Privacy Policy
Tribestour.com website and subdomains

1. Introduction

This Privacy Notice (“Notice”) establishes how AWT – Tour Operator, Unipessoal Ltd. protects the privacy of the Personal Data of our employees, customers, partners or any other entity with which AWT – Tour Operator, Unipessoal Lda . relate in the context of your activity.

As a tour operator, AWT – Tour Operator, Unipessoal Ltd. needs to collect, use and disclose Personal Data to carry out business functions and activities, including making and managing travel reservations on behalf of its customers. At AWT – Tour Operator, Unipessoal Ltd., we are committed to protecting the privacy and confidentiality of Personal Data and maintaining a controlled environment (physical, electronic, human and procedural controls) in line with operational risks.

In the context of the General Data Protection Regulation 2016/679 (“RGPD”), AWT – Tour Operator, Unipessoal Ltd. is a “data controller” of any personal information provided to us in the context of the relationship with our customers or any other Interested Parties.

By providing Personal Data, Interested Parties agree that this Notice will apply to how we handle your Personal Data and consent to its being collected, used and disclosed as detailed in this Notice. If they do not agree with any part of this Notice, the Interested Parties shall not provide us with their Personal Data. If you do not provide us with your Personal Data, as well as withdraw the Consent you have provided in accordance with this Notice, this may affect our ability to provide you with the services, or negatively affect the quality of the services we may provide to you. For example, most travel reservations must be made with the traveler’s full name and must include contact details and proper identification (eg passport details) and we cannot make reservations without this information. Note that there may be cases in which local data protection laws impose more restrictive practices for handling Personal Data than those established in this Notice. When this occurs, we will adjust our practices for handling Personal Data to comply with these same local laws.

2.What Personal Data do we collect?

Personal Data has the meaning given by local data protection laws and, where the RGPD applies, the meaning is considered to be given within the scope of the RGPD. Personal Data generally means data relating to an individual who can be identified from that data; or is identifiable from the combination of these data with other available data.

Generally, the type of Personal Data we collect is necessary to facilitate travel arrangements, support bookings or to organize travel-related services and/or products on behalf of our customers. In this regard, we normally process the following types of Personal Data about our customers: Contact data (such as name, residential / mailing address, telephone number, email address);

• Payment data;
• Passport details;
• Loyalty / frequent flyer program data;
• Data on dietary needs and health problems (if any); and
• Other data relevant to travel arrangements or required by the travel service provider(s) (eg airlines and accommodation or tourism providers).

When our customers contact us for other purposes, Personal Data relating to those purposes may also be collected. For example, we may collect Personal Data in order to be able to contact our customers in the context of a contest/campaign they have entered into or to respond to questions or comments they have submitted. We also collect data necessary for use in our business activities or those of our related entities, including, for example, financial details needed to process transactions, video surveillance images used for security purposes, or other relevant Personal Data that our customers may want from us. to supply.

Under some circumstances we collect Personal Data that may be considered sensitive data under local data protection laws. Sensitive data may include (without limitation) racial or ethnic origin, philosophical or religious beliefs or affiliations, sexual preferences or practices, criminal background or the alleged existence of a criminal offense, affiliation with political, professional or commercial associations, biometric and genetic information, data financial and health data. We will only collect sensitive data in accordance with local data protection laws, with the explicit consent of those concerned and where the data is reasonably necessary or directly related to one or more of our operational functions or activities (for example, to make plans for travel), unless required or authorized to do so by law. To the extent permitted or required by local data protection laws, our customers consent to us using and disclosing their sensitive data solely for the purpose for which it was collected, unless we subsequently receive their consent for another purpose. For example, if our customers provide us with health data relating to a travel insurance that they wish to take out, the customers consent to us using and disclosing this health data on their behalf in the contacts made with the entity promoting such travel insurance. Another example is when our customers want to make known their religious beliefs because they are interested, for example, in certain vacation packages, consenting to the use and dissemination of this information for the operation of the trip. We will not use sensitive data for purposes other than those for which it was collected, unless we receive the consent of its holders to do so.

3.How do we collect Personal Data?

We only collect Personal Data in accordance with local data protection laws. We generally collect Personal Data in the context of contacts made with our customers, unless it is unreasonable or impractical to do so. Generally, this collection will take place when our customers:

• contact us in person, by phone, letter, email;
• visit us through our website; or
• contact us through social media.

We may also collect Personal Data when our customers:

• buy or ask questions about travel plans or other products and services;
• enter contests or register for campaigns / promotions;
• sign up to receive marketing communications (eg e-newsletters);
• request brochures or other information.

In some circumstances, it may be necessary to collect Personal Data about our customers from third parties. This includes cases where an individual makes a travel reservation on behalf of another person(s) (for example, a family reservation, a group reservation or a reservation made by an employer). When this happens, we rely on the authorization of the person booking the trip to act on behalf of any other traveler on the booking, as well as that person’s consent to collect, use and disclose Personal Data in accordance with this Notice. Our customers must inform us immediately if they become aware that their Personal Data was provided to us by another person without their consent or if they did not obtain such consent before providing us with another individual’s Personal Data.

We make every effort to maintain the accuracy and integrity of the Personal Data we store and to ensure that all Personal Data is up to date. However, any Interested Party may contact us immediately if there is any change to their Personal Data or if they become aware that we have inaccurate Personal Data (please see section 13 below). We cannot be held responsible for any losses arising from inaccurate, wrong, defective or incomplete personal information that Interested Parties, or anyone acting on their behalf, provide to us.

4.How do we use Personal Data?

We will only process Personal Data when:

• We have been given consent to such processing (which may be withdrawn from us at any time, as detailed in section 8 of this Notice);
• Such processing is necessary for us to provide our services;
• This processing is necessary for the fulfillment of legal obligations; and / or
• Such processing is necessary for our legitimate interests or that of any third party receiving such Personal Data (as detailed in sections 5 and 6 of this Notice).

When a customer contacts us in the context of a travel inquiry or booking, the purpose for which we collect your Personal Data is generally to provide travel advice and/or assist in booking products and/or services related to the trips. However, the purpose of the collection may differ depending on the specific circumstances disclosed in this Notice (eg collection of Personal Data for the purpose of participating in a campaign, gathering feedback, etc.).

When a customer makes a reservation for travel or products/services with us, we generally act as an agent for travel service providers (eg for a hotel). In that case, we process Personal Data as necessary to provide the requested services, including the collection of Personal Data for our internal purposes, as described in this Notice, and for the travel service provider for whom we act as an agent (for example, for provide the contracted services). For example, if you book a flight through AWT – Tour Operator, Unipessoal Ltd., we will use Personal Data to allow the flight to be booked and we will disclose Personal Data to the airline to enable it to provide the flight service.

We may share data with our travel service providers (hotels, airlines, car rental companies or other providers related to travel bookings). These travel service providers may also use Personal Data as described in their respective privacy policies to obtain additional information to facilitate travel booking or the provision of requested services. We recommend that our Clients review the privacy policies of any travel service providers that are purchased through AWT – Tour Operator, Unipessoal Ltd. We will provide copies of all relevant travel service providers’ terms, conditions and privacy policies, upon request.

We act as agents for many travel service providers around the world, so it is not possible to list in this Notice all the travel service providers we serve (in particular their locations). For more information on the disclosure of Personal Data to travel service providers located outside the RGPD context, see section 6 of this Notice.

If there are any concerns regarding the transfer of Personal Data to a travel service provider, or if more information is needed, please refer to section 13 of this Notice.

The purposes for which we collect Personal Data also include:

• provide services or tools that our Customers choose to use (for example, saving travel preferences on our website in a wish list or storing Personal Data to enable pre-completion of online forms);
• identification of fraud or errors;
• legal or regulatory compliance;
• develop and improve our products and services;
• maintain or improve the relationship with our Customers, namely, creating and maintaining a customer profile that allows the provision of a service in line with their preferences;
• market research, customer satisfaction assessment and feedback on the services we provide;
• facilitate the participation of our Customers in loyalty programs;
• perform analysis related to our services, including, but not limited to, sales and travel destination preference trends;
• support internal organization and accounting;
• support the fulfillment of legal obligations or applicable customs/immigration requirements related to travel; and
• other purposes, as authorized or required by law (for example, to avoid a threat to life, protection of health or safety, or to enforce legal rights AWT – Tour Operator, Unipessoal Lda..

Where permitted by local data protection laws, we may use Personal Data to carry out marketing activities relating to our (and third-party) products and services that we believe may be of interest to our Customers, unless they have asked us not to receive such information. These campaigns may include, but are not limited to, emailing, digital marketing and other electronic notifications. Personal Data will be used to send digital marketing material (including e-newsletters, email, SMS, MMS and IM) if Customers have chosen to receive them. Customers can sign up to receive e-newsletters and other promotional / digital marketing materials by following the relevant links on our website or by asking one of our contributors to do so.

Any individual who does not wish to receive promotional or marketing material from us, or participate in market consultations or receive other types of communications, should refer to sections 8 and 13 of this Notice.

5.What Personal Data are disclosed to third parties?

At AWT – Tour Operator, Unipessoal Ltd. we do not sell, rent or exchange Personal Data. Personal Data will only be disclosed to third parties in accordance with the provisions of this Notice and in accordance with local data protection laws (note: in this Notice, reference to “disclose” includes transferring, sharing orally or in writing, sending or making available Personal Data for another entity).

Personal Data may be disclosed to the following types of third parties:

• contracted entities, suppliers and service providers, including:
• the situations in each of the circumstances described in section 4 of this Notice (“How do we use Personal Data?”);
• ICT solution providers that support us in providing products and services (such as any external data hosting providers we may use);
• publishers, printers and distributors of marketing material;
• organizers of events and exhibitions;
• marketing or market consulting agencies;
• courier services or courier services; and
• external consultants (such as lawyers, accountants, auditors or recruitment consultants);
• travel service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer managers and other related service providers;
• any third party to whom we assign or transfer any of our rights or obligations;
• people who book travel on behalf of others (for example, a family member, friend or co-worker);
• employers, in the context of business trips for corporate, business or government clients;
• contact persons (eg a family member) when our Clients are not reachable and the contact is, in our opinion, in the Client’s interest (eg where the person is concerned about their welfare or needs to act on behalf of the Client due to unforeseen circumstances);
• as required or authorized by applicable law, and to comply with the legal obligations of AWT – Tour Operator, Unipessoal Ltd.;
• customs or immigration services to comply with applicable legal obligations in the context of the trip;
• government agencies or public authorities to carry out valid and authorized requests, including court orders or any other valid legal process;
• regulatory bodies or law enforcement authorities, including for fraud protection and related security purposes; and
• enforcement agencies where illegal activity is suspected and where Personal Data is a necessary part of investigating or reporting the matter.

In addition to the foregoing, we will not disclose Personal Data without consent, unless we believe that disclosure is necessary to lessen or prevent a threat to an individual’s life, health or safety protection, public health or safety, or otherwise action is taken by an enforcement body (eg prevention, detection, investigation or punishment of criminal offences), or where such disclosure is authorized or required by law (including applicable data protection / privacy laws).

On the websites or social networks of AWT – Tour Operator, Unipessoal Ltd. users can choose to use certain third party resources with which we associate. These features, which may include social networking and geo-location tools, are operated by a third party and are clearly identified as such. These third parties may use or share Personal Data in accordance with their own privacy policies and we recommend that you consult their privacy policies in case you consider these tools relevant.

6.What Personal Data are transferred abroad?

We may disclose Personal Data to certain overseas recipients as described below. We will ensure that such international transfers are necessary for the performance of a contract between our Clients and third parties abroad or that they are subject to appropriate or adequate safeguards as required by local data protection laws (eg RGPD). We will provide copies of the relevant safeguards documents on request (see section 13 of this Notice).

It is possible for Personal Data to be transferred to an entity abroad located in a jurisdiction where it is not possible to guarantee a level of data protection equal to that existing in the context of the RGPD. In these cases, AWT – Tour Operator, Unipessoal Ltd. cannot be held responsible for the way in which these recipients handle, store and process Personal Data.

(a) Related entities abroad

AWT – Tour Operator, Unipessoal Ltd. operates a global business, including worldwide operations. Personal Data may be disclosed with our related entities abroad to support travel booking and/or to enable the performance of administrative, advisory or technical services, including the storage and processing of such data.

b) Travel service providers located abroad

In order to provide our services, it may be necessary for us to disclose Personal Data to relevant overseas travel service providers. We deal with many different travel service providers around the world, so the location of a relevant travel service provider will depend on the travel services provided. Relevant travel service providers will, in most cases, receive Personal Data in the country in which they will provide the services or on which their business is based.

(c) Our service providers located abroad

We may also have to disclose Personal Data to service providers located abroad for the purpose of supporting the provision of services, including the storage and processing of such data. Generally, we will only disclose Personal Data to such overseas recipients in the context of booking travel and/or to enable the provision of administrative and technical services provided on our behalf.

If there is any specific question about where or to whom Personal Data may be sent, please refer to section 13 of this Notice.

7. Information security

At AWT – Tour Operator, Unipessoal Ltd. we are committed to protecting Personal Data by implementing and maintaining adequate technical, organizational and human control measures to ensure a level of security in line with the risks related to:

• accidental or illegal destruction;
• loss; unauthorized alteration or disclosure;
• or improper access to Personal Data transmitted, stored or processed.

AWT – Tour Operator, Unipessoal Ltd. regularly monitors and reviews security controls and strives to protect Personal Data in the same way as it protects your sensitive business information.

AWT – Tour Operator, Unipessoal Ltd. destroys or mischaracterizes Personal Data whenever they are no longer relevant to the business or as required by law.

8.Rights in relation to the Personal Data we collect

If any interested party, that AWT – Tour Operator, Unipessoal Ltd. has Personal Data, and that it wishes to:

• update, modify, delete or obtain a copy of Personal Data; or
• restrict or prevent AWT – Tour Operator, Unipessoal Ltd. from using any personal information, including withdrawing any consent that it has previously given for the processing of such information; or
• obtain a copy of the personal information that has been processed based on your consent or as necessary to perform a contract to which you are a party, you must formally place the request to AWT – Tour Operator, Unipessoal Lda. through the contacts identified in section 13 of this Notice . After the request, an acknowledgment of the request will be made and information will be given on the period within which the Information will be made available.

AWT – Tour Operator, Unipessoal Ltd. will make every effort to respond to such requests within a month or less, although it may be necessary to extend this period for complex requests.

Additionally, AWT – Tour Operator, Unipessoal Ltd. reserves the right to deny access to the Information for any reason permitted by applicable laws. If the request for access to or correction of the Information is denied, the reasons for such refusal will always be communicated in writing, unless it is unreasonable to do so or when required by local data protection laws.

All communications relating to requests for access to Personal Data must be made formally in writing through the contacts identified in section 13 of this Notice.

If we are asked to AWT – Tour Operator, Unipessoal Ltd. to restrict or stop using Personal Data, withdrawing the consent previously provided for the processing of Personal Data, the ability to provide services or their quality may be negatively impacted. For example, most travel reservations must be made under the traveler’s full name and must include contact details and proper identification (eg passport details) and reservations cannot be made without this information.

Personal Data shared with AWT – Tour Operator, Unipessoal Ltd. must be accurate and individuals agree to update them whenever necessary. Additionally, they agree that, in the absence of any update, AWT – Tour Operator, Unipessoal Ltd. may assume that the data sent is correct.

Any individual may at any time request AWT – Tour Operator, Unipessoal Ltd. to stop sending marketing communications, and may use the unsubscribe links provided in marketing emails or through the contacts indicated in section 13 of this Notice.

In any of the situations listed above, you may be asked to provide a valid means of identifying the applicant to ensure that AWT – Tour Operator, Unipessoal Ltd. fulfills its security obligations and prevents unauthorized disclosure of Personal Data.

AWT – Tour Operator, Unipessoal Ltd., S.A. reserves the right to charge a reasonable administrative fee following any manifestly unfounded or excessive requests regarding access to Personal Data or for any additional copies of Personal Data requested.

9. Integrations with Social Networks

The websites and mobile applications of AWT – Tour Operator, Unipessoal Ltd. may use social media resources and tools (such as “Like” and “Share” buttons). These features are provided and operated by external companies (eg Facebook) and hosted either by external companies or directly on our website or mobile app. Social Tools may collect data related to the page visited on the website / mobile application, the IP address and may set cookies to improve the functioning of Social Tools.

In case the user has activated social media accounts, these may be able to share data about the visit and use of our website or mobile application with those same social media accounts. As such, interactions with Social Tools may be recorded by third parties. In addition, external companies may share with AWT – Tour Operator, Unipessoal Ltd. Personal Data in accordance with their policies, such as their name, profile picture, friend lists or any other information that individuals have chosen to provide with these same companies. In these cases, we may share this data with a third party for the purpose of driving targeted marketing through these same social media platforms. In this situation, users have the option to manage data sharing and be able to disable targeted marketing in their social media privacy settings.

All interactions with Social Tools are governed by the privacy policy of the external company providing them. More information about the data protection practices of these companies should be consulted directly in the privacy policy of these same companies.

10. IP addresses

When a user accesses the website, uses any mobile application, or opens digital mail from AWT – Tour Operator, Unipessoal Ltd., the servers can record data relating to the device or network to which the user is connected, including the IP address. An IP address is a series of numbers that identify a computer and are assigned when accessing the Internet.

The IP addresses may be used by AWT – Tour Operator, Unipessoal Ltd. for systems administration, investigation of security issues and compilation of anonymous data on the use of the website and/or mobile applications. IP addresses may also be associated with other Personal Data available about individuals for the purposes described above (for example, to better tailor marketing and advertising materials, provided you have opted in to receive digital marketing).

11. Tracking Technologies / Cookies

AWT – Tour Operator, Unipessoal Ltd. may use web analytics services from providers outside its websites and mobile applications, such as those listed in the “Cookie Policy”. Providers of these services may use technologies such as cookies and “web beacons” to help analyze visitors using their websites and applications.

For information on the use of cookies and tracking technologies, consult the Cookies Policy of AWT – Tour Operator, Unipessoal Ltd..

12.Associated websites

AWT – Tour Operator, Unipessoal Ltd. websites may contain links to third-party websites over which AWT – Tour Operator, Unipessoal Ltd. has no control. AWT – Tour Operator, Unipessoal Ltd. is not responsible for the privacy practices or the content of associated websites. AWT – Tour Operator, Unipessoal Ltd. recommends reading the privacy policies of any associated websites that are visited, as their practices and privacy policies may differ from those of AWT – Tour Operator, Unipessoal Ltd. Feedback / Complaints / Contact.

Any questions, comments or complaints about this Notice or about the processing of Personal Data; or if you intend to inform AWT – Tour Operator, Unipessoal Ltd. about a change or correction of Personal Data; or if you wish to receive information about the Personal Data that are processed by AWT – Tour Operator, Unipessoal Lda.; or for any complaints or comments relating to data protection; should be addressed to AWT – Tour Operator, Unipessoal Lda. through the contacts below:

Contact name at AWT – Tour Operator, Unipessoal Ltd: Claúdia Coelho

Email:[email protected]

Address: Rua Arquiteto Cassiano Barbosa, nº 44, Office 5, 1st floor

AWT – Tour Operator, Unipessoal Ltd. will respond to any queries or complaints received as soon as possible.

13. Changes to Notice

This Notice may be changed and updated. If an amendment is made to the Notice, the revised version will be duly filed and published and dated on the website AWT – Tour Operator, Unipessoal Lda., when it exists. If appropriate, in addition to updating the Notice, we may ask customers to consent to include other types of treatment.

This Privacy Notice was last updated on May 6, 2019.