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PRIVACY POLICY

Last updated: 03/01/2026

01. IDENTIFICATION AND CONTACT

SENSORY FRONTAGE – LDA, with Tax ID (NIPC) 519227727 and registered office at Rua Cidade Vila Cabral, no. 28, 1st Left, 1800-131 Lisbon (hereinafter the "Company"), undertakes to protect the privacy of users of the This Is Portugal platform.

  • Controller: SENSORY FRONTAGE – LDA.
  • Contact E-mail / DPO: geral@thisisportugal.pt

SENSORY FRONTAGE – LDA operates the This Is Portugal platform, dedicated to the editing and licensing of geolocated digital content. We act as the "Controller", ensuring full compliance with the General Data Protection Regulation (GDPR) and national legislation.

02. DATA COLLECTED AND PURPOSES

We collect data so that you can enjoy the cultural experience in a secure and technical manner. Personal data is all information that allows you to be identified directly or indirectly.

We collect and process this data in a minimal and strictly necessary manner for the following purposes:

Category of Data Purpose of Processing Legal Basis
Identification and Contact (Name, E-mail) Account management, delivery of audio licences and support. Performance of Contract
Billing Data (Name, Tax ID, Address) Compliance with tax and accounting obligations. Legal Obligation
Precise Geolocation (GPS) Map display. Performance of Contract
Technical Data (IP, Device, OS) Cybersecurity and software optimisation. Legitimate Interest
Transactional Data (Purchase history) Management of access and resolution of technical problems. Performance of Contract
Marketing E-mail (Optional) Sending news and promotions. Consent (Opt-in)

Geolocation Data: The processing of GPS coordinates is strictly technical and volatile. The Company does not store route history or create movement profiles of users.

Data Collected Automatically

Some data is collected automatically whenever you use the This Is Portugal platform, as it is necessary for its proper functioning and for the improvement of our services.

This data includes, but is not limited to:

  • Activity Data: Information about your interactions on the platform (products viewed, search history).
  • Location Data: General information about your location (through the IP address).
  • Browsing Data: Technical details about the device and access (browser type, operating system, access time).

03. WHY WE PROCESS YOUR PERSONAL DATA

The processing is based on the following grounds:

  • Performance of Contract: For the provision of the licence to use the digital content. Essential for your account to function. Without this data, the service cannot be provided.
  • Compliance with Legal Obligations: For the issuance of invoices and reporting to the Tax Authority. This is a mandatory legal requirement.
  • Legitimate Interest: We use your data to improve our services, ensure network security, prevent fraud, protect the Company's intellectual property and optimise your experience, provided that your privacy rights are not affected.
  • Your Consent: For direct-marketing purposes and non-essential cookies, we ask for your authorisation before using your data. Should you not authorise it, we will not process the data for that specific purpose and access to the services will not be affected.

04. DATA RETENTION AND SECURITY

The retention of your personal data is governed by the principle of minimisation, being kept only for the period strictly necessary to fulfil the purposes for which it was collected and in strict compliance with the applicable legal obligations.

A) Time Periods

  • Billing data is retained for the period legally required by Portuguese tax and accounting legislation, currently 10 (ten) years. – Basis: Compliance with Legal Obligation.
  • Account data is kept while the account is active. After 6 months of inactivity following a closure request, the data is deleted or anonymised. – Basis: Performance of Contract and Legitimate Interest (fraud prevention, security management and the possibility of reactivation by the user).
  • Communications and Customer Support: Retained for a maximum period of 5 (five) years after the resolution of the dispute or closure of the request. – Basis: Legitimate Interest (legal defence in the event of disputes and improvement of service quality).
  • Marketing Data (Consent): Retained until consent is withdrawn. – Basis: Consent.
  • GPS Deletion: Geolocation data is processed on a volatile basis and is deleted immediately after the closure of the session or the application. – Basis: Performance of Contract.
  • Security: We implement SSL/HTTPS encryption, restricted-access protocols and firewall. – Basis: Legitimate Interest and Compliance with Legal Obligation.

B) Exceptions to Deletion

  • Account Suspension/Block: Retention for the period of the suspension and any additional time necessary to prevent malicious reactivation.
  • Pending Disputes: Retained until the final and unappealable decision of any judicial, administrative or arbitral proceedings.

C) Deletion and Anonymisation

Once the applicable retention period has been reached, the Company shall proceed with the secure deletion or irreversible anonymisation of the personal data, retaining the latter only for statistical purposes.

05. SHARING OF DATA WITH THIRD PARTIES

The Company does not commercialise personal data. Sharing occurs only with subcontractors that ensure compliance with the GDPR:

  • Distribution Platforms: Apple App Store and Google Play Store (management of In-App purchases).
  • Technology Partners: Certified payment gateways (e.g., Stripe/PayPal), Cloud hosting (e.g., AWS/Google) and invoicing software.
  • Partners (Referral): If you use a referral code, the partner (e.g., Hotel or Driver) will only have access to confirmation that a sale has been made for the calculation of the commission. No personal data of the user (name or e-mail) is shared with the partner.
  • Public Authorities: Where required by law.

06. RIGHTS OF THE DATA SUBJECT

In accordance with the GDPR, the Client has the following rights, which may be exercised by written request to the contact e-mail indicated in point 1:

  • Access: To request confirmation of and access to personal data.
  • Rectification: To request the correction of incorrect or incomplete data.
  • Erasure ("Right to be Forgotten"): To request the erasure of your data, in certain legal circumstances.
  • Restriction of Processing: To request the restriction of processing, in certain legal circumstances.
  • Portability: To receive personal data concerning you and to transmit it to another controller.
  • Objection (General): To object to the processing of your data on the grounds of Legitimate Interest or the Performance of a Task Carried Out in the Public Interest.
  • Objection (Direct Marketing): To object to the processing of your data for direct-marketing purposes.
  • Not to be Subject to Automated Individual Decisions: The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you.
  • Withdrawal of Consent: To withdraw consent previously granted at any time, without compromising the lawfulness of the processing carried out until that date.

07. SECURITY AND PROTECTION OF YOUR PERSONAL DATA

SENSORY FRONTAGE – LDA undertakes to protect your personal data and to ensure its confidentiality and integrity. We implement appropriate technical and organisational measures to protect data against unauthorised or unlawful processing, as well as against accidental loss, destruction or damage.

Among the security measures applied, the following stand out:

  • Pseudonymisation and Encryption: Use of encryption techniques to protect data in transit and at rest.
  • Access Control: Implementation of mechanisms for restricted access to personal data, ensuring that only authorised personnel with a need to know for the performance of their duties have access.
  • Audits and Monitoring: Carrying out regular audits and security checks to ensure the effectiveness of the implemented controls.

08. UPDATES AND CHANGES TO THE PRIVACY POLICY

We reserve the right to update and modify this Privacy Policy at any time.

  • Notification of Changes: In the event of substantial changes affecting the way we process your personal data, we will notify you appropriately and in a timely manner, either through a prominent notice on our platform, a direct message in the user account, or via electronic mail.
  • Acceptance and Termination: Your continued use of our Services after notification of the changes constitutes acceptance of the new conditions.
  • Right of Objection: If you do not agree with the terms of the updated Privacy Policy or with the data-processing options provided therein, you may exercise your right of disengagement at any time by closing your account through the respective settings.

09. RIGHT TO COMPLAIN

  • The Client has the right to lodge a complaint with the supervisory authority in Portugal: National Data Protection Commission (CNPD) – www.cnpd.pt.
  • Data Protection Officer (DPO): For any matter relating to the processing of your data or to exercise your privacy rights, the Client may contact our Data Protection Officer (DPO) via the e-mail geral@thisisportugal.pt or by post to the address of the Company's registered office (Rua Cidade Vila Cabral, no. 28, 1st Left, Lisbon), addressed to the "Data Protection Officer".