Privacy Policy

The data controller for personal data processed via the www.okira2surf.pt website and Okira 2 Surf services is the entity operating the Okira 2 Surf surf school, based at Praia da Aguda, Vila Nova de Gaia, Portugal.

Okira 2 Surf provides: surf lessons, surf camp (accommodation and lessons at Praia da Aguda), SUP rental and lessons, surf team-building activities, and accepts customer testimonials via an online form.

The processing of your personal data is governed by Regulation (EU) 2016/679 (GDPR) and Portuguese Law no. 58/2019 of 8 August, which implements the GDPR in Portuguese law. Consent, contract performance and legitimate interest are the legal bases we use, depending on the processing in question.

We collect and process personal data in the following situations:

• Testimonials form: name, email, rating and comment — purpose: publication of testimonials on the website (moderated). Legal basis: consent.
• Cookies and tracking technologies (Google Analytics, Meta Pixel): site usage data, IP address, device identifiers — purpose: statistical analysis, site improvement and ad campaign optimisation on Google and Meta. Legal basis: prior consent (Art. 6(1)(a) GDPR).
• Contact by email or phone: data you send us — purpose: responding to enquiries about lessons, surf camp, SUP and team building. Legal basis: pre-contractual measures or contract.
• External booking links: when you click links to okira2surf.pt/book or surf camp booking forms (e.g. bnbforms.com), data collection is the responsibility of those third parties. Please refer to their respective privacy policies.

Your data may be disclosed to:

• Google Ireland Limited (Google Analytics) — United States, with appropriate safeguards under EU-approved Standard Contractual Clauses.
• Meta Platforms Ireland Limited (Meta Pixel / Facebook) — United States, with appropriate safeguards.
• Formspree (form processing) — for testimonial submissions; subject to their policies and transfer safeguards.

We do not sell or transfer your data to third parties for unauthorised marketing purposes.

Testimonial data is retained while the testimonial is published and for the period necessary to defend against any claims. Contact data is retained for the period necessary to manage the commercial relationship. Data collected by analytics cookies (Google Analytics, Meta Pixel) is subject to the retention periods defined by the respective providers (typically up to 14 or 26 months depending on configuration).

Under the GDPR and Portuguese Law no. 58/2019, you have the right to:

• Access — obtain confirmation that we process your data and access that data.
• Rectification — correct inaccurate or incomplete data.
• Erasure («right to be forgotten») — in certain conditions, request the deletion of your data.
• Restriction of processing — request that processing be suspended in certain cases.
• Data portability — receive the data you have provided to us in a structured, commonly used format.
• Object — object to processing based on legitimate interest or direct marketing.
• Withdraw consent — at any time, without affecting the lawfulness of prior processing.
• Complain — lodge a complaint with the Portuguese Data Protection Authority (CNPD), Rua de São Bento, n.º 148, 1200-821 Lisboa, www.cnpd.pt.

The website uses the following tracking technologies (cookies and similar), subject to your prior consent:

The consent you give through our cookie notice is freely given, specific, informed and unambiguous under Article 4(11) of the GDPR. You may accept only essential cookies or also accept analytics and advertising cookies. Choosing to reject non-essential cookies does not affect basic website navigation.

We implement appropriate technical and organisational measures to ensure the security and confidentiality of your personal data, in accordance with Article 32 of the GDPR.

Under Portuguese consumer law, if a dispute arises you may use alternative dispute resolution entities or submit compliments or complaints through Portugal’s electronic book of compliments and complaints at:

www.livroreclamacoes.pt

This is separate from exercising your data protection rights described in section 6.