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Privacy policy

Draft — pending legal review

Draft last updated: 2026-08-02 · v2026-08.v2

Working document pending legal review. It describes commitments the platform ALREADY enforces technically by design; points requiring regulatory decision are marked as [PENDING PCT].

1. Data controller

[PENDING PCT: name, address and contact of the controller — decision D-1]. Provisional privacy contact: the platform support channel.

2. Minimization by design

A professional’s public profile shows only a strict allowlist of professional data. Identification, contact details, address, financial data, documents and employer are never published. Internal staff searches show personal data masked by default; unmasking requires a cause and is audited.

3. Data we process and why

Account and identity (name, email, credentials, language): operating the service and access security. Professional validation (documents and identity verification): enabling publication, with PCT institutional review. Compliance (client screening): regulatory obligations. Contracting and payments (contracts, milestones, amounts, payout method): executing contracts; bank details are encrypted at rest and only the financial operator accesses them with cause. Communications (messages, tickets): providing the service and moderating with a non-destructive record.

4. Citizen identifiers

The identity number is never stored in the clear: only an irreversible cryptographic fingerprint (HMAC) is kept, allowing duplicate detection without reconstructing the number, and it is never exposed through the API or on screen.

5. Audit and traceability

Sensitive actions are kept in an immutable, cryptographically chained audit log (who, what, when and why). That log admits no modification or deletion, not even by administrators.

6. Where data is hosted

Infrastructure is hosted with European cloud providers, with no third-party dependencies while browsing (the web makes no requests to foreign domains). Backups are encrypted before leaving the server. [PENDING PCT: international transfers and their safeguards, per the framework applying to the legal vehicle].

7. Retention periods

Provisional reference: contractual and accounting data are kept while the relationship is alive and afterwards for as long as applicable accounting and tax rules require; the audit log is permanent by design. [PENDING PCT: final periods per category].

8. Individual rights

Access, rectification and erasure (the latter limited by accounting obligations and the immutable audit log) are exercised through the support channel, with identity verification of the requester. [PENDING PCT: legal bases and full catalogue of rights under the applicable law].

9. Changes to this policy

Each version is numbered and dated; a material change is announced inside the platform and requires renewed acceptance.