Thank you for your interest in the platform ExtraMilers, which has been developed for the provision of information and the promotion of accessible tourism on Greek islands (“Platform”). Because of the nature of the Platform and the personal information that you are invited to submit thereto and, as it is our intention that the Platform becomes a useful tool and provides a safe and functional environment for its users, it is important that you receive accurate information about the way that your personal information will be treated and that you are convinced that they will remain secure with us.
The Platform is developed by the societe anonyme with the name “ATCOM INTERNET & MULTIMEDIA S.A.” (“Partner”), which acts as the processor pursuant to the definitions of the Gerenal Data Protection Regulation for, on behalf and according to the instructions of AGONI GRAMMI GONIMI in relation to the administration of the Web Sites.
- COLLECTION OF PERSONAL INFORMATION
AGONI GRAMMI GONIMI collects the following types of personal information:
- Information abour points of interest that you introduce in the lists of favourite places that you create in the Platform.
- Information that you send to AGONI GRAMMI GONIMI when you provide feedback about points of interest shown on the Platform. This information might include your name, email address, telephone, the content of your communication (evaluation), as well as the medatata of such communication.
- Information that you send to AGONI GRAMMI GONIMI when you suggest new points of interest to be added to the Platform. This information might include your name, email address, telephone, the content of your communication (evaluation), as well as the medatata of such communication.
- Information that you send to AGONI GRAMMI GONIMI when you communicate with it through the communication form of the Platform. This information includes your name, email address, telephone, the content of your communication, as well as the medatata of such communication.
- Information that you otherwise provide to AGONI GRAMMI GONIMI or the Partner in relation to the Platform (usually, by telephone or email). This information might include your name, email address, telephone, the content of your communication, as well as the medatata of such communication.
- Information about your computer, mobile phone or other device, including your IP address, geographical location, type and version of your browser and operating system.
- Information about your visits and use of the Web Sites, including the external sources, the length of the visit, the page views and navigation path over the Web Sites.
- Any other personal information that you otherwise provide or send to AGONI GRAMMI GONIMI.
- USE OF PERSONAL INFORMATION
AGONI GRAMMI GONIMI uses your personal information for the following purposes:
- To create your personal account in the Platform.
- To provide you with the services of the Platform in the context of the performance of the Agreement, including finding more easily the points of interest that you introduced in the lists of favourite places and presenting personalised recommendations on the basis of your personal needs.
- To evaluate the accuracy of the information that AGONI GRAMMI GONIMI provides through the Platform or otherwise, to confirm the suitability of the points of interest that AGONI GRAMMI GONIMI suggests through the Platform and to constantly update and inform the information contained in the Platform.
- To provide support and instructions in relation to the Platform and its use.
- To communicate with you in relation to any issue related to the Platform and to answer any questions or complaints.
- To improve your interaction with the Platform.
- To send newsletters to you, to the extent that you made this choice when creating your personal account or afterwards. Please note that you can select to stop receiving newsletters at any time.
- To request your participation in surveys or other programmes related to the Platform and administer such surveys or programmes. Please note that such communications will not include any information or marketing material. In case they do, such requests will be sent to you only to the extent that you have made the relevant choice, which you can always revoke.
- For the exercise of any legal rights, the compliance with any legal obligations or judicial decisions or other state requests and the protection against third-party claims.
- For the purposes of the Platform, namely the development and improvement of the Platform, the collection, analysis and provision to third parties (in an anonymous form) of usage data regarding the Web Sites, the analysis of other data, the performance of audits, the protection of the Web Sites and personal accounts from frauds or other illegal activities, the protection of the integrity and security of the Web Sites and your connection to them, the support of your connection to the Web Sites, resolving Platform problems and the development of new services. For these purposes, AGONI GRAMMI GONIMI may de-identify and/or aggregate with other information, your Personal Information.
AGONI GRAMMI GONIMI would like to highlight that personal information relating to health will be used for those of the above purposes only that are relevant to the conclusion and performance of the Agreement.
- LEGAL BASIS FOR PROCESSING
AGONI GRAMMI GONIMI processes any personal information on the basis of:
- The legitimate interests of AGONI GRAMMI GONIMI. AGONI GRAMMI GONIMI collects your personal information in the context of the services that provides to you through the Platform in an expected for the purposes of the aforementioned services and legitimate way without affecting significantly your rights, freedom or interests.
- Your explicit consent in relation to any issue for which your consent is required (e.g. dispatch of the newsletter) or when the processing is not based on the above categories.
- DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
AGONI GRAMMI GONIMI undertakes to keep your personal information safe and confidential. It does not share your personal information with third parties, except to the extent that this is absolutely necessary. More specifically, your personal information may be disclosed as follows:
- From AGONI GRAMMI GONIMI to the Partner in the context of the administration of the Platform. ATCOM is contractually bound to apply appropriate measures of a technical and organizational nature for the protection of your personal information and to comply with the requirements of the General Data Protection Regulation.
- From AGONI GRAMMI GONIMI and/or the Partner to third parties for the provision of services, such as hosting, administration, maintenance or storage of data of the Platform, email dispatch, research and analysis, administration of actions, services and data, provided that the third parties are bound to apply appropriate measures of a technical and organizational nature for the protection of your personal information and to comply with the requirements of the General Data Protection Regulation.
- From AGONI GRAMMI GONIMI and/or the Partner to third parties for their compliance with any legal obligations or any judicial decisions or other state requests or the exercise of any legal rights or the protection against third-party claims.
- From AGONI GRAMMI GONIMI to third parties to which you have asked, or consented to, the disclosure of your personal information.
In any event, the employees of AGONI GRAMMI GONIMI and the Partner have access to your personal information, in both cases on a need to know basis and subject to confidentiality undertakings.
- TRANSFER OF YOUR PERSONAL INFORMATION OUTSIDE THE EU OR THE EEA
- YOUR RIGHTS
- You have the right to receive information about the processing of your personal information by AGONI GRAMMI GONIMI, the personal information that is processed, the processing purposes, the recipients of your personal information, the retention period, the existence of automated decision-making, as well as your rights (right of access).
- You have the right to request the rectification or completion or update of your personal information processed by AGONI GRAMMI GONIMI (right to rectification).
- You have the right to receive the personal information that you provided to AGONI GRAMMI GONIMI in a readable format, and to transmit or request from AGONI GRAMMI GONIMI to transmit such information to another data controller (right to data portability).
- You have the right to request from AGONI GRAMMI GONIMI to restrict the processing of your personal information until any objections of yours to said processing are reviewed (right to restriction of processing).
- You have the right to object to the processing of your personal information, in which case AGONI GRAMMI GONIMI will stop said processing, unless it undertakes such processing for legitimate and imperative reasons. It is in the context of this right that you may object to the processing of your personal information for the purpose of the dispatch of the newsletter (right to object).
- You also reserve the right to lodge a complaint with any competent supervisory authority if you believe that the processing of your personal information by AGONI GRAMMI GONIMI breaches the applicable legislation. The competent supervisory authority is the Greek Data Protection Authority (Kifisias Avenue 1-3, Ampelokipoi, www.dpa.gr).
- GENERAL TERMS
- To the extent that you provide personal information of a third person, you represent and warrant that:
- You are authorized by such third person to conclude the Agreement on behalf of him/her.
- AGONI GRAMMI GONIMI will retain your personal information for as long as needed in order to fulfil the processing purposes described above, except for perosnal information that AGONI GRAMMI GONIMI is obligated to retain for a longer period of time in order to comply with the applicable legislation, in which case your personal information will be deleted when this period expires. This period may be extended if necessary for the purpose of safeguarding the legitimate interests of AGONI GRAMMI GONIMI. In any event, it will retain your personal information throughout the period that you keep your personal account active. Your personal information relating to health will be deleted as soon as you delete your personal account. After the expiry of the retention period, your personal information will be deleted or anonymised to the extent that they might be used for statistical analysis purposes.
- AGONI GRAMMI GONIMI has put in place appropriate measures of a technical and organisational nature for the protection of your personal information from unauthorized or unlawful use and accidental loss or damage and to provide a level of data protection that meets the requirements of applicable law. Access to the Platform is possible with the use of a password that is encrypted. It is your obligation to keep the password secure and secret. AGONI GRAMMI GONIMI suggests that you create a strong password and that you periodically change it.
- In relation to personal information relating to health, AGONI GRAMMI GONIMI attaches significant importance to the adoption of measures relating to the protection of such information and to the revision of such measures whenever needed, its purpose being to maintain a high level of compliance with the requirements of the applicable legislation. In any event, it will demonstrate due diligence in relation to their disclosure to third parties, which will anyway take place only if neccesary, in order to safeguard your interests to the fullest.
- It should be also noted that the Platform is not addressed to minors. AGONI GRAMMI GONIMI does not intend to process any personal information of minors. In case a personal account is created by a minor, AGONI GRAMMI GONIMI will delete the personal information submitted as soon as it realizes such registration.
- HYPERLINKS TO THIRD PARTY SITES
It is likely that the Web Sites contain hyperlinks to third party sites. AGONI GRAMMI GONIMI does not bear any responsibility for the way any third parties process your personal information and urges you to review the privacy policies of such third party sites.