Privacy Policy

Last updated: 30 September 2026

This policy explains how MANICOBA uses your personal data when you visit manicoba.eu, use our "Find your solution" estimator, or contact us. We've kept it as short and plain as we can.

1. Who we are

MANICOBA is a web design, IT and marketing agency working with clients in Portugal and South Africa. The controller responsible for your personal data is:

Business: MANICOBA (Paul du Plessis)
Registered address: Rua Gil Simoes 73C Portimao 8500-449 Portugal
NIF: 307892808
Email: info@manicoba.eu
WhatsApp: +351 928 100 116

We are a small business and have not appointed a Data Protection Officer. If you have a question about your data, contact us using the details above.

2. What data we collect and where it comes from

When you use the estimator ("Find your solution"). The estimator is a guided form with four steps. You describe a business problem in your own words and answer a few questions. Please don't include sensitive personal data, or other people's personal data, in what you write. You review the suggested result, and only then enter your contact details and choose whether to send it to us.

When you send us an enquiry. If you submit the estimator result or the normal enquiry form, we receive the contact details you enter, your message, and the structured information that the form collects about your project (for example the answers you gave and the suggested solution).

When you contact us by email or WhatsApp. We keep your message and contact details so we can reply.

Staff sign-in. Our private operations area uses a sign-in service (Clerk). Only our own team signs in. Visitors and clients don't need an account.

Technical data. When you visit the site, our hosting provider and systems automatically process technical data such as your IP address, browser type and the pages you request. This is needed to deliver the site and keep it secure.

Giving us your data is up to you. To answer an enquiry we need at least a way to reach you.

3. Using AI in the estimator

AI assistance is optional and you choose whether to use it.

If you agree, the text you enter in the estimator may be sent to OpenAI, using an OpenAI model (currently gpt-5.6-luna) through Replit's OpenAI integration. OpenAI generates a project snapshot from it, which we show back to you.
If you don't agree, or AI isn't suitable for your request, a non-AI fallback creates the result instead, and your text is not sent to an AI service.
The normal enquiry form does not send your message to an AI service.
You review the result before you send anything to us. A person at MANICOBA reads each enquiry before anything is agreed. We don't make decisions about you based solely on automated processing.

4. Why we use your data and our legal basis

Purpose	Legal basis (GDPR)
Answering your enquiry and taking steps you ask for before any agreement	Steps at your request before a contract, or performance of a contract (Art. 6(1)(b))
Generating the estimator's project snapshot with AI	Your consent (Art. 6(1)(a)), which you can withdraw at any time
Replying to messages by email or WhatsApp, and running our business	Legitimate interest in answering enquiries and running a small business (Art. 6(1)(f))
Keeping the site and our systems secure and preventing abuse	Legitimate interest (Art. 6(1)(f))
Staff sign-in to our private area	Legitimate interest in keeping our systems secure (Art. 6(1)(f))
Meeting legal, tax or accounting obligations, if they apply	Legal obligation (Art. 6(1)(c))

We don't send marketing messages based on your enquiry. If we ever want to, we will ask for your consent first.

5. Where your enquiry goes

When you submit an enquiry, it is saved in a PostgreSQL database that is part of our website's infrastructure. This includes your message and the structured information about your project. A queued job then emails the enquiry to MANICOBA using our email delivery provider, Resend.

6. Who we share your data with

We don't sell your data. We use service providers that help us run the site and respond to you, and only as far as needed:

Replit (USA): hosts the website and its database, provides the OpenAI integration used for optional AI assistance, and provides a website analytics script.
OpenAI (USA): receives the text you enter in the estimator only if you choose AI assistance, in order to generate the project snapshot.
Resend (USA): delivers the enquiry emails to us.
Clerk (USA): provides sign-in for our staff area.
Google: our website loads its fonts from Google's servers, so Google receives your IP address and browser details when a page loads.
WhatsApp (Meta) and your email provider: if you choose to contact us on WhatsApp or by email, your messages are handled by those providers under their own terms and privacy policies.
OVH: provides the DNS for our domain.

We may also share data when the law requires it, for example with authorities or courts.

International transfers. Some of these providers (such as OpenAI, Resend, Replit, Clerk and Google) may process data outside the European Economic Area, including in the USA. Where that happens, the transfer relies on safeguards such as an EU adequacy decision or the European Commission's Standard Contractual Clauses, where applicable. Contact us if you would like more information.

7. How long we keep your data

Enquiries submitted through the site may be kept for up to 24 months. We review enquiries and delete or anonymise them after up to 24 months, unless we need to keep something longer for an agreement with you, a legal or tax obligation, or to deal with a complaint or legal claim.

Messages sent to us by email or WhatsApp are kept only as long as needed to answer you and keep a reasonable record of our conversation. Staff sign-in accounts are kept until the account is deleted. Technical logs kept by our hosting provider are held for a limited period set by the provider.

8. Cookies and similar technologies

See our Cookie Notice for the cookies and third-party requests currently used on the site.

9. Your rights

Under the GDPR you have the right to:

access the personal data we hold about you and get a copy;
have inaccurate data corrected (rectification);
have your data erased;
restrict how we use your data;
receive your data in a portable format (portability);
object to our use of your data where we rely on legitimate interest;
withdraw your consent at any time, where we rely on consent (for example for AI assistance). Withdrawing doesn't affect anything done before you withdrew.

To use any of these rights, email info@manicoba.eu. It's free. We may need to confirm your identity first. We will reply within one month. For complex requests we may extend this by up to two more months, and we'll tell you if we do. Some rights have legal limits.

You also have the right to complain to the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD): Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, www.cnpd.pt. We would appreciate the chance to sort out your concern first, so please contact us.

South Africa. If you are in South Africa, the Protection of Personal Information Act (POPIA) may also apply to you. It gives you similar rights, such as asking to see, correct or delete your information, and the right to complain to the Information Regulator (South Africa), inforegulator.org.za. You can use the contact details above for any request.

10. Security

We protect your data with appropriate measures. The site uses encrypted connections (HTTPS), and only our own team can open the private operations area, after signing in. No system is completely secure. If a data breach affects you, we will tell you and the relevant authority where the law requires it.

11. Children

Our website and services are meant for businesses and adults. We don't knowingly collect personal data from children. If you think a child has given us their data, contact us and we will delete it.

12. Changes to this policy

We may update this policy, for example if we add a new service or tool. The date at the top shows when it last changed.