Privacy Policy

Threshold Executive, Lda
Avenida do Algarve 4, 8100-221 Loulé, Portugal

1. Data Controller Identity 

Threshold Executive, Lda (Sociedade por Quotas) operates as the primary Data Controller for all information collected through this digital perimeter. We strictly adhere to the General Data Protection Regulation (GDPR) and applicable international data protection frameworks.

2. Data Collection 

We collect specific, minimal data points required to execute our business operations. This includes:

• Identity Data: Full name and corporate title.

• Contact Data: Professional email address.

• Technical Data: IP address, browser type, and time-zone setting (collected automatically for security and analytics).

• Transaction Data: Purchase history and selected service tiers. (Note: Financial details such as credit card numbers are processed directly by our secure payment gateways and are never stored on our servers).

3. Purpose of Processing 

The collected data is utilised exclusively for the following operational objectives:

• Delivering purchased digital assets (e.g., The 7-Day Autonomic Reset).

• Managing applications for the Priority Client Roster regarding Executive Mentorships and Executive Summits.

• Improving website functionality and user experience through aggregated analytics.

• Ensuring legal compliance and maintaining the security of our digital infrastructure.

• B2B Corporate Outreach and Networking: Under the lawful basis of 'Legitimate Interest' as defined by the GDPR, we collect and process publicly available professional contact data to conduct targeted B2B outreach, establish corporate networks, and offer relevant executive resilience advisory services to appropriate enterprise leaders.

4. Usage & Third-Party Sub-Processors 

Threshold Executive, Lda strictly prohibits the sale or unauthorised distribution of your personal data. Information is shared exclusively with heavily vetted third-party infrastructure providers necessary to fulfil our operational and legal obligations. These categories of recipients include:

• Customer Relationship Management (CRM): Enterprise-grade platforms used to track corporate pipelines, schedule audits, and manage client communication securely.

• Data Verification & Outbound Communication: Encrypted infrastructure utilised to verify the validity of professional contact data and dispatch corporate B2B correspondence.

• Payment Processing: Encrypted, industry-standard financial gateways. We do not process or store credit card details or secure financial data on our servers.

• Content Delivery: Secure enterprise hosting platforms used to deliver our digital assets, audio protocols, and online programmes.

All third-party vendors act as authorised sub-processors, are bound by strict Data Processing Agreements (DPAs) with standard contractual clauses, and operate under maximum enterprise security protocols.

5. Data Retention Parameters 

We retain personal data only for the duration necessary to fulfil our stated operational objectives, manage our corporate agreements, or comply with Portuguese and international tax obligations. Publicly sourced B2B contact data processed under 'Legitimate Interest' for outbound outreach is systematically purged or anonymised after 12 months of inactivity.

6. Security Measures 

We deploy robust physical, electronic, and managerial procedures to safeguard your data. This includes Secure Socket Layer (SSL) encryption across all web traffic, strict access controls for internal personnel, and regular security audits to prevent unauthorised access, alteration, or disclosure.

7. User Rights (GDPR) 

You maintain absolute sovereignty over your digital footprint. Under GDPR, you possess the right to:

• Access: Request a copy of the personal data we hold about you.

• Rectification: Correct any inaccurate or incomplete data.

• Erasure: Request the complete deletion of your personal data from our systems (the "right to be forgotten").

• Restriction: Request the suspension of the processing of your personal data.

• Data Portability: Request the transfer of your data to a third party.

8. Opt-Out Procedures & Contact 

You may withdraw consent for data processing or opt out of any communications at any time. Every correspondence from Threshold, Lda. includes a direct opt-out mechanism.

9. International Regulatory Compliance 

Threshold Executive, Lda operates under the jurisdiction of Portugal and complies strictly with the European General Data Protection Regulation (GDPR).

• UK Clients (UK GDPR): We process data in compliance with the UK GDPR and the Data Protection Act 2018. Your rights to access, rectification, and erasure remain absolute.

• United States Clients (CCPA/CPRA): For residents of California and applicable US states, we explicitly state that we do not sell your personal data. You maintain the right to request disclosure of data collection practices and request deletion of your information at any time.

• Canadian Clients (PIPEDA): We adhere to the fair information principles set out by PIPEDA, ensuring that personal data is gathered with consent and used solely for the stated operational purposes.

All cross-border data transfers are secured via standard contractual clauses and enterprise-grade encryption. To exercise any of your international data rights, contact the Data Controller at contact@thresholdexecutive.com.

To execute a data request, withdraw consent, or inquire about these policies, submit a formal request to our administration at contact@thresholdexecutive.com