Privacy Policy
Effective 5 November 2026.
The controller of your data is ALEXANDRE RODRIGUES, UNIPESSOAL, LDA, Portugal. Contact: privacidade@munninlabs.com. This policy follows the EU General Data Protection Regulation (GDPR) and Brazil's Lei Geral de Proteção de Dados (LGPD).
If you only read the site
Our hosting provider (Cloudflare) processes your IP address to deliver pages and protect the site from attacks.
Ads. To keep the site free, it can show ads from Google AdSense. To show, measure and, where allowed, personalise ads, Google uses cookies and collects browser data such as your IP address, cookie identifiers, browser details and how you interact with the ads. Google does this as an independent controller, under the Google Privacy Policy and How Google uses information from sites that use its services. Where the law requires it (for example in the European Economic Area and the UK), we ask for your consent before ad cookies are used, and you can change your choice at any time. You can also turn off personalised ads in My Ad Center. Legal basis: your consent where required (GDPR art. 6(1)(a)); otherwise our legitimate interest in funding a free service (GDPR art. 6(1)(f); LGPD art. 7, IX).
We count page views ourselves, without cookies and without third-party tools, to know which cases people read. For each page view we store the page, the language, the site that linked to it, your country (from Cloudflare) and whether you use a phone or a computer, plus a code that changes every day and can't be turned back into your IP address. So we can count a reader once per day, but can't follow anyone from one day to the next or identify them. Page view records are deleted after 13 months. If your browser sends "Do Not Track" or "Global Privacy Control", nothing is counted. Legal basis: our legitimate interest in knowing how the site is used (GDPR art. 6(1)(f); LGPD art. 7, IX).
If you comment
| Data | Why | Legal basis | How long |
|---|---|---|---|
| Google account ID, email, first name and last initial | To run your account and show your name on comments | Contract (GDPR 6(1)(b); LGPD 7, V) | Until you delete your account |
| Your comments | To publish them | Contract | Until you or a moderator delete them |
| IP address, date and time of sign-ins and comments | Legal obligation to keep access records | Legal obligation (GDPR 6(1)(c); LGPD 7, II; Marco Civil art. 15) | 6 months |
| Reports, moderation decisions, strikes | To enforce the Terms of Use and handle appeals | Legitimate interest in a safe comment section (GDPR 6(1)(f); LGPD 7, IX) | While the account exists, and as long as needed for appeals or legal claims |
| Banned email, stored as an irreversible hash | To stop banned users from coming back | Legitimate interest | While the ban stands |
Our own site uses one cookie, factum_session, to keep you signed in. It's strictly
necessary, so it doesn't need consent. It expires after 30 days or when you sign out.
Automated moderation
Reported comments are analysed by an AI model (Anthropic's Claude) that can keep, hide or remove them. Only the comment text, the article and the report reasons are sent; your name and email are not. A removal counts as a strike and can lead to a ban. You can always ask for a human to review a decision by emailing privacidade@munninlabs.com (GDPR art. 22; LGPD art. 20).
Who processes data for us
- Cloudflare (hosting, database, security)
- Google (sign-in)
- Google AdSense (ads, as an independent controller; see "Ads" above)
- Anthropic (AI review of reported comments)
Some of them process data outside the EU, including in the United States. Those transfers are covered by the EU-US Data Privacy Framework or by Standard Contractual Clauses. We don't sell your data.
Your rights
You can access, correct, delete or export your data, object to processing, and ask for human review of automated decisions. You can delete your account yourself from the comment section of any article. For anything else, write to privacidade@munninlabs.com. You can also complain to the Portuguese data protection authority (CNPD, cnpd.pt) or, in Brazil, to the ANPD (gov.br/anpd).
When you delete your account, we delete your name, email and comments right away. IP records stay until the 6-month legal period ends, and a banned email stays on the blacklist as a hash.