Cookie Policy

This policy applies to seamlessdoubt.com and every subdomain operated by Seamless Doubt — Sociedade Unipessoal Limitada (Portuguese VAT 519 387 473). It describes what cookies are, which ones we use, for what purpose, for how long, on what legal basis and how you can control them.

1. What is a cookie

A cookie is a small text file that a website stores on your device to retain information between visits — for instance, your theme preference. For the purposes of this policy, "cookies" also includes functionally equivalent technologies (local storage, session storage, pixels and fingerprinting), regardless of their technical name.

2. Categories of cookies we use

We classify cookies in two categories, in line with EDPB Guidelines 03/2022 and the Portuguese DPA (CNPD):

• Strictly necessary (consent-exempt): indispensable to deliver the service you explicitly requested — loading the site, recording your cookie choice and preventing abuse. They cannot be disabled without breaking the site.
• Non-essential (require prior consent): includes analytics, measurement, personalisation and any third-party cookie. They are not set before you give explicit consent in the banner.

3. Detailed inventory

Strictly necessary — always on

• sd-consent — stores your answer to the banner (accepted /rejected), so we don't ask again on every visit.
  Origin: first-party (seamlessdoubt.com). Duration: 12 months. Type: HTTP cookie. Legal basis: Art. 5(3) ePrivacy exemption (strictly necessary for a service requested by the user).
• sd-theme — stores your light/dark theme preference.
  Origin: first-party. Duration: 12 months. Type: HTTP cookie /localStorage. Legal basis: Art. 5(3) exemption (interface preference enabled by the user).
• Session and security cookies — set by Cloudflare and our hosting provider to prevent abuse, balance load and mitigate bots (e.g. __cf_bm, cf_clearance).
  Origin: Cloudflare. Duration: session up to 30 minutes. Legal basis: legitimate interest in network security (Recital 49 GDPR) and Art. 5(3) ePrivacy exemption.

Analytics — only with your consent

Only activated if you click "Accept all" in the banner. If you have not decided, or if you rejected, these cookies are not set and the corresponding scripts are not even loaded by the browser.

• Plausible Analytics (cookieless) — we favour a cookieless tool to reduce privacy impact. When enabled, it records aggregated metrics (page URL, referrer, aggregated country, device) without identifying the user, without cross-site profiling and without sharing data with third parties.
  Origin: plausible.io. Duration: no persistent cookies; stateless pixel call. Legal basis: consent (Art. 6(1)(a) GDPR).

What we don't do: we do not use advertising cookies, do no retargeting, do not share data with social networks for profiling and do not run behavioural fingerprinting.

4. Third parties and international transfers

Some technical sub-processors set strictly necessary cookies in the context of providing the service (CDN, bot mitigation). When enabled, analytics is processed in EU data centres. Should we, in future, integrate services that imply transfers outside the EEA, we will do so under the Standard Contractual Clauses approved by the European Commission (Decision 2021/914) and will update this policy accordingly.

5. How consent is obtained

1. On the first visit a non-modal banner is shown with equal visual prominence for "Accept all" and "Reject non-essential".
2. No non-essential cookie is set and no third-party script is loaded before your decision.
3. Your choice is stored in the sd-consent cookie for 12 months.
4. We treat no-choice, banner-close or continued browsing as a refusal — never as implicit acceptance.
5. Consent is specific to the cookie version described here. If we add a new category, we ask for consent again.

6. How to withdraw or change consent

Withdrawing consent is as easy as giving it, and takes effect immediately:

• On the site: click "Cookie settings" in the footer. The banner re-appears and you can redo your choice.
• In the browser: you can individually delete the sd-consent cookie or use your browser's settings (Chrome, Firefox, Safari, Edge, Brave) to clear cookies. Some preference features (theme) may stop being remembered.
• By email: write to geral@seamlessdoubt.com with the subject "Cookie consent withdrawal".

Withdrawing consent does not affect the lawfulness of processing performed before the request (Art. 7(3) GDPR).

7. Embedded third-party content

Today we do not embed videos, maps or social networks that set third-party cookies. When we publish customer videos, we will do so in privacy-enhanced mode (e.g. youtube-nocookie.com or self-hosted) and only after active user interaction, avoiding third-party cookies without consent.

8. Cookies and personal data

When a cookie allows your device to be identified, on its own or combined with other data, it is treated as personal data under the GDPR. Our Privacy Policy applies, including the rights of access, rectification, erasure, objection and portability.

9. Complaints

If you believe the processing of cookies infringes applicable law, you may lodge a complaint directly with the Portuguese Data Protection Authority (CNPD) — Av. D. Carlos I, 134, 1.º, 1200-651 Lisbon, geral@cnpd.pt — without needing to contact us first.

10. Changes to this policy

This policy may be updated to reflect technical changes, new sub-processors or new regulatory guidance. The "Last updated" date at the top reflects the version in force. Material changes (for instance, adding a new category of cookies) trigger a fresh consent request.