Privacy policy

Thank you for your interest in the ExtraMilers platform, which was developed to inform and promote accessible tourism in the Greek islands (hereinafter referred to as the “Platform”). Due to the nature of the Platform and the personal information you are required to submit to it and as our purpose is to be a useful tool and to provide a secure and functional environment to its users, it is important that you receive accurate information on how your personal information will be used and make sure it is secure with us.

With this privacy policy (hereinafter referred to as the "Privacy Policy"), the civil non-profit company named "AGONI GRAMMI GONIMI", which is based in Athens, Spyridonos Trikoupi 52 & Asimaki Fotila 1, 114 73, Greece (hereinafter referred to as the "AGONI GRAMMI GONIMI”), in its capacity as data controller according to the definitions of the General Data Protection Regulation (GDPR), communicates, explains and defines the terms with, and the purposes for which it collects, stores, uses and generally processes your personal information, which it collects when you visit, subscribe or otherwise use the website https://www.extramilers.eu/, which hosts the Platform, the Platform itself, its mobile applications or other mobile devices (hereinafter all the above referred to as the "Websites"), as well as when contacting it by telephone or via e-mail regarding Platform issues.

The Privacy Policy constitutes, together with the Terms of Use, the Agreement in which you enter into with AGONI GRAMMI GONIMI for the granting of the right of access and use of the Platform. Terms in capital letters will have the meaning given to them in the Terms of Use and vice versa, unless otherwise stated in the Privacy Policy.

The Platform has been developed by the société anonyme under the name "ATCOM INTERNET & MULTIMEDIA SA" (hereinafter referred to as the "Partner"). The Partner acts as the data processor according to the definitions of the General Data Protection Regulation (GDPR) on behalf of, in the name and according to the instructions of AGONI GRAMMI GONIMI regarding the Websites’ management.

• COLLECTION OF PERSONAL INFORMATION

AGONI GRAMMI GONIMI collects the following types of personal information:

1. Information which you are obligated to submit when creating your personal account on the Platform. The creation of a personal account is necessary for entering into the Agreement with AGONI GRAMMI GONIMI for the provision of the Platform’s services,  e.g., the right of access and use of the Platform. This information concerns: a) as long as you register as a PWDs user your state of health, any disability, as well as the use of any aids, whether you are accompanied, your country of residence, your languages ​​of communication, your name, your gender, your age, your weight, your email address and your Platform password, b) as long as you register as a Volunteer user your place of residence, your name, your gender, your age, your email address, your telephone number, your photo, your previous service, your education, your training, your languages of communication and your Platform password. WITH THE CREATION OF YOUR PERSONAL ACCOUNT, YOU SPECIFICALLY ACKNOWLEDGE THAT YOU WISH TO ENTER INTO AN AGREEMENT WITH AGONI GRAMMI GONIMI FOR THE PROVISION OF PLATFORM’S SERVICES, UNDER WHICH YOU GIVE YOUR CONSENT TO THE PROCESSING OF SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THE PRIVACY POLICY, WHICH IS PART OF THE AGREEMENT. 

1. Information on points of interest that you enter in the favorite place lists which you create in the Platform.

1. Information you send to AGONI GRAMMI GONIMI when you provide feedback on points of interest that appear on the Platform. This information may include the name, email, telephone, as well as the content of the communication (evaluation) and its metadata. 

1. Information that you send to AGONI GRAMMI GONIMI when you suggest new points of interest to be added to the Platform. This information may include the name, email, telephone, as well as the content of the communication (evaluation) and its metadata.

1. Information that you send to AGONI LINE FERTILIZED when you activate through your personal account one of the Platform’s artificial intelligence tools (AI Tools), such as Face Recognition, Speech to Text, Immersive Reader and Text Analytics. This information may include the name, email address, a photograph of your face, your voice, and the content of the communication and its metadata.

1. Information that you send to AGONI GRAMMI GONIMI when you communicate with it through the contact form provided by the Platform. This information includes the name, email address, telephone, as well as the content of the communication and its metadata.  

1. Information you provide to AGONI GRAMMI GONIMI or the Partner about the Platform in any other way (by phone or via email). This information may include the name, email adress, telephone, as well as the content of the communication and its metadata.  

1. Information about your computer, mobile phone or other device, including IP address, geolocation, browser type and version, and operating system.

1. Information related to the visits and use of the Websites, including the external source, the duration of the visit, the display of pages and the navigation path to the Websites. 

1. Any other personal information you provide or send in any way to AGONI GRAMMI GONIMI. 

In case you provide as a PWDs user to AGONI GRAMMI GONIMI personal information regarding health, by any way or means of communication, you explicitly declare that you provide them in the context of your Agreement with AGONI GRAMMI GONIMI for the provision of the Platform’s services and that you accept and agree to their processing, in accordance with the Privacy Policy which is part of the Agreement. 

• USE OF PERSONAL INFORMATION

AGONI GRAMMI GONIMI uses your personal information for the following purposes:

1. For the creation of your personal account on the Platform.

1. To provide you with the Platform’s services in the context of the execution of the Agreement, including the easy search and finding of points of interest that you add to the lists of favorite places and the presentation of personalized proposals based on your personal needs.

1. To assess the validity of the information provided by AGONI GRAMMI GONIMI through the Platform or otherwise, to confirm the suitability of the points of interest which AGONI GRAMMI GONIMI proposes through the Platform and for the constant updating and enrichment of the information contained in the Platform. 

1. To provide assistance and guidance on the Platform and its use.

1. To contact you regarding any issue regarding the Platform and to answer to any questions, queries and complaints.

1. For your information regarding any Platform changes or significant changes to the Privacy Policy and Terms of Use, as well as for sending communications required by law.  

1. To improve your interaction with the Platform. 

1. For the provision of information material / newsletter from AGONI GRAMMI GONIMI, to the extent that you make this choice during the creation of your personal account or later. Please note that you can choose to stop receiving the above information material/newsletter at any time.

1. To send you requests to participate in surveys or other programs related to the Platform, as well as to conduct the relevant surveys or programs. Please note that these will not include information/promotional material. In case they do, requests will only be sent to you if you made the relevant choice when creating your personal account or later, which you can always revoke.  

1. For the exercise by AGONI GRAMMI GONIMI or the Partner of any of their legal rights, their compliance with any legal obligation or court decision or other request of a state body and their protection from third parties’ claims.

1. For the purposes of the Platform, i.e. for the development and improvement of the Platform, the collection, analysis and provision of data on the Websites’ use (in an anonymous form) to third parties, the analysis of other data, the conduct of audits, the protection of the Websites and personal accounts against fraud and other illegal activities, the protection of the integrity and security of the Websites and your connection to them, the service of your connection to the Websites, the resolution of Platform’s problems and the development of new services. For these purposes, AGONI GRAMMI GONIMI may make your personal information anonymous and / or combine it with other information.   

AGONI GRAMMI GONIMI indicates that PWDs users’ personal information regarding health, will be used only for those of the above purposes which are related to the conclusion and execution of the Agreement.

• LEGAL BASIS OF PROCESSING

AGONI GRAMMI GONIMI processes personal information based on:

1. The Contract that you enter into with AGONI GRAMMI GONIMI for the free provision of the Platform’s services. AGONI GRAMMI GONIMI will always inform you as to what personal information must be submitted for the creation of your personal account on the Platform and the provision of its services. In the event that you do not wish your personal information to be processed in accordance with the Privacy Policy, please do not create a personal account on the Platform.
2. The legal interest of AGONI GRAMMI GONIMI. AGONI GRAMMI GONIMI collects your personal information in the context of the services it provides you through the Platform for purposes expected in connection with these services and legitimate without substantially affecting your rights, freedom or interests.
3. Your explicit consent in relation to any issue that requires consent (e.g., sending of the information material/newsletter) or when the processing is not based on the above categories. 

• DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

AGONI GRAMMI GONIMI is committed to keeping your personal information secure and confidential. It does not share your personal information with third parties unless it is absolutely necessary. More specifically, disclosure can take place:

1. From AGONI GRAMMI GONIMI to the Partner in the context of the Platform management. ATCOM S.A. is contractually committed to implement appropriate technical and organizational measures for the protection of your personal information and to comply with the requirements of the General Data Protection Regulation.

1. From AGONI GRAMMI GONIMI and/or the Partner to third parties for the provision of services, such as hosting, management, maintenance and storage of the Platform data, email distribution, research and analysis, management of actions, services and data, provided that third parties commit to implement appropriate technical and organizational measures for the protection of your personal information and to comply with the requirements of the General Data Protection Regulation. 

1. From AGONI GRAMMI GONIMI and/or the Partner to third parties for their compliance with any legal obligation or court decision or other state body request, or the exercise of any legal right or for their protection from third parties’ claims. 

1. From AGONI GRAMMI GONIMI to third parties to which you have requested/given explicit consent to disclose your personal information. 

In any case, the employees of AGONI GRAMMI GONIMI and of the Partner have access to your personal information in both cases to the extent that this is necessary for the fulfillment of the purposes mentioned above and under the condition of confidentiality. 

• TRANSFER OF PERSONAL INFORMATION TO COUNTRIES OUTSIDE THE EU AND EEA

AGONI GRAMMI GONIMI does not transfer your personal information outside the European Union or the European Economic Area. However, some third parties to whom your personal information is disclosed may be located in countries other than the one in which they were collected, and which do not provide the same level of protection as the country of collection.  In this case, AGONI GRAMMI GONIMI will ensure that your personal information is protected in accordance with the applicable law and the processing will be done in accordance with the Privacy Policy.   

• YOUR RIGHTS

• You have the right to receive information on whether AGONI GRAMMI GONIMI processes your personal information, what personal information it processes, the purposes of processing, the recipients of your personal information, the retention periof, the making of automated decisions based on them, as well as for your rights (right of access). 

• You have the right to request from AGONI GRAMMI GORIMI to correct, supplement or update any personal information that AGONI GRAMMI GONIMI processes (right of rectification). 

• You have the right to ask AGONI GRAMMI GONIMI to erase any of your personal information to the extent that it is not necessary for the processing purposes described above or is not among those required to create and maintain your personal account. You also have the right to delete your personal account, revoking your consent to the processing of your personal information by AGONI GRAMMI GONIMI whenever you wish, in which case your personal information will be erased from the Platform, unless otherwise specified in the Privacy Policy (right to erasure).

• You have the right to receive the personal information you provided to AGONI GRAMMI GONIMI in a readable format, as well as to transfer it or to ask AGONI GRAMMI GONIMI to transfer it to another data controller (right to data portability). 

1. You have the right to ask AGONI GRAMMI GONIMI to restrict the processing of your personal information until your objections to this processing are considered (right to restriction of processing).

1. You have the right to object to the processing of your personal data, in which case AGONI GRAMMI GONIMI will terminate the processing in question, unless it proceeds to it for legal and compelling reasons. This right includes the termination of the processing of your personal information for the purpose of sending the information material/newsletter (right to object).

1. You can exercise your rights under the Privacy Policy and the General Data Protection Regulation by sending a message to the email address mentioned in the "Contact" section below. Please state explicitly in the message subject that this is a request related to the exercise of a right. AGONI GRAMMI GONIMI will respond immediately and in any case within the legal deadlines. The exercise of the above rights does not affect the lawfulness of the processing of your personal information up to that time and has no retrospective effect. 

1. You also have the right to file a complaint to the competent supervisory authority if you consider that the processing of your personal information by AGONI GRAMMI GONIMI violates the applicable legislation. The competent authority is the Hellenic Data Protection Authority (1-3 Kifissias Avenue, Ampelokipi, www.dpa.gr).

• GENERAL TERMS

1. To the extent that you provide third party’s personal information, you explicitly declare that: 

• This third party has authorized you to enter into the Agreement on his behalf.

• You have obtained the third party’s explicit consent to submit the personal information required for entering into the Agreement or, where consent is not the legal basis for the processing, you have informed the third party on the processing in accordance with the Privacy Policy. 

• The third party explicitly agrees to the processing of its personal information in accordance with the Privacy Policy. 

1. AGONI GRAMMI GONIMI will retain your personal information for as long as it takes to fulfill the processing purposes listed above, except from your personal information that AGONI GRAMMI GONIMI must retain for a longer time period in order to comply with the applicable legislation, in which case your personal information will be deleted as soon as this period has elapsed. This period may be extended to protect the legal interest of AGONI GRAMMI GONIMI. In any case, it will keep your personal information as long as you keep your personal account active. In case you have registered as a PWDs user your personal health information will be deleted as soon as you delete your personal account. At the end of the retention period, your personal information will be erased or anonymized, to the extent that the information is used for statistical analysis. The information collected by the Platform’s AI tools, in case you have activated one or some of them [e.g., Face Recognition, Speech to Text, Immersive Reader and Text Analytics], as well as cookies used for the paired devices, will be deleted from the databases of AGONI GRAMMI GONIMI as soon as you deactivate them or as soon as you delete the personal account through which you activated them.

1. AGONI GRAMMI GONIMI has taken appropriate technical and organizational measures to protect your personal information from improper or illegal processing or accidental destruction and loss, as well as to ensure a level of protection that meets the requirements of applicable legislation. In addition, you can access the Platform using the password you selected when creating your personal account, which is encrypted. It is your responsibility to keep your password secure and confidential. AGONI GRAMMI GONIMI recommends that you create a strong password and change it regularly. 

1. In relation to your personal health information, AGONI GRAMMI GONIMI pays special attention to take effective measures for their protection and to review them whenever necessary, in order to maintain a high level of compliance with the requirements of the applicable legislation. In any case, it will show due care in relation to their disclosure to third parties, which in any case will only take place if necessary, in order to safeguard your interests to the maximum extent. 

1. It is noted that the Platform is not intended for minors and AGONI GRAMMI GONIMI has no intention of processing personal information of minors. In case a minor user registers in the Platform, AGONI GRAMMI GONIMI will delete the relevant information as soon as it becomes aware of it. 

• CONTACT

You can contact AGONI GRAMMI GONIMI for questions or complaints regarding the Privacy Policy, the way AGONI GRAMMI GONIMI processes your personal information or any other issue regarding the security of your personal account and your access to the Platform, by email to info@extramilers.eu, as well as by phone at +30 213 088 636. 

• HYPERLINKS TO OTHER WEBSITES

Websites may include hyperlinks to third parties’ websites. AGONI GRAMMI GONIMI is not responsible for processing of your personal data by third parties and urges you to refer to any updates/privacy policies of these third parties to be informed about the processing of personal data by them.

1. POLICY AMENDMENTS

This Privacy Policy was drafted on July 24, 2020. AGONI GRAMMI GONIMI reserves the right to update or amend the Privacy Policy from time to time by publishing the latest version on the Websites. Please do check them periodically to be informed of any amendment. AGONI GRAMMI GONIMI will notify you in the event of substantial amendments to the Privacy Policy.