Privacy Policy
Last updated: 5 August 2026
Sea Breeze respects the privacy of its customers, website visitors and users of its booking services.
This Privacy Policy explains how Sea Breeze collects, uses, stores and protects personal data in connection with its website, booking process, boat tours and related communications.
1. Data controller
The controller responsible for the processing of personal data is:
Ruben Miguel Almeida Sequeira, trading as Sea Breeze
Tax Identification Number: 246 065 443
Address: Urb. Alto das Palmeiras, Lot 8, 3rd Floor A, 8500-815 Portimão, Portugal
Email: seabreeze.algarve@gmail.com
For any question relating to this Privacy Policy or the processing of personal data, data subjects may contact Sea Breeze using the email address above.
2. Scope of this Privacy Policy
This Privacy Policy applies to personal data processed through:
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The Sea Breeze website;
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The Wix booking system;
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Email or direct communications with Sea Breeze;
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Bookings received through Click&Boat, BoatBooker and GetYourGuide;
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Payment and invoicing processes;
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Photographs or videos taken during Sea Breeze tours, where authorised.
External booking platforms have their own privacy policies and may process personal data as independent data controllers. Customers should also consult the privacy policy of the platform through which they make their booking.
3. Personal data collected
Depending on the channel used and the nature of the booking, Sea Breeze may process the following personal data:
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Name of the person making the booking;
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Contact details provided through a booking platform, email or other communication channel;
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Number of participants;
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Number of adults and children;
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Date, time and type of tour booked;
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Booking reference;
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Payment status;
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Communications relating to the booking;
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Billing information required for the issue of an invoice;
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Photographs or videos, where the customer has authorised their capture or use;
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Technical information relating to the use of the website, including IP address, browser type, device information, pages visited and interaction data;
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Cookie and analytics information, subject to the user’s cookie preferences.
When a booking is made through Click&Boat, BoatBooker or GetYourGuide, Sea Breeze may receive personal data collected by the relevant platform that is necessary to manage and provide the booked service.
Sea Breeze does not request health data, medical information or information concerning reduced mobility through its standard booking process. Customers should avoid submitting sensitive personal data unless it is strictly necessary for their safety or participation in the tour.
4. Data relating to children
Children may participate in Sea Breeze tours provided that they are accompanied and supervised by a responsible adult.
Bookings must be made by an adult. Sea Breeze may record the number of children included in a booking for organisational, capacity and safety purposes.
Sea Breeze does not intentionally collect personal data directly from children.
Photographs or videos in which a child is identifiable will only be captured or used for promotional purposes with the prior authorisation of the child’s parent or legal guardian.
5. Purposes and legal grounds for processing
Sea Breeze processes personal data for the following purposes and on the following legal grounds.
5.1. Managing enquiries and booking requests
Personal data may be processed to:
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Respond to enquiries;
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Confirm availability;
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Provide information about tours;
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Prepare or manage a booking;
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Communicate changes, delays or cancellations;
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Provide information relating to meeting points, schedules or tour requirements.
The legal basis for this processing is the performance of a contract or the taking of steps at the customer’s request before entering into a contract.
5.2. Providing the booked service
Personal data may be processed to organise and provide the boat tour, confirm the number of participants and manage operational communications. The legal basis is the performance of the service contract entered into with the customer.
5.3. Processing payments
Where a payment is made through Click&Boat, payment information is processed through that platform and its payment service providers.
Sea Breeze may receive confirmation that the payment has been completed, cancelled or refunded, together with the information required to identify the booking.
Sea Breeze does not store complete payment card details.
The legal basis for processing booking and payment confirmation data is the performance of the service contract.
5.4. Invoicing and compliance with legal obligations
Personal data may be processed through Moloni to issue invoices, maintain accounting records and comply with applicable tax and legal obligations.
The legal basis is compliance with legal obligations to which Sea Breeze is subject.
5.5. Website operation and security
Technical data may be processed to:
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Operate and maintain the website;
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Ensure website and account security;
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Prevent fraud, misuse or unauthorised access;
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Diagnose technical problems;
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Maintain records necessary to establish, exercise or defend legal claims.
The legal basis is Sea Breeze’s legitimate interest in operating a secure website, protecting its services and defending its legal rights.
5.6. Website analytics
Sea Breeze uses Google Analytics to understand how visitors use the website, assess website performance and identify areas for improvement.
Where legally required, analytics cookies and similar technologies will only be used after the visitor has provided consent through the website’s cookie management system.
Consent may be withdrawn or changed at any time through the available cookie settings.
5.7. Photographs and videos
Sea Breeze may capture or use photographs and videos taken during tours for purposes such as:
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Sharing images with customers;
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Publishing content on the Sea Breeze website;
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Publishing content on social media;
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Promoting Sea Breeze tours and services.
Identifiable photographs or videos will only be used for promotional purposes with the prior consent of the persons concerned.
Consent is voluntary. Refusing consent will not affect the customer’s ability to participate in a tour.
Consent may be withdrawn at any time by contacting Sea Breeze. Withdrawal does not affect the lawfulness of any use carried out before consent was withdrawn.
6. No direct marketing
Sea Breeze does not currently operate a newsletter or use customer personal data to send regular direct marketing communications.
Operational communications concerning a booking, including confirmations, changes, cancellations, payment information and safety or meeting instructions, are not considered marketing communications.
Should Sea Breeze introduce newsletters or promotional communications in the future, this Privacy Policy and the relevant consent mechanisms will be updated before such processing begins.
7. Data received from external booking platforms
Customers may book Sea Breeze services through:
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Click&Boat;
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BoatBooker;
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GetYourGuide.
These platforms may collect personal, contact, booking and payment information under their own terms and privacy policies.
Sea Breeze receives only the information made available by the relevant platform that is necessary to identify the booking, contact the customer and provide the booked service.
The external platform may act as an independent data controller for the personal data collected directly through its website, application or payment system.
Requests concerning data held exclusively by an external platform should be addressed directly to that platform.
8. Service providers and recipients of personal data
Personal data may be processed by or disclosed to the following categories of recipients, where necessary:
Wix
Wix provides the Sea Breeze website, hosting infrastructure and booking functionality. Information submitted through the Sea Breeze website may be stored and processed through Wix systems.
Click&Boat
Click&Boat processes bookings and payments made through its platform and provides Sea Breeze with the information required to fulfil the booking.
BoatBooker and GetYourGuide
These platforms process bookings made through their respective services and provide Sea Breeze with the customer and booking information required to provide the tour.
Moloni
Moloni is used for invoicing and the management of legally required billing and accounting information.
Google Analytics may process technical and usage information, subject to the user’s cookie preferences and applicable consent requirements.
Public authorities and professional advisers
Personal data may also be disclosed:
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Where required by law;
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In response to a lawful request from a competent authority;
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To comply with tax, maritime, judicial or regulatory obligations;
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To establish, exercise or defend legal claims;
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To insurers, legal advisers or other professional advisers where necessary.
Sea Breeze does not sell or trade personal data.
9. International transfers
Some service providers used by Sea Breeze may process or store personal data outside Portugal or outside the European Economic Area.
Where personal data is transferred to a country that does not benefit from an adequacy decision by the European Commission, the relevant provider must apply an appropriate transfer mechanism, such as the European Commission’s Standard Contractual Clauses, together with any additional safeguards required by applicable law.
Further information about international transfers performed by Wix, Google and the external booking platforms is available in their respective privacy policies.
10. Data retention
Sea Breeze retains personal data only for as long as necessary for the purpose for which it was collected.
The following retention periods generally apply:
Enquiries and booking information
Personal data relating to enquiries, communications and completed or cancelled bookings will generally be retained for up to one year after the tour, cancellation or last relevant contact.
Data may be retained for a longer period where necessary to manage a complaint, resolve a dispute, defend a legal claim or comply with a legal obligation.
Invoices and accounting records
Personal data contained in invoices, accounting records and tax documentation will be retained for the period required by Portuguese tax law, which is generally ten years.
Photographs and videos
Photographs and videos used with the customer’s consent may be retained until:
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Consent is withdrawn;
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The content is no longer required;
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The relevant promotional material is removed or replaced;
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Continued use is no longer appropriate.
Withdrawal of consent will not require the withdrawal of printed materials already distributed or affect uses lawfully made before the withdrawal request was received.
Analytics information
Google Analytics information will be retained in accordance with the settings configured by Sea Breeze and the applicable retention periods established by Google.
Legal claims
Where personal data is necessary for the establishment, exercise or defence of legal claims, it may be retained until the applicable limitation periods have expired.
11. Data security
Sea Breeze adopts appropriate technical and organisational measures to protect personal data against:
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Unauthorised access;
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Unlawful processing;
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Accidental loss;
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Alteration;
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Disclosure;
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Destruction.
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These measures may include access controls, password protection, secure website communications, restricted account access and the security measures provided by the technology platforms used by Sea Breeze.
Access to personal data is limited to persons and service providers who require it for the purposes described in this Privacy Policy.
Although Sea Breeze takes reasonable steps to protect personal data, no website, communication system or electronic storage method can guarantee absolute security.
Where a personal data breach occurs, Sea Breeze will assess the incident, document it and notify the competent supervisory authority and affected data subjects where required by applicable law.
12. Cookies
The Sea Breeze website uses cookies and similar technologies.
Some cookies are necessary for the operation, security and booking functions of the website. These cookies may be used without consent where they are strictly necessary to provide a service requested by the user.
Optional cookies, including Google Analytics cookies, are used subject to the visitor’s consent where required by law.
Visitors can accept, reject or manage optional cookies through the cookie settings made available on the website.
Disabling necessary cookies may affect certain website or booking functions.
13. External links
The Sea Breeze website may contain links to third-party websites, booking platforms, social media services or other external services.
Sea Breeze is not responsible for the privacy practices, security or content of external websites.
When users access an external website or platform, the processing of personal data is governed by the privacy policy of that external provider.
14. Data subject rights
Subject to the conditions established by applicable data protection law, data subjects may exercise the following rights:
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Right of access to their personal data;
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Right to rectification of inaccurate or incomplete data;
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Right to erasure of personal data;
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Right to restriction of processing;
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Right to object to processing based on legitimate interests;
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Right to data portability, where applicable;
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Right to withdraw consent at any time;
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Right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects, where applicable;
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Right to lodge a complaint with a supervisory authority.
Requests may be submitted to: seabreeze.algarve@gmail.com
Sea Breeze may request additional information where necessary to confirm the identity of the person making the request and protect personal data against unauthorised disclosure.
The exercise of these rights may be restricted where the continued processing of personal data is required to comply with a legal obligation, establish or defend legal claims or protect the rights of another person.
15. Complaints
Data subjects have the right to lodge a complaint with the Portuguese supervisory authority: Comissão Nacional de Proteção de Dados — CNPD.
A complaint may be submitted directly through the official CNPD channels.
Before submitting a complaint, data subjects may contact Sea Breeze so that the matter can be reviewed and, where possible, resolved.
16. Automated decision-making
Sea Breeze does not use personal data to make decisions based solely on automated processing that produce legal effects or similarly significantly affect customers.
17. Changes to this Privacy Policy
Sea Breeze may update this Privacy Policy to reflect:
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Changes to its services;
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Changes to the website or booking process;
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The introduction or removal of service providers;
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Changes to applicable legal or regulatory requirements.
The date of the most recent update will be displayed at the beginning of this Privacy Policy.
Material changes may also be communicated through the website or other appropriate channels.