1. About MOSKAN
1.1 We respect your privacy we are committed to protecting your personal data. This privacy notice informs you about how we look after your personal data as customer, potential customer, visitor or user of our website or/and application and provide information about your privacy rights and how the legislation protects you. We are the data controller and responsible for your personal data within the meaning of Article 24 of Regulation (EU) 2016/679 (hereinafter "GDPR") ("Data Controller").
1.2 We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO at the following contact details.
Name of legal entity: MOSKAN Brokering (trading as: "MOSKAN")
Name of DPO: Kyriakos Vigellis
Email address: firstname.lastname@example.org"
You have the right to make a complaint at any time to your country"s supervisory authority for data protection issues. In Greece this is the Hellenic Data Protection Authority, details of which can be found via the following link: www.dpa.gr. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance using the contact details above.
2. Changes to the privacy notice and your duty to inform us about changes
This version was last updated on 20 May 2019. This notice replaces all previous disclosures and notices related to the collection and general management of your personal data. We reserve the right to make changes to this notice, without prejudice to conditions mandated by law. If there are material changes to this notice or our information practices change in the future, we will notify you by posting the changes on our website. It is important that the personal data we hold about you is accurate and current. We hereby ask that you notify us in the event your personal data change during the course of your relationship with us. This notification may be made directly by you in person or by contacting the competent department, depending on the capability of the service you are using or the program in which you are participating.
3. Categories of information that we collect
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
" Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
" Contact Data includes billing address, delivery address, email address and telephone numbers.
" Financial Data includes bank account and payment card details.
" Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
" Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
" Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
" Usage Data includes information about how you use our website, products and services.
" Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
4. How we collect your information
We collect personal data about you whenever you use our services (whether services are provided directly by us or by other companies or agents acting on our behalf), when you use our website, or when you use our mobile application, in accordance with the conditions mandated by law.
5. Why we process your information
" Where we need to perform the contract we are about to enter into or have entered into with you or to take steps at your request prior to entering into a contract (Article 6(1)(b) GDPR).
" In the event processing is necessary to safeguard our legitimate interests (or those of a third party), unless overridden by your interests, fundamental rights and freedoms (Article 6(1)(f) GDPR).
In the event processing is necessary for compliance
with a legal obligation (Article 6(1)(c) GDPR).
when we have your explicit consent to do so for one or more specific purposes (Article 6(1)(a) GDPR).
We may ask you to provide consent through our website,
through our applications, by e-mail, messaging services or by telephone.
We may give you the opportunity to provide separate consent to each Data Controller.
In the event we rely on your consent as legal basis for processing your personal data, please note that you have the right to withdraw consent either entirely or partially with regard to a specific purpose at any time by contacting us through the contact details listed under par. 1 of this notice.
In the event you do not provide consent, you will not be able to receive certain information or communication. However, we reserve the right to send you information based on other legal grounds.
6. Purposes for which we will use your personal data and legal grounds for processing on which we rely
All purposes for which we process your personal data and the legal basis supporting such processing are described below.
The processing of your personal data may rely on additional legal bases. You may contact us in the event you require clarification regarding a particular purpose.
6.1 Entering into a contract and steps taken at pre-contractual stage
We process your personal data for the purpose of entering into a contract with you or to take steps at your request prior to entering into a contract, in accordance with Article 6(1)(b) GDPR in order to:
" Register you as a new customer to MOSKAN.
" Inform you of any changes made to MOSKAN terms and conditions, offers, notices, or this privacy notice.
" Process your requests (made by telephone, in writing or electronically).
6.2 Protection of legitimate interests - balancing
We process your personal data to safeguard our legitimate interests after carefully weighing them, in accordance with Article 6(1)(f) GDPR in order to:
" Pursue (judicially and extra-judicially) our claims (including the collection and recovery of money owed to us) and to defend ourselves against third-party claims (MOSKAN legitimate interest in defending and judicially pursuing its rights/claims).
" Process and manage your orders (including managing payments, fees and charges).
" Keep your information up to date (MOSKAN legitimate interest in maintaining contact with its customers and/or its partners).
" Inform you about developments related to our offers and deals by using the information provided by you at any stage of our cooperation (MOSKAN legitimate interest in satisfying customers and providing timely, updated and accurate information offers and deals).
" Learn about your preferences (MOSKAN legitimate interest in providing the best possible customer service),
" Manage, develop and promote our services (MOSKAN legitimate interest in the competitiveness and relevance of our Services),
" Use data analytics and prepare statistics and reports, including examining the manner in which you use our products and services, to improve our website, our products and services, our relationship with you and your experiences (MOSKAN legitimate interest in ongoing development of its services).
" Safeguard the security of the Internet and our systems, including troubleshooting problems and system maintenance (MOSKAN legitimate interest in the security of the Internet and its systems),
" Allow us to verify authenticity and prevent potential fraud (MOSKAN legitimate interest in protecting itself against potential harm).
We process your personal data so we can send you customized offers and information of interest to you, provided you have consented to such, in accordance with Article 6(1)(a) GDPR.
Specifically, based on your consent, we can:
" Customize the information and offers we send you about our services to each of you based on your interests and preferences,
" Undertake direct promotional and marketing campaigns to grow our business and to refocus our marketing strategy,
" Request your participation in surveys and completion of questionnaires and to process such information,
" Deliver relevant website content and advertisements to you.
6.4 Compliance with legal obligation
We also process your personal data to ensure
compliance with obligations established by law (e.g. taxes) and within the
framework of our cooperation with various national and international
authorities, in accordance with Article 6(1)(c) GDPR.
7. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
8. Third Party Links
Our website may include links to third-party websites, microsites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. Therefore, whenever you make use of these links or microsites or when you leave our website, please read the privacy notice of the third party.
9. Cookies, Web beacons and other similar technologies
Our Website does not use "cookie" and "web beacon" technology.
10. Mobile & Location based services
We provide mobile apps that can be downloaded to your smartphone or mobile device. These apps have a variety of functionalities that enhance the customer experience. In addition to providing services, our apps may collect personal data that will be used in accordance with this notice. We provide a link to this notice to customers prior to their downloading of any of our apps. If you allow our mobile apps to access your location information on your device, our mobile apps may use your mobile device"s Global Positioning System (GPS) technology and other technology (such as wireless transmitters known as beacons) to provide you with information and offers based on the location of your device. We may use this location information to enhance your travel experience by delivering push notifications and other content to your mobile device, providing navigation assistance as you move around our locations, and sending you information and offers about products, services, or activities we believe may be of interest to you, following your explicit consent. We may share this information with third parties, including business partners and service providers, to provide information, offers, and services that may be of interest to you. You may prevent or limit collection of location information by changing the settings in the app, or by changing your device"s settings.
11. Children"s privacy
We do not knowingly collect any information from anyone under 15 years of age. Our website, products and services are all directed to people who are at least 15 years old or older. If you are under 15, do not use or provide any information on this website or on or through any of its features / register on the website, make any purchases through the website or provide any information about yourself to us, including your name, address, telephone number or email address. If we learn that we have collected or received personal data from a child under 15 (apart from the data for reservation and ticketing purposes), we will delete that information, unless consent is given or authorised by the holder of parental responsibility over the child. If you believe we might have any information from or about a child under 15 (apart from the data for reservation and ticketing purposes), please contact us.
12. Who else may have access to your information
To best serve you, we may share your personal data with service providers that provide support services to us or that help us market our products and services. Service providers are third parties who perform services on our behalf. They are contractually restricted from using your information in any manner other than in helping us to provide you with the products and services available from MOSKAN.
In particular, we may often need to share your personal data with third parties such as airlines, airport operators, customs, agents, buyers, sellers, consultants, and various authorities involved.
We may disclose your personal data to a third party to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We may also disclose your personal data to a third party when you ask us to do so or when we believe it is required by law.
13. Countries having access to your information
Our servers, storing and keeping your information secure, are located in the European Economic Area. However, we may have a number of staff members and service providers who are located in other countries. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it, by ensuring at least one of the following safeguards is implemented:
" We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
" Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
" Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
contact us if you want further information on the specific mechanism used by us
when transferring your personal data out of the EEA.
14. Data Security
We have put in place appropriate security measures (including encryption, anonymization and/or pseudonymization procedures where required) to prevent your personal data from being accidentally lost, altered, disclosed or used, or accessed in an unauthorized way. Additionally, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
15. Retention of your information
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
16. Your rights
You have the right to:
1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to the processing of your personal data when we rely on our legitimate interest (or the legitimate interest of a third party) and in this particular case, you have reason to object to processing on these grounds as you believe it impacts on your fundamental rights and freedoms. You also have the right to object to processing of your personal data for direct marketing purposes.
5. Request a restriction on processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data"s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish
to exercise any of the rights set out above, please contact us.
17. No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
18. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
19. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Personal data is information that can be related to an individual. Data is considered personal, if the person it concerns can be identified, directly or indirectly. Examples include the individual"s name, an identification number, date of birth, location data and contact details. It does not include data where the identity has been removed (anonymous data).
Sensitive personal data or special categories od data include data such as: religion, ideological, political views or activities, health, genetic or biometric information, the racial and ethnic origin, administrative or criminal proceedings and sanctions.
Profiling is any form of automated processing of personal data consisting of the use of personal data in order to evaluate certain personal aspects relating to an individual.
Data subject is a physical person to whom personal data relates.
Data processing / processing is any activity, operation or set of operations performed on personal data or sets thereof, irrespective of the procedure and the means (automated or not) applied, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, revision, disclosure by transmission, dissemination or otherwise making available, alignment or combination, interconnection, blocking (locking), erasure archiving, viewing and destruction of personal data.
Data file means any structured set of personal data which are accessible in such a way as to make it possible to deduce the person in question from the data.
Disclosure means making personal data accessible.
Data Protection Impact Assessment is a systematic process for identifying, evaluating and documenting the risks and impact of personal data processing activities to the rights of individuals.
Data controller is the legal person who decides the purpose and means of processing personal data.
Data processor is the physical or legal person that processes personal data on behalf of the data controller.