Privacy Policy
Effective date: September 28, 2026
This Privacy Policy explains how SW Trails collects, uses, stores and protects your personal data when you visit the website, contact us or book a service.
1. Data Controller
The data controller is Ayun Trindade, trading as SW Trails, based in Aljezur, Algarve, Portugal.
For privacy-related questions or requests, contact: ayun@swtrailsalgarve.com
2. What Data We Collect
Depending on how you contact us or which service you book, we may collect:
- Name
- Email address
- Phone number
- Date of birth or age
- Height, weight and bike-sizing information
- Booking and tour details
- Emergency contact information, if provided
- Relevant health, medical or safety information that you voluntarily provide
- Photo or video consent choices
- Technical information required for the website and forms to function, such as IP address and browser information
3. How We Collect Your Data
Personal data may be collected when you:
- Submit a booking form
- Submit the website contact form
- Contact SW Trails by email, phone or messaging service
- Make a payment or request an invoice
- Participate in a tour or guided activity
4. How We Use Your Data
Your personal data may be used:
- To respond to enquiries and booking requests
- To arrange, confirm and provide tours
- To communicate about meeting points and logistics
- To provide suitable bikes and equipment
- To help protect rider health and safety
- To process payments, deposits, invoices and refunds
- To manage photo and video consent
- To meet legal, tax and administrative obligations
- To establish or defend legal claims where necessary
5. Legal Basis for Processing
Depending on the information and purpose involved, personal data is processed on one or more of the following grounds:
- Contract: to arrange and provide a service that you request or book
- Legal obligation: to meet tax, accounting or other legal requirements
- Legitimate interests: to communicate with customers, operate the business, prevent misuse and provide activities safely
- Consent: where consent is required, including certain uses of photographs, videos or voluntarily supplied health information
- Vital interests: where information must be used in an emergency to protect someone’s health or safety
6. Health and Safety Information
Health or medical information is only requested where it may be relevant to safely providing the activity. You should only provide information that is relevant to your participation.
This information is normally processed with your explicit consent. In a genuine emergency, it may also be used where necessary to protect your vital interests or those of another person.
7. Data Retention
Personal data is retained only for as long as reasonably necessary for the purpose for which it was collected.
Booking communications and safety information are retained only while needed to manage the booking, provide the activity, resolve disputes or establish legal claims. Invoices, payment records and other administrative information may be kept for the period required by Portuguese tax and accounting law.
When personal data is no longer required, it will be deleted or securely anonymised where reasonably possible.
8. Sharing Your Data
SW Trails does not sell or rent your personal data.
Personal data may be shared only where necessary with service providers or other parties such as:
- Website hosting and booking-form providers
- Email and communication providers
- Payment providers and financial institutions
- Accounting or administrative service providers
- Medical services, emergency services or insurers where necessary
- Legal authorities where disclosure is required by law
Service providers are only given the information reasonably necessary for their role.
9. International Data Transfers
Some website, booking, email or technology providers may process information outside Portugal or the European Economic Area.
Where an international transfer takes place, SW Trails relies on an appropriate legal transfer mechanism or safeguards required under applicable data-protection law.
10. Your Rights
Subject to the conditions and limits established by law, you may have the right to:
- Access your personal data
- Correct inaccurate or incomplete personal data
- Request deletion of your personal data
- Restrict the processing of your personal data
- Object to certain processing
- Receive certain data in a portable format
- Withdraw consent at any time where processing is based on consent
Withdrawing consent does not affect processing that lawfully took place before consent was withdrawn.
To exercise any of these rights, email ayun@swtrailsalgarve.com . SW Trails may need to verify your identity before completing the request.
11. Complaints
If you believe your personal data has been processed unlawfully, you may submit a complaint to Portugal’s supervisory authority:
Comissão Nacional de Proteção de Dados (CNPD)
Website:
www.cnpd.pt
12. Data Security
Reasonable technical and organisational measures are used to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. However, no website, transmission or storage system can be guaranteed to be completely secure.
13. Cookies and Technical Services
This website does not use advertising cookies or personal data for behavioural advertising or profiling.
Basic technical services may process limited connection information, such as an IP address or browser information, when required to display the website, load fonts, prevent misuse or submit a form.
14. Automated Decision-Making
SW Trails does not use personal data to make automated decisions or create profiles that produce legal or similarly significant effects.
15. Changes to This Policy
This Privacy Policy may be updated when the website, services or legal requirements change. The effective date at the top of this page will show when the latest version took effect.
16. Contact
For any privacy-related question or request, contact:
Ayun Trindade, trading as SW Trails
Email:
ayun@swtrailsalgarve.com
Location: Aljezur, Algarve, Portugal