where it is the basis for processing.

Send requests to privacy@nomeracapital.pt or write to the registered office above. We may need proportionate information to verify your identity. Requests normally receive a response within one month; any lawful extension will be explained.

You may complain to Portugal’s Comissão Nacional de Proteção de Dados (CNPD) or another competent supervisory authority. These rights are governed by the General Data Protection Regulation and applicable national law.

7. Analytical tools and policy updates

Fund scores and comparisons assess investment funds and observed portfolio decisions. Investor tools use the inputs you provide to support your own research; their outputs do not constitute a lending, insurance or immigration decision about you. See the Terms of Use & Data Disclaimer for the scope of the information service.

Changes to this policy are identified by the update date. Material changes to how your personal data is used will be communicated as required by law.