Privacy Policy & Data Protection

1. Introduction and Data Controller

Welcome to Scenebreezyhb (operated by Scenebreezyhb Hospitality Lda., Company Registration PT-518920412, headquartered at Avenida do Infante D. Henrique 44, 1100-244 Lisboa, Portugal). We are committed to safeguarding the privacy of visitors to our website, prospective guests, and concierge clients in full adherence to the General Data Protection Regulation (Regulation (EU) 2016/679 - "GDPR"), the Portuguese Data Protection Law (Lei n.º 58/2019), and relevant international privacy regulations including the California Consumer Privacy Act (CCPA).

2. Data We Collect and Methods of Collection

We collect personal data only when necessary to deliver our boutique hospitality curation and concierge advisory services. The categories of data collected include:

• Direct Identification Data: Full name, email address, telephone contact number, and travel party preferences submitted via our concierge inquiry forms.
• Stay Preferences & Inquiry Details: Requested travel dates, guest count, dietary preferences, special occasion notes, and preferred coastal regions.
• Technical & Browsing Data: Internet Protocol (IP) address, browser type, device specifications, operating system, referral URLs, time zone settings, and anonymized user interaction telemetry collected via privacy-compliant analytics.

3. Legal Bases for Data Processing

Under Article 6 of the GDPR, we process your personal data under the following lawful bases:

• Performance of a Contract or Pre-contractual Measures: Processing required to coordinate with verified Portuguese hotels, book bespoke itineraries, or provide concierge quotes upon your direct request.
• Consent: Where you have voluntarily opted into our seasonal digital travel editorial dispatches or accepted non-essential cookies.
• Legitimate Interests: To optimize our website performance, protect against fraudulent inquiries, and preserve the security of our digital systems.
• Legal Obligations: Compliance with Portuguese tax, accounting, and tourism reporting regulations.

4. Third-Party Processors & International Transfers

We do not sell, rent, or trade your personal information. Data may be shared strictly under confidentiality agreements with:

• Vetted Partner Boutique Stays: Selected hotels and villa estates in Portugal only when you request an explicit reservation or booking inquiry.
• Cloud Infrastructure Providers: Secure EU-based cloud hosting facilities utilizing AES-256 encryption at rest and in transit.
• Communications & CRM Infrastructure: Managed transactional email platforms adhering strictly to EU Standard Contractual Clauses (SCCs).

5. Data Retention Periods

We retain personal information only for as long as necessary to fulfill the purposes for which it was gathered. Concierge inquiry records are retained for a maximum of 24 months from your last interaction. Technical web logs are purged every 90 days. Accounting and invoice records are preserved for the statutory 10-year period mandated under Portuguese fiscal legislation.

6. Your Rights Under GDPR and CCPA

As a data subject, you possess enforceable legal rights regarding your personal information:

• Right of Access: You may request a copy of the personal information we hold about you.
• Right to Rectification: You may ask us to rectify inaccurate or incomplete records.
• Right to Erasure ("Right to be Forgotten"): You may demand the deletion of your personal data when it is no longer required for legitimate processing.
• Right to Restriction of Processing: You may request the restriction of processing under certain contested circumstances.
• Right to Data Portability: You may request your data in a structured, commonly used, machine-readable format.
• Right to Object: You can object at any time to processing based on legitimate interests or direct marketing.

To exercise any of these statutory rights, please contact our Data Protection Officer at [email protected] with the subject line "GDPR Data Rights Request".

7. Data Protection Officer & Supervisory Authority

If you believe our processing of your personal information infringes your privacy rights, you have the right to lodge a formal complaint with the Portuguese National Data Protection Commission:

Comissão Nacional de Proteção de Dados (CNPD)
Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, Portugal
Website: www.cnpd.pt