1. Data controller
Paulo A F Carvalho, Lda, tax number 509350291, trading as ONVICTA, is responsible for the processing of personal data collected through this website and through communications from its users.
For privacy-related questions or to exercise your rights, you may contact us at journeys@onvicta.com.
2. Personal data we may collect
Depending on how you interact with us, we may process information such as your name, email address, telephone number, destination or type of journey of interest, information you voluntarily include in messages and other data necessary to respond to your request.
The website may also generate technical information such as IP address, access date and time, device, browser, pages viewed and security logs where necessary for operation, security and technical diagnostics.
3. Purposes and legal bases
Data submitted through the contact form is used to assess your request, contact you and, where applicable, prepare proposals or take pre-contractual steps requested by you.
Processing may be based, as applicable, on pre-contractual steps requested by the data subject, compliance with legal obligations, legitimate interests relating to security, management and the defence of rights, or consent where legally required.
We will not use data provided in a travel enquiry for electronic marketing communications without an appropriate legal basis.
4. Recipients and service providers
ONVICTA may use service providers strictly necessary for website operation and contact management, including hosting, email, technical maintenance, security and other business tools.
Such providers should process personal data only under appropriate instructions and subject to applicable confidentiality and data protection obligations.
5. International transfers
Where a service provider involves transferring personal data outside the European Economic Area, ONVICTA will seek to ensure an appropriate legal mechanism is in place, such as an adequacy decision, standard contractual clauses or another safeguard permitted by applicable law.
6. Data retention
Personal data is retained only for as long as necessary for the purposes for which it was collected and to comply with applicable legal obligations.
Contact enquiries that do not result in a contractual relationship may generally be retained for up to 24 months after the last interaction, unless a legitimate reason or legal obligation justifies a different period.
7. Cookies, analytics and tracking pixels
The website may use technologies strictly necessary for its operation and, subject to the user’s choices, measurement, analytics or advertising tools.
Where a tracking technology is not strictly necessary, its activation respects the consent preferences made available to the user.
Submitting a form is not interpreted as consent to advertising tracking or marketing.
8. Your rights
Subject to the conditions provided by applicable law, you may exercise rights of access, rectification, erasure, restriction of processing, data portability and objection.
Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing previously carried out.
Requests concerning these rights may be sent to journeys@onvicta.com.
9. Complaints
If you believe that the processing of your personal data infringes applicable law, you have the right to lodge a complaint with the Portuguese Data Protection Authority, Comissão Nacional de Proteção de Dados (CNPD), without prejudice to other available administrative or judicial remedies.
10. Security
ONVICTA adopts technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, improper disclosure or destruction.
No Internet-connected system can guarantee absolute security, and the measures used are reviewed according to risk and technological developments.
11. Changes to this policy
This Privacy Policy may be updated to reflect legal, technological or operational changes. The current version will always be made available on this page together with the date of the latest update.