Information regarding the processing of your personal data

Privacy Policy

Introduction

The use of the "Discover Greece Audio Guides" Platform [hereinafter the "Platform"] provided through our website "https://audio.discovergreece.com" [hereinafter the "Website"] and through the corresponding application available through Google Play Store or App Store [hereinafter the"Application"] is subject to the TERMS & CONDITIONS OF LICENSE & PROVISION OF SERVICES (link) and this PRIVACY POLICY ("Privacy Policy").

By using our Platform and our services, you unconditionally declare that you have reviewed, understood and accepted all the terms included in the Terms & Conditions of License & Provision of Services and this Privacy Policy. If you do not agree with any of the terms contained in the Terms & Conditions of License & Provision of Services and/or the Privacy Policy, you must refrain from visiting and using the Platform and its services.

The Privacy Policy may be subject to amendments and adjustments, from time to time, whenever deemed necessary and without prior notice to you, which will apply from the date they are published on the Platform. We therefore recommend that you review the Privacy Policy regularly.

The Privacy Policy describes how our Company, as "Controller" according to the definitions of the applicable legislation on the protection of personal data [General Data Protection Regulation (EU) 2016/679 or simply "GDPR", Law 4624/2019], collects and processes personal data and other information about you, the users of our Platform, Website and services, as well as how our Website and our Platform use cookies and any other identification technologies.

Company Details

The full details of our Company, which acts as a Controller of your personal data, are as follows:

Name: MARKETING GREECE ANONIMI ETAIRIA PROOTHISIS KAI ANAPTIKSIS TOY TOYRISMOY

Registered Seat/Postal Address: Athens (20 Voukourestiou Street, PC 106 71)

VAT number: 800486464

GEMI Number: 125083101000

Contact Phone: +306977086471

Email: support@discovergreece.com

Scope & Purpose of the Privacy Policy

The Company is committed to safeguarding the confidentiality of your personal data. The Privacy Policy is intended to help you understand, among other things, the following:

- the purpose for which we process your personal data,

- the categories of your personal data that we collect and process,

- the retention period of your personal data,

- the categories of recipients of your personal data, if any,

- if we transfer such data to a country outside the European Union (EU)/European Economic Area (EEA);

- if we make automated decision-making or profiling, and

- the rights you have in relation to the processing of your personal data, as well as how you can exercise them.

The Privacy Policy is categorized into the following distinct sections/chapters for your convenience:

1. When and why do we collect and process your personal data?

2. Which categories of your personal data are processed in each case?

3. What are the legal bases for the processing of your personal data?

4. How long do we keep your personal data?

5. To whom do we disclose and/or transfer your personal data?

6. How do we ensure of the security of your data?

7. What rights do you have in relation to your personal data?

8. Links to Third- Party Websites

9. How can you contact us?

10. When does this Privacy Policy apply?

1. When and why do we collect and process your personal data?

1.1. Simple browsing of the Website: Our Company does not collect any of your personal data during your simple browsing of our Website, unless you have consented to the use of specific categories of cookies in accordance with the Cookies Policy of our Company, in which case we process the data collected through such cookies.

1.2. Communication: When you contact us directly for any reason (e.g. through our Website, the Platform, or based on any other contact details of use), we process certain categories of your personal data to respond to our communication.

1.3. Creating a Personal Account: For registration on the Platform, you are given the option to create a personal electronic account, through which you gain access to certain services (hereinafter referred to as "Personal Account” or ”User Account”). If you create a Personal Account, we will process certain categories of your personal data to complete and manage your registration.

1.4. Subscription to Newsletter: Users who wish to be informed about the news and articles of our Website can subscribe through the Website to our newsletter. When you subscribe to the list of recipients of our newsletter, we process specific categories of your personal data in order to provide you with the relevant material.

1.5. Services: When we provide you with our services, we process specific categories of your personal data in order to respond to the contractual / transcactional relationship between us.

2. Which categories of your personal data are processed in each case?

2.1 "Personal data"/"personal data" means data relating to you as an identified or identifiable natural person, i.e. a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name.

2.2 Data we collect directly from you: The personal data we process is provided to us directly by you. Especially:

2.2.1. Simple browsing of the Website: During your simple browsing on our Website you do not provide us with your personal data, as no personal data is collected or processed during such activity in accordance with clause 1.1. above, unless you have consented to the use of certain categories of cookies in accordance with our Company's Cookies Policy so that we will process the data collected through such cookies.

2.2.2. Communication: When you contact us as detailed in clause 1.2. above, we collect and process certain categories of your personal data for communication purposes, such as to respond to your queries or requests for information. In particular, during our communication in any way (e.g. via email, through any available contact form) we collect and process the information you provide to us directly, and may include: your name, your email address, your telephone number, and the message you address to us. We will use this information to contact us and respond to your query and/or request.

2.2.3. Create a Personal Account: To register as a user on the Platform and create a Personal Account in accordance with clause 1.3. herein, we collect and process the following personal data: your email and password for user authentication purposes and to access your personal account. If you wish to register your full name, we will also collect this data. In addition, for as long as you keep your Personal Account active and use it, we process further information about its content and the actions you perform through it (e.g. information about the digital material you use, log-in and log-out time from the Personal Account, information about any request you make for Personal Account password recovery, the content of your Personal Account).

2.2.4. Subscription to Newsletter: When you subscribe to our newsletter, by completing the relevant form on the Website in accordance with clause 1.4 above, we collect and process your e-mail address in order to be able to send you the relevant material.

2.2.5. Services: When we provide you with our services through the Platform, we process specific categories of your personal data, such as: your identification data (name), contact details (email address, telephone number), information about the contract between us, the services you have ordered, information about the pricing of the services provided (e.g. user subscription details on specific content of the Platform. We may also process data related to your location when using the Platform, if you provide us with your consent (e.g. when you ask us to show you the nearest tourist attractions or when you plan guided tour activities through the Platform).

2.3. Data collected using cookies and other tracking technologies: We also use cookies and collect information about how you use the Website, technical information, including information about access time, volume of data transmitted, status of transmission, browser type, version and language, browser plug-in type and version, IP address, operating system and system interface, time zone and location setting, and information such as the referral website, pages you visit, actions you take, patterns of visits and navigation on a website.

Please see in detail the Cookies Policy of our Website, which is available here. The Cookies Policy is an integral part of this Policy and also governs the use of the Website and the Platform.

2.4. Data collected by third parties: We receive some of the above-mentioned technical data, concerning your device details (e.g. manufacturer, model, display characteristics, operating system, etc.), or behavioral data (e.g. clicks, choices), from analytics providers such as Google.

2.5. Anonymized – statistical data: We may process anonymized and statistical data for any purpose, in particular for statistical purposes and for improving the services – information provided on the Website. Although this data may be derived from your personal data, it is not considered personal data as long as it does not directly or indirectly reveal your identity (for example, we may collect anonymous, statistical data on website usage in order to calculate the percentage of users who have access to certain elements of the Website).

3. What are the legal bases for the processing your personal data?

3.1. We process your personal data when the law permits us to do so, that is, when there is a legal basis, in accordance with the applicable legislation, such as in the following cases:

3.2. Performance of Contract: processing is necessary for the performance of a contract between us in accordance with case (b) of para. 1 of Art. 6 GDPR, as in the case of executing your orders through the Platform and providing the Services in accordance with clause 1.5 and 2.2.5 above. Also, according to case (b) of para. 1 of Art. 6 GDPR, processing is necessary to take steps at your request prior to entering into a contract, such as when you ask for information or a price offer regarding paid services/subscriptions of the Platform.

3.3. Consent: You have provided your consent in accordance with case (a) of para. 1 of Art. 6 GDPR, to process your personal data for one or more specific purposes such as: when you communicate directly with us through our Website or Platform or by any other means under terms 1.2., 2.2.2. above, when you create a Personal Account on the Website in accordance with clauses 1.3., 2.2.3. above, when you subscribe to our newsletter under terms 1.4., 2.2.4. above, when you consent to the processing of your location data during the provision of services, as well as to the installation and use of specific, optional types of cookies (see more details Cookies Policy).

3.4. Legal Obligation: The processing of your personal data is necessary to meet our legal obligations in accordance with case (c) of para. 1 of Art. 6 GDPR, e.g. in case we are requested by a competent judicial authority to access your personal data, or when we provide you with paid services through the Platform and we need to meet the requirements of tax law (e.g. processing necessary data for the issuance of the tax document required by law).

3.5. Legitimate Interests of our Company: The processing is necessary for the purposes of legitimate interests pursued by our Company, provided that your fundamental rights do not outweigh those interests, in accordance with case (f) of para. 1 of Art. 6 GDPR. Such legitimate interests include: (a) controlling the effective and safe operation of our Website, as well as securing it from malicious actions, (b) optimizing our Website, (c) monitoring its operation.

3.6. Please note that we do not use automated decision-making without human intervention, including profiling, in a way that produces legal consequences concerning you or otherwise materially affects you.

4. How long do we keep your personal data?

4.1. In general, we retain your personal data for as long as necessary by law, depending on the purpose and type of processing.

4.2. In particular, your personal data will be retained for as long as it is necessary to achieve the purposes for which we collect it, e.g. for as long as necessary to provide you with features of our Website and Platform and the services requested. Once the purpose for which data processing is achieved, we will either delete your personal data or anonymize your personal data, unless there are legal grounds for retaining it. Especially:

- We retain your personal data that we collect from you when you communicate and/or interact with us through our Website or any other available means of communication for the necessary period of time until the final resolution of the relevant issue for which you have contacted us (e.g. submission of a request or query), and until any related claims are barred.

- We retain your personal data that we collect from you when you subscribe to the Personal Account or the Newsletter, for as long as you remain subscribed and we delete them in case you withdraw your consent and request that your Personal Account be deleted and you are unsubscribed as a member of the recipient list of our Newsletter.

- We retain your personal data that we collect from you when you contract with us for as long as the contractual relationship between us lasts, as well as for the maximum time required from its expiration to meet our legal obligations under the legislation governing our Company's activity (e.g. keeping tax documents) and until any related claims are time-barred.

4.4. Regarding cookie retention times/duration, please refer to our Cookies Policy, available and here.

5. To whom do we disclose and/or transmit your personal data?

5.1. Service Providers: Our Company may appoint external/third party service providers (e.g. internet service providers, providers of advertising services, technical support of the Website and the Platform, email, data hosting), who will provide us with support services and who may process certain categories of your personal data in the course of providing the services acting as "Processors" in accordance with the applicable legislation on the protection of personal data. Our Company ensures that third party service providers are contractually bound to protect your personal data in accordance with applicable law.

5.2. Other recipients: Our Company may disclose, in compliance with the applicable legislation on the protection of personal data, your personal data to judicial and/or prosecuting authorities, independent authorities, government authorities, if required by applicable law.

5.3. Data transfers outside the European Union/European Economic Area: If, to the extent, within the scope and for the needs of the aforementioned purposes, your personal data needs to be transferred outside the European Union, the transfer of such data will take place in accordance with the applicable legislation and our Company will ensure an adequate level of data protection. Through the conclusion of appropriate contracts for the transfer of data based on Model Contractual Clauses, which are accessible to you upon your request at support@discovergreece.comor by taking other measures to provide an adequate level of data protection, our Company ensures or confirms that the recipients provide an adequate level of protection of your personal data.

6. How do we take care of the security of your data?

Taking into account the latest developments, the cost of implementation and the nature, scope, context and purposes of processing, as well as the risks of varying probability and severity for the rights and freedoms of natural persons from processing, we implement appropriate technical and organizational measures to ensure a level of security commensurate with the risks of processing.

7. What rights do you have in relation to your personal data?

Under the conditions provided for in the applicable legislation, you have the following rights regarding your personal data:

7.1. Right of access: You can contact us in order to inform you and explain if and what personal data we hold about you, as well as how we process it. You may also request a copy of your personal data, if they are processed.

7.2. Right to rectification: If you believe that your data is inaccurate or needs to be updated, you have the right to demand that inaccurate personal data be corrected and that incomplete information be completed.

7.3. Right to erasure: Under certain conditions, e.g. when the data is no longer needed, you have withdrawn your consent, the data has been unlawfully processed, you can ask us to delete it.

7.4. Right to restriction of processing: If you consider that your data is inaccurate or its processing is unlawful or you consider that the data is no longer needed by us or you have objections to automated processing, you have the right to demand the restriction of processing.

7.5. Right to object: You may object to the processing of your personal data by us on grounds relating to you and relating to your particular situation, unless, inter alia, there are compelling legitimate grounds for the processing, which override your interests, rights and freedoms. You also have the right to object when a decision concerning you is based solely on automated processing, including profiling, and this decision produces legal effects or significantly affects you (statutory exceptions apply).

7.6. Right to data portability: You may request to receive your data in a structured, commonly used and machine-readable format, as well as to transmit your data to another organization (controller), which you will indicate to us.

7.7. Right to withdraw consent: If the processing of your personal data is based on your consent (e.g. in the case of subscribing to our newsletter or in the case of creating a Personal Account), you have the right to revoke it at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out before such withdrawal.

7.8. Right of Appeal: We inform you that you have the right to appeal to the Hellenic Data Protection Authority (HDPA) for issues relating to the processing of your personal data. The Hellenic Data Protection Authority is based in Athens (Kifisias 1-3, PC 115 23). Regarding the competence of the Hellenic Data Protection Authority and how to submit a complaint, you can visit the website of the Hellenic Data Protection Authority (www.dpa.gr).

7.9. Exercise of Rights: In order to exercise your rights you can contact us in writing via email or at our postal address.

8. Links to Third Party Websites

The Website (and/or the Platform) may include links to other websites, platforms and/or applications that we do not control (hereinafter referred to as "Third- Party Sites"). The Privacy Policy does not cover information collected by Third Party Websites that you visit through links that may be on the Website. The aforementioned Third Party Sites have their own Privacy policies and terms and conditions of use. We encourage you to read them before navigating and/or using these Third-Party Sites.