"she told me she was sorry, that there had been a special offer on sunbeds, and it had seemed like the right thing to say at the time"
To whom had it seemed like the right thing? The speaker, or the "she" at the beginning?
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There is an elided "that"
. . .there had been a special offer on sunbeds, and [that] it had seemed like the right thing to say at the time.
So both these clauses are reported speech, as spoken by HER.
And, because we don't know what anybody else said "at the time", we must infer that what SHE said at the time was what "seemed like the right thing to say."