PRIVACY POLICY

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7 May Travel, Lda. is committed to protecting the privacy and personal data of its clients, partners and users of its website, fully complying with Regulation (EU) 2016/679 – General Data Protection Regulation (GDPR) – and Law No. 58/2019, of August 8, which ensures its implementation in national territory.

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1. IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER

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CONTROLLER: 7May Travel Lda, with NIPC 518 282 937, RNAVT no. 12077 and registered office at Avenida da Liberdade no. 6, 3620-373, Moimenta da Beira, Viseu, Portugal, holder of the Honeymooners brand rights in Portugal. | EMAIL: legal.department@honeymooners.travel

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2. DATA COLLECTION AND PURPOSES OF PROCESSING

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COLLECTION: This policy covers data collection activities online through various channels, such as the brand’s website and respective social networks (Facebook and Instagram).

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PURPOSES: Personal data is processed for the following purposes: booking and organization of personalized experiences, issuing bookings and tickets, payment processing, sending commercial communications and newsletters, customer support and complaint management.

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2.1. BOOKING AND ORGANIZATION OF PERSONALIZED EXPERIENCES: Honeymooners collects the personal data strictly necessary for the design, planning, booking and follow-up of the contracted experience, including the sending of confirmations and travel documentation, as well as the management of requests or complaints. This data may include: name, date of birth, nationality, passport number, address, phone and email contacts, travel preferences, data relating to interests, special events (e.g.: honeymoon, wedding anniversary), personalized requests, and reason and detail of any complaints. LEGAL BASIS: contract performance and Honeymooners’ legitimate interest in ensuring a personalized and effective service.

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2.2. OBTAINING VISAS OR SPECIFIC AUTHORIZATIONS: In certain destinations, it may be necessary to collect data required by official entities for the purpose of issuing visas or similar documents. This data includes, depending on the destination country: passport number, vaccination record and, in specific cases, criminal record certificates. LEGAL BASIS: compliance with legal obligations imposed by international authorities.

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2.3. SATISFACTION SURVEYS: Honeymooners may contact clients after the trip to assess their satisfaction with the services provided. Responding to surveys is entirely optional and aims to gather feedback to continuously improve the Honeymooners experience. LEGAL BASIS: Honeymooners’ legitimate interest in continuous improvement of its services.

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2.4. ADMINISTRATIVE, ACCOUNTING AND TAX MANAGEMENT: Personal data may be processed for compliance with applicable legal and administrative obligations, particularly with regard to invoicing, archiving and tax reporting. Data commonly processed for this purpose include: name, address and Tax Identification Number (TIN). LEGAL BASIS: compliance with legal obligations and Honeymooners’ legitimate interest in good client relationship management.

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2.5. COMMERCIAL AND INSPIRATIONAL COMMUNICATIONS: With your consent or based on legitimate interest, Honeymooners may use your contact data (name, email, phone) to send you communications about new destinations, real couple stories, special campaigns or other experiences that may interest you. You may withdraw your consent at any time, as provided in this policy. LEGAL BASIS: Honeymooners’ legitimate interest in maintaining a continuous relationship with its clients or consent when required.

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2.6. MANAGEMENT OF SPECIAL EVENTS, CONTESTS AND PROMOTIONAL ACTIVATIONS: When you participate in contests, giveaways or events organized by Honeymooners, data such as name, address, email and phone number may be collected for the purpose of managing your participation, direct contact and awarding prizes or experiences. The rules applicable to each initiative are set out in the respective regulations. LEGAL BASIS: data subject’s consent.

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2.7. ORGANIZATION OF EVENTS, IN-PERSON EXPERIENCES AND HONEYMOONERS COMMUNITY GATHERINGS: Whenever Honeymooners organizes conferences, immersions, community gatherings or other in-person experiences, personal data of participants may be collected for purposes of registration, accreditation, accommodation management, venue bookings and associated services. This data includes: name, phone, email, institution where you work/study (when applicable), username and password (in case of online registration), billing data (address and Tax Identification Number), and information about optional services requested, such as accommodation, transfers or meals. LEGAL BASIS: contract performance and Honeymooners’ legitimate interest in efficiently managing the participation of its guests and clients.

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3. PERSONAL DATA COLLECTION

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3.1. CATEGORIES OF DATA PROCESSED: Identification: name, date of birth, nationality, passport number; Contact: email, phone, address; Payment: bank or credit card data; Sensitive data (e.g.: health or food), when strictly necessary and with explicit consent.

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3.2. COMMUNICATION AND SHARING OF PERSONAL DATA: In the context of the booking and/or organization of the contracted experience, Honeymooners may communicate your personal data to third parties, exclusively when necessary to ensure service delivery, compliance with legal obligations or the brand’s legitimate interest.

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3.3. RECIPIENTS: TOURISM SERVICE PROVIDERS: such as airlines, hotels, private transportation companies, local operators and insurers, only to the extent necessary for the correct provision of each reserved service and in accordance with the destination country's legislation; GOVERNMENT AUTHORITIES OR PUBLIC ENTITIES: such as immigration, border control, public security or anti-terrorism authorities, when legally required; STRATEGIC BUSINESS PARTNERS: acting on behalf of Honeymooners, such as technology service providers, IT platforms, marketing and digital communication agencies, auditors, accountants and legal advisors, always under contractual clauses of confidentiality and data protection; CORPORATE TRANSACTIONS CONTEXT: such as mergers, acquisitions or internal restructurings, provided that such communication is necessary and proportionate, and duly safeguarded by the legitimate interest of Honeymooners or third parties involved.

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3.4. INTERNATIONAL DATA TRANSFERS: Depending on the destination of the contracted trip, it may be necessary to transfer personal data to service providers located outside the European Economic Area (EEA), whenever this is essential for the proper performance of the obligations arising from the contractual relationship established. Any international data transfer will be carried out in strict compliance with Regulation (EU) 2016/679 (GDPR) and applicable national legislation, and only when adequate safeguards are ensured, namely through adequacy decisions, standard contractual clauses or other legally valid mechanisms.

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3.5. DATA OF MINORS: The processing of personal data of minors is carried out only with the prior and express consent of those holding parental responsibilities or a duly authorized legal representative. With regard to this data, the said legal representatives may exercise all rights enshrined in the General Data Protection Regulation (GDPR), as legally authorized holders.

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3.6. PERSONAL DATA RETENTION PERIOD: Personal data is retained only for the period strictly necessary for the purposes for which it was collected, as described in this Policy, without prejudice to longer periods arising from compliance with legal obligations or the exercise of Honeymooners’ duly substantiated rights or legitimate interests. In the case of data processed for commercial communication purposes, it will be retained until opposition to its processing is expressed or consent is withdrawn, as applicable, or up to two years after the last relevant interaction with Honeymooners.

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4. PERSONAL DATA SECURITY MEASURES

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Honeymooners adopts appropriate technical and organizational measures to ensure a level of security appropriate to the risk, protecting personal data against unauthorized access, loss, disclosure, alteration or accidental or unlawful destruction. Data processing is carried out by duly authorized staff or by service providers contractually bound to Honeymooners, all subject to confidentiality obligations and with access only to the data strictly necessary for the performance of their duties, according to the specific purposes of the processing.

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5. EXERCISE OF DATA SUBJECT RIGHTS

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Under the General Data Protection Regulation (GDPR), data subjects have the following rights, within legally applicable limits.

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5.1. RIGHT OF ACCESS: the data subject has the right to request information about the personal data processed, as well as to obtain a copy thereof.

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5.2. RIGHT TO RECTIFICATION: the data subject has the right to request the correction or update of inaccurate or incomplete data.

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5.3. RIGHT TO ERASURE OF PERSONAL DATA: the data subject has the right to request the erasure of personal data, provided there are no legitimate legal grounds justifying their retention by the data controller.

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5.4. RIGHT TO DATA PORTABILITY: the right to receive the personal data provided, in a structured, commonly used and machine-readable format, and to request their transmission to another data controller, when technically feasible.

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5.5. RIGHT TO OBJECT: the data subject has the right to object to the processing of personal data based on legitimate interest or for direct marketing purposes.

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5.6. RIGHT TO RESTRICTION OF PROCESSING: the data subject has the right to request the restriction of processing in certain circumstances.

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5.7. RIGHT TO WITHDRAW CONSENT: the data subject has the right to withdraw consent to data processing, where such processing is based on consent, at any time, without compromising the lawfulness of the processing carried out previously.

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5.8. The exercise of the above rights must be made through a written request, accompanied by proof of identity, expressly indicating the right(s) to be exercised. The request may be sent via email to legal.department@honeymooners.travel.

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6. CLIENT’S RESPONSIBILITY

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If it is understood that the processing of personal data carried out by Honeymooners violates the provisions of the General Data Protection Regulation or applicable national legislation, a complaint may be submitted to the competent supervisory authority: Comissão Nacional de Proteção de Dados (CNPD), available at www.cnpd.pt.

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7. INFORMATION ON THE USE OF COOKIES

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Please refer to our Cookie Policy, available on our websites, to learn how to manage your cookie settings and for detailed information on the cookies used by Honeymooners, as well as the purposes of their use.

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8. CHANGES TO THE PRIVACY POLICY

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Honeymooners reserves the right to make changes or updates to this Privacy Policy at any time. Any changes will be published on the company’s digital platforms and official channels, taking effect from the date of availability. Regular consultation of this document is recommended to stay informed of any updates.

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LAST UPDATED: May 14, 2025