Dear Costumer,
As you may know, the law implementing Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016, regarding the protection of individuals with respect to the processing of personal data and the free movement of such data, also known as the General Data Protection Regulation (hereinafter referred to as GDPR), has come into effect
Break Free Adventours is committed to protecting the personal data of our customers. We want you to understand our Privacy Policy and what it means for you. If you have any questions about our Privacy Policy, you can contact our Privacy Officer at info@breakfreeadventours.com, indicating "Privacy Policy" in the subject line. info@breakfreeadventours.com indicando no assunto Política de Privacidade.
1. Data Controller
1.1. The primary data controller for your data, in relation to our services, is Break Free Adventours, with the corporate identification number 514606711, headquartered at Tv. Picoto, nº19 4800-157 Guimarães. Break Free Adventours is represented by Bruno Daniel Martins de Oliveira, with identification number 12112862 and professional address at Tv. Picoto, nº19 4800-157 Guimarães.
2. Collection and Use of Personal Data
2.1. In order to conduct its activities and for contact purposes with its customers, Break Free Adventours may collect, with the authorization of the respective holders, personal data voluntarily provided by individuals or legal entities, in any form, including: names of individuals or legal entities, tax identification number, address/headquarters, email address and telephone contact, travel itinerary, age, emergency contact information, passport details, medical information for travel purposes (when applicable), insurance details, ISIC data (when applicable), nationality, residence, dietary preferences, travel reviews, travel and accommodation preferences, comments you provide, travel destination information, and payment information.
2.2. The above-identified data is collected and processed for appropriate and compatible use with the correct and necessary development of Break Free Adventours' commercial activities and for legal and functional reasons inherent to the operation of its goods and/or services.
2.2.1. The personal data collected may be used, where permitted by law, for the following purposes: travel reservations; pre-reservations; communication with customers and clarification of doubts; processing requests for travel and accommodation information; providing similar travel services; processing payments; direct marketing communications (if you have consented to the processing of your personal data for this purpose); requesting services/products; billing; deliveries and actions deemed necessary within the scope of the relationship established between Break Free Adventours and the data subject, as well as for the functioning and statistical analysis of the website and to participate in contests or sweepstakes organized by us, subscribe to our newsletter or request a brochure. We use this personal data for the management of contests/sweepstakes or to provide the information you request.
2.3. The data subject authorizes Break Free Adventours to collect, process, and use their personal data as described in this form. Authorization may be withdrawn at any time.
2.4. Break Free Adventours collects personal data from individuals applying for a job or similar positions at Break Free Adventours to the extent necessary to: identify the person; assess their suitability for the position applied for. This information may include the name, contact information, academic qualifications, professional experience, criminal record data, information related to residence and/or citizenship, as well as other information necessary for selecting potential collaborators and other personnel.
2.5. Break Free Adventours collects personal data (as described above) from agents and agencies to the extent necessary to allow them to book Break Free Adventours trips and to be duly recognized for such bookings. If you are an agent traveling with Break Free, Break Free may also collect employment-related information to confirm your eligibility for tourism industry promotions.
2.6. The data of minors are collected and processed with the consent of parents or a legal guardian. Regarding this data, parents or the legal guardian can exercise the rights granted to data subjects by the GDPR.
3. Legal Basis
3.1. The processing of personal data by Break Free Adventours is based on various legal grounds, depending on the respective purposes:
a) Execution of a contract or pre-contractual measures at the request of the data subject (pre-reservation and travel reservation; communication with customers and clarification of doubts; processing of information requests; request for services/products; billing and deliveries; payment processing);
b) Consent of the data subject (subscription to newsletters when you are not yet our customer or user, participation in events, competitions, and campaigns, use of performance cookies for statistical analysis, product and service reviews);
c) Legitimate interest of Break Free Adventours to manage and improve its website, as well as to ensure that its use is in compliance with the respective terms and conditions, fraud control and prevention, sending marketing communications when you are already our customer and have not objected, as well as requesting your opinion and conducting satisfaction surveys;
d) Compliance with legal obligations to which Break Free Adventours is subject
3.2. When data processing is based on the legitimate interest of Break Free Adventours, we take the necessary measures to analyze the impact of processing on your interests. Break Free Adventours will not process your personal data if this analysis concludes that our interests are overridden by your rights and freedoms.
3.3. 3.3. Your personal data may also be used for the following purposes: to better understand your needs as a customer and determine eligibility for our products and services; to provide information about our products and services, or the products and services of our partners that we believe may be of interest to you (provided you have given us your valid consent, if necessary); to provide ongoing services and assistance, including resolving any issues related to the services or products you request from Break Free Adventours; to ensure the protection and safety of our passengers and products; to conduct internal accounting and business management; to comply with laws, regulations, and immigration requirements.
4. Confidentiality, Security, and Data Retention
4.1. The data collected by Break Free Adventours is stored in its system and is processed securely and confidentially.
4.2. Data processing and access are restricted to Break Free Adventours employees/collaborators who perform professional tasks that, by their nature, involve the intervention and/or management of the relationship between Break Free Adventours and the data subject.
4.3. Personal data will be retained by Break Free Adventours for the necessary duration, namely, for as long as the relationship between the company and the respective data subjects or the purpose for which the data was collected subsists. Once the period justifying its retention has ended, the data will be destroyed within an appropriate timeframe.
5. Data Sharing
5.1. If you book a tour with Break Free Adventours, we may use local service providers. Please note that Break Free Adventours may need to provide certain personal data to our service providers in order to provide you with your experience. When booking travel services with us, you accept the collection, use, and disclosure of your personal data by Break Free Adventours—and the corresponding collection and use by relevant travel partners or suppliers—for the purposes of managing and providing the travel services you request.
5.2. Break Free Adventours may transfer your personal data to third parties who provide services on our behalf. For example, we may use service providers to authorize and process payments, host our customer support operations, display advertisements on our website, send emails or other communications, or manage our contests and promotions.
5.3. Notwithstanding confidentiality and proper treatment, the data subject authorizes Break Free Adventours to transfer their data (only the strictly necessary ones) to third parties for "cloud" storage, to external accounting firms hired by us where accounting services are provided to us, as well as to credit and risk analysis companies or the granting/contracting of credit insurance or services associated with insurance activities in general, or to other service providers to provide the contracted experience.
5.4. Your data may also be transmitted to third parties whenever there is a legal obligation justifying the communication of the data.
5.5. Break Free Adventours will not commercialize any collected data with third parties.
5.6. We may transfer any of your personal data as an asset in the context of a merger or sale (including transfers made in bankruptcy or insolvency proceedings) involving all or part of Break Free or as part of a corporate reorganization or another change in corporate control.
6. Changes to the Privacy Statement
6.1. Break Free Adventours reserves the right to modify, add, or revoke, partially or entirely, this privacy policy at any time and without prior notice, with immediate effect, but without prejudice to the legal rights granted to data subjects.
6.2. Any changes will be disclosed on this same web page, so we recommend periodic visits to this page to stay informed about the latest version.
7. Data Subject Rights
7.1. Data subjects who have provided data to Break Free Adventours have the right to request access to their personal data (known as a "data subject access request"). This allows them to receive a copy of the personal data we have about them and verify that we are processing it legally.
7.2. Data subjects who have provided data to Break Free Adventours have the right to request corrections to any data we hold about them. This allows them to correct any incomplete or inaccurate data we hold about them, although we are required to verify the accuracy of the new data provided.
Data subjects who have provided data to have the right to request the limitation of the processing of their personal data. This allows them to request the suspension of processing their personal data in the following circumstances: (a) if they wish to determine the accuracy of the data; (b) whenever our use of the data is illegal, but they do not wish to have it deleted; (c) whenever they wish to maintain the data even if we no longer need it, as necessary, to establish, exercise, or defend legal claims; or (d) if they have objected to the use of their data but we need to verify whether we have legitimate reasons to use it.
7.4. Data subjects who have provided data to Break Free Adventours have the right to request the erasure of personal data. This allows them to request the deletion or removal of personal data whenever there is no valid reason for us to continue processing it. They also have the right to request the deletion or removal of their personal data whenever they have successfully exercised their right to object to the processing (see below), whenever we have processed their information illegally, or whenever we are obliged to delete their personal data to comply with local legislation. Note, however, that we may not always be able to comply with their deletion request for specific legal reasons that will be communicated, if applicable, at the time of their request.
7.5. Data subjects who have provided data to Break Free Adventours have the right to object to the processing of their personal data whenever we rely on a legitimate interest (or those of third parties) and there is a particular situation that leads them to object to the processing on this basis, as they feel that it affects their fundamental rights and freedoms. They also have the right to object whenever we process their personal data for direct marketing purposes. In some cases, we can demonstrate that we have legitimate grounds to process their information that overrides their rights and freedoms.
7.6. Data subjects who have provided data to Break Free Adventours have the right to request the transfer of their data to the data subject or a third party. We will provide them, or a third party of their choice, with their personal data in a structured, commonly used, and machine-readable format. Please note that this right only applies to automated information for which we originally obtained consent to use or used the information to execute a contract with them.
7.7. Data subjects who have provided data to Break Free Adventours have the right to withdraw their consent at any time when we depend on consent to process their personal data. However, this does not affect the legality of any processing carried out before they withdraw their consent. If they withdraw their consent, we may not be able to provide certain products or services to them. We will notify them if this is the case at the time they withdraw their consent.
7.8. The data subject will not have to pay any fee to access their personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under these circumstances.
7.9. We try to respond to all legitimate requests within one month. Occasionally, it may take longer than a month if your request is particularly complex or if you have made several requests. In that case, we will notify you and keep you informed.
7.10. Additionally, you have the right to lodge a complaint at any time with the relevant data protection authority identified in section 13.
8. Security
8.1. 8.1. We have implemented measures designed to help protect the personal data in our custody and control. We maintain reasonable administrative, technical, and physical safeguards in an effort to ensure protection against unauthorized access, use, modification, and disclosure of personal data in our custody and control. Unfortunately, no data collection or transmission over the Internet or other publicly accessible communication networks can be guaranteed to be 100% secure, so we cannot guarantee the security of such information.
8.2. We have data retention processes in place to retain our customers' personal data for the period necessary for the purposes outlined above or otherwise to comply with legal requirements.
9. Communication and Marketing
9.1. We will communicate with you by email, SMS, call, or notification through the app associated with our services/website to confirm your registration, a pre-booking or booking, for information requests, for complaints, information, and other issues related to our business, for marketing communications, or for other transactional messages related to our services. Since such transactional messages are mandatory for us, you cannot opt-out of them.
9.2. However, you may request at any time that we stop sending you marketing communications by accessing the opt-out link in the email or SMS message sent to you or by changing your communication settings in your account.
9.3. You may receive marketing communications from us if you have requested such information; if you use our website; if you have provided us with your details when participating in a contest; or if you have registered in a promotion.
10. Data Storage
10.1. Your personal data may be stored and processed by our service providers in Portugal and other jurisdictions. For information regarding the policies and practices of our service providers, please contact us at the email address provided above.
10.2. Our service providers receive the information necessary to perform their functions, and we do not authorize them to use or disclose your personal data for their own benefit.
10.3. Please note that if you are a resident of the UK, the European Union, or the European Economic Area ("EEA"), we may store your personal data outside the EEA. For example, we may store your personal data in Canada (which has been recognized by the European Commission as having an adequate level of privacy protection).
10.4. We may also need to transfer your personal data to travel service providers and third parties outside the EEA, for example, when a supplier is located outside the EEA. Countries outside the EEA may not have the same privacy laws as those in the UK, Canada, and the EEA. We will take reasonable steps to ensure the protection of your privacy rights.
10.5. We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purpose of satisfying any legal, accounting, or reporting requirements.
10.5. We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purpose of satisfying any legal, accounting, or reporting requirements.
11. Links to Third-Party Websites
11.1. Our website may contain links to third-party websites or applications. If you access any of these links, please note that each one will have its own privacy policy. We do not control these websites/applications and are not responsible for these policies. Upon leaving our website, we recommend that you read the privacy statement of every website you visit.
12. Contacts
12.1. For any additional information or to exercise your rights, please check our account/privacy settings or contact us at the following email address: info@breakfreeadventours.com.
13. Supervisory Authorities
13.1. For local data protection matters, your local authorities may also be contacted in your local language.
13.2. In Portugal, the Supervisory Authority is as follows:
CNPD – Comissão Nacional de Protecção de Dados
Rua de São Bento, n.º 148 – 3.º
1200-821 Lisboa
Telephone +351 213928400; Fax: +351 213976832
14. Additional Information
14.1. Break Free Adventours informs all its customers that all this information, as well as terms and conditions and privacy policies, are available on our website.
14.2. The use of our website and our services implies acceptance of this privacy policy. The Break Free Adventours team reserves the right to change this policy without prior notice. Therefore, we recommend that you regularly check our privacy policy to stay updated.
14.3. For the purpose of complying with the provisions of the General Data Protection Regulation, I have been informed by Break Free Adventours of all service conditions and privacy policies.
15. Cookies, Google Analytics, and Web Beacons
15.1. Like other websites, we collect and use information when you access our website, such as your IP (Internet Protocol), your ISP (Internet Service Provider, like MEO, NOS, or others), the browser you used when visiting our website (such as Internet Explorer or Firefox), the time of your visit, and which pages you visited within our website, as well as the city and country from which you accessed us. However, this information is anonymous and will only be used for statistical purposes.
15.2. We use cookies to store information, such as your personal preferences when you visit our website. This may include a simple pop-up or a link to various services we provide.
15.3. Cookies can be recognized by services like Google for potential advertisements elsewhere on the internet. The addition of cookies on our website is important for us to define our type of customer and user. Nevertheless, all information provided by Google Analytics is private, and we only have basic information about users, such as the location from which you visit us, the operator, how long you stayed on our website, and which pages you viewed.
15.4. To review and/or change your cookie consent options, you can do so through your browser or by making changes in antivirus programs such as Norton Internet Security. Alternatively, you can simply visit us in an incognito window in your browser. However, this may alter how you interact with our website or other websites. This may affect or prevent you from logging into programs, sites, or forums within our and other networks.
15.5. In summary, at Break Free Adventours, we only have your data for statistical purposes. Cookies taken by third parties (such as Google) are entirely their responsibility.
15.6. We may also use third parties to help us gather and analyze information about the sections you visit on the website in order to evaluate and improve the customer experience, website usability, and to help us assess some specific information related to your visits to our website.