Privacy Policy

Last updated: January 2025. Controller: Natacha Reina da Costa e Ruffer trading as Kirk Copywriting, Av. Marquês Leal 23, 2765-495 Estoril, Portugal. VAT PT514823901.

1. Who we are

Kirk Copywriting is a copywriting agency operated by Natacha Reina da Costa e Ruffer. We provide professional copywriting and content strategy services to clients globally, delivered digitally. Our registered address is Av. Marquês Leal 23, 2765-495 Estoril, Portugal. For privacy-related questions, contact us at hello@kirkcopywriting.com.

2. What personal data we collect

We collect personal data in the following circumstances:

When you contact us

If you use our contact form, send us an email, or call us, we collect: your name, email address, phone number (if provided), and the content of your message.

When you place an order

When you proceed to checkout, we collect: first name, last name, email address, phone number, and country. Payment information is handled exclusively by Stripe and is never stored on our servers.

When you visit our website

We collect standard web server logs including IP addresses, browser type, pages visited, and referring URLs. We may use cookies for functional and analytical purposes — see our Cookie Policy for details.

3. Legal basis for processing

We process your personal data on the following legal grounds under GDPR Article 6:

  • Contract performance (Art. 6(1)(b)): processing necessary to deliver services you've purchased or to respond to your pre-contractual enquiry.
  • Legitimate interests (Art. 6(1)(f)): maintaining our website, preventing fraud, improving our services.
  • Consent (Art. 6(1)(a)): for non-essential cookies where we request your consent.
  • Legal obligation (Art. 6(1)(c)): for tax and accounting records required under Portuguese law.

4. How we use your data

  • To communicate with you about your enquiry or project
  • To process and deliver your order
  • To issue invoices and maintain required financial records
  • To respond to support or follow-up questions
  • To improve our website and services
  • To comply with legal obligations

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

5. Who we share your data with

We share personal data only with:

  • Stripe Inc.: our payment processor. Stripe's privacy policy is available at stripe.com/privacy.
  • Email/hosting providers: for operating our contact systems, under data processing agreements.
  • Accountants/tax advisors: as required for legal compliance, under confidentiality obligations.

6. Data retention

We retain personal data for as long as necessary to fulfil the purposes described above. Specifically:

  • Project and client records: 5 years after project completion, as required by Portuguese tax law.
  • Contact enquiries not leading to a project: 12 months.
  • Server logs: up to 90 days.

7. International transfers

If your data is transferred outside the European Economic Area (for example, to Stripe's servers), such transfers take place under appropriate safeguards including Standard Contractual Clauses approved by the European Commission.

8. Your rights under GDPR

As a data subject within the EEA, you have the right to:

  • Access the personal data we hold about you.
  • Rectification of inaccurate or incomplete data.
  • Erasure ("right to be forgotten") where no legal ground requires continued processing.
  • Restriction of processing in certain circumstances.
  • Data portability for data provided under consent or contract.
  • Object to processing based on legitimate interests.
  • Withdraw consent at any time where processing is consent-based.

To exercise any of these rights, contact us at hello@kirkcopywriting.com. We will respond within 30 days. You also have the right to lodge a complaint with the Portuguese supervisory authority, CNPD (Comissão Nacional de Proteção de Dados), at cnpd.pt.

9. Security

We take reasonable technical and organisational measures to protect your personal data from unauthorised access, loss, or disclosure. All data transmissions to our website are encrypted using TLS. Payment data is handled exclusively by PCI-DSS compliant Stripe infrastructure.

10. Changes to this policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated date. For material changes, we will notify active clients by email where feasible.

11. Contact

For any privacy-related questions or requests: hello@kirkcopywriting.com or by post to Av. Marquês Leal 23, 2765-495 Estoril, Portugal.