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GDPR

Privacy Policy

Last updated: June 13, 2026

Executive Tour Service respects your privacy and is committed to protecting your personal data. This policy describes how we collect, use and protect your information, in compliance with Regulation (EU) 2016/679 (GDPR) and applicable Portuguese law.

1. Data Controller

The entity responsible for the processing of personal data is Executive Tour Service, with registered office at Avenida Itália 276 A, 2765-418 Monte Estoril, Portugal. Contacts: geral@sucessoededicacao.pt · +351 967 750 607. For any data-protection matter you may reach us via the contacts above; we have not appointed a Data Protection Officer (DPO) as we do not meet the requirements of Art. 37 GDPR, and your request will be handled directly by management.

2. Personal Data Collected

We process only data strictly necessary: (a) identification and contact data — name, email, phone; (b) trip data — pickup, drop-off, dates, flight number, number of passengers, special requirements; (c) free-text message submitted in the form; (d) billing data when applicable (Tax ID, address); (e) technical browsing data strictly necessary for the site to function (IP address, device type, language).

3. Purposes of Processing

We process your data to: (a) reply to information and quote requests; (b) manage bookings, transfers and contracted experiences; (c) issue invoices and comply with tax and accounting obligations; (d) provide customer support before, during and after the service; (e) ensure site security and fraud prevention; (f) with your express consent, send commercial communications about our services.

4. Legal Basis (Art. 6 GDPR)

Each processing has a specific legal basis: performance of a contract or pre-contractual steps (quotes, bookings, service delivery); compliance with a legal obligation (invoicing, accounting, tax retention); legitimate interest (commercial relationship management, site security, fraud prevention); express and revocable consent (commercial communications and non-essential cookies, where applicable).

5. Recipients and Processors

We do not sell or transfer data to third parties for commercial purposes. Your data may be shared with: drivers and operational partners strictly necessary to deliver the service; technology providers (web hosting, email, cloud infrastructure) bound by data-processing agreements under Art. 28 GDPR; accounting and audit firms; public authorities when legally required.

6. International Transfers

Some of our technology providers (hosting, email, messaging) may involve transfers of data outside the European Economic Area, including to the USA. Such transfers are carried out under the European Commission's Standard Contractual Clauses and/or the EU-US Data Privacy Framework, ensuring a level of protection equivalent to GDPR.

7. Retention Periods

We retain data only for the period needed: requests not converted into a booking — up to 12 months; contractual and operational booking data — during the contractual relationship and 5 years thereafter; tax and invoicing data — 10 years (legal obligation); data processed under consent — until consent is withdrawn.

8. Data Subject Rights

You have the right to: access your data; rectify it; erase it ('right to be forgotten'); restrict processing; object to processing; data portability; withdraw consent at any time (without affecting the lawfulness of prior processing); not be subject to automated decisions. You may exercise these rights by emailing geral@sucessoededicacao.pt, with a reply within 30 days. You may also lodge a complaint with the supervisory authority — Portuguese Data Protection Authority (CNPD), www.cnpd.pt.

9. Cookies

We use only strictly necessary cookies (language preference, consent, session). These cookies are exempt from prior consent under Art. 5(3) of the e-Privacy Directive. We do not use tracking, advertising or profiling cookies. You can manage cookies in your browser settings.

10. Information Security

We adopt appropriate technical and organisational measures to protect your data against unauthorised access, loss, destruction or disclosure, including encrypted connection (HTTPS/TLS), access control, cloud infrastructure with security certifications, and internal data-protection training.

11. Automated Decisions and Profiling

We do not make solely automated decisions with significant legal effects on data subjects, nor do we carry out profiling within the meaning of Art. 22 GDPR.

12. Minors

Our services are intended for adults. We do not knowingly collect data from minors under 16 without the authorisation of those holding parental responsibility.

13. Changes to the Policy

This policy may be updated to reflect legal or operational changes. The version in force is always available on this page, with the last update date indicated.

14. Client Area and Marketing Communications

If you create a client-area account, we process email, password (stored hashed), name and phone for authentication and account management, on the basis of contract performance. With your express consent (ticked at registration or in 'My account'), we send commercial communications by email and/or WhatsApp. You may withdraw each consent independently at any time in the client area or via the unsubscribe link included in marketing emails. WhatsApp is provided by Meta Platforms, Inc. (USA), implying an international transfer under the Standard Contractual Clauses. We keep the consent history as GDPR proof while the account exists and for 5 years after its deletion.

Contact

For any question about this policy or the processing of your data, contact us at geral@sucessoededicacao.pt or +351 967 750 607.

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