The Way by TFY, headquartered at Rua do Polo Norte, 18, Office 3.1, Lisbon, with NIPC 506540359, is committed to protecting the privacy of your personal data and to processing and ensuring the security of such data in accordance with the personal data protection legislation, in particular, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, General Data Protection Regulation - “GDPR”. This Privacy Policy aims to clarify how The Way by TFY treats your data and your rights as a data holder.
Any data made available to The Way by TFY will be understood as obtained, processed, and transmitted in strict observation and full compliance with the requirements established in the GDPR and legislation in force.
 
Data Protection Officer:
In accordance with the provisions of the GDPR, The Way by TFY acts as the entity responsible for processing your data. To obtain any clarification related to this Privacy Policy or the treatment of your data, you can contact The Way by TFY through Contact US
  
Type of personal data, Purposes, and Grounds for Processing:
This Policy covers The Way by TFY online and offline data collection activities including collected data through various channels, such as brand websites, agencies, and events/fairs in which The Way by TFY participates.

The Way by TFY collects and processes your data for several processes detailed below:

Reservation or purchase of services: There is a set of data that must necessarily be collected so that The Way by TFY can organize and provide the requested services (including sending the booking confirmation and travel documents), as well as manage any complaints related to the reservation or purchase of services, such as name, date of birth, identification document details, address, number of loyalty cards, mobile or telephone number, e-mail address, data related to travel preferences, data related to interests, reason and complaint details, special occasions and special requests. The basis for collecting this data is the management of the contractual relationship and the legitimate interest of The Way by TFY.  

Conducting satisfaction surveys: in order to assess your level of satisfaction with the services provided, The Way by TFY will be able to send you quality surveys. Customers are not obliged to respond to these quality surveys, which aim to collect opinions about the services provided, in order to improve/develop them. The basis for the processing of this data is The Way by TFY legitimate interest in continuously improving the quality of its services.
 
Management and administration: the data collected for The Way by TFY fulfill its accounting/tax and legal and administrative obligations, typically including your name, address, tax identification number or passport, and driver’s license. The basis for the treatment of this data is the fulfillment of a legal obligation and the legitimate interest of The Way by TFY in the management of the relationship with the client.


Commercial and promotional communications: The Way by TFY collects data such as name, phone or mobile number, and email address, in order to provide you with information about services that may be of interest to you (for example, marketing communications or campaigns and promotions), collecting your consent when necessary. At any time, you may object to the processing of your data for these purposes, as stipulated in the paragraph below "Exercise of your Rights". The basis for the processing of this data is The Way by TFY legitimate interest or, when requested, its consent.
 
Management promotional events: the data collected so that The Way by TFY can consider and manage your participation in a promotional event are in general the name, address, mobile or telephone number, and email address. For more information on promotions or promotional events, you can consult the regulations or terms and conditions included in each promotion/event. The basis for the processing of your data is your consent.
  
Organization of congresses and events, namely to manage the registration/registration of participants, accreditation, management of the respective accommodation and management of spaces, your identification data will be collected, such as name, telephone and e-mail address, name of the institution where you work/study, user name and password created for online registration, personal data required for billing, namely the tax identification number and address, data on other services requested, namely hotels, transfers, and meals. The basis for collecting this data is the management of the contractual relationship and the legitimate interest of The Way by TFY.

Provision of personal data:
As part of your reservation and/or purchase, The Way by TFY may provide your details:
 
To service providers (such as airlines, hotels, rent-a-car companies, operators, insurance companies, and other contracted service providers), so that they use it for correct rendering each requested service (in this case, the data will only be used for that specific purpose) and to comply with the legislation of the destination countries;
 
Government authorities (eg, immigration, border control, public security, and security, and anti-terrorism entities).
  
International Data Transfers:
Depending on the destination you are traveling to, The Way by TFY may need to transfer your data to service providers, inside or outside the European Union (provided that such transfer is essential for the execution/provision of the service).
Any transfer of personal data to a third country will only be carried out in compliance with legal obligations or provided that compliance with applicable Community and national legal rules in this area is guaranteed. 

Minor data:
Minority data is collected and processed with the consent of the parent or legal guardian. Regarding this data, parents or legal guardians can exercise the rights that the GDPR grants to data subjects.
 
Period of retention of personal data:
Your data is kept by The Way by TFY for the period strictly necessary to fulfill the aforementioned purposes, except when there are conservation obligations imposed by applicable law, or legitimate interest, which impose the maintenance of your personal data for a longer period.
 
Personal Data Security Measures:
The Way by TFY uses appropriate security measures to protect your data, including appropriate technical and organizational measures to protect it against abusive or illegal treatment and against accidental loss, damage, or destruction.
The data are processed by employees of The Way by TFY or by authorized service providers, accessing only the data strictly necessary, depending on the specific purposes for which the data was collected.
 
Exercise of your Rights:
As the data owner, you can exercise the following rights, within the legally established limits:

Access to personal data [When submitting an access request, you will be provided with access and details on the personal data processed by The Way by TFY.]
 
Correction of personal data [If your personal data is incomplete or incorrect, you can request the correction of it.]
 
Right to be forgotten [In exercising its right to be forgotten, The Way by TFY will, if applicable, erase your personal data.]
 
Personal data portability [When requesting the portability of your personal data, you will receive, in an automatic reading format, the personal data you have provided and which are processed based on your consent or the performance of a contract.]
 
Opposition to the processing of personal data [For reasons related to your particular situation, you have the right to object to the processing of your personal data by The Way by TFY based on legitimate interest or in relation to direct marketing.]

Revocation of consent to treatment [If you revoke your consent, The Way by TFY will remove your consent from the activity you specify].
 
The exercise of these rights depends on a written request (including a copy of a document proving the client's identity and mention of the right or rights you wish to exercise), to be sent by one of the following channels:
 
Address: Rua do Pólo Norte, 18, Office 3.1, Lisbon
Email: info@thewayportugalspain.com
In-person: Rua do Pólo Norte, 18, Office 3.1, Lisbon, by filling in the appropriate form
 
After submitting the request with the necessary information, The Way by TFY will respond within one to two months, taking into account the complexity and the number of requests.
 
Supervisory Authority:
If you believe that there is a problem with the way The Way by TFY is handling your data, you have the right to file a complaint with the national supervisory authority (National Data Protection Commission - CNPD) at www.cnpd.pt.
 
Information on the use of Cookies:
See our Cookie Policy, on our websites, to find out how you can manage your cookie settings and for detailed information about the cookies that The Way by TFY uses, as well as the purposes of their use. For more information on the Cookie Policy, please click here.
  
Changes to the Privacy Policy:
The The Way by TFY reserves the right, at any time, to make changes or updates to this Privacy Policy, these changes being duly updated on our platforms and websites. Check regularly to check for any updates or changes to this policy.