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Privacy Policy


The protection of your privacy and personal information is important to Spot Travel Tours. In this Privacy Policy (“Privacy Policy”), you will find information regarding how we collect, use and otherwise process your personal information.

In our Privacy Policy, we follow the practices adopted in the scope of security and protection of personal data, pursuant to the provisions of Cape Verdean Law No. 133 / V / 2001 of January 22, amended by Law 41 / VIII / 2013, of 17 September, which establishes the General Legal Framework for the Protection of Personal Data of Individuals and at the international level, in accordance with the new Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of persons with regard to the processing of personal data and the free movement of such data. This Privacy Policy applies to the website as well as all related Spot Travel Tours websites, mobile applications and services that link to this Privacy Policy (collectively, the “Website”) unless we have posted a specific privacy policy to a particular website or service. In that case, that specific privacy policy will apply.

Moreover, when you use the Website, you also have responsibilities which are outlined in the Terms and Conditions section of the Website. We recommend that you consult these Terms and Conditions prior to using the Website in order to inform yourself of your obligations.

This Privacy Policy covers all personal information that we collect, use and otherwise process when you interact with the Website or with us. All personal information will be processed in accordance with this Privacy Policy and with applicable laws, which can vary depending on your country of residence. If you do not agree with any provisions or changes to this Privacy Policy, please do not use the Website.

Personal information is collected, held and more generally processed by SPOT  TRAVEL TOURS SU LDA., having its registered office in Rua da Morna, Santa Maria, Cape Verde 4111, VAT registration number 227381408 hereinafter referred to as “Spot Travel Tours”, and its affiliates “we”, “our” or “us”.

For legal residents of the European Union, note that the processing of your personal information is founded on at least one of the following legal bases:

  • You have consented to the processing activity;
  • The processing activity is necessary for compliance with one or more legal obligations;
  • The processing activity is necessary for the performance of a service you have requested;
  • The processing activity is necessary for one or more of the following legitimate interests pursued by us, our affiliated entities and/or a third party:
  1. To better understand our customers’ interests and preferences by analyzing, profiling and monitoring their behavior on the Website in order to globally improve the Website, our products and services;
  2. To offer you an optimal customer experience, namely by tailoring the Website, our products and services (including advertisements and e-mails) to your interests and preferences;
  3. To ensure the proper functionality and security of the Website.

These processing activities benefit both us and you without undermining or overriding any of your rights, interests or fundamental liberties.

Note that when the processing of your personal information is based on consent, you can withdraw such consent at any time by contacting us.

We reserve the right to modify this Privacy Policy to adapt it to any technological or legal change, to adjust it to reflect changes made to the Website or for any other purpose. All updates to our Privacy Policy will be posted on this page or otherwise mentioned to you if required by applicable laws.


We collect personal information under the circumstances listed below. In certain circumstances or for certain purposes, providing your personal information is voluntary (for example, when you sign up to Spot Travel Tours). However, in other circumstances, providing your personal information is mandatory and we may not be able to provide you with the services or products requested if you choose not to provide such information. For example, if you purchase a tour online, some personal information is needed to be able to send you the voucher and the invoice.

We collect your personal information in the following circumstances:

  • When you sign up to Spot Travel Tours;
  • When you buy a tour, ticket, package or other products;
  • When you interact with the digital content on the Website;
  • When you participate in a contest and/or a survey;
  • When you send us an inquiry or otherwise communicate with us;
  • When you apply for a job;
  • When you provide us with your personal information while onsite at an event, such as when you log in to the Wi-Fi network;
  • When you post comments on the Website;
  • When you choose to give us permission to access your information from third party websites (for example, by linking to social media networks like Facebook).

Some of your personal information may be provided by our affiliated companies and/or commercial partners, including companies that sell products worldwide.


Under the circumstances listed in the “How We Collect Information” section of this Privacy Policy, the following information may be collected:

  • Personal Information

To facilitate reading, the expression “personal information” is used throughout this Privacy Policy. For interpretation purposes, this expression shall have the meaning set forth in the legislation that is applicable to you. For instance, for legal residents of the European Union, “personal information” shall be read throughout this Privacy Policy as “personal data” as defined under the General Data Protection Regulation. In any case, we treat any information that makes it possible to identify you as an individual as personal information. For example, we consider your given name, surname, date of birth, postal address, telephone number, e-mail address, mobile number, as well as any information that is considered personal information under applicable laws to be personal information.

We collect and process the following categories of personal information:

  • Contact information, such as your given name, surname, postal address, telephone number, e-mail address;
  • Economic information, such as financial information that may be provided in connection with our services (including to purchase tickets to shows, to purchase gift cards);
  • Login information, such as the ID and password you use to connect to your account on our Website;
  • Interests and preferences information;
  • Any other information that you provide directly and voluntarily, including any message you send to us by e-mail and/or by contacting our customer service.
  • Information collected automatically (“usage information”)

We, as well as third-party advertisers, service providers and content providers, may use a variety of cookies and similar tracking technologies (“Cookies”) that automatically collect certain Website usage information whenever you visit or interact with us (“usage information”). Usage information may include without limitation your information about your browser, operating system, all the areas within our sites and e-mails that you visit, including content that you browse, and the time of day, among other information. Usage information may also include your IP address or other unique identifier (“device identifier”) for the device you use to access the Website. A device identifier is a number that is automatically assigned to your computer, mobile phone, or other device used to access the Website and our servers identify your device by its device identifier. Subject to applicable laws, some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the device used to access our Website.

Some usage information may be considered as personal information under certain laws, such as the IP address under the laws applicable in the European Union. To the extent that we combine usage information with your personal information, we will treat the combined information as personal information under this Privacy Policy.

Cookies can be used by us and by third parties for analytics purposes and to send you interest-based advertisements. Please read our Cookie Policy to learn more about the type of technology used, the type of information collected, why it is collected, how it is used and how you can manage your preferences regarding the use of such technologies (including how you can opt-out of certain behavioural ads).

  • Information about someone else

If you submit information on behalf of another individual (for example a friend, a family member, a member of a tour group you are organizing), you must ensure that you have his/her consent to share his/her personal information with us and you confirm that you have this consent.

  • Children’s Information

We take children’s privacy seriously. We do not knowingly collect personal information from children through the Website. If you are a minor under the laws of your country, please do not submit any personal information through the Website without the express consent and participation of a parent or guardian.


We collect and process personal information to:

  • Manage the account creation process on the Website and, more generally, manage your personal account;
  • Deliver the services you have requested and/or the tickets or other products you have purchased through the Website;
  • Design, maintain, analyze, manage, improve, market and provide products and services via the Website;
  • Help us perform transactions and verify your identity with the transaction you have requested;
  • Respond to your inquiries;
  • Perform quality assurance, sales, marketing and other business analysis;
  • Organize contests and other promotional activities;
  • Contact you in connection with services for which you have booked (including notifying you of postponed or cancelled any of our services);
  • Communicate with you about changes to our policies;
  • Send you a customer satisfaction survey after you have attended one of our services, where permitted under applicable laws or with your consent (if required);
  • Understand your needs and interests and provide you with optimal services and personalized advertisements, services and products by performing profiling, where permitted under applicable laws or with your consent (if required);
  • Improve the Website performance, respond to your requests regarding the Website, remember your Website preferences/settings;
  • Send you specific information, promotional and marketing communications about Spot Travel Tours or third party products and services (for example, offers, discounts, ticket presale notices, newsletters and birthday communications), where permitted under applicable laws or with your consent (if required); and
  • Analyze and process your application for a possible job opportunity.


When we send or display personalized communications or content, we may use some techniques that qualify as “profiling” (i.e. any form of automated processing of personal information consisting of using the aforesaid information to evaluate certain personal aspects relating to a natural person, for example to analyze or predict aspects concerning that person’s personal preferences, economic situation, interests, behavior, location or movements).

More particularly, we may collect personal information about you in the different scenarios mentioned above, centralize this information and analyze it to evaluate and predict your personal preferences and/or interests. Based on our analysis, we then send or display communications and/or content tailored to your specific interests/needs.

You may have the right to object at any time to the use of your personal information for “profiling”. Please see “Your rights regarding your personal information” section below.


Our Website contains advertising and content provided by third parties who may associate themselves with us and other members of the Spot Travel Tours Group. Our Website also includes hyperlinks to such third parties’ websites. These third parties have privacy policies that may be different from this Privacy Policy. The information collected and stored by third parties, whether through our Website or a third party’s website, remains subject to their own policies and practices, including what information they share with us, your choices on their services and devices, and whether they store information in the Cape Verde or elsewhere. We are not responsible for the manner that your information may be collected, used, disclosed and otherwise processed by said third parties, and encourage you to familiarize yourself with and consult their privacy policies and terms of use. To the extent we combine information we receive from third parties with personal information we collect directly from you on the Website, we will treat the combined information as personal information under this privacy policy.


For the purposes outlined in the Privacy Policy, we may share your information with other companies in the Spot Travel Tours as well as with the different third parties listed hereafter, which may be located all around the world:

  • Service providers: Your personal information may be shared with third parties acting on our behalf or for us, such as online travel agencies, payment processors, data processors, hosting service providers, technical systems consultants and marketing agencies;
  • Promotional partners: We may share your personal information with third parties who may associate themselves with us for the presentation of our Tours, travel packages or for any other activity or other promotions;
  • Other parties with your consent: If you have expressly provided your consent to receive information from other third parties that are not included in this list, we will share the personal information that you have provided with such third parties. Your personal information may then be used by such third parties in order to provide you with offers, products, promotions and services related to their respective activities or for any other purpose you have consented to;
  • Business transaction: We reserve the right to transfer your personal information without seeking your express permission in the event of a business transaction such as a bankruptcy, merger, acquisition, reorganization or sale of assets. In doing so, we will use commercially reasonable efforts to ensure that your personal information continues to be used in a manner that is consistent with this Privacy Policy;
  • Legal or administrative bodies: We may share your personal information with third parties (including legal or administrative bodies, governmental authorities, jurisdictions) if we believe that disclosure is reasonably necessary to enforce this Privacy Policy, to detect or prevent fraud, security or technical issues or to comply with any applicable law, regulation, legal process or governmental request.

Please note that once we share your personal information with an individual member of the Spot Travel Tours or with a third party, it may become subject to such individual member’s or third party’s privacy practices unless it is specifically provided for that the present Privacy Policy applies. Please note that we make commercially reasonable efforts to have your personal information used by such individual members and third parties in a manner that is consistent with this Privacy Policy.

“Spot Travel Tours” shall mean Spot Travel Tours SU LDA and its subsidiary, affiliated and parent companies, which may offer their products and services under various brands.


We have adopted reasonable security procedures to help protect against loss or theft, unauthorized access, disclosure, copying, use, or modification to the personal information you provide to us. While we strive to protect your personal information, we cannot guarantee or warrant the security of any personal information you disclose or transmit on the Website and cannot be responsible for the loss, theft, unauthorized access, disclosure, copying, use, or modification of your personal information, unless such acts are the result of our gross negligence or willful misconduct, unless otherwise provided by law.


We will retain your personal information only as long as is necessary for the fulfillment of the purposes outlined in this Privacy Policy or for a longer period if required or permitted under applicable laws.

We may retain your personal information for an additional period in archive databases, including for the duration of applicable statutes of limitation in order to be able to exercise our rights and/or defend ourselves in case of legal claims. Please note that if you merely unsubscribe from marketing communications such as the newsletter, we may nonetheless continue to use your personal information for marketing and business analytics purposes, unless you withdraw your consent to this activity or object to it by contacting us.


To stop receiving promotional e-mails from us or from another member of the Spot Travel Tours SU LDA, follow the link at the bottom of the promotional e-mail or contact us. Please note that despite unsubscribing from receiving promotional e-mails, we may continue to send you e-mails, such as e-mails regarding services you have requested or other products you have purchased through the Website.


SPOT TRAVEL TOURS SU LDA (hereinafter identified as “Spot Travel Tours” and its affiliates “we”, “our” or “us”) having its registered office in Rua da Morna, Santa Maria, Cape Verde 4111, VAT registration number 227381408 would like to inform you (hereinafter identified as “User”) that when surfing on the website (including domains and subdomains, hereinafter, some data will be collected. For this reason, this policy informs you about the cookies or other files of similar functionality such as pixels local shared objects, cookies flash, invisible pixels or web bugs, device fingerprinting or even hidden identifiers (hereinafter referred as “Cookies” or “Cookie”) used on this Website (the “Website”) in order to offer you a better browsing experience.

By using our services, you accept the use we make of cookies.


A Cookie is an alphanumeric online identifier that is set on your computer, tablet, mobile or similar device (collectively referred to as “Device”) when you browse the Website. It enables us to gather certain information about you and how you use the Website. In doing so, we can namely improve the Website’s performance, respond to your requests regarding the Website, remember your Website preferences/settings, offer you an optimal experience with the Website, personalize the services on the Website and the Website content and, in accordance with applicable legislation, send you advertisements tailored to your interests.


Cookies allow us to offer you a better browsing experience by remembering the pages you already visited on our Website and, in some cases, by saving your preferences to personalize your next visit.

We set Cookies on your Device for the following reasons:

2.1.2.a) [technical purpose] to carry out the transmission of a communication over an electronic communications network, in particular, the so-called cookies will be used to:

  • Guarantee the regular browsing and fruition of the website (for examples, to purchase or to log in reserved areas) – known as browser and session cookies;
  • Gather aggregated information about the number of users who access the website and how the visit the site itself – known as analytics cookies;
  • Allow to browse under a series of selected criteria (such as the language, selected items to purchase), in order to improve the service provided by the website

2.1.2b) [legal purpose] to fulfil the consequent legal obligations.



This website uses analytical, technical and third party cookies.

2.3.a) Analysis cookies:

They allow for monitoring and analyzing the behavior of users of the websites to which they are linked. All the information about the total number of visitors to the Website is collected, therefore it is anonymous. This information is used in order to measure the activity of the websites, application or platform, as well as for the elaboration of the users’ navigation profiles, in order to be able to implement improvements according to the analysis of the data on the use made by the users in relation to to the service.

Spot Travel Tours cannot control and is not responsible for the content and accuracy of the Google Analytics terms and conditions and privacy policies. It is Google, Inc that determines the purpose of the processing and the use of the information captured on them, as well as the operation and duration of the cookies, and that, according to information provided by both, the user can avoid capturing that information by refuse the installation of cookies by configuring your browser.

2.3.b) Technical cookies:

Allow the user to browse the site and use as different options or services available, and are allowed to have access to all sections without problems. For example, they are used to control traffic and data communication, identify a session, access parts of restricted access, remember the items present in an order, carry out the order purchase process, complete the registration order, or participation in an event, use security elements during navigation, store content for broadcasting videos or sound or share content through social networks. These cookies are necessary to allow the proper functioning of the website: without these cookies the services for which the user access the website cannot be provided.

2.3.c) Third party cookies:

 Third party cookies are cookies that have been written on to your device by a web site that is different from the web site you are visiting. The word “party” helps clarify this idea as it refers to the actual domain or web site that places the cookie onto your device. A third party cookie can be created if the web page you are opening loads any content from another web site/domain. By simply having a piece of content such as an advert from another site loaded on the web page you are viewing, you are granting permission for that other site to create its cookie on your device.


As regards to the cookies, you may:

  • Exercise the right set by article 7 Legislative Decree 30.06.2003, no 196 and following, within the limits and under the terms prescribed by the articles 8, 9 and 10 of the afore mentioned Legislative Decree;
  • Exercise the right set by articles 13 and 14 of EU2016/679 decree and following, within the limits and under the terms prescribed by the GDPR afore mentioned EU Legislative Decree;
  • Select and deselect the individual cookies in every moment.
  • Withhold your own consent, at any time, when installing any type of cookies;
  • Show your opinion about the use of cookies.


You may set your browser to block Cookies, including those associated with our services. However, it is important to remember that certain features of the Website may not function properly if Cookies are disabled. Cookies enable you to take full advantage of some of the Website’s best features, so we recommend that you keep them enabled.

Below is an explanation of how to manage your Cookie preferences for some of the more popular web browsers:

  • For Internet Explorer (9, 10, 11), select:
  • Tools
  • Internet Options
  • Confidentiality
  • Set according to your choice
  • For Chrome, select:
  • Settings
  • Show Advanced Options
  • Confidentiality
  • Set according to your choice
  • For Mozilla Firefox, select:
  • Menu “Tools”
  • Options
  • “Privacy” Tab
  • Set according to your choice
  • For Safari, select:
  • Preferences
  • Confidentiality
  • Set according to your choice

You may also use the “help” function on the toolbar of your web browser to prevent your browser from accepting new Cookies, to have your browser notify you when you receive new Cookies, and to disable Cookies altogether.


We may update this Statement in the future. If we believe that there are substantial changes, we will inform the user, at least, in one of the following ways: sending a communication about the changes, posting a notice on the website and / or publishing an updated Statement on the website. We will indicate at the beginning of the statement the date of its most recent update. We recommend that the user consult this statement periodically in order to review its most current version, as well as review the statement periodically to get the latest information about our privacy practices.


For any information about privacy policy, personal data, user rights and cookies treatment please send an email to

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