PRIVACY POLICY FOR THE WEBSITE www.grapeharbor.com

1. IDENTIFICATION OF THE DATA CONTROLLER

2. DUTY TO PROVIDE INFORMATION

The protection of personal data of natural persons is governed in Portugal by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and by Law No. 58/2019 of 8 August, which ensure the protection of natural persons with regard to the processing of personal data and the free movement of such data.

“Personal data” means any information, of any nature and regardless of the medium, including sound and image, relating to an identified or identifiable natural person; therefore, the protection does not cover data relating to legal persons.

An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more specific elements of their physical, physiological, psychological, economic, cultural or social identity (for example, their name associated with their telephone number or email address).

By reading this Privacy Policy, the User is informed about the processing of their personal data carried out by Twilight and Breeze Lda through the website www.grapeharbor.com.

3. PURPOSES OF THE PROCESSING OF PERSONAL DATA

The personal data that we collect and process through the above-mentioned Website will only be used for the following purposes:

• Managing the contracting of services carried out through the Website, such as contact requests or reservation management;
• Sending periodic communications with news relating to the activities of Twilight and Breeze Lda and the sector in which it operates;
• Anonymous and aggregated analysis of the use of the services, in order to identify Users’ habits and trends, with a view to improving the services offered and meeting Users’ specific needs;
• In the event of a contract, the data collected through this Website, together with other data obtained within the scope of the contractual relationship, will be used for human resources management, to ensure compliance with legal obligations and to provide employees with the necessary means to carry out their professional activities;
• Complying with national and international legal provisions or executing an order from the competent judicial authorities;
• Complying with legal obligations arising from applicable data protection legislation, as well as exercising data subjects’ rights, in particular defending a right in legal proceedings.

Twilight and Breeze Lda guarantees the confidentiality of all data provided. Nevertheless, although Twilight and Breeze Lda collects and processes data securely and in a manner that prevents its loss or manipulation, using the most appropriate techniques for this purpose, it should be borne in mind that the collection of data over open networks does not allow personal data to circulate under conditions of absolute security, and there is a risk that it may be accessed and used by unauthorised third parties.

Failure to provide data marked as mandatory may result in the inability to respond to the data subject’s request.

4. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

Twilight and Breeze Lda processes Users’ data:

• when they give their free, specific, informed and unambiguous consent to the processing of their personal data for specific purposes; and/or
• when it is necessary for the performance of a contract to which the User is a party, or for taking pre-contractual steps at the User’s request; and/or
• to comply with legal obligations to which Twilight and Breeze Lda is subject; and/or
• for the purposes of the legitimate interests pursued by Twilight and Breeze Lda or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

The User guarantees that the information provided is true, accurate, complete and up to date, and shall be responsible for any direct or indirect damage or loss that may be caused as a result of breaching this obligation.

Where the data provided belongs to a third party, the User guarantees that they have informed that third party of the matters contained in this document and obtained their authorisation to provide their data to Twilight and Breeze Lda for the purposes indicated.

5. RETENTION PERIOD

Twilight and Breeze Lda only retains and processes your personal data for as long as necessary or required to fulfil the purposes described above, applying appropriate data retention criteria to each processing activity and in accordance with applicable legal and regulatory obligations.

Twilight and Breeze Lda retains personal data in its systems in such a way that data subjects can be identified according to the following criteria:

• for a period no longer than necessary to fulfil the purposes for which the data was collected, unless otherwise provided for by legal or contractual obligations;
• to comply with specific legal or contractual obligations;
• where applicable and lawful, until the Data Subject requests objection to or erasure of their data.

6. DISCLOSURE OF DATA

In addition to disclosures made in compliance with legal obligations, the Data Subject’s personal data may be accessed, in addition to Twilight and Breeze Lda, by:

• external service providers of Twilight and Breeze Lda, acting as data processors;
• national and international companies belonging to the same group as Twilight and Breeze Lda;
• authorities in general, administrations, entities and public bodies, both national and international;
• Twilight and Breeze Lda

7. INTERNATIONAL TRANSFERS OF DATA

The personal data collected will be processed within the European Economic Area, with no international transfers of data to third countries or international organisations.

In the event that personal data is processed outside the European Economic Area, this will only take place following the adoption of appropriate safeguards and the required level of protection, in accordance with personal data protection legislation.

8. INFORMATION SECURITY

Twilight and Breeze Lda has implemented appropriate technical and organisational security measures to ensure the security of the personal data provided by the User, with the aim of preventing its alteration, loss, processing and/or unauthorised access, taking into account the current state of technology, the nature of the data stored and the risks to which it is exposed.

Personal data is processed with the level of protection required by law to ensure its security and prevent its alteration, loss, processing or unauthorised access, taking into account the state of technology. The User acknowledges and accepts that security measures on the Internet are not infallible.

Where Twilight and Breeze Lda engages other entities to provide services involving the disclosure of personal data, such entities will be required to adopt the necessary technical and organisational measures to protect personal data against destruction, loss, alteration, disclosure, unauthorised access or any other form of unlawful processing.

9. EXERCISE OF RIGHTS

In accordance with the provisions of the GDPR, the User may exercise their rights of access, rectification and, where applicable, restriction of processing, erasure, portability, objection and withdrawal of consent, under the terms of the GDPR, by submitting a written request through any of the following means and specifying the right or rights they wish to exercise:

10. SUPERVISORY AUTHORITY

The User also has the right to lodge a complaint with the Comissão Nacional de Proteção de Dados regarding matters relating to the exercise of their rights and the protection of their personal data, if they consider that their data protection rights have been infringed.

11. THIRD-PARTY PAGES

The Website may contain advertising, links or other content that links to or redirects users to pages and services of suppliers, advertisers, affiliates, sponsors of Twilight and Breeze Lda and other third parties.

However, Twilight and Breeze Lda does not control the content or links that appear on such pages and is not responsible for the practices used by such pages or websites. Twilight and Breeze Lda advises Users to consult the privacy policy of such pages, as well as their terms and conditions.

Browsing or interacting with any other website, including those that contain an external link to the Website, is subject to the terms and conditions of that website. Under no circumstances shall Twilight and Breeze Lda be responsible for such access and use.

12. PROCESSING OF DATA CARRIED OUT BY THE COMPANY THAT DEVELOPS AND MANAGES THE WEBSITE AS AN INDEPENDENT DATA CONTROLLER

Without prejudice to the processing of data collected through the Website being the responsibility of Twilight and Breeze Lda, as identified above in Section 1 of this Privacy Policy, we inform the User that MIRAIFUTURE PORTUGAL, LDA., with registered office at Buganvília Plaza 1, Quinta do Lago, 8153-013 Almancil and NIPC 515 139 092, may, in specific situations, act as an independent Data Controller, determining autonomously the purposes and means of processing.

This applies, in particular, to data processed to ensure the operation, maintenance and security of the booking engine.

In such situations, the User’s data will be processed in accordance with the following information:

• Purpose: to ensure the operation, security and continuous improvement of the Website;
• Legal basis: legitimate interest;
• Retention period: for the period strictly necessary to fulfil these purposes.

Mirai ensures that, even in these situations, it only processes data that is strictly necessary, adopting appropriate technical and organisational measures to ensure its security and confidentiality.

The User may exercise the rights referred to in Section 9 by submitting a written request through any of the following means and specifying the right or rights they wish to exercise:

The User may also exercise the rights provided for in Section 10.

13. CHANGES TO THE PRIVACY POLICY

In order to ensure that this document remains appropriate, Twilight and Breeze Lda reserves the right to review this Policy at any time it considers appropriate. Users are therefore advised to check this privacy policy regularly and/or each time they access the Website.

Updated on 14/05/2026.