Privacy Policy

Last updated: August 20, 2026

INTRODUCTION & DATA CONTROLLER

Paloma Feijoo (“I”, “me”, or “my”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how I collect, use, store, and safeguard your personal information when you visit https://www.palomafeijoo.com (“Website”), subscribe to my email list, or book my personal styling, image coaching, and consultancy services.

For the purpose of the EU General Data Protection Regulation (GDPR) and applicable data protection legislation, Paloma Feijoo is the Data Controller responsible for your personal data.

If you have any questions regarding this Privacy Policy, you can contact me at paloma@palomafeijoo.com.

WHAT PERSONAL DATA I COLLECT

Depending on how you interact with my Website and services, I may collect and process the following categories of personal data:

Identity & Contact Data: Name, email address, phone number, and billing details provided during booking, contact form inquiries, or digital download requests.
Service & Intake Data: Information submitted via questionnaires, intake forms, lifestyle details, sizing, style preferences, and session notes required to deliver services (UNCOVER—your style path, UNFOLD—your style edit, UNLOCK—your style identity, and UNVEIL—your style profile).
Client Photographs: Face, body silhouette, and garment photographs submitted for analysis or used to construct your custom digital Style Magazine in UNLOCK—your style identity and UNVEIL—your style profile.
Payment Data: Payment transactions processed securely through Squarespace Payments. I do not store full credit card numbers or financial details on my servers.
Technical & Usage Data: IP address, browser type, device information, and interaction data collected automatically via cookies, Squarespace Analytics, and security tools (Google reCAPTCHA).

SENSITIVE & SPECIAL CATEGORY DATA

Due to the deeply personal nature of image coaching and neurodivergent-focused styling, you may choose to share sensitive information regarding your body image, self-concept, lifestyle challenges, or neurodivergence (e.g., autism, ADHD, giftedness).

Explicit Consent: By submitting personal photos, questionnaires, or disclosing sensitive personal information, you explicitly consent to my processing this data solely for the purpose of preparing and delivering your bespoke styling and coaching services.
Withdrawal of Consent: You may withdraw your consent for sensitive data processing at any time by contacting me at paloma@palomafeijoo.com. Please note that withdrawing consent may affect my ability to deliver services that depend on photo analysis or intake data.

HOW AND WHY I PROCESS YOUR DATA (LEGAL BASES)

I process your personal data under the following legal bases:

Performance of a Contract: To fulfil booking obligations, conduct video sessions via Google Meet, prepare personalised materials, and deliver your digital Style Magazine.
Explicit Consent: To handle personal photographs, intake questionnaires, sensitive personal disclosures, and to send marketing communications when you download UNLEARN—your style reframe.
Legitimate Interests: To secure my Website against automated spam and fraud (Google reCAPTCHA), improve site performance, and manage administrative records.
Legal Obligation: To comply with tax, legal, and accounting laws in Portugal and the European Union.

GOOGLE reCAPTCHA & FORM SECURITY

My Website uses Google reCAPTCHA on contact and inquiry forms to protect against automated spam and malicious bot activity.

Data Processing: reCAPTCHA analyses hardware, software, device characteristics, and IP address data to perform risk analysis during form submissions.
Legal Basis: This data is processed based on my legitimate interest in securing my Website and communications.
Data Controller Status: Under applicable terms, Paloma Feijoo acts as the Data Controller for reCAPTCHA risk analysis data on this site, and Google acts as a Data Processor.

DATA RETENTION & DELETION TIMELINES

I retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

Client Photographs (Google Drive): Submitted photos are stored on encrypted cloud servers (Google Workspace) and are permanently deleted 30 days following the completion of your service package or the delivery of your UNVEIL—your style profile digital Style Magazine.
Client Photographs (Canva): Photos temporarily uploaded to Canva for designing personalised worksheets or your Style Magazine are permanently deleted from Canva within 7 days of service completion.
Intake Forms & Session Notes: Retained securely for up to 12 months following package completion to support ongoing client continuity, after which they are permanently deleted upon request.
Email Marketing Data: Retained until you unsubscribe via the link in any email or request complete removal.
Financial & Transaction Records: Retained for the statutory period required under Portuguese tax and accounting laws (up to 10 years).

THIRD-PARTY DATA PROCESSORS

I share your data only with trusted third-party service providers necessary to run my business and deliver your services:

Squarespace: Website hosting, appointment scheduling, and Squarespace Payments processing.
Google Workspace: Virtual 1:1 sessions (Google Meet), business email communication (Gmail), calendar scheduling (Google Calendar), and secure encrypted file storage (Google Drive).
Canva: Third-party graphic design platform used temporarily to assemble personalised exercises and custom digital Style Magazines.
Google reCAPTCHA: Website form security and threat detection.

All third-party processors are bound by data processing agreements requiring them to protect your data in compliance with GDPR.

YOUR DATA PROTECTION RIGHTS UNDER GDPR

Under European data protection law, you have the following rights:

Access: Request a copy of the personal data I hold about you.
Rectification: Request correction of inaccurate or incomplete personal data.
Erasure ("Right to be Forgotten"): Request immediate deletion of your personal data or submitted photographs.
Restriction: Request that I restrict processing of your personal data under certain conditions.
Data Portability: Request a structured, machine-readable copy of your data.
Objection: Object to processing based on legitimate interests or direct marketing.
Withdrawal of Consent: Withdraw consent for sensitive data or photo processing at any time.

To exercise any of these rights, email me directly at paloma@palomafeijoo.com.

INTERNATIONAL DATA TRANSFERS

My business operates in Lisbon, Portugal (EU). However, my primary service infrastructure relies on global service providers:

Squarespace & Google Workspace: Store data on secure servers that may include facilities in the United States.
Safeguards: Transfers outside the European Economic Area (EEA) are governed by standard contractual clauses (SCCs) and data privacy frameworks to ensure your data receives EU-equivalent protection.

SUPERVISORY AUTHORITY & COMPLAINTS

If you are located in the EU and believe your personal data has been handled improperly, you have the right to lodge a complaint with a supervisory authority.

My lead data protection authority is:

Comissão Nacional de Protecção de Dados (CNPD) Av. D. Carlos I, 134 - 1.º 1200-651 Lisboa, Portugal Website: https://www.cnpd.pt

You may also contact your local data protection authority within your EU member state.

CHILDREN'S PRIVACY

My services and Website are strictly intended for adults aged 18 and over. I do not knowingly collect or process personal data from children under 18. If you believe data from a minor has been submitted, please contact me immediately for deletion.

CHANGES TO THIS PRIVACY POLICY

I may update this Privacy Policy periodically to reflect changes in operational practices, legal requirements, or service structures. Updates become effective immediately upon posting on this page with a revised "Last updated" date.

CONTACT INFORMATION
For any privacy questions, photo deletion requests, or data access inquiries:

Paloma Feijoo
Lisbon, Portugal
Email: paloma@palomafeijoo.com
Website: https://www.palomafeijoo.com