The Portugal Civics Issue LLC
Privacy Policy
Effective date: 08/02/2026 · Version 2.2 · Updated 10 August 2026
Replaces the Publication Privacy Policy of 25 May 2026, which covered the newsletter only.
1. Who we are
The Portugal Civics Issue LLC is a Texas limited liability company, file number 806683528. We publish a newsletter about Portugal's citizenship exam and we run a study platform for it.
We are the data controller for the information described here, including our newsletter subscriber list.
Email: chris@theportugalcivicsissue.com
Post: The Portugal Civics Issue LLC, 19141 Stone Oak Pkwy, Ste 104, PMB 395, San Antonio, TX 78258, United States
We answer privacy requests within 30 days, and faster where the law requires it.
2. What this policy covers
theportugalcivicsissue.com, including student sign-in atlearn.theportugalcivicsissue.com/dashboard/learn.theportugalcivicsissue.com, the practice and question bank area- Our newsletter at
read.theportugalcivicsissue.com, hosted by Substack - Email you send us
Substack, and every other provider named in section 5, also handles data under its own privacy policy. Where we name one, read theirs too.
3. What we collect
The lists below describe what we collect and what we understand our providers to collect. They are examples, not closed lists, and each provider's own policy is the authority on what it does.
If you create a student account
- Your email address, which is required
- Your name, if you give one
- Which plan you are on and whether it is active
- Your progress through each of the five themes, recorded as a percentage
- Any private notes you write in the platform
- Your quiz and practice attempts and scores in the practice area
- Technical session data, including your IP address, your browser's user agent string, and the times you sign in. This is standard authentication logging and it keeps accounts secure.
- If you were enrolled through a partner school or organization, we record which partner, so your access can be reconciled with them
You sign in either with a link emailed to you or with Google. There is no password on your account with us, so we do not store one. If you sign in with Google, Google gives us your email address, your name, and your Google account identifier. We do not receive your Google password and we do not get access to anything else in your Google account.
If you buy a plan
Payment is handled by a third-party payment provider (to be determined). You give your payment details to that provider, not to us. We never see or store your card number.
Our payment provider passes us the record of the transaction, including your email address, what was bought, when, the amount, the country you bought from for tax purposes, and the status of your subscription. We need that to give you access and to keep our books.
If you subscribe to the newsletter
Substack collects your email address, your display name if you give one, your subscription date, whether you opened or clicked an issue, the region it infers from your connection, and anything you post in comments.
If you email us
We receive your email address and whatever you write. Mail to chris@theportugalcivicsissue.com is forwarded to a Gmail account run by the same person.
If you just visit
Our sites use Google Analytics 4 to measure traffic — pages viewed, how you arrived, approximate location from your IP address, and device and browser type — but only if you accept analytics cookies. Nothing analytics-related loads until you do (see section 11). Our hosting providers keep standard server logs, which include IP addresses.
What we do not collect
We do not run advertising trackers, retargeting pixels, or behavioral profiling beyond the analytics named above. We do not buy or rent lists. We do not sell your data and we never have. We do not make automated decisions that produce legal effects about you.
4. Why we use it, and our legal basis
| What we do | Why | Legal basis (UK/EU GDPR) |
|---|---|---|
| Run your account and give you access | You asked us to | Performance of a contract |
| Save your progress and your notes | It is the product | Performance of a contract |
| Take payment and keep tax records | You bought something; the law requires records | Contract, and legal obligation |
| Reconcile access with a partner school that enrolled you | Delivering the arrangement you signed up under | Performance of a contract, and legitimate interests |
| Send you the newsletter | You signed up | Consent |
| Send service email about your account | You need to know about your own subscription | Contract |
| Keep accounts and the platform secure | Stopping account sharing and abuse | Legitimate interests |
| Measure site traffic with Google Analytics | Knowing what people read | Consent |
You can withdraw consent for marketing email at any time using the unsubscribe link in any email, or by writing to us. That does not affect anything we did before you withdrew it.
5. Who receives your data
| Recipient | What it handles | Where |
|---|---|---|
| WordPress / Tutor LMS, hosted by Nexcess | Student accounts, sign-in, progress and notes, courses, quiz attempts | United States |
| Payment provider (TBD) | Checkout, payment, tax, receipts, subscription status — once a provider is selected | To be determined |
| Netlify | Hosting for theportugalcivicsissue.com, server logs | United States |
| Sign-in with Google, Google Analytics, Workspace and Gmail email | United States | |
| Substack | The newsletter, its subscriber list, its analytics | United States |
| Partner schools and organizations | If one enrolled you, confirmation that your seat is active | Wherever that partner operates |
We picked each provider partly on its published privacy commitments. Each processes data under its own policy.
We disclose data to nobody else, except where the law requires it or to protect our rights, and we do not sell it.
6. Sending data outside your country
We operate from the United States and the providers above process data there.
Many of our readers are in the European Union, the United Kingdom, Brazil, and other CPLP countries. If that is you, your data is processed in the US. Each provider named above maintains its own safeguards for the transfers it makes, generally the EU Standard Contractual Clauses or an equivalent.
7. How long we keep it
- Student account data: while your account is open, and for 12 months after you close it in case you come back. Then we delete it.
- Private notes and progress: deleted with the account.
- Transaction and tax records: as long as US tax and accounting law requires us to keep them.
- Newsletter subscriptions: until you unsubscribe, then removed from the active list.
- Email you send us: as long as we need it to deal with what you wrote about.
Ask us to delete sooner and we will, wherever we are free to. Some records we cannot delete on request: tax and transaction records the law makes us keep, and technical logs held by our providers on their own retention schedules, including authentication logs and web server logs.
8. Your rights
Wherever you live, you can ask us to:
- Show you the data we hold about you
- Correct anything wrong
- Delete it
- Export it in a portable format
- Stop using it for a given purpose, or object to us using it at all
- Withdraw consent you gave earlier
Write to chris@theportugalcivicsissue.com. We will not charge you and we will not make it difficult. We may need to confirm who you are first.
If you are in the EU, EEA, or the UK, you also have the right to complain to your national data protection authority. In Portugal that is the Comissão Nacional de Proteção de Dados (CNPD). You do not have to come to us first, though we would rather you did so we can fix it.
If you are in California, we honor the rights the CCPA describes whether or not that law currently applies to a business our size: the right to know, to delete, to correct, to opt out of sale or sharing, to limit the use of sensitive personal information, and not to be treated differently for exercising any of them. We do not sell or share personal information as those terms are defined, so there is nothing to opt out of.
9. Children
The platform is not for children. You must be 18 or older to create an account or buy a plan.
We do not knowingly collect personal information from anyone under 18. If you are a parent or guardian and think a child has signed up, write to chris@theportugalcivicsissue.com and we will remove the account and its data.
10. Security
Student data sits in a Postgres database with row-level security enabled, so access is scoped to the signed-in account. Signing in with an emailed link or with Google means there is no password on your account with us to be stolen.
We use two-factor authentication on our own accounts with the providers above wherever they support it.
No internet service can promise absolute security. Protect the email account you sign in with, since anyone who reads your email can request a sign-in link.
If a breach happens that puts your rights at risk, we will tell you and the relevant regulator within the deadlines the law sets.
11. Cookies
The platform sets cookies that keep you signed in. Those are strictly necessary, are not optional, and the site does not work without them.
We also offer analytics cookies, through Google Analytics 4, and these are entirely optional. The first time you visit, a banner asks whether to turn them on. Nothing analytics-related — no Google Analytics script, no cookie, no request — loads or runs unless you choose Accept. If you choose No thanks, none of it ever loads, and we do not ask again as you move between pages.
You can change your mind at any time, in either direction, using the Cookie choices link in the footer of any page. Accepting turns analytics on; declining turns it off.
12. Changes
We review this policy at least once a year. If we change it materially, we will email account holders at least 30 days before it takes effect, unless the law requires something faster. The version number and effective date at the top tell you which version you are reading. We keep prior versions and will send you one on request.
13. Contact
Email: chris@theportugalcivicsissue.com
Post: The Portugal Civics Issue LLC, 19141 Stone Oak Pkwy, Ste 104, PMB 395, San Antonio, TX 78258, United States
The Portugal Civics Issue LLC, a Texas limited liability company, file number 806683528.
Related pages: Terms of Service · Refund Policy · Legal and disclaimers