Legal
Swingo by Avenidas
Website: www.swingo.pt
Last updated: 30 June 2026 · Effective date: 30 June 2026
This Privacy Policy explains how Swingo collects, uses, shares and protects your personal data when you visit www.swingo.pt, contact us, request a quotation, make a booking, or use our tours, private driver and transfer services.
We are committed to protecting your personal data and to processing it in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, the "GDPR"), Portuguese Law no. 58/2019 of 8 August, Law no. 41/2004 of 18 August on privacy in electronic communications, and the guidance of the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados ("CNPD").
The data controller is:
Privacy contact
Depending on how you interact with us, we may collect the following categories of personal data.
Full name, email address, telephone number (including country code), postal address or hotel/accommodation address used for pickup, and (where you contact us through them) social media or messaging identifiers.
Booking or reservation number, the Service booked, date and time, number and composition of the party, pickup and drop-off locations, preferred language, itinerary preferences, the sales channel used, and the price and payment status of your booking.
Where you choose to share it, information about reduced mobility, accessibility needs, medical conditions relevant to the Service, food allergies or intolerances, and the ages of children travelling with you. Some of this is "special category" data (data concerning health) under Article 9 of the GDPR and is treated with additional care (see Section 6).
Information needed to take or confirm payment. For direct bookings, card payments are handled by a third-party payment service provider; we do not store full card numbers on our own systems. For bookings made through a sales channel, payment data is held by that channel.
The content of your emails, contact-form submissions, website chat, WhatsApp and other messages with us, call notes, and your service feedback and reviews.
When you visit www.swingo.pt, we and our service providers may collect your IP address, device and browser information, pages viewed, referring pages, and similar data through cookies and similar technologies (see Section 8).
Your preferences for receiving marketing, and your interactions with our marketing and advertising.
You do not have to give us personal data, but if you do not provide the information needed to make and deliver a booking, we may be unable to provide the Service.
We collect personal data:
We process personal data only where we have a legal basis under Article 6 of the GDPR. The table below summarises our main processing activities.
| Purpose | Examples | Legal basis |
|---|---|---|
| Manage quotations and bookings | Confirming bookings, arranging pickups, assigning guides and drivers, sending reminders and service information | Performance of a contract with you, or steps taken at your request before entering a contract (Art. 6(1)(b)) |
| Deliver the Service safely | Sharing necessary details with your guide, driver or a subcontractor; accommodating special requirements | Performance of a contract (Art. 6(1)(b)); for health-related data, your explicit consent (Art. 9(2)(a)) |
| Customer care and communications | Replying to your messages; handling changes, complaints and refunds | Performance of a contract (Art. 6(1)(b)); our legitimate interests in managing our relationship with you (Art. 6(1)(f)) |
| Payments, invoicing and accounting | Taking payment, issuing invoices, keeping accounting records | Compliance with a legal obligation (Art. 6(1)(c)); performance of a contract (Art. 6(1)(b)) |
| Legal and regulatory compliance | Obligations under tourism, tax, accounting and consumer law; responding to lawful requests from authorities | Compliance with a legal obligation (Art. 6(1)(c)) |
| Reviews and service improvement | Inviting reviews after a Service; analysing feedback to improve quality | Our legitimate interests in improving our Services (Art. 6(1)(f)) |
| Marketing | Sending offers and news where permitted; measuring and personalising advertising | Your consent (Art. 6(1)(a)) and/or our legitimate interests, subject to your right to object (Art. 6(1)(f)) |
| Website, security and fraud prevention | Operating and securing the website; preventing and detecting fraud and misuse | Our legitimate interests in running a safe, secure service (Art. 6(1)(f)); for non-essential cookies, your consent |
| Establishing, exercising or defending legal claims | Managing disputes, chargebacks and claims | Our legitimate interests (Art. 6(1)(f)); compliance with a legal obligation (Art. 6(1)(c)) |
Where we rely on legitimate interests, we have weighed those interests against your rights and freedoms. You can ask us for more information about that assessment using the contacts in Section 2.
Some information you may share so we can deliver a Service safely (for example reduced mobility, a medical condition, or a food allergy) is special category data under Article 9 of the GDPR. We process it only:
We collect only what is necessary, share it only with those who need it to deliver your Service safely (for example your guide or driver), and delete or anonymise it when it is no longer needed. You can withdraw your consent at any time using the contacts in Section 2, although this may affect our ability to accommodate the requirement.
7.1. We send marketing communications only where the law allows, either with your consent or, for existing customers, in relation to our own similar Services where you have not objected.
7.2. You can opt out at any time, free of charge, by using the unsubscribe link in any marketing email or by contacting us at info@swingo.pt. Opting out of marketing does not stop service-related messages (for example a booking confirmation or a pickup reminder), which are necessary to deliver your booking.
8.1. Our website uses cookies and similar technologies. Strictly necessary cookies are needed for the site to function. Other cookies, including analytics and advertising cookies (for example those used with Google and Meta services), are used only with your consent.
8.2. When you first visit www.swingo.pt you are shown a cookie banner that lets you accept, refuse or manage non-essential cookies. You can change your choices at any time through the cookie-settings link in the website footer.
8.3. The table below lists the main cookies and similar technologies currently used. Exact names and durations should be confirmed with a live cookie scan of the website and kept up to date.
| Cookie / technology | Provider | Purpose | Type | Typical duration |
|---|---|---|---|---|
| Consent record | Swingo / consent tool | Stores your cookie preferences | Strictly necessary | Up to 12 months |
| Session / hosting | Website host | Keeps the site working and secure during your visit | Strictly necessary | Session |
| Website chat | Chat provider | Enables the website chat and keeps your conversation during the session | Strictly necessary / functional | Session to 12 months |
| Booking engine | Bokun | Supports the booking and checkout process where used | Strictly necessary / functional | Session |
_ga, _ga_* | Google Analytics | Measures site usage and audience statistics | Analytics (consent) | Up to 24 months |
_gid | Google Analytics | Distinguishes users for analytics | Analytics (consent) | 24 hours |
_gcl_au | Google Ads | Measures advertising performance and conversions | Advertising (consent) | Up to 90 days |
_fbp | Meta Pixel | Measures and targets advertising through Meta | Advertising (consent) | Up to 90 days |
8.4. The analytics and advertising tools we currently use are Google Analytics, Google Ads and the Meta Pixel. These set the cookies marked "consent" above and are activated only after you accept the corresponding category in the cookie banner. Withdrawing consent stops further use of those cookies.
We share personal data only as needed and with appropriate safeguards. Recipients may include:
We require our processors to act only on our instructions and to protect your data under written agreements that meet Article 28 of the GDPR. We do not sell your personal data.
Some of our service providers process data outside the European Economic Area (EEA), for example certain IT, email, productivity or messaging providers based in the United States. Where personal data is transferred outside the EEA, we rely on an appropriate safeguard recognised under the GDPR, such as a European Commission adequacy decision or the European Commission's Standard Contractual Clauses, together with any additional measures needed to protect your data. You can ask us for more information using the contacts in Section 2.
We keep personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, accounting, tax and reporting obligations.
When data is no longer needed, we securely delete or anonymise it.
Under the GDPR you have the right to:
These rights are subject to the conditions and exceptions in the GDPR and Portuguese law.
To exercise any of your rights, contact us at info@swingo.pt. We may need to verify your identity before acting on a request. We will respond without undue delay and in any event within one month, which may be extended by two further months for complex or numerous requests, in which case we will let you know. Exercising your rights is free of charge, unless a request is manifestly unfounded or excessive.
If you believe we have not handled your personal data correctly, we ask that you contact us first so we can try to resolve the matter. You also have the right to lodge a complaint with the Portuguese supervisory authority:
Comissão Nacional de Proteção de Dados (CNPD)
Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, Portugal
Telephone: +351 213 928 400
Website: www.cnpd.pt
Email: geral@cnpd.pt
You may also complain to the supervisory authority of your country of residence or workplace within the EU.
We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing. Where we use limited analytics or advertising profiling for our website and marketing, this is done with your consent for non-essential cookies and does not have legal or similarly significant effects on you.
We use appropriate technical and organisational measures to protect personal data against unauthorised or unlawful access, loss, alteration or disclosure. These include access controls, use of reputable service providers, and limiting access to personal data to those who need it to do their work. No system can be guaranteed to be completely secure, but we work to maintain measures appropriate to the risk and review them regularly.
Our Services are booked by adults. We do not knowingly collect personal data directly from children. Where children travel as part of a booking, the data about them (such as age, or a relevant allergy) is provided by the responsible adult who makes the booking.
Our website and communications may contain links to third-party websites (for example sales channels, attractions or review platforms). We are not responsible for the privacy practices of those websites. We encourage you to read their privacy notices.
We may update this Privacy Policy from time to time. The current version is always published at www.swingo.pt, with the "last updated" date shown above. Where changes are significant, we will take reasonable steps to bring them to your attention.
For any question about this Privacy Policy or about how we handle your personal data, contact us at info@swingo.pt or by post to Data Protection at our registered office (Section 2).