Privacy Policy

---

This document concerns the protection of individuals with regard to the processing of personal data and the free movement of such data and is fully regulated by Portuguese law.

Special Moments Tours is permanently committed to protecting the privacy of personal data provided by its customers in the context of the services it provides.
This document aims to provide users with the necessary information about Special Moments Tours’ privacy policy, so that they can give their express, free and informed consent to the processing of their personal data by Special Moments Tours, when requested during the subscription process.

The customer declares to know and accept the rules of the privacy code available on the website of Special Moments Tours consenting to the publication/disclosure of their personal data.

The personal data provided by users during the subscription process of the services by Special Moments Tours will be processed in the terms legally and regularly provided.

Processing of personal data means any operation or set of operations carried out with or without the aid of electronic or automated means, concerning the collection, recording, organization, maintenance, interrogation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, communication, disclosure, suppression and destruction of data, whether the data is contained in a database or not.

The processing of personal data may consist – partly as a result of how the customer decides to use the Services in text files, photographic or video images, audio tracks, telephone lines and, any other information that can be used to identify the data subject, according to the type of services requested.

This procedure will respect the principles of legality, good faith and transparency and ensure respect for users’ rights, in particular their right to privacy.

Purpose of processing

The purpose of this procedure is to allow Special Moments Tours to provide the services in the manner intended by the customer, as well as the independent management of the service by the customer. For this purpose, the customer must register as a user and create a profile when Special Moments Tours provides services. Collection, storage and processing of data for subsequent operations, technical and administrative management of the services and exchange of electronic communications.

The processing of the data by Special Moments Tours will comply with all applicable legal regulations, particularly in compliance with tax and accounting obligations that restrain it.

The personal data of users will also be processed for the purpose of enabling “web browsing”.

The purpose of this processing is also related to the collection, storage and organization of the customer’s personal data with a view to carrying out statistical analysis in an anonymous form. This analysis will not allow the identification of the customer and will only be used to assess the quality of the services provided by Special Moments Tours.

Processing Procedures

Personal customer data will be processed electronically and automatically.

Communication and disclosure of common personal data

Common personal data (of a non-sensitive nature) may be communicated by Special Moments Tours:

To persons and companies that provide legal, tax, financial, digital and accounting consulting services to Special Moments Tours;

Institutions, entities and/or authorities to whom the data must be transmitted under the terms of the statute and/or the law;

Commercial partners of Special Moments Tours, but only if the customer gives his express consent.

Optional or mandatory consent

If the customer does not provide his or her personal data, the subscribed services may not be activated, being this a decision made by Special Moments Tours.

The customer’s consent is also optional in relation to the processing of data for the purpose of market research, research and statistical analysis; the sending of advertising and information material via telephone service providers, via automatic messages without the mediation of an operator or by fax.

The customer’s consent is also optional for the reception of unsolicited commercial messages. These must be immediately and unambiguously identified as such and contain an indication that the recipient of the message may in future refuse to receive messages with such content.

If the customer chooses not to give his express consent to the processing of his personal data for commercial purposes when asked to do so, such refusal will not have any consequences with regard to the provision of the service by Special Moments Tours.

If the customer provides consent as described above, he/she may be admitted to participate in promotional contests organized/promoted by Special Moments Tours.

Processing of sensitive data

When the customer uses the services of Special Moments Tours, certain personal data classified as sensitive may be processed, particularly data revealing race or ethnic origin, religious, philosophical or other convictions, political opinions, party affiliation, health status or sexual orientation.

Special Moments Tours suggests that the customer does not publish sensitive personal data, except if it is strictly necessary or if he chooses services that do not imply such publication.

In any case and apart from exceptional situations, such data can only be published with the express and specific consent of the customer in writing or in another equivalent form.

On the basis of the above, Special Moments Tours reminds you that if the customer does not give his express consent to the processing of sensitive data and wishes to use services involving the processing of sensitive personal data at a later stage, he will have to modify his registration beforehand by giving the necessary consent.
If for any reason the customer does not give his express consent for the processing of sensitive personal data and subsequently subscribes to services which presuppose such processing Special Moments Tours cannot be held responsible, since the disclosure of sensitive data on the web will be the sole responsibility of the customer, regardless of the fact that the management of the web space is provided by Special Moments Tours.

However, Special Moments Tours reiterates the aforementioned importance of the prior modification of the registration by the customer, granting the necessary authorization for the processing of sensitive data if he intends to use services that necessarily involve the use/processing of that information.

Sensitive data, particularly data revealing the customer’s sexual orientation will not be communicated (except in cases of legal imposition) or disclosed by Special Moments Tours.

If the customer intentionally uses the services provided by Special Moments Tours to communicate and/or disclose his sensitive personal data on the internet, such situation does not represent any conduct accepted or practiced by Special Moments Tours, since the customer communicates that information as part of the private and independent management that he makes of the web space provided by Special Moments Tours or as part of the normal use of the services provided by the latter.

Possible processing of third parties’ personal data provided by the data subject
When the customer uses certain services (e.g. promotional activities carried out by Special Moments Tours which allow him to request the registration of domain names in favour of third parties, the personal data of third parties provided by the customer to the operator can be processed. In this case, the customer assumes the role of independent data manager and the inherent legal obligations, including the compensation for any damage caused to the third party by violation of the rules regarding the protection of personal data. In any case, if the customer provides or processes personal data of third parties while using services provided by Special Moments Tours, the customer guarantees and assumes fully that the third party has previously authorized the processing of his personal data.

Data Controller and Data Processor

The data controller is: Special Moments Tours , with registered office at Rua Henrique Alegria bloco 8, nº 17-A | 4150-392 Porto.

You may contact the data processors, in accordance with the law, at any time by contacting the offices of the data controller – Special Moments Tours in order to exercise the rights provided for by law.

Data storage and security measures

The data will be stored for the time defined by applicable laws and regulations, on the servers of Special Moments Tours. In any case, your data will be stored strictly for the period of time necessary to carry out the aforementioned purposes, which shall correspond to the duration of the contractual relationship between Special Moments Tours and the customer. If you cancel your account, as soon as you stop using the Services, your data will be deleted, except when the maintenance of such data is strictly necessary for the fulfillment of legal, financial, tax and accounting obligations, after the customer’s use of the Service has ceased. Once these obligations are met, your data will be deleted. We also inform you that this data will be collected, processed and maintained in full compliance with the legal provisions.

Right of access to personal data and other rights

The customer has the right to be informed

• of the source of the personal data;
• of the purposes and methods of the processing
• of the logic applied to the processing, in particular whether it is carried out
• with the help of electronic means
• of the identification of the data controller, data processor and their representatives;
• of the entities or categories of entity to which the personal data may be communicated and who may know such data as designated representative(s) in the State’s territory, data processor(s) or person(s) responsible for processing.

The customer has the right to obtain:

• a) update, rectification or, where interested, integration of the data;
• b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is necessary for the purposes for which they were collected or consequently processed;
• c) certification to the effect that the operations as per letters a) and b) have been notified to the entities to whom the data were communicated or disseminated, unless this requirement proves impossible or is manifestly disproportionate to the right that is to be protected.

The Customer has the right to reject, in whole or in part:

• a) on legitimate grounds, the processing of personal data concerning him/her, even if they are relevant to the purpose of the collection;
• b) the processing of personal data concerning him/her performed for the purpose of sending advertising material or direct selling or else for the assessment of market performance or commercial communication.

Contact:

For any information in order to exercise the rights provided by law under the terms described above the client may write to:

Special Moments Tours
Rua Henrique Alegria block 8, nº 17-A | 4150-392 Porto
The Customer may also send his information request via e-mail to the following e-mail address: [email protected]