Cookie Privacy Policy

The purpose of this privacy policy is for you to:

• Understand what data we collect;
• Understand why we collect this data;
• Understand what we do with the data.

Any processing of personal information will comply with the principles of compliant processing of personal information as set out in the Data Protection Laws. These are that personal information will be:

• Processed fairly and lawfully and in a transparent manner;
• Processed for specified, explicit, and legitimate purposes;
• Adequate, relevant, and limited to what is necessary for the purpose;
• Accurate;
• Kept in a form that permits the identification of you for no longer than necessary for the purpose it was collected and kept secure.

We collect personal information to implement and improve our services. The data we collect is: Personal information you provide to us, such as your name, address, email address, phone number, payment information, and profile-related information.

Personal information provided to us by third parties, such as user ratings or API from websites such as LinkedIn, Google, Facebook.

The Information generated by the use of our services, including, but not limited to:

• Any personal information or comments that you may provide to us through the toolkits or chatbots;
• Login details, including time;
• Settings / preferences;
• Details of your use of our website or other services and information collected through cookies and other tracking technologies, including but not limited to your IP address and device information (such as your mobile operating system name and version, phone make and model, etc.);
• Data that may be cached locally for performance improvements and offline use and the internet browser and operating system used (website).

This data may be stored in our database and captured as part of our logs or analytics systems. This information may be associated with your user account and is considered private.

Any personal information collected from you will be processed for the purposes of performing our contract with you, for legitimate business reasons, to comply with our legal obligations or where you have consented to our use of your information. We may use your personal information for the following purposes:

• To improve our services;
• To provide better recommendations;
• To complete financial transactions using payment information;
• To show profile information such as your email address, name, and profile picture;
• When you contact us we may store a record of our communication including your profile information;
• For compliance with our legal obligations. We may use your email to inform you about our services or to notify you about important changes or developments to our website, apps, or services;

With your consent, we may send you offers or marketing emails by email. We may market to you by e-mail, SMS, push notifications, post or telephone. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe, or opt-out of further communication on any electronic marketing communication sent to you or you can let us know by contacting us using the details set out below.

We share certain personal information with registered and authorized users/companies to provide our services or wish to contact you to hire you as a Data Protection Expert. We will take steps to reasonably ensure that all-sufficient technical and organizational security measures are taken by such registered and authorized users/companies to ensure that your personal data is treated securely and in accordance with this privacy policy.

We may otherwise share your information with any third party for the reasons set out above or, if necessary, for the following reasons:

• Where the disclosure is necessary to enable us to provide our services to you;
• To comply with the law, any legal process, or any governmental or law enforcement inquiry. Any such request will be reviewed by our team and maybe appealed against if such request does not follow standard procedure or unnecessarily compromises user privacy;
• Where the disclosure is to third party service providers, on the understanding that they will keep the personal information confidential; or To solve technical or security issues; or Investigations such as possible cases of fraud, violation of terms and service, or to protect the rights of publicity and our clients in compliance with the law.

Our service may contain links to other sites that are not operated by us. These sites are governed by their terms and privacy policies. As such, we are not responsible for the operation and information practices of third parties, and if you click on these links, we would strongly advise that you should read the privacy policy of these third-party sites before using the site.

Where we provide links to third-party websites, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.

We have no control over the contents of these third-party services or websites.

Payments are processed by Fareharbor, which is responsible for securely storing the payment information (e.g. credit and debit card numbers) of all our customers and users. Such information, including any financial transaction made, is subject to Fareharbor’s privacy policy.

We take security seriously, and our technical and privacy experts work day and night to protect your confidential and personal information against unauthorized access, modification, disclosure, or destruction. We will implement appropriate technical and organizational measures to ensure an appropriate level of security, including the pseudonymization and encryption of personal information and the ability to restore the availability and access to personal information in a timely manner in the event of a physical or technical incident. For example:

We encrypt communications with our services where appropriate.

We have strong guidelines for how the personal information of users and customers may be accessed by our employees and contractors.

We carefully review security measures taken by any third parties used to implement or improve our services.

We regularly review our security policies with regard to the storage, processing, and collection of personal information.

We provide awareness and training to employees and contractors.

Although we take every reasonable measure to protect our users’ information and its integrity, we do not guarantee the complete security of our applications, services, or the security of any third parties involved in the implementation or improvement of our services. Moreover, devices or communication channels may be compromised, and as such, any submission of information is done at your own risk.

We do not knowingly collect or solicit personal information from anyone under 18 or knowingly allow such persons to register for the Services. If you are under 18, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 may provide any personal information to us or on the Services. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please write to us at the address specified below.

Cookies are files with a small amount of data, which may include a unique anonymous identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.

Our website uses cookie data to improve the website and your experience. When you use our website, you agree to our use of cookie data. Otherwise, you may choose not to use our website. For more information on the types of cookies we use, please review our Cookies Policy.

To provide our service, your personal information may be transferred outside the European Economic Area (the “EEA”) to implement and improve our service.

Many of the countries will be within the EEA or will be ones which the European Commission has approved, and will have data protection laws that are the same as or broadly equivalent to those in the United Kingdom.

However, some transfers may be to countries that do not have equivalent protections, and in that case, we shall use reasonable efforts to implement contractual protections for personal information. While this will not always be possible where we are required to transfer the information to comply with and perform our contract with you or where we have a legal obligation to do so, any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws.

For the avoidance of doubt, safeguards in the form of [EU Commission approved standard contractual clauses / binding corporate rules adopted by the recipient / the EU- US Privacy Shield for transfers to the United States] will be implemented we transfer personal information to our service providers for processing.

We implement appropriate measures to uphold the terms of this privacy policy. When we receive complaints from users, clients, or any third party, we do our best to follow up and resolve the issue in compliance with the Data Protection Laws and the terms and conditions of our services and company.

We will keep your information as long as necessary for the processing purpose that it was collected, and any other permitted linked to purpose, including legal, regulatory, and legitimate business purposes.

Our retention periods are based on our business needs and your personal information that is no longer needed is either irreversibly anonymized or securely destroyed. In general, we (or our service providers on our behalf) will hold this information for a period of seven years, unless we are obliged to hold it for a longer period under law or applicable regulations.

We will use reasonable efforts to keep your personal information up to date. However, we need you to notify us without delay in the event of any change in your personal circumstances so that we can keep your personal information up to date.

You may at any time request a copy of your personal information. This right can be exercised by writing to the company at the address specified below.

You also have the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of your personal information, and to object to certain uses of your personal information, in each case subject to the restrictions set out in applicable data protection laws.

In any case, where we rely on your consent to process your personal information, you have the right to change your mind and withdraw your consent by writing to us at the address specified below.

Where we rely on our legitimate purpose to use and disclose your personal information, you are entitled to object to such use of your personal information. If you do so, we will cease to use and process your personal information for that purpose unless we can show compelling legitimate reasons for us to continue or need to use the personal information for legal claims.

In limited circumstances, you may also have the right to data portability regarding certain of your personal information, which means you can request that we provide it to you or your third-party nominee.

You also have the right to lodge a complaint with the Information Commissioner’s Office about the processing of your personal information.

We reserve the right to modify this privacy policy as necessary. Any changes to this privacy policy that reduces the rights of our users or customers will result in prior notification and will require explicit consent from the user. Significant changes to our policies may result in email notifications. The latest privacy policy binds personal information that users and customers have consented to.

This privacy policy is governed by the laws of Portugal.

Any queries or complaints regarding the use of the personal information by us and the exercise of individual rights should be addressed to Eco Trilha Viagens e Turismo, Lda at [email protected]

Effective Date 5th May 2021