Legal

Privacy Policy

Last updated: 31 August 2026

1. Data controller

The controller responsible for personal data processed in connection with this website and the services offered is:

Name: Gonçalo Calado Moreira da Silva
Tax identification number (NIE): X1247069D
Professional service address: Carrer Cabera 29, 08030 Barcelona, Spain
Email: contact@goncalomoreira.com

2. Personal data collected

Depending on the nature of an enquiry or engagement, the following categories of personal data may be processed:

• identity and contact data, such as a name or pseudonym and email address;
• information contained in enquiries, correspondence and follow-up communications;
• contract, billing, payment and transaction information;
• for the Trader / Investor Profile, the date, exact time and place of birth and any specific question or concern the client chooses to provide;
• for Bespoke Market Timing Research, information about the requested markets, exposure, time horizon and decision context; and
• technical information processed by the hosting platform when the website is accessed, such as IP address, browser information, request logs and security events.

A client may use a pseudonym for the Trader / Investor Profile. The date, exact time and place of birth remain necessary to perform that service.

3. Sources of personal data

Personal data is normally obtained directly from the person making an enquiry or entering into an engagement.

If a client supplies personal data concerning another person, the client is responsible for having an appropriate legal basis or authorisation to provide it and for informing that person where required.

4. Purposes and legal bases

Personal data may be processed for the following purposes:

• Responding to enquiries and assessing a proposed engagement: to take steps at the request of the individual before entering into a contract.
• Accepting, administering and performing an agreed service: where processing is necessary for the performance of a contract.
• Preparing and delivering reports, research, updates, clarifications and calls: where necessary to perform the agreed service.
• Managing invoices, payments, accounting and tax records: to perform the contract and comply with legal obligations.
• Maintaining correspondence, protecting the website and establishing or defending legal claims: on the basis of legitimate interests in administration, security and the protection of legal rights.
• Publishing a testimonial, case study or identifiable example: only with the person’s prior permission, which may be withdrawn for future use.

Personal data will not be used for unrelated marketing without an appropriate legal basis.

5. Required and optional information

Information requested to define, contract or perform a service must be supplied where indicated. If required information is not provided, it may not be possible to assess the request or deliver the service.

A client’s legal name is not required for the analytical content of a Trader / Investor Profile and a pseudonym may be used. Identification or billing information may nevertheless be required where necessary for contracting, payment or legal compliance.

6. Recipients and service providers

Personal data is not sold.

It may be processed or disclosed, only where necessary, by:

• website hosting, infrastructure and security providers;
• email and communications providers;
• banks or payment-service providers used for an agreed payment;
• professional advisers supporting accounting, tax, legal or technical matters; and
• public authorities, courts or regulators where disclosure is legally required.

Service providers are permitted to process personal data only for the relevant service and subject to applicable data-protection obligations.

7. International transfers

Some technology, hosting or communications providers may process data outside the European Economic Area.

Where an international transfer is subject to the GDPR, it will rely on an applicable adequacy decision, approved contractual safeguards or another lawful transfer mechanism.

8. Retention

Personal data is retained only for as long as reasonably necessary for the relevant purpose:

• enquiries that do not become engagements are normally retained for up to 12 months after the last substantive contact;
• service correspondence and working materials are retained through delivery and the agreed 30-day follow-up period, and may then be deleted or anonymised unless further retention is necessary;
• contracts, invoices, payment and accounting records are retained for the periods required by applicable law; and
• information necessary to establish or defend a legal claim may be retained until the relevant limitation period has expired.

Data may be retained for a longer period where required by law, an unresolved dispute or a request from a competent authority.

9. Security

Reasonable technical and organisational measures are used to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.

No internet or email transmission can be guaranteed to be completely secure. Clients should avoid sending unnecessary sensitive information and should contact the controller before sending material requiring additional safeguards.

10. Automated decision-making

Personal data is not used to make solely automated decisions that produce legal or similarly significant effects.

The analytical frameworks used in the Trader / Investor Profile support human interpretation and do not automatically determine a person’s opportunities, restrictions or financial decisions.

11. Website technology and cookies

The website does not intentionally use analytics, advertising or behavioural-marketing cookies.

The hosting and security infrastructure may process essential technical information necessary to deliver the website, maintain security and prevent misuse. If non-essential cookies or analytics are introduced in the future, the relevant information and consent controls will be provided where required.

12. Rights

Subject to the conditions established by applicable law, individuals may request:

• access to their personal data;
• rectification of inaccurate or incomplete data;
• erasure of their data;
• restriction of processing;
• objection to processing based on legitimate interests;
• data portability; and
• withdrawal of consent, where consent is the legal basis, without affecting earlier lawful processing.

Requests may be sent to contact@goncalomoreira.com. Information reasonably necessary to verify the requester’s identity may be requested before acting on a request.

Individuals also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) or another competent supervisory authority.

13. Children

The services are not directed to children. Personal data concerning a person under 18 should not be submitted without first contacting the controller and establishing an appropriate legal basis.

14. Changes to this policy

This Privacy Policy may be updated to reflect changes in the services, data-processing practices or applicable law. The current version and its revision date will remain available on this page.