GDPR Privacy Notice - Greeka.com
General Data Protection Regulation (GDPR), Article 13 and 14 of Regulation EU 2016/679.
www.greeka.com is a product of GREEKA Ltd.
What is the purpose of this notice?
This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing by GREEKA Ltd. when using this website.
This document has been designed using the guidance procedures provided by the Information Commissioner Office (ICO) and in relation to the statutory requirements with regards to our obligations to the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).
Who is the Data Controller for personal data?
GREEKA is the Data Controller as it collects personal data directly from a Data Subject. In these circumstances GREEKA will be acting under a ‘Legitimate Interest’ to legally process the data for the management of travel for the Data Subject and to fulfil the Service provided. GREEKA also acts as a Data Controller for any personal data held regarding its own employees, and legally processes this data under its Contract of Employment with those Data Subjects.
What personal data does GREEKA collect?
In the course of providing its Services, GREEKA collects, uses, and discloses personal data. Personal data is any information that can be used to identify you or that we can link to you. You, as a traveler or user of the Services, may be asked to provide certain personal data when you use our Services. The provision of personal information is voluntary but mandatory in order for us to fulfil the service. Depending on our websites and services, we might collect personal data, such as:
- Names, contact and personal information of the travelers or person making an online travel booking (work and home/mobile phone, email, address, gender, Age);
- Traveler bookings details: ferry companies, ferry names, dates and hours of departures, arrivals, tickets prices, accommodation types chosen, car rental type, accommodation type, hotel or accommodation name, location of holiday, car rental type);
- Travel documentation (e.g. passport/visa/drivers license number, expiration dates, citizenship, date of birth, place of birth, gender, vehicle licence plate);
- Payment data (corporate/personal credit cards) and bank information; and
- Logins, user IDs, employee IDs, passwords, IP addresses, and browsing information.
- Other personal data supplied by you via email/contact forms, affiliations requests, Job requests, Curriculum Vitae and by registering to our communities.
How does GREEKA collect personal data?
GREEKA collects personal data:
- Directly from you when you access various parts of our Websites and Services, including when you communicate with us via email or other channels;
- From other sources, for instance the company which you are an employee of or are otherwise traveling on behalf of (“Company”), including such Company’s third parties who may send us your personal data on your or your Company’s behalf; and
- From the network of websites accessible through or utilized by our Services and our company, including third party suppliers and our GREEKA related companies, affiliates, subsidiaries, joint ventures, partners, subcontractors, and agents. This includes personal data we collect automatically through our websites, for instance by using cookies and similar technologies.
How does GREEKA use personal data?
GREEKA limits the use of personal information to the purposes identified in this Policy and for which the individual has provided implicit or explicit consent. We retain personal information for only as long as it is necessary to fulfill the stated purposes, except with the consent of the individual or as required by law.
GREEKA uses personal data to:
- Provide its Travel Services and fulfill its obligations to travellers or companies representing the travellers (e.g. complete and administer travel reservations, assist in managing the travel, provide reporting, provide notices about your account and the Services, inform you of updates to our websites and applications and other changes to our products or Services).
- Communicate with you, for instance by email, post, and phone or via GREEKA’s websites and to provide you with customer service.
- Understand how our websites are used and provide a customized experience as you use our Services, such as by providing interactive or personalized elements on our Services and providing you with content based on your interests (see our “Cookies” policy https://www.greeka.com/cookies-policy.htm for more information).
- Fulfill a request made by you or your Company (e.g. reporting, questions, or other requests about your personal data).
- Send you newsletters, marketing emails, and other information or materials that may interest you, as well as showing personalized advertisements. Where required, we will obtain your consent before sending such marketing messages or showing personalized advertisements.
- Carry out our obligations and enforce your, our, or other’s rights as we believe reasonably necessary (e.g. billing and collection, fraud prevention, comply with legal obligations, and respond to legal proceedings or requests from legal authorities and law enforcement or other third parties).
Who does GREEKA disclose personal data to and why?
Personal data collected is shared with or disclosed to:
- GREEKA and its related companies, affiliates, subsidiaries, joint ventures, partners, subcontractors, and agents as necessary to fulfill and support the Services, including bookings and assistance, ticket insurance, responding to requests, and assessing or offering promotions.
- Your Company for reporting, auditing, tracking and other purposes as necessary with your Company, including those of its personnel they request we send or make personal data available to.
- Third party service providers you or your Company request we send personal data to (e.g. providers who secure compensation for delayed, canceled ferries on behalf of travelers; safety and tracking information providers;).
- Third party service providers to complete travel arrangements and reservations and fulfill the Services (e.g. ferry companies, car rental agencies and other ground transportation companies, hotels, cruise lines, destination management companies, and other related travel suppliers for booking/ticketing purposes; industry reporting authorities; equipment and technology vendors, including, without limitation, online booking tool providers; visa and passport providers; credit card companies and payment collection and processing companies).
GREEKA may be acquired, merge with another business, sell, or liquidate its assets, acquire, or buy other businesses or assets. In such transactions, personal data is generally one of the transferred business assets. In the event of an acquisition, sale, liquidation, or merger, your personal data and non-personal identifying information may be automatically assigned by us in our sole discretion to a third party.
How does GREEKA store and protect personal data?
GREEKA stores personal data on its servers located in France and managed internally. Those server are PCI-DSS certified.
GREEKA uses appropriate technical and organizational security measures to protect the personal data GREEKA holds on its network and systems from unauthorized access, disclosure, destruction, and alteration. We conduct periodic reviews of our data collection, storage, processing, and security measures to verify we are only collecting, storing, and processing personal data that is required for our Services and to fulfill our contractual obligations. While we make every effort to protect the integrity and security of our network and systems, we cannot guarantee, ensure, or warrant that our security measures will prevent illegal or unauthorized activity related to your personal data. When using our Services, you should be aware that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect your personal data, we do not warrant the security of any data and information that you transmit to us over the Internet and you do so at your own risk.
In order to protect your personal data, we kindly ask you to not send us credit card information or other similar personal data to us via email. Please alert us immediately if you believe any of your personal data has been misused. Please note, we will never ask you to disclose your credit card information in an unsolicited phone call or email.
GREEKA has adopted the following principles to govern its collection and processing of Personal Data:
- Personal Data shall be processed lawfully, fairly, and in a transparent manner.
- The Personal Data collected will only be those specifically required to fulfil travel, accommodation, or other travel-related requirements. Such data may be collected directly from the Data Subject or provided to GREEKA via his /her employer. Such data will only be processed for that purpose.
- Personal Data shall only be retained for as long as it is required to fulfil contractual requirements, or to provide statistics to our Client Company.
- Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.
- The Data Subject has the right to request from GREEKA access to and rectification or erasure of their personal data, to object to or request restriction of processing concerning the data, or to the right to data portability. In each case such a request must be put in writing.
The Data Subject has the right to make a complaint directly to a supervisory authority within their own country. GREEKA Data Protection compliance is supervised by:
Moutopoulos Olivier, Operations manager
84 Knyaz Boris I Str., Sofia, Bulgaria, Zip Code 1000
- Personal Data shall only be processed based on the legal basis except where such interests are overridden by the fundamental rights and freedoms of the Data Subject which will always take precedent. If the Data Subject has provided specific additional Consent to the processing, then such consent may be withdrawn at any time (but may then result in an inability to fulfil travel requirements).
- GREEKA will not use personal data for any monitoring or profiling activity or process, and will not adopt any automated decision making processes.
How long does GREEKA keep my personal data?
What about links to third party websites and services?
Does GREEKA collect personal data of children?
GREEKA does not collect personal data directly from children. Individuals under 18 years of age should not use our Services to submit any personal data about themselves. However, if a booking includes children, we will collect their name and surname and gender as for any other traveler.
What are my rights with respect to my personal data?
As a Data Subject you have rights under the GDPR. GREEKA will always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.
You may choose what personal data (if any) you wish to provide to us. However, if you choose not to provide certain details or to provide false details, your experience with some or all of our Services may be affected.
How can I exercise my rights or make complaints?
GREEKA will strive to maintain an accurate and complete record of your personal information for the purposes identified in this Policy. If you believe your personal information may be inaccurate, you may contact us to access your personal information and take steps to verify, update, correct, erase it.
The identity and contact detail for the Data Protection Officer within GREEKA is:
Attn: Moutopoulos Olivier, Operations manager
Address: 84 Knyaz Boris I Str.
City/Zip/Country: Sofia, 1000 Bulgaria
GREEKA will respond to your requests to the email address or phone number that you have registered with us or we otherwise have on file for you or any other suitable method. Depending on your request, we may review the request with you and/or your Company to assist in resolving and responding to the request.
We will provide a response within 30 days of receiving an access request.
We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal data. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority in your country (if one exists in your country).
Personal Data: (Article 4 of the GDPR)personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing: (Article 4 of the GDPR): means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction.
Legal Basis for Processing: (Article 6 of the GDPR): At least one of these must apply whenever personal data is processed: 1. Consent: the individual has given clear consent for the processing of their personal data for a specific purpose. 2. Contract: the processing is necessary for compliance with a contract. 3. Legal obligation: the processing is necessary to comply with the law (not including contractual obligations). 4. Vital interests: the processing is necessary to protect someone’s life. 5. Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law. 6. Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Consent: the individual has given clear consent for the processing of their personal data for a specific purpose.
Contract: the processing is necessary for compliance with a contract.
Legal obligation: the processing is necessary to comply with the law (not including contractual obligations).
Vital interests: the processing is necessary to protect someone’s life.
Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.
Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Data Controller: (Article 4 of the GDPR): this means the person or company that determines the purposes and the means of processing personal data.
Data Processor: (Article 4 of the GDPR): means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.
Data Subject Rights: (Chapter 3 of the GDPR) each Data Subject has eight rights. These are:
- The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
- The right of access; this is your right to see what data is held about you by a Data Controller.
- The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
- The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
- The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
- The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
- The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
- Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.