Last updated: 14/07/2025

Welcome to Master Keys. This Privacy Policy explains how we collect, use, and protect the personal information you provide when using our website.

1. Who We Are
Master Keys is a professional partnership between two independent consultants from the companies Extrawisdom Lda, also known as “Trade Solutions” and HMS Marketing Unipessoal Lda, also known as “HM Suite”, both operating in the hospitality consultancy sector. Master Keys is not a separate legal entity or licensed company but a collaboration based in Portugal.

2. What Personal Data We Collect
We collect personal data solely through our website’s contact form, including:

• Name
• Email address
• Phone number
• Any information you voluntarily provide in your written message

3. Purpose of Data Collection
Your personal data is collected exclusively to:

• Respond to your inquiries
• Provide further information about our consultancy services
• Communicate with you based on your request

We do not use your information for automated decision-making or profiling.

4. Legal Basis for Processing
In accordance with the General Data Protection Regulation (Regulamento Geral sobre a Proteção de Dados – RGPD), the lawful bases for collecting and processing your personal data are:

• Consent: You provide clear consent for us to process your data by submitting the contact form.
• Legitimate Interest: To respond to inquiries and potential client requests related to our services.

5. Data Retention
We will retain your data only for as long as necessary to fulfill the purpose of your request or for as long as required by applicable law. If no further communication occurs, your data will be deleted within 12 months of your last contact.

6. Data Sharing and Transfers
Your data will not be sold, rented, or shared with third parties. It is accessible only to the two consultants from Trade Solutions and HMS Marketing for the purpose of responding to your request.

We do not transfer your personal data outside of the European Economic Area (EEA).

7. Your Rights Under RGPD
As a data subject under RGPD, you have the following rights:

• Right of access – to know what data we hold and how it is used
• Right to rectification – to correct inaccurate or incomplete data
• Right to erasure – to request the deletion of your data
• Right to restrict processing – to limit how we use your data
• Right to data portability – to receive your data in a usable format
• Right to object – to object to the use of your data under certain conditions
• Right to withdraw consent – at any time

To exercise any of these rights, please contact us via email at info@master-keys.com

If you believe your rights have been violated, you have the right to lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD), the Portuguese Data Protection Authority: https://www.cnpd.pt

8. Security Measures
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, misuse, or disclosure.

9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in the law or our practices. The latest version will always be posted on our website with the effective date.