Friday, 18 September 2026

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Privacy and Cookie Policy

INTRODUCTION

The privacy policy described below provides you with an overview of how Entre Etapas handles your personal data and your rights in this matter, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council – General Data Protection Regulation (“GDPR”) and other applicable legislation on privacy and data protection. The specific personal data that will be processed and how it will be used largely depends on the services requested and agreed upon with you.

This privacy policy applies to the personal data of our Website Users, Clients, Suppliers, and Candidates, whenever these are individuals.

Each time you use the Site, you are subject to the Privacy and Cookie Policy in effect at that time, so we suggest that you carefully read these Policies to ensure you agree with their terms.

From time to time, we may change this Privacy Policy. If you wish to stay updated, please visit this page, as all changes will be posted here.

For the purposes of applicable data protection legislation, the company responsible for processing your personal data is This Is Entertainment, Consultoria e Produção de Eventos, Lda.

GLOSSARY

Delete – We will permanently delete your personal data once the retention period ends or when we receive a valid request from you to do so, provided there are no legitimate interests justifying the retention of your personal data.

Candidates – includes candidates for all positions advertised or promoted by Entre Etapas, including permanent, part-time, and temporary positions, and positions under a self-employed work arrangement with Entre Etapas; as well as individuals who have submitted a spontaneous resume to Entre Etapas unrelated to a specific job offer. Individual contractors, self-employed workers, and employees of suppliers or other third parties who apply for positions at Entre Etapas will be treated as candidates for the purposes of this Privacy Policy.

Personal data: any information relating to a natural person that can directly identify them or makes them identifiable, directly or indirectly, in particular by reference to an identifier.

Clients – customers and others to whom Entre Etapas provides services or supplies goods in the course of its business.

Suppliers – refers to partners, consultants, merchants (including individual merchants) and independent workers or any other entity that supplies goods or provides services to Entre Etapas.

Personnel – includes employees as well as interns directly involved in Entre Etapas’ activities.

General Data Protection Regulation (GDPR) – a legal instrument of the European Union that aims to harmonize European legislation regarding data protection.

What type of personal information do we collect?

Entre Etapas collects various types of personal data depending on the different purposes, as explained below. We emphasize that we do not intentionally collect personal information from individuals under 18 years of age. If we detect that we have unintentionally collected personal information from individuals under 18 years of age, we will take the necessary steps to delete the information as quickly as possible, unless we are required by applicable law to retain it.

  • CUSTOMER DATA: We only collect the data necessary for the preparation, fulfillment, and execution of any contract entered into between the Customer and Entre Etapas, as well as to respond to any subsequent complaints relating thereto. Normally, we only need your contact details (such as name, telephone number, email address, postal address, and postal code) to ensure that our relationship proceeds smoothly.
  • SUPPLIER DATA: We only collect the data necessary for the preparation, fulfillment, and execution of any contract entered into between the Supplier and Entre Etapas, as well as to respond to and manage any related complaints. We will collect contact person data, including your company’s data, such as names, phone numbers, and email addresses. We will also collect bank details so that we can make payments.
  • WEBSITE USERS: We only collect the data necessary to ensure a good experience when using the Site and to allow you to enjoy all the potential and capabilities it provides, as well as to help us manage the services we provide. This includes information such as how you use our site, how often you access it, your browser type, your IP address, the location from which you access our site, the language you choose to view it in, and the times when our site is most popular, as well as other information better described in our cookie policy below.
  • CANDIDATE DATA: Depending on the relevant circumstances and applicable local laws and requirements, we may collect all or part of the following information: such as name and contact details (telephone and email), immigration status (if you require a work permit), a photo of you; professional situation and activity, such as education information; employment history; current remuneration, pensions and related benefit provisions, if required for the position you are applying for; supplementary information that you choose to share with us, specifically in your cover letter, curriculum vitae or during interviews; supplementary information that our Clients may share about you or that we discover from other third-party sources (i.e., references);

Please note that the above list of categories of personal data that we may collect is not exhaustive.

OBLIGATION TO PROVIDE DATA

Within the scope of our commercial or work relationship, you will need to provide the personal data necessary to establish and create this relationship and to fulfill the pre-contractual and contractual obligations and due diligence arising therefrom, as well as those that we are legally obliged to collect. Without this data, we will, as a general rule, have to refuse to enter into or execute the contract, or we will not be able to maintain the contract and will have to terminate it.

If you do not provide us with the necessary information and documentation, we will not be able to establish or continue the desired business or employment relationship, or process any requests you may make to us.

HOW WE COLLECT PERSONAL DATA

We may collect personal data in various ways.

-Personal data that we receive directly from you if you proactively contact us, usually by phone or email; and/or if we contact you by phone or email or through business development activities more generally.

-Enter your details on the Entre Etapas website via the form as part of the registration process; or

-Send your resume by email or leave a paper copy of your resume;

-Participate in a contest through a social media channel, such as Facebook, Instagram, or another;

-Subscribe to our newsletter or register for one of our events;

– Personal data that we receive from other sources, usually through due diligence or other market information. We also receive personal data from other sources, for example if you “like” our Facebook page or “follow” us on Twitter or Instagram, we will receive personal information from those sites.

We collect your data automatically through cookies, in accordance with your browser’s cookie settings.

LEGAL BASIS

1) For the provision of products and services: Entre Etapas may use your personal data when necessary to execute the contract between you and Entre Etapas, as well as to identify you. We may also use your Personal Data to prevent and investigate possible misuse thereof.

2) Marketing Activities: We may periodically send you information that we believe may be of interest to you. In particular, we may use your data for the purposes listed below, when appropriate, namely: to allow us to develop commercial or marketing actions, in particular to promote the dissemination of new features or new products and services; to send you data on reports, promotions, offers, events and to establish contacts; to provide you with information about certain discounts and offers to which you are entitled due to your relationship with Entre Etapas; to allow us to send newsletters, which may contain information relating to promotional campaigns, information about events, discounts, promotions and offers, invitations, reminders relating to your reservations, dissemination of new features, new products or services and to send information about participation in contests and sweepstakes, in accordance with the thematic preferences you have indicated to us by email; to provide you with information about personalized and exclusive offers of products and services identified based on your personal preferences and behaviors, as well as from the use of products, services and browsing on the websites.

3) Other purposes: to store (and update when necessary) your information in our database so that we can contact you regarding contracts you wish to enter into/have entered into with us; to offer you services or to obtain support and services from you; to comply with certain legal obligations; to help us target appropriate marketing campaigns, and Entre Etapas may make automated decisions, including profiling; in rare circumstances, to assist us in the assertion, exercise or defense of a right and to protect the vital interests of the data subject, we may also use your personal data if we deem it necessary to do so for the defense of our legitimate interests.

4) Product and service development: Entre Etapas may use your personal data for the development of its products and services. However, we will predominantly use aggregated data and statistical information for this purpose. Entre Etapas keeps a record of the pages our customers visit within the website to determine which services/products are most requested. In this case, information is collected relating to the computer or device (including mobile devices) you use to access it, the website from which you accessed ours, the type and language of your browser, operating system, cookies, the country from which you are accessing, referring and exit pages, URL, platform type, the number of clicks made, domain names, landing pages, pages visited and the order in which you visited them, the time spent on a particular page, the date and time you accessed our website, access errors and other similar information that your browser sends us.

5) Communication: Entre Etapas may use your personal data to communicate with you, in particular to send news related to our products or services, or to provide assistance in aspects related to customer support, in particular to respond to and process user requests through customer service channels, as well as to monitor the quality of our service. In this case, your full name, email address and telephone number are collected.

6) Recruitment Activities: To fill vacancies, we may conduct internal recruitment activities. Below, we list several ways in which we may use and process your personal data for this purpose:

6.1) Collecting your data through you or other sources, such as LinkedIn;

6.2) Store your data (and update it when necessary) in our database so that we can contact you regarding recruitment;

6.3) Evaluate data about yourself in relation to the vacancies that we think are suitable for you;

6.4) Allow you to submit your resume, apply online for job openings, or sign up for alerts about job openings that we think may be of interest to you;

6.5) To fulfill our obligations arising from any contracts entered into between us;

6.6) To fulfill our obligations arising from any contracts entered into between Entre Etapas and third parties relating to your recruitment;

6.7) Streamline our payroll and invoicing processes;

6.8) Verify the data you provided, using third-party resources (such as psychometric assessments or skills tests) or to request information (such as references, to the extent that this is appropriate under applicable law and you have provided us with the contact details of the references and obtained prior authorization from them to transmit their personal data, as well as authorize us to contact them); and

6.9) To fulfill our legal obligations, including those related to the detection of crimes or the collection of taxes or fees.

We use and process your personal data for the management and execution of contracts or other actions requested by the data subject (Article 6(1)(b) GDPR); within the scope of a legitimate interest (Article 6(1)(f) GDPR); based on your consent (Article 6(1)(a) GDPR) and due to legal imperative or in the public interest (Article 6(1)(c) and (e) GDPR).

ENTITIES WITH WHICH WE SHARE YOUR PERSONAL DATA

When appropriate and in accordance with local laws and requirements, we may share your personal data in various ways and for various reasons with the following categories of people:

-In the course of an investigation, complaint or procedure, to the tax authorities, auditing bodies, the Administration, public bodies, the Court, the Immigration and Borders Service (“SEF”) and the Security Forces, who are responsible for the matter;

-Third-party service providers who perform functions on our behalf (including external consultants, business partners and professional advisors such as lawyers, auditors and accountants, recruitment firms, technical support functions and IT consultants who carry out testing and development work on our company’s technology systems);

-Third-party IT service providers and external document storage providers, where we have an appropriate data processing agreement (or similar protections);

-In the event of an acquisition or sale of businesses or assets, we may share your personal data with potential buyers of those businesses or assets.

-In the case of payments, credit institutions and other payment service providers, as well as providers of technological services related to payment services to whom data is transmitted to carry out the transaction, may be obliged by the legislation of the State where they operate, or by agreements concluded by it, to provide information on transactions to the authorities or official bodies of other countries, located both inside and outside the European Union, in the context of combating the financing of terrorism, serious forms of organized crime and the prevention of money laundering.

Safeguarding your personal data.

We are committed to taking all reasonable and appropriate measures to protect the personal information we hold from misuse, accidental or unlawful alteration, loss, and unauthorized disclosure or access. To this end, Entre Etapas uses security systems, rules, and other procedures to ensure the protection of your personal data, as well as to prevent unauthorized access to data, its misuse, disclosure, loss, or destruction.

If you suspect any misuse, loss, or unauthorized access to your personal information, please inform us immediately.

PERSONAL DATA RETENTION

We only retain your personal data for as long as necessary to fulfill the purpose for which we collected it, to respond to your needs, to respond to requests you make to us, or to comply with our contractual and legal obligations, using the criteria mentioned:

  1. a) When you purchase products and services, we will retain your personal data for the duration of our business relationship, including any claims that may arise, as well as for a period of ten (10) years after the termination of such relationship, without prejudice to compliance with the legal obligations of the data controller;
  2. b) When you contact us to ask questions, request information and clarifications, we will keep your personal data for the period necessary to resolve your issue/provide the requested information and/or clarifications;
  3. c) When you create a customer account, that is, when you register on our website, we will keep your data until you ask us to delete it or after a period of inactivity of five years;
  4. d) Regarding the data collected during the recruitment process, for a maximum period of five years after the recruitment process has ended;
  5. (e) Regarding the use of cookies, we keep them for as long as necessary to achieve their inherent purposes, as detailed in the Cookie Policy;
  6. f) The time period stipulated in the applicable legislation; or
  7. (g) Until the specific purpose applicable to certain data ceases to exist.
  8. h) If there is a pending judicial or administrative offense proceeding, the data will be kept for the duration of the proceeding and for up to six months after the final judgment is issued.

Once the aforementioned retention periods have expired, personal data will be deleted and/or erased in a completely secure manner.

HOW TO ACCESS, CHANGE OR REMOVE THE PERSONAL DATA YOU HAVE PROVIDED TO US

  • Right to object: This right allows you to object to the processing of your personal data by us, for reasons relating to your particular situation, when your personal data is processed for one of the following reasons: (i) our legitimate interests; (ii) to allow us to perform a task in the public interest or in the exercise of official authority; (iii) to send you direct marketing materials, including profiling; and (iv) scientific, historical, research or statistical purposes.

If you exercise your right to object, we will stop processing the data to which you objected, unless: we can demonstrate that we have compelling legitimate grounds for the processing which override your interests or we are processing your data for the establishment, exercise or defense of a legal claim.

  • Right to withdraw consent: If we have obtained your consent to process your personal data for specific purposes, you may withdraw this consent at any time, and we will cease carrying out the specific activity to which you previously consented, unless we consider there to be an alternative reason justifying our continued processing of your data for this purpose, in which case we will inform you of this condition.
  • Data Subject Access Requests: You may ask us, at any time, to confirm the information we hold about you, as well as request additional information about the purposes of the processing, the period for which we retain your data, the existence of automated decisions, the recipients to whom the data is disclosed, among other information provided for in Article 15 of the GDPR. We may ask you to verify your identity and provide further information about your request. If we grant you access to the information we hold about you, we will not charge for this access unless your request is “manifestly unfounded or excessive”. If you request additional copies of this information, we may charge a reasonable administrative fee, where legally permitted. In cases where we are legally permitted, we may refuse your request. If we refuse your request, you will always be informed of the reasons for doing so.
  • Right to be forgotten/erasure: In certain circumstances, you have the right to request that we delete your personal data. Normally, exercising this right must meet one of the following criteria: the data is no longer necessary for the purpose for which we originally collected and/or processed it; when you have withdrawn your consent for us to process your data and there is no other valid reason for us to continue processing it; if you object to the processing and there are no overriding legitimate interests justifying it; the data has been unlawfully processed (i.e., in a way that does not comply with the GDPR); or it is necessary for the data to be erased in order for us to comply with our legal obligations as a controller.

This right, however, does not apply, and therefore Entre Etapas may continue to process your data legitimately when necessary.

– To exercise the right to freedom of expression and information;

– To fulfill legal obligations or to perform a task of public interest or the exercise of official authority;

– For reasons of public health in the public interest;

– For archiving, research or statistical purposes; or

– For the exercise or defense of a right.

When fulfilling a valid request for data erasure, we will take all reasonable practical steps to delete the data.

  • Right to restriction of processing: In certain circumstances, you have the right to restrict the processing we carry out on your personal data. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until: (i) one of the circumstances listed below is resolved; (ii) we have obtained your consent; or (iii) further processing is necessary for the establishment, exercise or defense of a legal claim, the protection of the rights of another person or for reasons of important public interest of the EU or of a Member State.

The circumstances under which you have the right to request the restriction of the processing of your personal data are:

– If you contest the accuracy of the personal data we process about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;

– If you object to the processing of your personal data for our legitimate interests. In this situation, you can request that the data be restricted while we verify our grounds for processing your personal data;

– If our processing of your data is unlawful, but you prefer to restrict our processing of it instead of deleting it; and

– If we no longer need to process your personal data, but we require the data for the establishment, exercise or defense of a legal right.

If we have shared your personal data with third parties, they will be notified of the restricted processing, unless this is impossible or involves a disproportionate effort. We will, of course, notify you before lifting any restriction on the processing of your personal data.

  • Right to rectification: You have the right to request that we rectify any inaccurate or incomplete personal data we hold about you. If we have shared this personal data with third parties, they will be notified of the rectification unless this proves impossible or involves a disproportionate effort. Where appropriate, we will also disclose to you which third parties we have disclosed the inaccurate or incomplete personal data to. In cases where we consider it reasonable not to comply with your request, we will explain the reasons for the decision. It is important that the personal information we hold about you is accurate and up-to-date. Please inform us if there are any changes to your personal information during the period we retain your data.
  • Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, which in Portugal is the National Data Protection Commission (Comissão Nacional de Proteção de Dados). You can contact them in the following ways: Telephone (+351) 213928400 / Privacy Helpline: +351 21 393 00 39 Email:  geral@cnpd.pt. Address: Rua de São Bento, nº 148-3º, 1200-821 Lisboa / Fax: +351 21 397 68 32

If you wish to exercise any of these rights or withdraw your consent to the processing of your personal data (if consent is our legal basis for processing your personal data), please contact us. Please note that we may keep a record of your communications to help us resolve any issues raised by you.

CONTACT

If you wish to exercise any of the above rights, suspect misuse, loss or unauthorized access, or have any comments or suggestions regarding this Privacy Policy, you can contact us at the following address:  geral@upwego.pt .

GUARANTEES

The user guarantees that the personal data communicated to Entre Etapas is true and accurate and undertakes to notify any changes or modifications to said data, assuming sole responsibility for losses and damages caused by the erroneous, inaccurate, or incomplete communication of the data. The user is expressly warned that by disclosing personal data in public Entre Etapas media such as Facebook, LinkedIn, and Instagram, this information may be viewed and used by third parties. Entre Etapas does not read any personal communications published on its clients’ own web pages.

COOKIE POLICY

What is a cookie?

A “cookie” is a small information file that is stored on your computer’s hard drive and records your browsing activity on a website so that, when you visit that website again, it can present you with personalized options based on the information stored about your last visit. We may also use cookies on our website to analyze traffic and for advertising and marketing purposes, which do not harm your system. If you wish to check or change the type of cookies you accept, you can do so in your browser settings.

Cookies collected and used:

Website language, user age, browser pixel ratio, session code.

Google referrers:

Cookies used for analytics.

How do we use cookies?

We use cookies to do two things to track your use of our website. This allows us to understand how you use the site and track any patterns that emerge individually or from larger groups, which will help us develop and improve our website and services in response to what our visitors want and need; and

Consent:

In accordance with Law No. 41/2004 of August 18, the storage of information and the possibility of accessing information stored on a user’s terminal equipment (namely through cookies) are only carried out by Entre Etapas if the user has given their prior and express consent to the installation of cookies on their equipment. Therefore, we ask that you accept this Privacy and Cookie Policy before using the websites.

How to prevent the use of cookies on websites

The Customer has the right to withdraw consent to the use of cookies by Entre Etapas at any time, by deleting the cookies stored on their computer through the configuration options of their internet browser.

Finally, if you want more control over the installation of cookies, you can install programs or browser add-ons known as “do not track” tools, which will allow you to choose which cookies you want to allow.

If cookies are blocked or not authorized, no cookies will be stored on your device, but the proper functioning of our websites is not guaranteed. Therefore, the customer may not be able to fully benefit from the content available on NICI’s websites, and each time you access the website, you will always be asked for permission to use cookies.

To declare, exercise, or defend rights.

It may sometimes be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in relation to the exercise or defense of legal claims. Article 9(2)(f) of the GDPR permits such processing when it is “necessary for the establishment, exercise or defence of legal claims or where courts are acting in their judicial capacity”. This may arise, for example, where we need to obtain legal advice in relation to legal proceedings or where we are legally obliged to retain or disclose certain information as part of legal proceedings.

CHANGES TO THE DOCUMENT

Entre Etapas may occasionally amend this statement and its Privacy Policy to reflect the company’s image and customer feedback. We encourage our customers to periodically review our Privacy Policy to stay updated on how Entre Etapas protects their information, and we will inform them whenever relevant changes are made to our Privacy Policy.