Privacy Policy

1. Introduction

This Privacy Notice establishes how Portugal Footprints protects the privacy of the personal data of its employees, clients, partners, or any other entity with which Portugal Footprints relates in the context of its activity. 

As a travel agency and DMC, Portugal Footprints is required to collect, utilize and disclose personal data to facilitate essential functions and business operations, which involve handling and managing travel reservations on behalf of our clients. We are fully dedicated to safeguarding the privacy and confidentiality of all personal data and maintain a range of process-related controls to ensure its protection.

At Portugal Footprints, we take data privacy seriously and are committed to endorsing the new General Data Protection Regulations (GDPR) and other applicable legislation, which are built around the principles of transparency and control. Our operations are based in Portugal and we have implemented a consistent approach to data protection providing you with peace of mind when working with us, regardless of your location in the world. This notice comprehensively covers information about your privacy rights and the legal protections afforded to you.

Our Privacy Notice will inform you about how we handle your personal data when you visit our website or social media pages, regardless of where you access them from, or when you provide personal data to us through alternative channels, such as telephone, email, Skype, WhatsApp, etc.

2. Purpose of this Privacy Policy

It is important that you carefully review this privacy notice alongside any other privacy notice or fair processing notice we may provide on specific occasions when we collect or process your personal data. By doing so, you will have a comprehensive understanding of how and why we utilize your data. Please note that this privacy notice complements the other notices and does not supersede them.

Personal data is collected for the following purposes:

  • Facilitating the proper functioning of the activity associated with a Destination Management Company (DMC).

  • Providing necessary information to service providers involved in fulfilling the reservations or services contracted by the Client.

  • Managing, administering, expanding, and improving the services subscribed to or used by the Client, tailored to their preferences and interests.

  • Verifying credit cards and other payment methods indicated by the Client for payment purposes.

  • Conducting analyses on the usage patterns of services by Clients.

  • Establishing and developing statistical analyses.

  • Carrying out advertising, promotional and commercial prospecting activities, subject to the Client's consent.

  • Offering optional survey forms to the Client for feedback purposes.

The Client has the option to grant Portugal Footprints permission to process their personal data in order to assess their profile and provide them with appropriate products and services. These services may be provided by Portugal Footprints or third-party entities.

Portugal Footprints may share the Client's information with third parties solely for the purpose of fulfilling the requested reservation and for administrative reasons, as required by the applicable legislation for travel/service implementation.

 

3. Data Controller

Portugal Footprints is the data controller and responsible for handling your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

You can reach out to Portugal Footprints via email at info@portugalfootprints.com or by contacting us at our physical address: Rua Almada Negreiros, Nº 14, Bloco 1. 1º Dto, 2790-304 Queijas.

If you have any inquiries regarding this privacy notice or wish to exercise your legal rights, please contact us using the email address provided above.

While you retain the right to lodge a complaint with the Comissão Nacional de Proteção de Dados (National Data Protection Committee), we believe in a collaborative approach to addressing concerns and would appreciate the opportunity to handle any issues directly with you in the first instance.

4. Type of Data Collection

Personal data or personal information refers to any information about an individual through which their identity can be determined. It does not include data where the identity has been removed (anonymous data).

In the course of our interactions, we may collect, use, store, and transfer various types of personal data, which we have categorized as follows:

  • Identity Data: This category comprises details unique to your identity, including your first name, last name, username, or any comparable identifier. Additionally, it encompasses information necessary for event services with suppliers, such as hotels, which may require passport details or gender-related data.

  • Contact Data: This encompasses details that enable us to get in touch with you, such as your postal address, email address, telephone numbers, Skype ID and other communication channels.

  • Financial Data: This comprises information related to your payment methods, such as bank account and payment card details.

  • Transaction Data: This involves particulars of the transactions you undertake with us, including payment details and other information about services you have purchased.

  • Technical Data: Additional technical information that we may collect when you use our website, such as your IP address, login data, time zone, browser type, operating system, and other device-related data.

  • Usage Data: This includes information about how you interact with our website and utilize our services.

  • Marketing and Communications Data: This includes your preferences concerning marketing communications from us and third parties, as well as your communication preferences.

  • Aggregated Data: This includes statistical or demographic data that may be derived from your personal data but does not disclose your identity directly or indirectly. Such data is not considered personal data in the eyes of the law.

On certain occasions, we may collect personal data from our clients that could be classified as sensitive data in accordance with local data protection laws. Sensitive data can include information related to:

  • Dietary requirements which may disclose your religious or philosophical beliefs

  • Affiliation with political, professional, or commercial associations

  • Loyalty programs/frequent flyer detailed data

  • Health

  • Passport or ID details for travel bookings or certain entrance passes and/or visa issuance support

  • Genetic and biometric data

Generally, the type of personal information we collect is necessary to facilitate travel arrangements, support reservations or to arrange services and/or products relating to travel on behalf of our clients.

Our collection of sensitive data adheres strictly to local data protection laws and requires explicit consent from the subject. We will only collect such data when reasonably necessary or directly related to our functions or operational activities, particularly for events, conferences or incentive travel programs, unless otherwise mandated or allowed by law. Furthermore, we will use and disclose sensitive data solely for the purpose for which it was collected, as permitted by local data protection laws. For instance, if our clients willingly share their religious beliefs to explore vacation packages tailored to their interests, we will use and disclose this information solely to organize the trip

If you fail to provide personal data

By providing us with your personal data, you acknowledge that this notice governs how we handle and process such information, and you consent to the collection, usage, and disclosure of your personal data as outlined herein. If you disagree with any aspect or part of this Notice, kindly refrain from providing us with your personal data. However, should you choose to grant consent for the use of your personal data, you reserve the right to withdraw that consent at any time.

Please be aware that not providing us with your personal data or withdrawing your consent as per this Notice may impact our ability to offer services or potentially affect the quality of the services provided.

5. Data Retention

Portugal Footprints retains your personal data only for the necessary duration to fulfill the purposes for which it was collected, in strict accordance with the law and guidelines provided by the Comissão Nacional de Proteção de Dados (the National Commission for the Protection of Data), or until you exercise your right to object, request erasure, or withdraw your consent, whichever is applicable.

To determine the appropriate retention period, we take into account the amount, nature, and sensitivity of the personal data, the potential risk of unauthorized use or disclosure, the specific purposes for which we process the data, the possibility of achieving those purposes through alternative means and the relevant legal requirements.

Moreover, certain basic information about our clients, such as contact, identity, financial, and transaction data, is mandated by law to be retained for ten years after they cease being clients for legal and tax purposes.

6. Methods of Data Collection

We use different methods to collect data from and about you including through:

  • Direct interactions:

    • when you fill in forms

    • when you correspond with us by post, phone or email

    • when you complete online registration forms 

    • when you request that we provide services or information to you

    • when you register on our website

    • when you request leaflets or other information

    • when you enter contests or register in campaigns/promotions

    • when you sign up to receive marketing communications (for example newsletters)

    • you reply to a survey and provide feedback

    • when you complete online job applications, including registering as a freelance specialist

  • Automated technologies or interactions as you interact with our website. We may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy below.

  • Various third parties as the Registo Comercial and the Comissão Nacional de Eleições based inside the EU (your identity contact and financial data from publicly available sources).

We adhere strictly to local data protection laws while collecting personal data. Generally, we gather personal data within the context of interactions with our clients, obtaining it directly from them unless it is impractical or unreasonable to do so.

We take utmost care to maintain the accuracy and completeness of the personal data we store and ensure it remains up-to-date. If there are any changes to your personal data or if you become aware of any inaccuracies, we encourage you to promptly inform us. However, please be aware that we will not be held responsible for any losses resulting from inaccurate, faulty, or incomplete personal information provided by you or anyone acting on your behalf.

7. Personal Data Usage

We will utilize your personal data only in situations permitted by law. The most common circumstances in which we will use your personal data are as follows:

  • To fulfil a contract with you and recover any debts owed to us.

  • To request your feedback through reviews or surveys, enabling us to update our records and comprehend how clients use our products and services.

  • To manage and safeguard our website, ensuring network security and preventing fraud.

  • To offer suggestions and recommendations regarding goods or services that might be of interest to you.

  • To process applications and foster business growth.

  • To comply with legal or regulatory obligations.

  • To develop and improve our products and services.

  • To maintain or improve the relationship with our clients, namely by creating and maintaining a customer profile that allows the delivery of a service aligned with their preferences.

  • To facilitate the participation of our clients in loyalty programs.

Typically, we do not rely on your consent as the legal basis for processing your personal data, except in cases of direct marketing communications sent via email or text message. These campaigns may include, but are not limited to, email submissions, digital marketing and other electronic notifications. You can choose to stop receiving marketing messages at any time by either using the "unsubscribe" option in our emails or contacting us at info@portugalfootprints.com. However, please note that opting out of marketing messages will not affect any personal data provided to us in relation to the services we provide or other transactions.

8. Personal Data Sharing

We may share personal data with our travel and events' service providers, such as hotels, transportation companies, and venues, or other providers related to reservations. These travel service providers may also use the personal data as described in their respective privacy policies to facilitate the booking process or provide the requested services. We advise our clients to review the privacy policies of any travel and event service providers they utilize through Portugal Footprints. Should you request it, we will provide copies of the relevant terms, conditions and privacy policies of these providers.

Since we act as intermediaries for a vast number of travel and event service providers, it is not feasible to list them all in this Notice, particularly their locations but these are some of them:

  • Contracted entities, suppliers and service providers

  • Event service providers such as transportation companies, restaurants, airlines, team-building companies, hotels, catering companies, historical venues, transfer managers, and related service providers

  • Contact persons (e.g., family members) when our clients are not reachable and contact is deemed in the client's interest (e.g., for well-being or in unforeseen circumstances).

  • Publishers, printers, and distributors of marketing materials

  • Organizers of events and exhibitions

  • Courier services

  • External consultants (e.g., lawyers, accountants, auditors, or recruitment consultants)

  • Travel service providers, such as wholesalers, tour operators, car rental companies and related service providers.

  • Individuals making travel reservations on behalf of others (e.g., family members, friends, or co-workers)

  • Employers in the context of corporate or government business trips

  • As required or authorized by applicable law to comply with Portugal Footprints' legal obligations

  • Customs or immigration services to meet applicable legal obligations related to travel.

  • Government agencies or public authorities to comply with valid and authorized requests, including court orders or other legal processes.

  • Regulatory authorities or law enforcement agencies for fraud protection and security purposes.

  • Supervisory agencies when there is suspicion of illegal activity, and personal data are necessary for investigation or reporting

In the event of acquiring or merging with other businesses, your personal data may be used by the new owners as outlined in this privacy notice.

Furthermore, we will not disclose personal information without consent, except when we believe it is necessary to prevent a threat to life, health, or safety, protect public health or safety, or take action regarding criminal offences, or when authorized or required by law (including data protection/privacy laws).

We require all third parties to respect the security of your personal data and handle it in accordance with the law. We do not permit our third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.

Third-party links

This website may contain links to third-party sites, including plug-ins and applications, over which Portugal Footprints has no control. Clicking on such links or enabling connections may lead to the collection or sharing of your personal data by third parties. Please note that Portugal Footprints is not responsible for the privacy statements of these third-party websites, as they may have different practices from ours. As you leave our website, we recommend reading the privacy notice of every website you visit to understand their data handling policies.

9. Data Transferred Abroad

Although we primarily operate in Portugal, personal data may be shared with our related entities abroad to provide support in travel reservations and/or facilitate administrative, consultative or technical services including data storage and processing. These suppliers play a crucial role in delivering services to you. As such, we comply with the principles of GDPR or equivalent applicable legislation and may transfer data to foreign countries (in relation to the services provided to you under the contract for your benefit) and your consent is hereby granted for such transfers.

You also acknowledge that when your personal data is transferred outside the EU, data protection controls may not be as comprehensive as those required within the EU. In such instances, Portugal Footprints cannot be held accountable for how these recipients handle, store and process your personal data.

10. Data Security

At Portugal Footprints, we implement appropriate security measures to prevent accidental loss, unauthorized access, alteration, or disclosure of your personal data. We ensure that access to your personal data is limited to employees, agents, contractors, and other third parties who process the data solely based on our instructions.

Our security controls are subject to regular monitoring and review, and we prioritize the protection of personal data with the same diligence as sensitive business information. We have established procedures to address any suspected personal data breach and will notify you and the relevant regulator in accordance with legal requirements.

Personal data is destroyed or de-identified when it is no longer relevant to our business or as mandated by law.

Nevertheless, please be aware that while we take significant measures to safeguard your data, no method of transmission over the internet or electronic storage can be entirely infallible, and we cannot guarantee absolute data security.

11. Your Legal Rights

Under data protection laws, you have certain rights concerning your personal data, which include:

  • Request access to your personal data

  • Request correction of your personal data

  • Request erasure of your personal data

  • Object to processing of your personal data

  • Request restriction of processing your personal data

  • Request transfer of your personal data

  • Right to withdraw consent

You have the right to access, correct, update, or delete your personal information at any time. If you wish to exercise any of these rights or have any questions regarding your data, please contact us at info@portugalfootprints.com.

Portugal Footprints retains the right to:

  • Deny access to the information for reasons allowed by applicable law. In such cases, we will communicate the reasons for refusal in writing, except when doing so is unreasonable or prohibited by local data protection laws.

  • Charge a reasonable administrative fee for manifestly unfounded or excessive requests for access to personal data or for any additional copies of personal data requested.

To confirm your identity and ensure your right to access your personal data (or exercise any other rights), we may require specific information from you. This is a security measure to prevent disclosure to unauthorized individuals. Additionally, we might contact you for further information related to your request to expedite our response.

We strive to address all legitimate requests within four weeks. However, in complex cases or when multiple requests have been made, the process might take longer. If this occurs, we will notify you and keep you informed of the progress.

12. Data Integration with Social Networks

Portugal Footprints’ website and social networks utilize networking features and tools, such as "Like" and "Share" buttons, provided and operated by external companies, which are hosted externally. These social networks may collect data related to the visited pages on the website or mobile application, including the IP address, and may set cookies to enable the networking features to function properly.

If users have activated social networking accounts, they may have the option to share data about their visits and usage of our website or mobile application with their social network accounts. Interactions with these networking features may also be tracked by third parties. Additionally, the external company providing the features may share personal data, like the user's name, profile picture, friend lists, or other voluntarily disclosed information, with Portugal Footprints, following its own policies. We may also share data with the external company to promote targeted marketing through the social network platform. Users have the option to manage data sharing and disable targeted marketing in their social network privacy settings.

All interactions with social networks are governed by the privacy policy of the external company providing them. For more information on the data protection practices of these companies, please refer directly to their respective privacy policies.

13. Cookie Policy

This Cookies Policy explains how we use cookies and similar tracking technologies on our website. By continuing to browse or use our website, you consent to the use of cookies as described in this policy.

What are Cookies?

Cookies are small text files that are placed on your device (computer, smartphone, tablet, etc.) when you visit a website. They store certain information about your interactions with the website and help improve your browsing experience.

Which types of Cookies do we Use?

  • Essential Cookies: These cookies are necessary for the website to function properly. They enable core functionalities, such as enabling you to navigate the site and access secure areas.

  • Analytical Cookies: These cookies help us analyse website traffic and usage patterns. They provide us with insights into how visitors interact with our website, which allows us to improve its performance and content.

  • Functional Cookies: These cookies enhance your experience on our website by remembering your preferences and choices (e.g., language, region) to provide a more personalized experience.

  • Advertising and Targeting Cookies: These cookies are used to deliver targeted advertisements that are relevant to your interests. They may also be used to limit the number of times you see a particular ad and help measure the effectiveness of advertising campaigns.

Third-Party Cookies

We may also use third-party cookies on our website. These cookies are set by external services that we use to enhance the functionality of our site and to provide us with valuable insights. Third-party cookies are subject to the respective privacy policies of these third-party providers.

Your Cookie Choices

Upon visiting our website you will be presented with a cookie banner seeking your consent to use non-essential cookies. You have the option to accept or decline non-essential cookies. If you choose to decline we will only use essential cookies that are necessary for the website's basic functionality.

You can also manage your cookie preferences through your web browser settings. Most browsers allow you to control cookies, including accepting or rejecting them and deleting cookies already stored on your device. However, please note that by disabling certain cookies, some features of our website may not function properly.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in applicable regulations. Any updates will be posted on this page, and the date of the last update will be indicated at the end of the policy.

This Privacy Notice was last updated on 01st January 2025.

15. Contact 

If you have any questions, comments or complaints about this Notice or about the processing of personal data, please contact us:

Name: Inês Viegas

Email: info@portugalfootprints.com

Address: Rua Almeida Negreiros, Nº 14, Bloco 1, 1º Dto, 2790-304 Queijas

We will respond to any queries or complaints received as soon as possible.