Short version: We collect only what we need to answer your enquiries and improve the website. We don't sell your data, we don't send unsolicited marketing, and you can ask us to delete everything at any time.
1. Who We Are
Random Portugal is a Lisbon-based tourism operator providing guided day trips and city experiences across Portugal.
- Business name: Random Portugal
- Location: Lisbon, Portugal
- Email: [email protected]
- WhatsApp: +351 939 130 138
As a data controller, we are responsible for deciding how and why your personal data is processed. This policy applies to the website www.randomportugal.com and any personal data you provide when you contact us or use our booking process.
2. What Data We Collect
2a. Contact form & enquiries
When you fill in our contact form or send us a message, we collect:
- Your name
- Your email address
- Any message content you voluntarily provide (tour preferences, travel dates, group size, etc.)
2b. WhatsApp booking
When you click a "Book" or "WhatsApp Us" button, you are redirected to WhatsApp (owned by Meta Platforms, Inc.). Any conversation that takes place happens within WhatsApp's platform and is also subject to WhatsApp's Privacy Policy. We retain chat transcripts for up to 12 months to manage your booking and assist with any follow-up questions.
2c. Analytics data (Google Analytics 4)
We use Google Analytics 4 (GA4) to understand how visitors use our website. GA4 collects:
- Pages visited and time spent on each page
- General geographic location (country/city level)
- Device type and browser
- How you arrived at the site (search engine, social media, direct, etc.)
This data is anonymised — it is not linked to your name, email, or any personally identifying information. GA4 uses cookies to track sessions. Google's data processing terms apply; see Google's Privacy Policy for full details.
2d. Data we do NOT collect
- Payment card details (all payments are handled offline by arrangement)
- Passport or identity document information
- Sensitive categories of personal data (health, religion, ethnicity, etc.)
3. Why We Process Your Data (Legal Basis)
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Responding to your enquiry or booking request | Name, email, message content | Pre-contractual steps / Contract performance (Art. 6(1)(b)) |
| Managing your booking and follow-up | Name, WhatsApp messages | Contract performance (Art. 6(1)(b)) |
| Understanding how the website is used to improve it | Anonymised analytics data | Legitimate interest (Art. 6(1)(f)) |
| Complying with legal obligations | Booking records where required by Portuguese law | Legal obligation (Art. 6(1)(c)) |
4. How Long We Keep Your Data
- Enquiries that did not convert to a booking: Deleted within 3 months of the last contact.
- Booking records (WhatsApp conversations, emails): Retained for up to 2 years after the tour date, then deleted.
- Analytics data: Retained by Google Analytics for 14 months, then automatically deleted.
5. Sharing Your Data
We do not sell, rent, or trade your personal data. We share data only in the following limited cases:
- WhatsApp / Meta: When you initiate a WhatsApp conversation with us, your messages are processed by Meta under their own terms.
- Google Analytics: Anonymised usage data is shared with Google LLC as part of our analytics service.
- Legal requirements: We may disclose data if required to do so by Portuguese or EU law, a court order, or to protect the safety of our staff or customers.
We do not use third-party marketing platforms, email list providers, or ad networks that would receive your personal data.
6. Cookies
Our website uses a small number of cookies:
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
| _ga | Google Analytics | Distinguishes unique users | 2 years |
| _ga_XXXXXXX | Google Analytics | Maintains session state | 2 years |
You can disable cookies in your browser settings at any time. Disabling analytics cookies will not affect your ability to use the website or book tours. To opt out of Google Analytics tracking across all websites, you can install the Google Analytics Opt-out Browser Add-on.
7. Your Rights Under GDPR
If you are located in the EU or UK, you have the following rights regarding your personal data:
- Right of access: Request a copy of the personal data we hold about you.
- Right to rectification: Ask us to correct inaccurate data.
- Right to erasure ("right to be forgotten"): Ask us to delete your data, subject to certain legal exceptions.
- Right to restrict processing: Ask us to limit how we use your data.
- Right to data portability: Receive your data in a structured, machine-readable format.
- Right to object: Object to processing based on legitimate interests.
- Right to lodge a complaint: You have the right to complain to the Portuguese data protection authority, the CNPD (Comissão Nacional de Proteção de Dados) at cnpd.pt.
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
8. Data Security
We take reasonable technical and organisational measures to protect your personal data against unauthorised access, accidental loss, or destruction. Our website is served over HTTPS. Email and WhatsApp communications are subject to the security measures of those respective providers.
No method of transmission over the internet is 100% secure. While we do our best to protect your data, we cannot guarantee absolute security.
9. International Transfers
Google Analytics may transfer anonymised data to servers located outside the EU/EEA, including the United States. Google participates in the EU-U.S. Data Privacy Framework, providing an adequate level of protection for such transfers.
We do not otherwise transfer personal data outside the EU/EEA.
10. Children's Privacy
Our website and services are not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.
11. Changes to This Policy
We may update this privacy policy from time to time. The date at the top of this page shows when it was last revised. Material changes will be reflected in the "Last updated" date. We encourage you to review this page periodically.
12. Contact Us
For any questions, requests, or complaints about this privacy policy or how we handle your data:
- Email: [email protected]
- WhatsApp: +351 939 130 138
We aim to respond to all data-related requests within 30 days.