Privacy and Cookies Policy
The Policy explains how we use any personal data we collect about you (either “user” or “you”) when you use the Website. This Policy is designed to protect you, our users, by informing you what personal data is collected, how we will use the information about you, with whom we share it, how long we keep it and how to contact us if you have any queries or concerns about our use of your personal information. Your use of the Website and any micro-sites is subject to your agreement with this Policy.
In this Policy, the term “personal data” or “personal information” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Legislation (as defined below).
Please read the following carefully. Entering into this Website and providing your consent to our use of your personal data in accordance with the terms of this Policy indicates that the user has reviewed this Policy and has agreed to be bound by it. If you do not agree to these terms you must leave the Website immediately. If you no longer consent to our processing of your personal data, you may request that we cease such processing by contacting us via the ‘How to contact us’ facility referred to below.
What information do we collect about you?
Portugal.com does not attempt to collect further data without user consent that enables personally identifiable profiling of our users.
We collect and collate generic information on all our Website traffic that is only ever represented in aggregate format.
Portugal.com may ask users for feedback (free text entry, product and services ratings or similar) to help analyze the quality and performance of our services and that of our third parties. Information collected for this purpose is done so voluntarily and is used to aid our understanding of customer needs and opinions only. Specific quotes and reviews may be used in our review, testimonials and stories pages; however this is done so with express and explicit consent of our users.
How will we use the information about you?
We collect information about you to manage your Website account, process your booking order, and, if you agree, email you, via newsletters, about other tourism products and services we think may be of interest to you. We may also use your information collected from the Website to personalize your repeat visits to our Website.
We do not use, handle or share IP addresses from visitors to our Website.
A cookie is a small text file that is placed on your hard disk by a web server which enables a website and/or mobile app to recognize repeat users, facilitate the user’s ongoing access to and use of a website and/or the mobile app and allows the website and/or mobile app to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising.
You can find a list of cookies we use and the purpose for which we use them in our Cookies Policy.
Marketing/Newsletter (Opt-in and Opt-out)
We would like to send you information about products and services and promotional activities which may be of interest to you. When you enter your contact details on our Website forms you will have the opportunity to opt-in to receive promotional information from us. This can be done via a two step confirmation process; first by checking the relevant yes box on the form, and, secondly by clicking on the re-confirmation link you receive via email. If you have consented to receive marketing, you may opt-out at any time by unsubscribing from the newsletter itself or contacting us. Third Parties
Third Party Services
We use service providers to help us run the Website or services available on the Website. Any third parties who access your data in the course of providing services on our behalf are subject to strict contractual restrictions to ensure that your data is protected, in compliance with Data Protection Legislation.
Portugal.com uses third party service providers including booking.com (hotels), Rentalcars.com (car), Viator (tours) to fulfill direct bookings reservations of travel services in Portugal and Spain. During the process of booking you will be notified of each supplier identity and protected under their respective privacy policies:
Age Advertising Disclosure
Children under the age of 16
We ask that persons under the age of 16 do not submit any personal information to us. We will not knowingly accept any data from a person who is under the age of 16 years.
What rights do you have?
- As a data subject, you have the following rights under the Data Protection Legislation:
- The right of access to personal data relating to you;
- The right to correct any mistakes in your personal data;
- The right to ask us to stop contacting you with direct marketing;
- The rights in relation to automated decision taking;
- The right to restrict or prevent your personal data being processed;
- The right to have your personal data ported to another data controller;
- The right to erasure; and
- The right to complain to the DPC if you believe we have not handled your personal data in accordance with the Data Protection Legislation.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your personal data, please contact us. We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period
Right to access to personal data relating to you
- You may ask to see what personal data we hold about you and be provided with:
- A summary of such personal data and the categories of personal data held;
- Details of the purpose for which it is being or is to be processed;
- Details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
- Details of the period for which it is held (or the criteria we use to determine how long it is held);
- Details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
- Any information available about the source of that data;
- Whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling.
Requests for your personal data must be made to us (see ‘How to contact us’ below) specifying what personal data you need access to. To help us find the information easily, please give us as much information as possible about the type of information you would like to see.
If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.
We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your personal data or correct any mistakes in your personal data
You can require us to correct any mistakes in your personal data which we hold free of charge. If you would like to do this, please:
- Email or write to us (see ‘How can you contact us’ below);
- Let us have enough information to identify you (e.g. name, registration details); and
- Let us know the information that is incorrect and what it should be replaced with.
If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact us’ below).
Right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
See ‘How can you contact us’ below). You can also click on the ‘unsubscribe’ button at the bottom of any newsletter email sent to you from us for immediate opt-out.; and
Let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’.
These rights will not apply in all circumstances, for example where the decision is (i) authorized or required by law, (ii) necessary for the performance of a contract between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavor that steps have been taken to safeguard your interests.
Right to restrict or prevent processing of personal data
In accordance with Data Protection Legislation, you may request that we stop processing your personal data temporarily if:
- You do not think that your data is accurate (but we will start processing again once we have checked and confirmed that it is accurate);
- The processing is unlawful but you do not want us to erase your data;
- We no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
- You have objected to processing because you believe that your interests should override the basis upon which we process your personal data.
If you exercise your right to restrict us from processing your personal data, we will continue to process the data if:
- You consent to such processing;
- The processing is necessary for the exercise or defense of legal claims;
- The processing is necessary for the protection of the rights of other individuals or legal persons; or The processing is necessary for public interest reasons.
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your personal data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to personal data that you have provided to us – it does not extend to data generated by us.
The right to data portability also only applies where:
- The processing is based on your consent or for the performance of a contract; and
- The processing is carried out by automated means.
Right to erasure
In accordance with Data Protection Legislation, you can ask us to erase your personal data where:
- You do not believe that we need your personal data in order to process it for the purposes set out in this Policy;
- If you had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data;
- You object to our processing and we do not have any legal basis for continuing to process your personal data;
- Your data has been processed unlawfully or have not been erased when it should have been; or
- The personal data have to be erased to comply with law.
We may continue to process your personal data in certain circumstances in accordance with Data Protection Legislation.
Where you have requested the erasure of your personal data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on the Website or otherwise engage in any disruptive behavior on any Portugal.com service, we may remove such content.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to personal data to employees, contractors and agents who need to know such personal data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place.
We will implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks that are presented by the processing of your personal data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data transmitted to our Website and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. We are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that the Website may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.
Portugal.com sites may also be linked to websites operated by third parties. These links are meant for your convenience only. Links to third party sites do not constitute endorsement on the part of Portugal.com of those sites and we are not responsible for the privacy practices of the owners and operators of those sites. We encourage you to review the privacy policies and practices on each site which asks you to submit personal information.
We will notify serious data breaches to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A personal data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your personal data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
We have implemented appropriate technical and organizational measures that render the personal data unintelligible to anyone not authorized to access it, such as encryption; or
ü We have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialize; or
ü It would involve disproportionate effort, in which case we may make a public communication instead.
Who we share your data with
Portugal.com only shares your date internally and solely with the purpose of fulfilling your reservation.
Portugal.com does not sell or pass on your personal details to third parties without your consent, except in the following, highly unlikely, instances:
- Where it is required by applicable law or pursuant to a court or similar order
- Where it is required urgently to prevent serious loss or damage to property of Portugal.com
- Where it is required for the purposes of obtaining legal advice or for the purposes of, or in the course of, legal proceedings to which Portugal.com is a party or a witness.
- Where we store your data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you consent to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. The safeguards in place with regard to the transfer of your personal data outside of the EEA are the entry by us into appropriate contracts with all transferees of such personal data.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
How long will we retain your personal data?
Portugal.com complies with the highest standards when collecting and using personal information. No personal information will be retained for longer than is necessary to fulfill a legitimate business need or as required by applicable law. If you have not engaged with us for 3 years then we will delete your personal details from our database.
Changes to the Policy
We keep our Policy under regular review and we reserve the right to amend this Policy at our discretion and users shall be deemed to accept the modified Policy by continuing to access the Website to submit personal information on or after the date of modification. We will place any updates on this Website.
How to contact us
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
Data Protection Officer
PO Box 683
Aptos, CA 95003
We will not levy any charge in respect of the above actions.
Whenever you use our online services, including our applications, cookies and other tracking technologies can be used in various ways, like making the Portugal.com website work, to analyze traffic, or for advertisement purposes. These technologies are either used by us directly, or by our business partners, including third-party service providers and advertisers we work with. If you want to learn more about what a cookie is, how they’re used and what your choices are, you can read more here.
What’s a cookie?
A cookie is a small amount of data that’s placed in the browser of your computer or on your mobile device. So-called “first-party cookies” (not as much fun as they sound) are cookies served by the entity operating the domain through which the cookie is served. Portugal.com’s own cookies are therefore “first-party cookies.” In case we allow others to service cookies through the Portugal.com websites and apps, these cookies are so-called “third-party cookies.”
In addition, there’s a difference between session cookies and permanent cookies. Session cookies only exist until you close your browser. Permanent cookies have a longer lifespan and aren’t automatically deleted when you close your browser. We strive to serve cookies or allow the serving of cookies with a maximum lifespan of 5 years. Only in exceptional circumstances, like for security purposes and where absolutely necessary, will a cookie have a longer lifespan than that.
In addition, other tracking technologies are used which are similar to cookies. These can include web beacons (also known as pixel tags, web bugs, or gifs), tracking URLs, or software development kits (SDKs). A web beacon is a tiny graphic image of just one pixel that can be delivered to your computer as part of a web page request in an app, in an advertisement, or in an HTML email message. Pixels can be used to retrieve info from your device, like your device type or operating system, IP address, and time of visit. They’re also used to serve and read cookies in your browser. Tracking URLs are used to understand from what referring website the Portugal.com websites or apps are used. SDKs are small pieces of code included in apps that function like cookies and web beacons.
All these technologies together are referred to in this Cookie Statement as “cookies.”
How are cookies used?
Cookies are used for different purposes. They allow you to be recognized as the same user across the different pages of a website, between websites, or when you use an app. The types of info that we collect through cookies include IP address; device ID; viewed pages; browser type; browsing info; operating system; internet service provider; timestamp; whether you have responded to an advertisement; the referring URL; and features used or activities engaged in within the website/apps.
Technical Cookies: We try to give our visitors an advanced, user-friendly website and apps that adapt automatically to their needs and wishes. To achieve this we use technical cookies to show you our website, to make them function correctly, to create your user account, to sign you in, and to manage your bookings. These technical cookies are absolutely necessary for our website to function properly.
Analytics Cookies: We use these cookies to gain insight into how our visitors use Portugal.com. This means we can find out what works and what doesn’t, optimize and improve our websites or apps, understand the effectiveness of advertisements and communications, and ensure we continue to be interesting and relevant. The data we gather can include which web pages you’ve viewed, which referring/exit pages you’ve entered and left from, which platform type you’ve used, which emails you’ve opened and acted upon, and date and time stamp info.
It also means we can use details about how you interacted with the site, like the number of clicks you make on a given page, your mouse movements and scrolling activity, the search words you use, and the text you enter into various fields. We use analytics cookies as part of our online advertising campaigns to learn how users interact with our website or apps after they’ve been shown an online advertisement. This may include advertisements on third-party websites. Analytics cookies may also be used to enable our business partners to learn if their customers use accommodation offers integrated into their websites.
Commercial Cookies: We use third-party cookies as well as our own to display personalized advertisements on our websites and on other websites. This is called “retargeting,” and it’s based on browsing activities like the destinations you’ve been searching for, the accommodations you’ve viewed, and the prices you’ve been shown.
What are your choices?
To learn more about cookies and how to manage or delete them, just visit allaboutcookies.org and the help section of your browser. In the settings for browsers like Internet Explorer, Safari, Firefox or Chrome, you can set which cookies to accept and which to reject. Where you find these settings depends on your browser – use the “Help” function in your browser to locate the settings you need.
If you decide not to accept certain technical and/or functional cookies, you might not be able to use some functions on our website. We currently don’t support “Do Not Track” browser settings. In case a common standard has been developed that defines what exactly will be meant by “Do Not Track” browser signals, we’ll review Cookie Statement again.