Privacy and Cookie Policy

Privacy and Cookie Policy

1.  Introduction:
The personal data and privacy of the visitors of our website www.hellenic-travelgroup.com, are very important  to us and we are committed to its protection. This Policy is intended to inform you about the information we collect and process when using our online store and making your purchases through it. The receipt of this data makes us responsible for processing and based on the legislation governing Personal Data and in particular the General European Regulation 679/2016 and the National Law number 4624 (Government 137/29 Aug. 2019), we provide you with information on who we are, why we collect your personal data, how we use it and what your rights are as personal data subjects.

Your consent to the use of cookies in accordance with the terms of our policy during your first visit to the website, allows us to use cookies every time you visit our website. For the definition of the concept of cookies see below under 10.

2.  Legal processing of personal data
The company of Hellenic Travel Group owned by CHARALAMPOS STRATIGIS of GEORGE (hereinafter for the sake of brevity called "COMPANY", for the full details of which see section Terms of Use), complying with the provisions of the European Regulation on Personal Data Protection 2016/679) and to the relevant Greek legislation, manages the Personal Data that are communicated to it with the utmost care. In order to ensure the confidentiality and security of Personal Data, the COMPANY has taken the necessary organizational  and technical measures, drawing up internal security policies, using appropriate electronic  means, informing and properly training its staff.

THE COMPANY undertakes to carry out lawful processing of Personal Data, as it collects and processes them exclusively for defined, explicit and legal purposes and only to the extent necessary for the implementation of these purposes. The data  maintains, takes care to be accurate and up to date, seeking for this purpose the assistance of the data subjects, where the natural persons to whom this data relates, and retains the data for as long as is necessary for the implementation of the specific purposes.

3. What is the Processing of Personal Data
According to General European Regulation 679/2016, processing of personal data is, any act or series of transactions carried out with or without the use of automated means, on personal data, such as collection, registration, organization, structure, storage , the adaptation or alteration, retrieval, retrieval of information, use, disclosure by transmission, dissemination or any other form of disposal, correlation or combination, restriction, deletion or destruction of such data.

4. Personal data being processed
THE COMPANY collects and processes Personal Data, the information related to a natural person who is identified or can be identified from this information, regardless of whether the identification can be done directly or indirectly. The processing of this data means any work performed in relation to this data, whether automated or not. Personal Data includes, for example, information such as name, home address, e-mail address or telephone number.

For the specific purposes of processing Personal Data, for example  for information on products, services, promotions, offers, events and competitions, via email, brochures, newsletter, sms, telephone and other electronic means, as well as for research and statistical purposes, Hellenic Travel Group  may collect and process, as an indication, the following information:

• Name
• Gender and date of birth
• Profile photos
• Contact details (home address, postal code, contact telephone, email address)
• Other personal information (ID number) etc.
• Personal and family situation
• Information about the user's training or employment
•  Interests, hobbies, preferences and general transactional behavior
•  Information contained in any of your communication with us  via e-mail or through the website including communication content and metadata.

In case you choose not to provide us with any of your personal information, this may affect some of our transactions. In addition, during the use of the online store of the COMPANY, further data are automatically collected for technical reasons, such as:

• IP address (Internet Protocol address) of the access computer
•  geographic location
• website from which you visit us (recommendation)
• our websites you visit
• date, time, duration and frequency of visits to our website
• browser type and version and browser settings
•  operating system
• username and other information from your profile.

This technical information may, in certain cases, constitute personal data. As a general  rule, we use technical data, however, only to the extent necessary for technical reasons, for the operation and protection of our online store against cyber-attacks and malicious use, as well as in anonymous form for statistics purposes.

5. What is the purpose of processing your personal data
When you use the online store, when you order or when you attempt to place an order but do not complete it, we collect, process and use the personal data and information you provide to us within the framework of applicable personal data protection legislation.

The information we request from you, in order to make it possible to provide the services you need, are marked as mandatory fields. Other information is optional. For the conclusion and execution of the contracts of sale of products to you, through our electronic and physical distribution network, we request, as the case may be, contact information such as name, telephone number, address for delivery and invoicing, as well as information about the payment method you have chosen, information that is occasionally forwarded to partner companies (e.g. logistics, distribution, etc.). In addition, we use your data in our customer database that we maintain, so that only relevant data is stored there. In order to avoid typing errors and to ensure that the items you have ordered have actually been received by you, we check that the address you have entered is written in a complete and accurate manner.

During the payment process, we do not record or store payment information in this transaction, such as credit card numbers or other bank and other information. You provide this information directly and exclusively to the respective payment service provider. The processing of your personal data is done mainly for the smooth execution of your contractual relations with us or third parties (cooperating companies).

The COMPANY also stores and uses personal data and technical information, to the extent that this is necessary to prevent and deal with any malicious use or other illegal behavior on our website, e.g. to maintain data security in the event of cyber-attacks against our computer systems. Finally, we store and use your data to the extent that we are legally obliged to do so, for example in the light of a formal directive or a judicial or other decision of the Authorities, as well as to safeguard rights and claims, as well as to cases of defense of the COMPANY before the Courts, regular or arbitration.

In summary, personal data is collected in particular for the following purposes:

• The best and most user-friendly management of our website and business
• The personalized layout of the site for you
• The provision of services and the activation of the use of your available services on our website
• The purchase and sale of goods through our online store
• The shipment of the goods you buy through our website
• Sending transactions, invoices and payment reminders to you, as well as collecting payments from you
• Sending non-advertising communications
• Sending email notifications about your requests
• Sending an advertising or newsletter (newsletter) via e-mail if you have requested it (you can inform us at any time if you no longer wish the newsletter)
• Sending promotional communications related to our business or third-party businesses that we believe may be of interest to you, through notifications or, if you have agreed to it, by '' byemail '' or similar technology (you can let us know at any time) moment if you no longer want advertising communications)
• The provision of statistical data of our users  to third parties (which will not be able to identify any user of this information)
• The management of requests and complaints that you have submitted yourself or are related to our website
• Maintaining the security of the site and preventing any fraud
•  Confirmation of users' compliance with the terms and conditions of our website (including the monitoring of personal messages circulating through the online messaging service)
• Any other legal use.

6. What is the legal basis for processing your data
 The processing of your data is carried out on a case basis and depending on the purpose of the processing. Specifically, it is performed according to: 

• The fulfillment of the conditions for the execution of contractual obligations
• Your unconditional consent, where required
• The current legal and regulatory framework
• The legal interests of our business
• Other legal purpose

7. Who are the recipients of your data
 Recipients of your data can be:

• The authorized personnel or the executives of our COMPANY, within the framework of their responsibilities and based on the commonly accepted rules of confidentiality.
• Service companies, which will process your personal data strictly on our behalf. These service providers are bound by contracts and terms of confidentiality. When transmitting the data, the COMPANY  takes all necessary measures to ensure the maximum possible level of security. The COMPANY declares that it has signed contracts in advance with these companies, which include conditions related to the taking of security measures by them and the monitoring by the COMPANY of these measures.
• The competent Supervisory and Administrative Independent Authorities, as well as the Prosecution and Judicial Authorities.
• The authorized staff of any cooperating companies (logistics, storage, transport, distribution, etc.) within their responsibilities.

We may disclose your personal  information to any of our interest companies, affiliates or members of our group of  as required for the purposes referred to in this policy and to the extent  provided by law.

8. Data Security
 The security of your personal  data is a high priority for the BUSINESS. Therefore, we protect your data stored with us by taking all kinds of technical and organizational measures to effectively prevent its loss or alteration or misuse by third parties. In particular, our employees, who process personal data, are committed to maintaining confidentiality. To protect your personal data, the data is transmitted in encrypted form and stored on secure (password protected and firewall) servers. It goes without saying, however, that the transmission of information on the Internet is inherently insecure and we cannot guarantee the absolute security of the data circulating through it, which you accept having read our Privacy Policy and using our online store. It goes without saying that your own contribution to the security of your data is crucial, as you are responsible for maintaining the confidentiality of the code and username you use to Log in to our website (we will only ask for your password when you log in to our website) and your debit / credit card details (which you provide directly to the competent banking institutions or bodies).

9. What is the retention time of your personal data
 Your personal data is kept for as long as necessary in order to achieve the purpose for which we have collected it, as well as those provided by applicable law. Our concern is that the personal data we process for any purpose is not retained for longer than is necessary for that purpose. All your personal data is subject to this Privacy Policy and in case of revocation of your consent the legality of the processing for the period before it is not affected.

10. Cookies
For the highest quality and most efficient provision of our services offered, our website uses cookies. This section provides detailed clarifications and definitions in order for the User to be able to fully understand the meaning and function of cookies. Particularly:

10.1. What are cookies?
Cookies  are small data files, which are stored on our computer in the memory of the web browser, after visiting some websites. The cookie does not contain or collect information individually, but when read from a server, it provides information to make it easier and friendlier for the visitor to browse the website visited by recording, among other data, user preferences, error detection and / or the collection of data from statistics. The cookie does not harm the visitor's computer and the information that allows the identification of persons is not stored when browsing any website that uses this policy. The full use of our website requires the acceptance of cookies. If you wish to disable cookies, you may still be able to browse the website. However, some of its features may be disabled. Most browsers (e.g. Internet  Explorer, Mozilla Firefox, Safari, and Google Chrome) have cookies enabled automatically. You can set the degree to which cookies are accessible to each browser. As soon as you do not make changes, it automatically means that there is acceptance of the visitor in the default settings of the browser and that it agrees with the policy of use of cookies.

10.2. How we use cookies
 There are different types of cookies that fall into the following categories:

• Session cookies: are automatically deleted at the end of each visit.
• Permanent cookies: remain during many visits to the website.
• Third-party cookies (3rd-party cookies): used by affiliate or non-affiliate websites that are integrated within our website or to which we connect.

10.2.1. Session cookies
These cookies allow the visitor to use the functions of the website, such as the reminder of a recurring domain element in a browsing session. In addition, they help reduce the need for information transfer across the Internet. They are not stored on the computer and expire when you pause browsing.

10.2.2. Permanent cookies
 Permanent cookies are used to identify new visitors to the website. These cookies consist of specific  browsing  information, such as how the visitor arrived at the website, the internal pages they visited, the choices made, and the mean followed through it.

10.2.3.Cookies of third parties

Our website does not use cookies of this category.

10.3. Cookies Management
 Enable or disable cookies.  If you do not know the type and version of browser you are using to access the web, click Help at the top of the browser window, and then click About. The relevant information you want will then be displayed.

10.4. More information
 For further information on cookies, we suggest you visit the following addresses: www.allaboutcookies.org
 www.youronlinechoices.eu
 www.google.co.uk/goodtoknow/data-on-the-web/cookies

11. Link to other websites
 Hellenic Travel Group website may contain "hyperlinks" or banners to third party websites. Our COMPANY  is in no way responsible for the practices and data protection measures regarding the external websites to which you can access through these links, nor can it control them. Please be aware of the protection of your data on these external websites.
 

12. International data transfer
 The information we collect can be stored, processed and moved between any countries in which we operate our business or where our partners operate. They may even be transferred to countries that do not have the same personal data protection legislation as in the European Economic Area, such as the USA, Russia, Japan, China, India, etc.

 As you know, browsing the Internet, is not always secure. The personal  data you provide through our website or submit for publication on our website may be exposed via the Internet anywhere in the world. We will make every effort as far as possible and under the provisions of our present Policy, but we can not in any case prevent the use or misuse of such information by third parties, especially those located abroad.

13. Consent and rights of personal data

By  choosing to agree and consent  to the processing of the Personal Data concerning you, you give your consent to the processing of the data for the above specific purposes, either by our COMPANY or by a company cooperating with us (for  purposes referred  in our present policy). You can revoke your consent at any time, as well as exercise any of your rights.

Your rights, as "data subjects", are the following:

• The right to information. The company provides you with transparency on how it processes and handles your personal data. You can contact us to answer your questions.
• The right of access. You are allowed, at any time, to access your personal data, so that you know and check the legality of the processing. The information will be provided without delay and no later than one (1) month from the receipt of your relevant request.
• The right of correction. You have the right to correct any inaccurate or incomplete data.
• The right to delete. You can request the deletion or removal of your personal data, as long as there is no serious reason to continue processing them.
• The right to restrict processing. You have the right to request a restriction on the processing of your personal data in the following cases: (a) when you dispute the accuracy of your personal data and until it is verified, (b) when you do not wish to have your personal data deleted restricting their use, (c) when your personal data is not used for processing purposes, but is necessary to establish, exercise and support legal claims, and (d) when you object to the processing and until it is verified that there are legitimate reasons which concern us and prevail over the reasons why you oppose the processing.
•  The right to transfer data. This allows you to obtain and reuse your personal data for your own purposes in various services.
• The right to withdraw consent and objection. You have the right to revoke your prior consent without prejudice to the lawfulness of processing based on your consent before revoking it and to object to a) processing based on legitimate interests or performance of duty in the public interest / exercise of public authority. b) direct marketing and c) processing for the purposes of scientific / historical research and statistics.
• Rights regarding automated decision making and profiling. If you wish to exercise any of the above rights, you should contact us by email at :
  info@www.hellenic-travelgroup.com

14. Recourse to the Data Protection Authority
 In case you do not receive a timely response or you are not satisfied with the response of our COMPANY, you have the right to file a complaint to the Personal Data Protection Authority. This can be done at the address www.dpa.gr, by phone at + 30 210 6475600, or in writing at: Personal Data Protection Authority of Kifissia no. 1-3, PC 115 23, Athens (or wherever else the  Authority is located).

15. Revisions to this Privacy Policy
 This privacy policy is reviewed and, if necessary, updated  from time to time, in accordance with applicable national and Community law, as well as any changes to our services and our use of personal data. You should check this section from time to time to make sure you understand any changes to our policy. We may notify you of changes to our policy by e-mail or SMS or through a private messaging system on our website.