Privacy Policy

Privacy Policy

Mondego AI Trading name of Howard Whiteson NIF: 320468321 Portugal

Last updated: May 2026


1. Introduction

Mondego AI, the trading name of Howard Whiteson (NIF: 320468321), is committed to protecting the privacy and personal data of all individuals whose information we process.

This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have in relation to it.

Mondego AI operates as both a data controller (in respect of data collected through this website and direct client relationships) and a data processor (in respect of personal data provided by clients for campaign purposes).


2. Who We Are

Trading name: Mondego AI Legal name: Howard Whiteson NIF: 320468321 Country of registration: Portugal Contact: [email protected] Website: https://mondego.ai


3. What Data We Collect

Data collected through this website:

Name and contact details submitted via enquiry or contact forms

Email address if provided voluntarily

Technical data including IP address, browser type, and pages visited, collected automatically via cookies and analytics tools

Data collected through client relationships:

Business contact information of client representatives

Information exchanged in the course of providing services, including emails and agreements

Data processed on behalf of clients:

Personal data contained within client databases, including names, phone numbers, email addresses, and other contact information

This data is processed solely on the instructions of the client and governed by a separate Data Processing Agreement


4. How We Use Your Data

We use personal data for the following purposes:

To respond to enquiries and communicate with prospective clients

To fulfil our contractual obligations under Partnership Agreements and Service Agreements

To operate and improve our services

To comply with legal and regulatory obligations

To send relevant service-related communications

We do not use personal data for unsolicited marketing without consent. We do not sell personal data to third parties under any circumstances.


5. Legal Basis for Processing

Where Mondego AI acts as a data controller, we process personal data on the following legal bases:

Contract: Processing necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract

Legitimate interests: Processing necessary for our legitimate business interests, including responding to enquiries and managing client relationships, where these are not overridden by your rights

Legal obligation: Processing necessary to comply with a legal obligation

Consent: Where you have given explicit consent, for example to receive communications from us


6. Data Processed on Behalf of Clients

Where Mondego AI processes personal data on behalf of a client as a data processor, the client is the data controller and is responsible for ensuring that the data has been lawfully obtained and that individuals have been informed of its intended use.

Mondego AI will process such data only in accordance with the client's documented instructions and the terms of the Data Processing Agreement in place between the parties.

Individuals whose data is processed as part of a client campaign and who wish to exercise their rights should contact the relevant client directly, as the data controller.


7. Data Sharing

Mondego AI may share personal data with the following categories of third parties where necessary to deliver our services:

Technology platform providers including GoHighLevel (CRM and automation platform)

SMS and voice service providers necessary to operate campaigns

Professional advisers including lawyers and accountants, under strict confidentiality obligations

We do not transfer personal data outside of the European Economic Area unless appropriate safeguards are in place in accordance with applicable data protection law.


8. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law.

Enquiry and contact data: up to 24 months from last contact

Client relationship data: for the duration of the agreement and up to 6 years thereafter for legal and accounting purposes

Campaign data processed on behalf of clients: as specified in the Data Processing Agreement, or returned and deleted upon termination of the agreement


9. Your Rights

Depending on your location and applicable law, you may have the following rights in respect of your personal data:

Right of access: to obtain a copy of the personal data we hold about you

Right to rectification: to have inaccurate data corrected

Right to erasure: to request deletion of your personal data in certain circumstances

Right to restriction: to restrict how we use your data in certain circumstances

Right to portability: to receive your data in a structured, machine-readable format

Right to object: to object to processing based on legitimate interests

Right to withdraw consent: where processing is based on consent, to withdraw it at any time

To exercise any of these rights, please contact us at [email protected]. We will respond within one month of receiving your request.

If you are unsatisfied with our response, you have the right to lodge a complaint with the relevant supervisory authority. In Portugal, this is the Comissão Nacional de Proteção de Dados (CNPD) at www.cnpd.pt.


10. Cookies

This website uses cookies to improve user experience and analyse site traffic. By using this website, you consent to the use of cookies in accordance with this policy.

We use the following types of cookies:

Essential cookies: necessary for the website to function

Analytics cookies: to understand how visitors use the site, using anonymised data

You can control cookie settings through your browser. Disabling certain cookies may affect the functionality of the website.


11. Security

Mondego AI takes appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction. These measures include secure platform hosting, access controls, and encrypted communications where applicable.

No method of transmission over the internet is completely secure. While we take all reasonable steps to protect your data, we cannot guarantee absolute security.


12. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page indicates when it was last revised. We encourage you to review this policy periodically.


13. Contact

For any questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact:

Howard Whiteson Mondego AI [email protected] https://mondego.ai


This Privacy Policy does not constitute legal advice. Mondego AI recommends that clients seek independent legal advice in their own jurisdiction where appropriate.