Privacy Policy — Green Approach Travel
Effective date: 8 January 2026
Company / Brand: Green Approach Travel (Adventure Travel & DMC, Madeira Island, Portugal)
Website: www.greenapproachtravel.com
Privacy contact: [greenapproachtravel@gmail.com] | [+351966498111] | [Caminho do Amparo nº2 , 9000-248. Funchal.]
1) Who we are
Green Approach Travel (“we”, “us”, “our”) organises and manages group travel programmes (B2B and directly with independent clients) and provides guided hiking activities on Madeira Island. For the purposes of the EU General Data Protection Regulation (“GDPR”), we act as a data controller for the personal data described in this Privacy Policy.
2) Scope
This Privacy Policy explains how we collect, use, share, and protect personal data when:
you visit our website,
you contact us or request proposals/quotations,
you book or participate in a trip, event, or guided hike arranged by us,
you are a representative/employee of a business client (B2B),
your data is provided to us by a business client or travel organiser (e.g., passenger/participant lists).
If you provide us with personal data about other travellers (e.g., your group), you confirm you are authorised to do so and that you have shared this Privacy Policy with them where appropriate.
3) Personal data we may collect
Depending on the service, we may collect:
A. Identification & travel details
Full name, nationality, date of birth
Passport/ID details (when required for bookings or supplier requirements)
Travel itinerary details, booking references, rooming lists, pickup points, flight details (if relevant)
B. Contact & business information (B2B)
Name, company, job title, work email, work phone
Billing contact details and correspondence history
C. Payment & invoicing
Billing address, VAT/tax details (where applicable)
Payment status and transaction references
(Note: we typically do not store full payment card details; payments are handled by payment providers.)
D. Preferences & service needs
Dietary requirements, accessibility needs, language preferences
Accommodation preferences and similar trip-related preferences
E. Health and safety information (special category data)
For hiking/adventure activities and duty-of-care, we may process limited health data such as:
relevant medical conditions, allergies, medications (only if you choose to provide them)
emergency contact details
F. Communications
Emails/messages/calls with us, feedback, support requests
G. Website usage data
IP address, device/browser data, pages visited, approximate location (derived from IP), cookies and similar technologies (see “Cookies” below)
4) How we collect personal data
We collect personal data:
directly from you (forms, email, phone, in person),
from your employer/client/travel organiser (B2B group lists and operational details),
from suppliers involved in delivering the trip (e.g., booking confirmations),
automatically through our website (cookies/logs).
5) Why we use personal data (purposes) and legal bases
We process personal data under GDPR legal bases such as contract performance, legal obligation, legitimate interests, consent, and (in limited cases) vital interests.
We use personal data to:
Prepare proposals and operate B2B group travel programmes (contract steps; legitimate interests).
Book and deliver travel services (contract), including coordinating logistics and suppliers.
Run guided hikes and adventure activities safely (contract; legitimate interests; vital interests where urgent safety applies).
Manage dietary/accessibility needs (contract; and where health data is involved, usually explicit consent or necessary protection of vital interests in emergencies).
Customer service and communications (contract; legitimate interests).
Billing, accounting, and legal compliance (legal obligation).
Improve our services and website (legitimate interests; consent where required for certain cookies).
Marketing (consent where required; or legitimate interests for B2B communications where permitted). You can opt out at any time.
We do not use your data for automated decision-making that produces legal or similarly significant effects.
6) Sharing your personal data
To deliver trips and activities, we may share relevant personal data with trusted third parties, such as:
accommodation providers (hotels, rural stays),
transport providers (transfers, coaches, taxis),
activity providers (canyoning, boat trips, cultural experiences, etc.),
local guides and hike leaders,
ticketing/booking platforms,
insurance providers (if arranged/required),
payment processors,
IT/hosting, CRM/email tools, analytics providers,
professional advisors (legal/accounting) when necessary,
public authorities where required by law.
Some suppliers act as independent controllers (they decide how they process data), while others act as processors (they process data on our behalf under contract).
We only share what is reasonably necessary to provide the services.
7) International transfers
Some suppliers or IT providers may process data outside the European Economic Area (EEA). Where this happens, we use appropriate safeguards such as EU adequacy decisions or Standard Contractual Clauses and additional protective measures as needed.
8) Data retention
We keep personal data only as long as necessary for the purposes described above, including:
Operational trip data: typically kept for the duration of planning and delivery, plus a reasonable period for follow-up and handling claims.
Accounting/tax records: retained for longer periods where required by applicable law.
Health/safety details (if provided): kept for the shortest time possible, usually deleted after the activity/trip unless needed to document an incident or meet legal obligations.
Marketing data: kept until you unsubscribe/withdraw consent or we decide it is no longer relevant.
9) Cookies and similar technologies
We may use cookies and similar tools to:
make the website work properly (essential cookies),
understand website performance and improve user experience (analytics),
support marketing where enabled (marketing cookies).
Where required by law, we will ask for your consent before placing non-essential cookies, and you can change your preferences at any time via our cookie settings (if implemented).
10) Your rights (GDPR)
Subject to legal conditions, you may have the right to:
access your personal data,
correct inaccurate data,
delete your data,
restrict processing,
object to processing (including certain marketing),
data portability,
withdraw consent (where processing is based on consent),
lodge a complaint with the supervisory authority.
In Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados (CNPD). Digital Strategy EU+1
To exercise your rights, contact us using the details in Section 1.
11) Security
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. However, no system is 100% secure, so we cannot guarantee absolute security.
12) Children’s data
Our services are primarily intended for adults and B2B clients. Where trips include minors, we process minors’ data only as necessary to deliver services and typically via the parent/guardian or the organising entity, in line with applicable law.
13) Third-party websites
Our website may contain links to third-party websites. We are not responsible for their privacy practices. Please review their policies.
14) Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will post the latest version on our website and update the “Effective date” at the top.
15) Contact
For privacy questions or requests, contact:
Green Approach Travel — Privacy
[greenapproachtravel@gmail.com] | [+351966498111] | [Caminho do Amparo nº2 , 9000-248. Funchal.]