We are glad for your interest in the protection of personal data on our website. It is important for us that you feel satisfied and safe when navigating our website regard our data protection policy as a customer-oriented quality feature. In the following notes on the personal data protection, we wish to inform on the way and the extent of personal data processing by MARKOU HOTEL AND TOURIST COMPANY S.A. GIOVANTI TRAVEL S.A. Personal data is information that is or may be classified directly or indirectly for each person. The legal basis for data protection is mainly the General Data Protection Regulation ο (GDPR).
1. In general When you navigate on the website of MARKOU HOTEL AND TOURIST COMPANY S.A. GIOVANTI TRAVEL S.A. various information is exchanged between your terminal and our server. In this case, personal data of the user may also be processed. The personal data collected in this way shall be used, among other things, for the improvement of our website or for the promotion of our company on the browser of your terminal.
2. Visiting our website Purpose of data processing / Legal basis: Upon entering our website, the following are automatically, and with no further action required by you, sent by the browser of your terminal • the IP address of the device with internet access that submitted the request; • access date and time; • the name and URL of the requested file • the website / application from which the website was accessed (referrer-URL), • your browser, the operating system of your computer that has access to the internet, as well as the name of the access provider to the server of our website and are temporarily stored in a log file for the following purposes: • confirmation of proper connection; • confirmation of easy use of our website / application; • assessment of the safety and stability of the system. If you have consented to the geolocation on your browser or operating system or other settings on your terminal, we will use this feature to provide you with personalized services related to your current location (e.g. the location of the nearest branch). We will process your location data obtained in this way exclusively for this purpose. The legal basis for the processing of the IP address is Article 6(1)(f) of the General Data Protection Regulation (hereinafter referred to as the GDPR). Our legitimate interest arises from the aforementioned purposes of data processing. Recipients / categories of recipients: We generally do not transfer this data to third parties. Duration of storing / storing criteria: The data is temporarily stored for the session and then deleted automatically. Once you stop using our website, geolocation data is deleted.
3. Contact form / contact via e-mail/ calls / customer surveys Purposes of data processing / legal basis: Personal data, which you provide to us when filling in a contact form, by phone or e-mail, will be certainly treated by us observing the confidentiality principle. We will use your data exclusively for a specific purpose, to process your request. The legal basis for this type of data processing is Article 6(1)(f) of the GDPR. Both our and your (legitimate) interest in this data processing arises from our goal to provide you with answers and possibly solve any existing problems and thus maintain and enhance your satisfaction as a customer or user of our website. Any participation in any of our customer surveys is on a purely voluntary basis. No information is stored during an anonymous survey, which would allow the identification of the survey participant. Only the date and time of your participation are stored. Any personal information you provide in response to our survey is considered to have been given voluntarily and is stored in accordance with the GDPR. Please do not note your name or similar information in the free-form text fields, which would allow the identification of yourself or others. In case you submit a declaration of consent in the context of a customer survey, Article 6(1)(a) shall be the legal basis for the processing of your data, which is based on your consent. Once you have agreed to a customer survey, you may withdraw your consent at any time and such withdrawal will be in effect for the future. More detailed regulations on these cases can be found in the special data protection policies of each customer survey. Recipients / categories of recipients: In general we do not transmit personal data to third parties. By way of exception, the data is processed by persons carrying out the processing on our behalf. These persons are carefully selected, supervised and contracted with us in accordance with Article 28 of the GDPR. Moreover, we may be required to transmit excerpts of your request to our counterparties (e.g. suppliers for product requests) in for your request to be processed. If the transmission of your personal data is required in an individual case, we will let you know in order for you to consent or not to such transmission. The results of our customer surveys are usually only used for internal evaluations. In general we do not transmit personal data to third parties. We do not transmit your personal data to third parties unless we obtain your express consent to do so. Storing duration/ Criteria determining the duration of storing: All personal data provided to us in the context of requests (suggestions, positive or negative reviews) through this website or by email, is deleted by us or is rendered anonymous no later than 90 days after the final response is provided. Experience has shown that, as a rule, after 90 days, no clarifying questions are submitted regarding our answers.
4. Competitions Purposes of data processing / legal basis: You have the opportunity through our website and newsletter toparticipate in competitions. Unless otherwise provided in the specialdata protection policies of each competition or if you have not provided us with additional express consent, the personal data you have provided to us as part of the competition shall be used exclusively in the context of organizing the competition (eg announcement of winners, notification of winners, sending the prize). The legal basis for this type of data processing is, in principle, Article 6(1)(b) of the GDPR. If you submit a declaration of consent relating to a competition,Article 6(1)(a) of the GDPR shall form the legal basis for the processing of the data based on consent. Once you have provided your consent relating to a competition, you may withdraw such consent at any time and such withdrawal shall have effect for the future. More detailed regulations on these cases can be found in the special data protection policies of each competition. Recipients / categories of recipients: Data may be transmitted to third parties only if this is necessary the competition to be carried out (e.g. sending the prize through a partner with which we cooperate). In general, the data cannot be further transmitted to third parties. Storing duration/ Criteria determining the duration of storing: After the end of the competition and the announcement of the winners, the personal data of the participants is deleted. In case the prize is an item, the data of the winners shall beretained for so long as legal guarantees are in force, so that such item may be restored or replaced in case of a defect.
5. Data processing for promotional purposes Purposes of data processing / legal basis: Provided that you consent to this, we analyze the user behavior in the context of our online presence and through the newsletters we send you. The evaluation of user behavior includes in particular the parts of the website that you visit and which links you enable there. By processing this information we create personalized user profiles that are classified by person and / or e-mail address, in order for the advertising offer of VASILEIOS MARKOU Co LTD in the form of a newsletter, advertising messages on the website and printed advertising material to be adjusted to your personal interests and in order for us to improve our online offers. The legal basis for the aforementioned processing is Article 6(1)(f) of the GDPR or, in case you have given your consent, Article 6(1) a) of the GDPR. The processing of existing customer data for our advertising purposes or third party advertising purposes should be considered to be our legitimate interest. Right to object You may object to the processing of your data for the aforementioned purposes at any time and free of charge, separately for each communication channel and the objection shall have affect for the future. All you need to do is send an e-mail or a letter to the contact details listed in paragraph 11. Recipients / Categories of recipients: In general we do not transmit personal data to third parties. Storing duration/ Criteria determining the duration of storing: If you withdraw your consent to certain means of advertising or object to certain means of advertising, your data will be deleted from the respective e-mail distributors. If you object, your contact address will be excluded from later processing of data for advertising purposes. We wish to stress that in exceptional cases, sending advertising material may continue temporarily after the receipt of the objection. This technically depends on the time required for advertising messages to be implemented and does not mean that we do not respect your objection. Thank you for your understanding.
6. Newsletter Purposes of data processing / legal basis: On our website we provide you with the opportunity to subscribe to our newsletter. If you consent to receiving our newsletter, we shall use your email address and possibly your name to send (if possible, personalized) information about products, promotions, competitions and news on the offer, as well as customer surveys. We shall store and process this data in order to send you newsletters. The contents of the newsletter include promotional activities (offers, discount offers, competitions, etc.) as well as the services of MARKOU HOTEL AND TOURIST COMPANY S.A. GIOVANTI TRAVEL S.A.. Provided that you consent to this, we analyze the user behavior in the websites related to www.giovanti.gr, and through the newsletters we send you. The evaluation of user behavior includes in particular the parts of the website that you visit and which links you enable there. By processing this information we create personalized user profiles that are classified by person and / or e-mail address, in order for the advertising offer in the form of a newsletter, advertising messages on the website and printed advertising material to be adjusted to your personal interests and in order for us to improve our online offers. The legal basis for the processing of data in the context of sending newsletters is the consent in accordance with Article 6(1)(a) of the GDPR. To ensure that you did not make a mistake when entering your email address, we have introduced a double-opt-In process: After entering your email address in the specified field, we will send you a confirmation link. Only if you select this confirmation link will your email address be sent to our distributors. You may withdraw your consent to receiving our newsletter, to the participation in customer satisfaction surveys and in the creation of personalized user profiles any time and said withdrawal shall have affect for the future, e.g. by unsubscribing from newsletter through our website. You will find the link to the page where you can unsubscribe on this website or at the end of each newsletter. By unsubscribing from our newsletter, your consent for the creation of a personalized user profile and for the reception of the personalized newsletter is also withdrawn. In this case your user data is deleted. Recipients / Categories of recipients: If external distributors are used to carry out the sending of the newsletter, they must be contractually bound in accordance with Article 28 of the GDPR. In general we do not transmit data to third parties. Storing duration/ Criteria determining the duration of storing: If you withdraw your consent to receiving the newsletter of Giovanti Travel, your email address shall be excluded from receiving any newsletters. Your data shall be deleted from the corresponding email distributors after 6 months.
7. Online presence and optimization of the websites
7.2. Google Analytics Purposes of data processing / legal basis: In order to customize and constantly optimize our websites according to our needs, we use, under Article 6(1)( f) of the GDPR, Google Analytics, a web analytics service of Google Inc. («Google»). Our legitimate interest arises from the aforementioned purposes. In this context, “pseudonymized” user profiles are created and cookies are used. Cookies record the following information about the use of this website: • browser type / version; • operating system used; • Referrer-URL (the previous page that you visited); • Hostname of the access computer (IP address); • server request time. The information is used to evaluate how our websites are used, to draw up reports on the activities on the websites and to provide additional services related to the use of the website and the internet for the purposes of market research and the adjustment of these websites to our needs. IP addresses become anonymous so that they cannot be matched (IP-masking). You can block cookies from being installed through the respective settings of your browser. However, we wish to highlight that in this case it may not be possible for you to use all the functions of the website. You can also block the analysis of data generated by cookies regarding the use of the website (including the IP address) as well as the processing of such data by Google by downloading and installing this browser extension. Instead of the browser extension, you can also, especially in mobile device browsers, block Google Analytics by selecting this link. You create and opt-out cookie, which blocks future analysis of your data when visiting the website. The opt-out cookie only applies to this browser and only to our website and is stored on your device. If you delete cookies from this browser, you must re-install the opt-out cookie. More information on data protection as regards Google Analytics can be found on the website of Google Analytics. Recipients / Categories of recipients: The information generated by the cookies is transferred to a Google server in the US and stored there. Under no circumstances is your IP address merged with other data from Google. This information may also be transmitted to third parties if provided for by law or if third parties process this data pursuant to the law. Storing duration/ Criteria determining the duration of storing: After “anonymization” of the IP address, identification of a person is no longer possible. Data generated for statistical purposes is deleted by Google Analytics after 50 months. Reports based on Google Analytics no longer refer to individuals.
7.3. Website targeting and optimization Purposes of the data processing / legal basis: By using cookies, our website analyzes and evaluates the information that is necessary for the optimization of our websites and the advertisements displayed on them. In this way, it is ensured that only the advertisements that are adapted to your real or alleged interests based on the user behavior so far will be displayed on your terminal. The information processed for these purposes contains, for example, information about the products in which you have been interested. The legal basis for this type of data processing is Article 6(1)(f) of the GDPR. Therefore, optimization of our websites in order to achieve the best shopping experience and to avoid advertisements for products in which you are not interested is advantageous for both you and us. Analysis and evaluation are carried out exclusively under a pseudonym and do not allow us to identify you. In particular, this information is not merged with your personal data. Recipients / Categories of recipients: The aforementioned service providers are the recipients of the data, the processing of which is based on a contract between them and us and is carried out only for a specific purpose according to our instructions. Storing duration/ Criteria determining the duration of storing: Cookies used here and the information contained therein shall be stored in accordance with the Cookie Terms and deleted immediately upon objection.
7.4. Retargeting Purposes of the data processing / legal basis: We also use re-targeting technologies of various providers. This allows us to develop our online offer in a way that you may find interesting. For this purpose, a cookie is created with which important data is collected under a pseudonym. In this case, information on your navigation behavior is collected for commercial purposes in anonymous form, stored in cookie data files on your computer and analyzed through an algorithm. Subsequently, targeted product recommendations and personalized advertising banners of products in which you are interested may be posted on our partners’ websites. Under no circumstances can this data be used to identify the visitor of the website. No direct personal data is processed and no user profiles are matched with personal data. This type of data processing is carried out under Article 6(1)(f) of the GDPR. By taking specific targeting measures, we wish to ensure that only advertisements that are suitable for your real or perceived interests will appear on your terminals. It is in our best interest, as well as yours, not to burden you with advertisements that do not meet your interests. If, nonetheless, you do wish personalized banner advertisements of Giovanti Travel not to be displayed on your terminal, you may object to said collection and storing of your data for the future by taking the following steps: B selecting the symbol that is on each advertisement banner (e.g. “I”) you will be transferred to each provider’s website. There, the systematic retargeting technology is used again and you may choose to “Opt-out”. If you unsubscribe from a provider, the “opt-out” cookie is stored on your computer, which will block the advertising banner of said provider from appearing in the future. Please note that you can unsubscribe only using your computer and the respective “opt-out” cookies may not be deleted from your computer. Alternatively, you can use the right to object detailed in section 7.5 of the present Data Protection Terms. Recipients / Categories of recipients: On our websites, we use re-targeting technologies of various provides, which process the above data in the context of retargeting. Further information on the cookies used by such providers can be found on the Cookies Terms. Storing duration/ Criteria determining the duration of storing: Cookies used for re-targeting purposes and the information contained therein are stored for the period provided for in the Cookies Terms and at the end of such period they are automatically deleted.
7.5. Power to object / opt-out You can block the targeting technologies analyzed in paragraphs 7.3 and 7.4, through the corresponding cookies settings on your browser (see also paragraph 7.1). At the same time you may block personalized advertisements based on your interests through the Preferences Manager or enable the opt-out cookies submitted according to paragraph 7.5.
8. Recipients outside the EU With the exception of the processing described in paragraph 7, we do not transmit your data to recipients based outside the European Union or the European Economic Area. The processing mentioned in paragraph 7 results in data transmitted to the servers of the tracking and targeting technologies providers authorized by us. Certain servers are located in the United States (for more information on the specific recipients please read the relevant reports). The transmission of data is carried out in accordance with the principles of the Privacy Shield as well as on the basis of the Standard Contractual Clauses of the European Commission.
9. Notes on data protection regarding business partners The following notes on data protection applies to persons that contact us, negotiate the conclusion of contracts with us and / or have concluded any agreement with us and in this context their data is processed. The General Data Protection Regulation (GDPR) of the EU as well as the applicable national data protection laws shall apply as a legal basis. The determination of which data is processed shall depend on the services provided that have been agreed. For this reason, these notes may only concern you in part.
HOW DO WE RECEIVE YOUR PERSONAL DATA AND WHICH CATEGORIES OF DATA DO WE USE? First of all, we receive your data from you personally. The processing of personal data that we have received from other companies, services or third parties in general, e.g. travel agencies, tourist units, financial services, etc., may be necessary. This may also include personal data that we may receive through information channels that we have created regarding any breaches of compliance or in the context of compliance investigations that we conduct. The following may be included in the aforementioned related data: Personal information (e.g. name, surname, address and other contact details, date and place of birth, citizenship), certification and identification data (e.g. identity details, signatures), data in the context of our business relationship (e.g. payment data, service data), photos and videos (e.g. when you enter our offices and for the protection of persons and goods) as well as other data categories similar to the aforementioned ones. You can always choose to contact us either by e-mail or by mail. Communication via e-mail, for technical reasons, under certain conditions shall be carried out without encryption.
PURPOSES AND LEGAL BASIS OF THE PROCESSING In order to fulfill contractual obligations (Article 6(1)(b) of the GDPR) The purposes of data processing arise from the performance of pre-contractual obligations preceding a contractually regulated business relationship and for the performance of the obligations of a contract entered into. In order to fulfill a legal obligation (Article 6(1)(c) of the GDPR) The purposes of data processing arise in some cases from legislative provisions. These legal obligations include, e.g. fulfillment of compliance and identification obligations, e.g. data processing in the context of requests from services. In order to fulfill a legitimate interest (Article 6(1)(f) of the GDPR) Additional processing of the personal data that you have provided for the execution of the contract may be mandatory. The legitimate interest in this case is the selection of the appropriate business partner, the entry into force of legal requirements, the assurance against compensation claims, access checks, the clarification of possible breaches of compliance, the prevention of criminal actions and the settlement of damages relating to a business relationship. When drawing up contracts, in order to fulfill the aforementioned legitimate interest, by way of exception we receive data on your creditworthiness from information agencies. We use the data of the information agencies on your creditworthiness to check your solvency. Information agencies store data that they receive, for example, from banks or businesses. This data include the last name, first name, date of birth, address and information on payments. You will receive information about the data stored that concern you directly from said information agencies.
WHO RECEIVES THE PERSONAL DATA THAT YOU PROVIDE? Within our company, the respective actors that need this data to perform contractual or legal obligations or to fulfill a legitimate interest obtain the right of access the data that you provided. In the context of contractual relations, we also hire persons carrying out data processing or service providers who may gain access to your personal data. Observance of the legal provisions for data protection is ensured in this case through a contract us and the above persons. The data may also be transmitted for the fulfillment of contractual obligations to companies within BLUE STAR FERRIES.
FOR HOW LONG IS THE DATA RETAINED? Personal data is retained for as long as is required for the above purposes to be achieved. As regards the retention period, the legal obligations arising from the applicable relevant national legislation are also important.
ARE YOU OBLIGED TO PROVIDE YOUR DATA? In the context of our business relationship you must provide the personal data necessary for the conclusion, execution and termination of the business relationship and for the performance of the relevant obligations, the data that we are obliged to collect by law or the data we are entitled to collect on the basis of our legitimate interest. Without the provision of such data, as a rule, we are not able to enter into a business relationship with you.
IS DATA TRANSMITTED TO THIRD COUNTRIES? If we transmit personal data to recipients outside the European Economic Area (EEA), such transmission is carried out only if the third country has been approved by the European Commission on the appropriate level of data protection, the appropriate level of data protection has been agreed with the recipient (e.g. through standard EU contractual clauses) or if you have consented to such transmission.
WHICH ARE YOUR RIGHTS AS DATA SUBJECT? You have the right to access free of charge, upon your request, your personal data that we retain. Moreover, in accordance with the legal provisions, you have the right to rectification and erasure your personal data, the right to data portability and the right to restrict processing of the data that concern you. In case your personal data is processed upon your consent, you reserve the right at any time to withdraw such consent for future reference. In this case, contact in writing or by e-mail the data protection officer noted below. Furthermore, you can lodge a complaint with the competent data protection authority if you disagree with the processing of your personal data.
CONTROLLER The controller is the enterprise with which you initiate or maintain a business relationship.
HAVE YOU GOT ANY MORE QUESTIONS?
Controller’s contact details: E-mail: firstname.lastname@example.org Postal address: 26 AKTI POSEIDONOS STR., 18531 PIRAEUS GREECE
10. Your rights as data subject
10.1 General information In addition to the right to withdraw the consent you have given us, you also have the following rights, provided that the legal conditions are met: • the right to access your personal data that we retain in accordance with Article 15 of the GDPR; • the right to the rectification of incorrect or incomplete data in accordance with Article 16 of the GDPR; • the right to erasure of your data that we retain in accordance with Article 17 of the GDPR; • the right to restrict the processing of your data in accordance with Article 18 of the GDPR; • the right to data portability in accordance with Article 20 of the GDPR; • the right to object in accordance with Article 21 of the GDPR.
10.2 The right to access in accordance with article 15 of the GDPR You have the right to be informed upon request and free of charge, in accordance with Article 15(1) of the GDPR, of your personal data we retain. This includes in particular: • the purposes of personal data processing; • the categories of the personal data that we process; • the recipients or categories of recipients to which the personal data concerning you is transmitted or is to be transmitted; • if possible, the period for which personal data will be retained or, where this is not possible, the criteria that determine said period; • if you have the right to submit a request to the controller regarding the rectification, erasure or restriction of the processing of the personal data concerning the data subject or the right to object to such processing; • the right to lodge a complaint with the competent data protection authority; • any available information on their origin, where the personal data is not collected by the data subject; • if there is an automated decision-making, including the creation of profiles provided for in Article 22, paragraphs 1 and 4 of the GDPR and, at least in these cases, important information on the thinking behind, as well as the significance and intended consequences of this. processing for the data subject. Where personal data is transmitted to a third country or to an international organization, the data subject has the right to be informed of the appropriate guarantees in accordance with Article 46 of the GDPR on the transmission of personal data.
10.3 The right to rectification in accordance with article 16 of the GDPR You have the right to request that we correct without undue delay any inaccurate personal data concerning you. Given the purposes of the processing, you have the right to request that incomplete personal data be completed, among other things by a supplementary declaration.
10.4 The right to erasure in accordance with article 17 of the GDPR You have the right to request that we erase without undue delay your personal data, in case any of the following conditions is met: • the personal data is no longer necessary for the purposes for which it was collected or processed; • you withdraw your consent on the basis of which the processing was carried out under Article 6(1)(a) or Article 9(2)(a) of the GDPR and there is no other legal basis on which such processing can continue to be carried out; • you object to the processing under Article 21(1) or (2) of the GDPR and there are no binding and legal grounds for the processing of the data under Article 21(2) of the GDPR; • the personal data was processed illegally; • the erasure of the data constitutes compliance with a legal obligation; • the personal data collected in connection with the provision of information society services referred to in Article 8 (1) of the GDPR. In case we have disclosed personal data and are obliged to erase it, taking into account the available technology and application costs, we shall take reasonable measures to inform third parties processing your personal data that your request that any links to such data or copies or reproductions of such data be deleted.
10.5 The right to restrict processing in accordance with article 18 of the GDPR You have the right to request that we restrict the processing of your data, in case any of the following conditions is met: • you question the accuracy of personal data; • the processing is illegal and you request that the use of the personal data is restricted instead of erasure of the data; • the controller no longer needs the personal data for the purposes of the processing, but such data is required by the data subject to establish, exercise or support legal claims; • or you object the processing under Article 21(1) of the GDPR, pending the verification as to whether the statutory claims of the controller prevail over the claims put forward by the data subject.
10.6 The right to data portability in accordance with article 20 of the GDPR You have the right to obtain the personal data concerning you, which you have provided to us in a structured, typically used and legible format, as well as the right to transfer such data to another controller without us being able to object to such transfer, in case: • the processing is based on consent in accordance with Article 6(1)(a) or Article 9(2)(a) or on a contract in accordance with Article 6(1)(b), and • processing is carried out automatically. When exercising the right to data portability you have the right to request that personal data be transferred directly from us to another controller, if this is technically possible.
10.7 The right to object in accordance with article 21 of the GDPR Under the conditions of Article 21(1) of the GDPR, you may object to the processing of your data on various grounds depending on the situation. The above general right to object applies to all data processing purposes described in the present Data Protection Terms, where data is processed under Article 6(1)(f) of the GDPR. Contrary to the special right to object concerning the processing of data for advertising purposes (cf. above, paragraphs 9 and 7.5), we are obliged under the GDPR to comply with this general right to object only if you establish your right on important grounds, such as a potential risk for your life or health. Furthermore, you may contact the competent data protection authority or the data protection officer of VASILEIOS MARKOU Co LTD.
11. Contact office 11.1 Contact office for questions or the exercise of your data protection rights For questions on the website or the exercise of your rights regarding the processing of your data (data protection rights) you may contact: E-mail: email@example.com Postal address: 26 AKTI POSEIDONOS STR., 18531 PIRAEUS GREECE
11.2 Contact office for questions on data protection For further questions on the processing of your data, you can contact the Data Protection Officer through the Controller.
11.3 Right to lodge a complaint with the data protection authority Furthermore, you have the right to lodge a complaint with the competent data protection authority at any time. You may contact the Data Protection Authority of the Member State where you reside or where your place of work is or of the country where the alleged infringement incurred or with the authority of the State where the controller is based.
12. Name and contact details of the Controller and contact details of the company’s data protection officer The present Data Protection Terms apply to data processing by MARKOU HOTEL AND TOURIST COMPANY S.A. GIOVANTI TRAVEL S.A., 26, AKTI POSEIDONOS STR., PIRAEUS (the “Controller”) and the website www.giovanti.gr. You can contact the data protection officer of GIOVANTI TRAVEL S.A. at the above address, for the attention of the data protection officer or at firstname.lastname@example.org. Our website is not intended for children under 16 years of age. When our services and products are to be used by a child under 16 years of age, the explicit consent of their parent is required in order for the personal data of the minor to be processed.