Privacy Policy 

1. Introduction

This Privacy Policy explains how Affordable Destiny Unipessoal Lda processes the personal data of Users and Guests who access the website www.affordabledestiny.pt or use its accommodation services. All processing is conducted in compliance with the General Data Protection Regulation (GDPR), applicable Portuguese law, and supervisory authority guidelines.

2. Data Controller

• Company: Affordable Destiny Unipessoal Lda
• Responsible Person: Hugo Capão
• Tax Number: 515504831
• Address: Avenida dos Combatentes da Grande Guerra 57, 1º Dto, 1495-039 Algés, Portugal
• Email: catarina.adestiny@gmail.com

3. Personal Data Collected

Depending on the User’s interaction with the Website and the services requested, the following data may be collected:

3.1. Identification and contact data
• Name, date of birth, identification document
• Email, phone number, address

3.2. Reservation and stay data
• Booking dates, selected accommodation unit, number of guests
• Specific stay requirements
• Payments made

3.3. Mandatory legal data
• Information required for reporting to SEF (Portugal’s Foreigners and Borders Service), as required by Portuguese accommodation regulations.

3.4. Automatic browsing data
• IP address, browser type, visited pages, time spent
• Technical or analytical cookies (see Cookies Policy)

4. Purposes of Processing

Data is used for:
1. Managing reservations and stays
2. Legal compliance, including mandatory reporting to SEF
3. Billing, accounting, and fiscal obligations
4. Communicating with the Guest (confirmations, arrival instructions, support)
5. Improving the Website and operational efficiency
6. Fraud prevention and incident management

5. Legal Basis for Processing

Processing is based on:
• Performance of a contract (reservations and stays)
• Compliance with legal obligations (SEF reporting, accounting)
• Legitimate interests (security and service improvements)
• User consent (cookies, optional communications)

6. Data Sharing with Third Parties

Data may be shared only with:
• SEF, as legally required
• Payment processing providers
• Accountants, auditors, or tax authorities
• Technical service providers (hosting, backups, email)
Data is never sold or used for external commercial purposes.

7. International Data Transfers

Data is normally processed within the EU. If transfers outside the EU are necessary, 
GDPR-compliant safeguards will be applied.

8. Data Retention

• Reservation and invoicing data: 10 years, per fiscal law
• SEF reporting data: retained according to legal requirements
• Marketing contact data: until consent is withdrawn
• Browsing data: per Cookies Policy

9. Rights of Data Subjects

Users have the right to:
• Access their data
• Rectify inaccurate data
• Erasure, when applicable
• Restrict processing
• Data portability
• Object to processing
• Withdraw consent (when processing is consent-based)
To exercise rights: catarina.adestiny@gmail.com

10. Data Security

Appropriate technical and organizational measures are implemented to protect data from unauthorized access, loss, or misuse.

11. Changes to the Privacy Policy

Affordable Destiny may update this Policy at any time. Significant updates will be published on the Website