Data collection and privacy notice
EUROPEAN UNION PRIVACY POLICY
This privacy policy applies solely to the processing of the personal data of data subjects who are in the European Union.
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our site (regardless of where you visit it from) or sign up for the trip and tell you about your privacy rights and how the law protects you.
We collect and use your personal data to provide you with the service you have requested.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through the use of our site or when you sign up for the trip including any data you may provide in the signup form.
This website is not intended for children and we do not knowingly collect data relating to children.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us by phone or text message. Contact information can be found on the organizers page.
Please note that the GDPR law gives you the right to lodge a complaint with a local data protection authority within the country in which you reside.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use and store different kinds of personal data about you. This data is never transferred to third parties unless required by law or to provide a service you have requested. See section 5 for more information. The data is grouped together as follows:
- Identity Data includes fullname, birthdate, birthplace, nationality, passport number, place of residence, country of residence, and various health information such as allergies and/or diet.
- Contact Data includes email address, physical address, and telephone number.
- Financial Data includes bank account details.
- Usage Data includes information about how you use our website.
We also collect Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to provide you with services. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling out the signup form or by corresponding with us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment and browsing actions.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the service that you requested.
- Where we need to comply with a legal obligation.
Change of purpose
We will only use your personal data for the purposes for which we collected it.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with third parties involved in the trip, such as the owners of the accommodation or the authorities.
The following data will be shared with the Portuguese authorities, as they require us to send them information about who is coming on the trip:
- Full name
- Nationality
- Passport Number
- Birthdate
- Birthplace
- Place of Residence
- Country of Residence
The following data will be shared with the company providing surfing lessons and rentals:
- Full name
- Your surfing level
The following data will be shared with the company providing accommodation:
- Full name
6. INTERNATIONAL TRANSFERS
The information you provide may be stored in countries outside the European Economic Area (EEA) that do not have similar protections in place regarding your data and restrictions on its use as set out in this privacy policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information you consent to these transfers for the purposes specified above.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.