re.tone, contact: data.protection@retone.mx

What is the scope of this Privacy Policy?

This Privacy Policy applies when you visit retone.mx, retone.pt or contact us through its forms; subscribe to our newsletter or receive our marketing communications; work with us as a customer, prospect, partner or supplier contact; take part in our Mendix training services; or apply for a job at re.tone.

What personal data does re.tone collect and why?

re.tone collects personal data for specific purposes including: answering contact requests (name, email, company name, message); delivering customer services (business contact details, project correspondence); invoicing and accounting (name, company, tax number, billing address); training services (name, email, company, attendance, exercise results); newsletter (email and engagement metrics); business development outreach (name, job title, company, business email, interactions); website analytics (pseudonymised usage data); and recruitment (CV, contact details, application information, interview notes). All processing is based on legal grounds under GDPR Article 6.

How does re.tone handle customer services and solutions?

When re.tone builds custom Mendix applications, provides embedded delivery teams or augments a customer's team, they act as Controller for business contact data of the customer's staff (names, roles, emails, project correspondence), and as Processor for any personal data inside the customer's applications and environments, processing it only on the customer's documented instructions under a data processing agreement.

How does re.tone use AI?

re.tone does not put customer personal data into AI tools unless the customer has approved it for that project. A person reviews all AI-assisted output before use or delivery. re.tone does not use AI to make automated decisions about individuals, including in recruitment. If an AI assistant is added to the website, users will be clearly informed they are interacting with AI.

How long does re.tone keep personal data?

re.tone keeps personal data only as long as the purpose requires. Customer, prospect and partner contacts are kept while in contact, with records deleted after 12 months of no interaction at yearly review. Newsletter data is kept until unsubscribe. Invoices and accounting records are kept for 10 years as Portuguese tax law requires. Job applications are kept until the recruitment process ends, or longer only with consent for future openings. Website analytics retention is set in Google Analytics.

What rights do individuals have under GDPR?

Under the GDPR, individuals have the right to: access the personal data held about them; have inaccurate data corrected; have data erased; restrict processing; receive data in a portable format; object to processing based on legitimate interest, including direct marketing, at any time; and withdraw consent at any time without affecting prior processing. Contact data.protection@retone.mx to exercise these rights.

Privacy Policy

1. Who we are

Honra Vertical, Lda., trading as re.tone, is the controller of the personal data described in this policy. We are a company registered in Portugal with tax and registration number (NIPC) 517436051, located at Rua dos Três Lagares, Incubadora A Praça, 6230-421 Fundão, Portugal.

For any question about this policy or your personal data, contact us at data.protection@retone.mx or by post at the address above.

We have not appointed a Data Protection Officer, as we are not required to under Article 37 of the GDPR.

2. Scope

This policy explains how we process personal data when you:

visit retone.mx, retone.pt or contact us through its forms;
subscribe to our newsletter or receive our marketing communications;
work with us as a customer, prospect, partner or supplier contact;
take part in our Mendix training services;apply for a job at re.tone.

You can always choose to provide less information. However, omitting some of this personal information may limit your ability to access all of the benefits of our website and services.

3. What we collect, why, and on what legal basis

We collect only what we need for each purpose below.

Purpose	Personal data	Legal basis (GDPR Art. 6)
Answering contact and "talk with an expert" requests	Name, email, company name, your message	Steps before a contract (6(1)(b)) or our legitimate interest in answering business enquiries (6(1)(f))
Delivering customer services and managing the contract	Business contact details of customer staff, project correspondence, meeting notes	Contract (6(1)(b)) and legitimate interest (6(1)(f))
Invoicing and accounting	Name, company, tax number, billing address	Legal obligation (6(1)(c))
Training services	Name, email, company, attendance, exercise results	Contract (6(1)(b))
Newsletter	Email and email opens and clicks	Consent (6(1)(a)), which you can withdraw at any time
Business development outreach to professional contacts	Name, job title, company, business email, interactions with us	Legitimate interest in promoting our services to businesses (6(1)(f))
Website analytics	Pseudonymised usage data, device and browser data, approximate location	Consent via the cookie banner (6(1)(a))
Recruitment	CV, contact details, information in your application, interview notes	Steps before an employment contract (6(1)(b)); consent for keeping your CV for future openings (6(1)(a))

We do not sell personal data, and we do not use it for profiling or automated decisions that have legal or similarly significant effects on you.

4. Customer services and re.tone own solutions

When we build custom Mendix applications, provide embedded delivery teams or augment a customer's team, we hold two roles:

Controller for the business contact data of the customer's staff we work with (names, roles, emails, project correspondence).
Processor for any personal data inside the customer's applications and environments. We process it only on the customer's documented instructions, under a data processing agreement, and only to the extent needed to deliver the service. Questions about that data should go to the customer.

re.tone own solutions are deployed and run by each customer in environments the customer manages. The customer owns and controls all data in its re.level instance. re.tone does not access that data and is not its controller or processor, unless a separate support agreement says otherwise.

5. Training services

For Mendix training services, we process participants' names, business emails, company, attendance and progress on exercises. We use this to run the sessions, track progress and issue completion records.

When a company enrols its own staff, that company decides who attends and receives their progress reports. We do not share participant data with Mendix or any other third party. If we record a session, we tell participants beforehand and ask for their agreement.

6. Marketing: website forms, newsletter, outreach and analytics

Website forms. Contact, "talk with an expert" and newsletter forms on retone.mx are managed in ActiveCampaign, and submissions are stored there.

Newsletter. We send it only to people who subscribed. Every email has an unsubscribe link, and we keep a record of when you subscribed and unsubscribed. ActiveCampaign records opens and clicks so we can see which content is useful.

Business development outreach. We may contact professionals at companies that could benefit from Mendix, low-code, agentic enterprise and AI services. We use business contact details that are publicly available, for example on company websites or professional networks, and tell you the source in our first message. You can object at any time, and we will stop contacting you.

Analytics. We use Google Analytics to understand how visitors use our website. It only runs if you accept analytics cookies in our banner.

Social media. When you interact with our social media accounts, such as LinkedIn, those platforms process your data under their own policies. For page statistics, we and the platform may act as joint controllers.

7. Recruitment

You can apply by sending your CV by email. We use your application only to assess you for the role, and only people involved in hiring can see it.

Please do not include sensitive information, such as health data, in your CV. If you are not hired, we delete your application when the process ends, unless you agree that we keep it for future openings.

8. Use of AI

We use Google Gemini to help with drafting, analysis and software delivery. Under these business terms, Google does not use our content to train its models.

We follow three rules:

We do not put customer personal data into AI tools unless the customer has approved it for that project.
A person reviews all AI-assisted output before we use or deliver it.
We do not use AI to make automated decisions about you, including in recruitment.

If we add an AI assistant to our website, we will tell you clearly that you are interacting with AI.

9. Who receives your data

We do not share personal data with third parties for their own purposes. We use these service providers (processors), bound by data processing agreements.

We may also disclose data to our accountants, legal advisers, or public authorities when the law requires it.

10. How long we keep your data

We keep personal data only as long as the purpose requires, and we review our contact records at least once a year.

Data	How long we keep it
Customer, prospect and partner contacts	While we are in contact. We delete records with no interaction in the previous 12 months at our yearly review.
Newsletter	Until you unsubscribe. We keep a record of your consent and unsubscribe as proof.
Invoices and accounting records	10 years, as Portuguese tax law requires.
Job applications	Until the recruitment process ends, or longer only if you agree that we keep your CV for future openings.
Website analytics	As set in Google Analytics.

If we add an AI assistant to our website, we will tell you clearly that you are interacting with AI.

11. Your rights

Under the GDPR, you have the right to:

Access the personal data we hold about you;
Have inaccurate data corrected;
Have your data erased;
Restrict how we process it;
Receive your data in a portable format;
Object to processing based on our legitimate interest, including direct marketing, at any time;
Withdraw your consent at any time, without affecting processing done before you withdrew it.

To exercise any right, email data.protection@retone.mx.

Last updated: October 19th, 2026

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