Privacy Policy
This Privacy Policy describes how The Vanderbilt Portfolio (“we,” “us,” or “our”) collects, uses, stores, shares, and protects information when you visit and interact with the Luanda Refinery intelligence platform, located at luandarefinery.com (“the Platform”). We are committed to protecting your privacy and handling any personal information we collect with care, transparency, and in accordance with applicable data protection legislation.
This Privacy Policy applies to all visitors to the Platform, regardless of geographic location, and covers all information collected through the Platform, whether automatically through technical means or voluntarily provided by users through communications and inquiries. We encourage you to read this Privacy Policy in full to understand our data practices before using the Platform.
By accessing and using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and sharing of information as described herein. If you do not agree with any aspect of this Privacy Policy, you should discontinue use of the Platform.
Information We Collect
The Platform collects several categories of information, each serving distinct purposes related to the operation, improvement, and monetization of the Platform. We distinguish between information that is collected automatically through technical means and information that is voluntarily provided by users.
Automatically Collected Information
When you visit the Platform, our web servers and analytics tools automatically collect certain technical information about your visit. This information is collected through standard web server logs, analytics scripts, and cookie technologies, and includes the following categories of data:
Network and Device Information. Your Internet Protocol (IP) address, which may be used to derive your approximate geographic location at the city or regional level. The type and version of the web browser you are using, including the browser’s user-agent string. Your operating system and its version. Your device type, including whether you are accessing the Platform from a desktop computer, laptop, tablet, or mobile phone. Your screen resolution and display characteristics. Your Internet service provider or mobile network operator.
Navigation and Usage Information. The URL of the website or page that referred you to the Platform, commonly known as the referring URL. The specific pages you visited on the Platform and the order in which you visited them. The date and time of your visit and the duration of time spent on each page. The links you clicked within the Platform, including links to external websites. The search terms you used if you arrived at the Platform through a search engine. Scrolling behavior and interaction patterns on individual pages.
Technical Performance Information. Page load times and rendering performance data. Error logs and technical exceptions encountered during your visit. Network latency and connection quality indicators.
This automatically collected information is used to understand how visitors discover and navigate the Platform, to identify the most popular and useful content, to optimize the Platform’s performance and user experience, to detect and prevent abuse and unauthorized access, and to generate aggregate statistical reports about Platform usage.
Information You Voluntarily Provide
When you contact us by email, submit an inquiry through any communication channel, or otherwise voluntarily provide information, we may collect the following categories of data:
Contact Information. Your name, email address, telephone number, and any other contact details you choose to provide. Your professional title, organizational affiliation, and business address if you provide this information in connection with a professional inquiry.
Communication Content. The content of your emails, messages, and inquiries, including any attachments or supporting materials you choose to share. Your feedback, comments, suggestions, and any other information you include in your communications with us.
Professional and Research Information. If you submit a custom research request, we may collect information about your research needs, your organization, your intended use of research deliverables, and your budget and timeline parameters.
We collect this voluntarily provided information solely for the purpose of responding to your inquiry, fulfilling your research or information request, and maintaining records of our communications for quality assurance and operational purposes.
Cookies and Tracking Technologies
The Platform uses cookies and similar tracking technologies to enable certain functionality, to collect analytics data, and to support the display of advertisements. A cookie is a small text file that is stored on your computer or mobile device when you visit a website. Cookies are widely used by website operators to enable website functionality, to improve user experience, and to provide information for analytics and advertising purposes.
For detailed information about the specific cookies used on the Platform, how they function, and your options for managing them, please refer to our dedicated Cookie Policy, which is available on the Platform and should be read in conjunction with this Privacy Policy.
The categories of cookies and tracking technologies used on the Platform include essential cookies that are necessary for the Platform to function correctly, analytics cookies that help us understand visitor behavior and improve the Platform, and advertising cookies that are used by third-party advertising partners to serve relevant advertisements.
Google Analytics
The Platform uses Google Analytics, a web analytics service provided by Google LLC (“Google”), to collect and analyze visitor traffic data. Google Analytics uses cookies to track visitor interactions with the Platform and to generate statistical reports about Platform usage. The data collected by Google Analytics includes, but is not limited to, page views and unique page views, session duration and bounce rate, geographic location of visitors at the country, region, and city level, traffic sources and referral paths, device and browser characteristics, and user flow and navigation patterns.
Google Analytics data is transmitted to and processed by Google on servers that may be located outside your country of residence. Google processes this data in accordance with Google’s Privacy Policy and Terms of Service. Google may also use this data to contextualize and personalize the ads of its own advertising network.
We have configured Google Analytics to anonymize IP addresses before storage and processing, which means that the full IP address is never stored by Google. We have also set the data retention period for Google Analytics data to the minimum available setting consistent with our analytical needs.
You can opt out of Google Analytics data collection by installing the Google Analytics Opt-Out Browser Add-on, which is available at tools.google.com/dlpage/gaoptout. This add-on instructs the Google Analytics JavaScript running on websites not to send information about your visit to Google Analytics.
Google AdSense
The Platform may display advertisements served by Google AdSense, a program operated by Google LLC that allows website publishers to display targeted advertisements. Google AdSense uses cookies, web beacons, and similar technologies to serve advertisements that are relevant to your interests based on your browsing history across this and other websites.
Google AdSense cookies may collect information about your visits to this and other websites, including the pages you viewed, the advertisements you interacted with, and the products or services you showed interest in. This information is used by Google and its advertising partners to build a profile of your interests and to display advertisements that are more likely to be relevant to you.
The use of advertising cookies by Google AdSense is governed by Google’s Privacy Policy and the Google Advertising Privacy Policy. You can opt out of personalized advertising by visiting Google’s Ad Settings page at adssettings.google.com, where you can adjust your advertising preferences and opt out of personalized ads. You can also opt out of third-party advertising cookies by visiting the Digital Advertising Alliance’s opt-out page at optout.aboutads.info or the Network Advertising Initiative’s opt-out page at optout.networkadvertising.org.
How We Use Information
The information collected through the Platform is used for the following purposes:
Platform Operation and Maintenance. To provide, operate, and maintain the Platform, including ensuring that pages load correctly, that content is displayed properly, and that the Platform remains accessible and functional.
Content Improvement and Development. To analyze visitor traffic patterns and engagement metrics in order to understand which content is most valuable to our readership, to identify gaps in our coverage, and to inform editorial planning decisions about future content development.
Analytics and Reporting. To generate aggregate statistical reports about Platform usage, traffic sources, geographic distribution of visitors, and content performance. These reports are used internally for operational and strategic purposes and do not identify individual visitors.
Advertising. To display relevant advertisements through Google AdSense and to generate advertising revenue that supports the continued operation of the Platform and the production of free-to-access content.
Communication. To respond to inquiries, feedback, research requests, and other communications received from users through the email channels published on the Platform.
Security and Abuse Prevention. To monitor the Platform for unauthorized access, abuse, spam, scraping, and other activities that threaten the security, integrity, or availability of the Platform and its content.
Legal Compliance. To comply with applicable laws, regulations, legal processes, and governmental requests, and to establish, exercise, or defend legal claims.
Data Sharing and Disclosure
We do not sell, rent, trade, or otherwise transfer your personal information to third parties for their own marketing or commercial purposes. We may share information with third parties only in the following limited circumstances:
Analytics and Advertising Service Providers. We share technical and usage data with Google Analytics and Google AdSense, which process this data on our behalf for the purposes of analytics and advertising as described above. These service providers are bound by their own privacy policies and data processing agreements.
Legal Requirements. We may disclose information if we believe in good faith that disclosure is required by law, regulation, legal process, or governmental request, or if disclosure is necessary to protect our rights, property, or safety, or the rights, property, or safety of our users or others.
Business Transfers. In the event that The Vanderbilt Portfolio undergoes a merger, acquisition, reorganization, or sale of assets, user information may be transferred as part of that transaction. We will notify users of any such transfer and any changes to the applicable privacy policy.
With Your Consent. We may share information with third parties when you have given us your explicit consent to do so.
Data Retention
We retain different categories of information for different periods, depending on the purpose for which the information was collected and our operational, legal, and regulatory requirements.
Analytics Data. Data collected through Google Analytics is retained for a period not exceeding 26 months from the date of collection, after which it is automatically deleted. We have configured Google Analytics to use the minimum retention period consistent with our analytical needs.
Server Logs. Web server access logs, which contain IP addresses, request timestamps, and page URLs, are retained for a period not exceeding 90 days for the purpose of technical monitoring, security analysis, and abuse detection. After this period, server logs are deleted or anonymized.
Communication Records. Records of email communications, inquiries, and research requests are retained for as long as necessary to fulfill the purpose for which they were collected, to maintain records of our correspondence for quality assurance, and to comply with applicable legal obligations. Communication records are typically retained for a period of three years unless a longer retention period is required by law.
Cookie Data. The retention period for cookie data varies by cookie type and is described in detail in our Cookie Policy. Essential cookies are session-based and are deleted when you close your browser. Analytics and advertising cookies have defined expiration periods as specified by the respective cookie providers.
Your Rights
Depending on your jurisdiction and applicable data protection laws, you may have certain rights regarding your personal data. These rights may include the following:
Right of Access. You may have the right to request confirmation of whether we process your personal data and, if so, to request access to that data along with information about how it is processed.
Right to Rectification. You may have the right to request correction of inaccurate personal data and completion of incomplete personal data.
Right to Erasure. You may have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purpose for which it was collected or when you withdraw your consent.
Right to Restriction of Processing. You may have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or when you object to processing based on legitimate interests.
Right to Data Portability. You may have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance.
Right to Object. You may have the right to object to the processing of your personal data for certain purposes, including processing based on legitimate interests and processing for direct marketing purposes.
Right to Withdraw Consent. Where processing is based on your consent, you may have the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
To exercise any of these rights, please contact us at info@luandarefinery.com. We will respond to your request within the timeframe required by applicable law, and in any event within 30 days of receipt. We may request additional information from you to verify your identity before processing your request.
International Data Transfers
The Platform is operated from servers that may be located in various jurisdictions. Information collected through the Platform, including data processed by Google Analytics and Google AdSense, may be transferred to and stored on servers located outside your country of residence, including in countries that may not provide the same level of data protection as your home jurisdiction. By using the Platform, you consent to the transfer of your information to these jurisdictions. Where required by applicable law, we ensure that appropriate safeguards are in place to protect your personal data during international transfers.
Children’s Privacy
The Platform is not directed at children under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have inadvertently collected personal information from a child under 16, we will take steps to delete that information as promptly as possible. If you believe that we may have collected information from a child under 16, please contact us at info@luandarefinery.com so that we can investigate and take appropriate action.
Security Measures
We implement reasonable technical and organizational measures to protect the information we collect and maintain against unauthorized access, alteration, disclosure, or destruction. These measures include the use of encrypted connections (HTTPS/TLS) for data transmission, access controls that limit access to personal data to authorized personnel, regular security assessments and monitoring of the Platform’s infrastructure, and secure configuration of web servers and associated systems. However, no method of data transmission over the Internet and no method of electronic storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our data practices, changes in applicable law, or for other operational or regulatory reasons. When we make material changes to this Privacy Policy, we will update the effective date at the bottom of this page and may also provide notice through other reasonable means, such as a notice on the Platform’s homepage.
We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information. Your continued use of the Platform after any changes to this Privacy Policy constitutes your acceptance of the updated policy.
Contact
For questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us at:
Email: info@luandarefinery.com
We will make reasonable efforts to respond to all privacy-related inquiries within two business days of receipt. For data subject access requests and other rights-related inquiries, we will respond within the timeframe required by applicable law.
Effective date: March 22, 2026.