Privacy Policy

Our Business takes the protection of its customers’ privacy very seriously. For this reason, we strictly follow the following data protection policy, which ensures a high level of services and fully complies with the applicable legal framework.



Through this Privacy Policy, we wish to inform you about the way our Business protects the confidentiality of your communications and collects, processes, uses and stores your personal data through our Website, as well as about the choices and rights available to you regarding the above collection and processing of your personal data. By visiting our Website, you acknowledge and accept the following privacy policy.



This Privacy Policy applies only to the travelbrands.gr Website. Users should note that our Website may contain links to other websites; however, our Business bears no responsibility whatsoever for the data protection practices, terms or content of such websites.



1. DEFINITIONS



For the purposes of this policy, the following definitions shall apply:



1.1. “Cookie” – a short piece of software code sent for storage by the Business’s web server to the User’s computer each time the User enters the Website, for the purpose of selectively recording the User’s browsing history within travelbrands.gr. It is necessary as a mechanism for the technical operation of the shopping cart service.



1.2. “Recipient” – any natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not they are a third party.



1.3. “GDPR” – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).



1.4. “Processing” – any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, retention or storage, modification, retrieval, use, transmission, dissemination or any other form of making available, alignment or combination, interconnection, restriction, deletion or destruction.



1.5. “Business” – our Business under the company name TRAVEL INTERNATIONAL BRANDS EE and the trade name “Travel Brands”, with registered office at 8 Ivis Street, Marousi.



1.6. “Business User” – a business that uses the services of the travelbrands.gr Website.



1.7. “Website” – the website accessible through the domain name travelbrands.gr, including all individual web pages that form part of it.



1.8. “Profiling” – any form of automated processing of personal data for the purpose of evaluating personal aspects relating to a natural person, in particular analysing or predicting aspects concerning work performance, financial situation, health, personal preferences or interests, reliability or behaviour, location or movements of the data subject.



1.9. “Personal Data” – any information relating to the online user or users of the travelbrands.gr Website.



1.10. “Consent” – any freely given, specific, explicit and informed indication of the data subject’s wishes by which, through a statement or clear affirmative action, the data subject signifies agreement to the processing of personal data relating to them.



1.11. “User” – the online user of the travelbrands.gr Website to whom the data relate and whose identity is known or can be determined, directly or indirectly.



2. SUBJECT MATTER



2.1. This policy sets out the terms and conditions observed by our Business for the protection of the privacy of travelbrands.gr Users. It includes the rules under which we may collect and process your personal data and ensures the confidentiality of such information.



2.2. Our Business reserves the right to amend and update this policy whenever it considers this necessary. Any amendments shall take effect upon their publication on the travelbrands.gr Website.



2.3. If any provision of this policy is considered invalid, unlawful or abusive for any reason, the remaining provisions shall remain valid and effective to the extent that they do not conflict with the intention expressed through this policy.



3. PROCESSING PRINCIPLES



We fully respect your fundamental rights and consider the protection of your privacy a priority for our Business. In this context, when processing your personal data, we follow the fundamental principles below:



3.1. We process your personal data lawfully and fairly and maintain full transparency towards you regarding the manner in which we handle your personal data.



3.2. We collect and process your data only for specified, explicit and legitimate purposes, as stated in this policy, and we do not further process them in a manner incompatible with those purposes.



3.3. We process your personal data only to the extent that they are appropriate and relevant to the purposes mentioned above, while limiting such processing to what is necessary for those purposes.



3.4. We make reasonable efforts, with your cooperation, to ensure that the data we process are accurate and, where necessary, kept up to date in relation to the purposes of processing, taking all reasonable measures for their prompt deletion or correction in the event of inaccuracies.



3.5. We retain your personal data in a form that permits your identification only for as long as required for the processing purposes mentioned above.



3.6. We process your personal data in a manner that guarantees their security through the use of appropriate technical or organisational measures.



3.7. We do not intend to further process your personal data for a purpose other than that for which they were collected.



3.8. We inform you that you are under no obligation to provide your personal data and that there are no consequences arising from failure to provide such data. Furthermore, we inform you that your personal data will not be used for automated decision-making, including profiling.



3.9. Subject to the provisions of this policy, we do not disclose or transfer your personal data to further third parties without your consent unless this is permitted by law or by the agreement between us.



3.10. We inform you that we do not transfer your personal data to any third country or international organisation for which there is no adequacy decision by the European Commission under the GDPR.



3.11. In general, we fully comply with applicable legislation and with all obligations arising from it in our capacity as the lawful controller of your personal data.



4. TYPES OF DATA



4.1. The types of personal data that we collect and process from you depend on the services you choose to receive from us. Thus, during (a) access to and use of the Website, (b) registration for the email newsletter service, (c) creation of a personal account and (d) provision of services, you provide our Business with the following types of personal data.



4.2. When browsing our Website, you provide the following data:



  • Internet Protocol Address (IP Address).
  • Browsing data within the Website.
  • Service preference information.
  • Data concerning completed transactions.
  • User-generated content.


4.3. When registering for our email newsletter service, you provide us with the following data:



  • Email address.


4.4. When creating a personal account, you provide us with the following data:



  • Username.
  • Password.
  • Email address.
  • Full name.


4.5. In addition, where any User contacts us by email or other means, we collect and process personal data related to such communications, under the terms and conditions of this policy, in order to respond to the relevant requirements and requests and to improve the services we provide.



4.6. The Business does not collect or gain access to personal data of its Users/customers relating to online payment for services provided through the Website, such as credit card numbers and security codes. Such data are collected and processed exclusively by and under the responsibility of the cooperating bank during the execution and completion of each sale using the redirect method, namely by transferring the User from the travelbrands.gr Website to a web page under the responsibility of the relevant banking institution.



4.7. Our Business does not collect or gain access in any way to special categories of personal data (“sensitive data”) or data relating to criminal convictions and offences of its Users/customers. You are required to refrain from posting such data relating to yourself or third-party data subjects. If you post such data on our Website, they will be removed as soon as they come to our attention. We bear no liability towards you or any third party for the posting and/or processing of sensitive data resulting from your acts or omissions in breach of the above obligation.



5. PURPOSES AND LEGAL BASIS OF PROCESSING



5.1. Personal data necessary for browsing and using our Website, pursuant to Article 6(1)(b) of the GDPR, are collected and processed by our Business for the following purposes:



  • Technical ability to ensure the uninterrupted operation of our Website.
  • User-friendly and easy operation of our Website.
  • Improvement of your online experience while browsing and using our Website.
  • Recording consumer habits through the use of anonymous statistical data.
  • Sending informative emails to subscribers of the email newsletter service.


5.2. Personal data necessary for the provision of our services within the framework of the contractual relationship between us, pursuant to Article 6(1)(b) of the GDPR, are collected and processed by our Business for the following purposes:



  • Performance of our Business’s contractual obligations towards ordinary and Business Users of our Website.
  • Direct, adequate and effective provision of our services.
  • Tax-related use and use for invoicing and evidence of provision of the ordered services.
  • Communication with our customers in the context of proper performance of our services and for resolving any complaints.
  • Improvement and updating of our products and services so as to meet our customers’ needs as effectively as possible.
  • Administrative organisation and operation of our Business.
  • Management of our customer base.
  • Support of legal claims.


5.3. Our Business collects and processes personal data of Users/customers solely for the aforementioned purposes and only to the extent absolutely necessary for their effective fulfilment. Such data are relevant, appropriate and limited to what is necessary in view of the above purposes, are accurate and, where required, kept up to date. Furthermore, such data are retained only for the period required to achieve the purposes for which they were collected and processed and are deleted thereafter.



6. CONSENT



6.1. Our Business may process personal data only following the lawful consent of Website Users for the following purposes:



  • For commercial communication, marketing and advertising of our services or the services of third parties through SMS, telephone, email, internet, fax, post, social media and/or any other appropriate communication channels.
  • For research and/or analysis purposes aimed at better understanding your needs, preferences, interests, experiences and/or habits as a consumer.
  • For the operation and management of any loyalty programmes.


6.2. You provide your consent to the processing of your personal data for the above purposes through an electronic declaration presented in a manner clearly distinguishable from other matters and in an intelligible and easily accessible form. Your consent is given freely, and your personal data are provided without such provision constituting a legal or contractual obligation on your part or a requirement of our company for entering into a contract with you.



6.3. In this context, by completing the relevant online field, you expressly declare that you wish to provide your consent for the above purposes in accordance with the terms and conditions of this policy. You provide such consent in the following ways:



  • When registering for the email newsletter service.
  • When creating a personal or business account.
  • When ordering services and entering into contracts through our Website.


6.4. You have the right to withdraw your consent at any time. Withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Consent may be withdrawn in the same manner in which it was provided.



7. THIRD-PARTY RECIPIENTS OF DATA



7.1. Our Business does not transfer your personal data or connect its database in exchange for financial or other consideration with any third-party private companies, natural or legal persons, public authorities, services or other organisations.



7.2. For the purposes of processing described in this policy, our Business may provide access to or transfer the following categories of your personal data to the following processors acting on its behalf and under its instructions:



  • Your financial data to the credit institution with which we cooperate from time to time for the processing of payments to and from your bank accounts and credit card accounts, for the purpose of settling your financial obligations towards our Business.
  • Your personal data to the web hosting service provider with which we maintain a contractual relationship, for the purpose of hosting such data on the travelbrands.gr Website.
  • Your personal data to the company providing us with software and database maintenance and support services for the purpose of supporting the travelbrands.gr Website.
  • Preference data and contact details to third-party marketing and advertising companies for commercial communication, marketing and advertising of our services or services of third parties.
  • Your personal data to third-party consulting companies for the provision of data analysis services.
  • Your financial and contact information to debt collection companies in the event of overdue debts owed to our Business, following prior notification to you.
  • Your personal data to auditors, accountants, financial or professional advisers and investors in the context of a transfer of part or all of the Business, merger, spin-off of a business sector or other universal succession, liquidation, bankruptcy or submission of our Business to another procedure under bankruptcy law.


7.3. The processing of your personal data by the above entities cooperating with us is carried out under our supervision and solely on our instructions and is subject to the same data protection policy or to a policy providing at least the same level of protection.



7.4. If required by a court or other administrative authority, as well as in any other case where it has a legal obligation to do so, our Business may disclose your personal data to the extent provided by law, following notification to you.



7.5. You acknowledge and authorise our Business, upon your instruction and on your behalf, to provide your contact details, specifically your full name, address, email address and mobile and/or landline telephone number, or some of these details, as well as any other personal data requested, to any professional or business whom you have requested or accepted to provide the service selected by you. Our Business expects and requests such professionals to respect your Personal Data, to use them only within the purposes of operating our Website and not to disclose them to third parties. Nevertheless, you acknowledge and unconditionally accept that our Business is unable to supervise such professionals or businesses regarding compliance with the above commitments, that you assume the relevant risk and that our Business shall bear no liability whatsoever nor owe any form of compensation if a professional who has gained access to your Personal Data uses them for purposes other than providing services to you or discloses them to third parties without your permission.



8. DATA CONFIDENTIALITY AND SECURITY



8.1. In order to ensure the proper use and integrity of your personal data and to prevent unauthorised or accidental access, processing, deletion, alteration or other use thereof, our Business implements appropriate internal policies and adopts all appropriate organisational, technical, physical, electronic and procedural security measures and technological standards in accordance with applicable laws and regulations.



8.2. Data processing by our Business is carried out in a manner that ensures confidentiality and physical and logical security, taking into account the state of the art, implementation costs and the nature, scope, context and purposes of processing, as well as risks of varying likelihood and severity for your rights and freedoms.



8.3. Your personal data are processed exclusively by authorised personnel of the Business specifically designated for this purpose and bound by strict confidentiality obligations.



9. DATA RETENTION PERIOD



9.1. We retain your personal data for as long as the purposes for which they were collected and described above remain valid.



9.2. Our Business may retain your personal data after the fulfilment of the purposes of their collection and processing only in the following specifically listed cases:



  • Where we are subject to a legal obligation under an applicable provision of law.
  • For use before tax and social security authorities and any other supervisory authority within the applicable statutory limitation period.
  • Where required for the operation and organisation of our Business, provided that your data are pseudonymised.
  • For the protection of our rights and legitimate interests before any competent court and any other public authority.


9.3. After expiry of the retention period, your personal data are destroyed from our records and systems in accordance with our Business policy, provided that their continued retention is no longer required for the purposes described above.



10. RIGHTS



10.1. As data subjects, you have the right to request and obtain access to, information about and a copy of the personal data that we collect and process. If you wish to receive a copy of part or all of your personal data, please contact us using the Business contact details set out in the relevant section of this policy.



10.2. We further inform you that you may at any time exercise your rights, subject to the terms and conditions of the law, as arising from the GDPR, regarding the rectification, deletion and portability of your personal data, as well as restriction of and objection to their processing.



10.3. The above requests must be submitted in writing by postal letter to the registered office of our Business. Our Business will respond to each request within one month of receipt. Following notification to you, this period may be extended by an additional two months where required, taking into account the complexity and number of requests. Any rejection of your request shall be duly reasoned.



10.4. If your requests do not meet the conditions laid down by law, our Business reserves the right either: (a) to charge a reasonable fee, taking into account the administrative costs of providing the information or communication or carrying out the requested action, or (b) to refuse to act on your request.



10.5. Where there are doubts concerning the identity of the natural person submitting the request, we reserve the right to request additional information necessary to confirm their identity.



10.6. If your rights are infringed, we inform you that you have the right to lodge a complaint with the Hellenic Data Protection Authority or another competent supervisory authority.



11. USER OBLIGATIONS



11.1. By using the Website and providing your personal data following consent, you acknowledge that you are obliged to provide true, accurate and complete information requested by our Business. You must also inform our Business of any changes to such information so that it remains accurate and up to date.



11.2. If it is established that you are not complying with the above obligations, or if our Business has reasonable grounds to suspect that the information provided is false or incomplete or in any way contrary to the law, the Terms of Use or this Privacy Policy, we reserve the right to reject your registration application or to suspend or immediately terminate your account without notice. In such a case, you shall not be entitled to any compensation as a result of rejection of your application or suspension or termination of your account.



11.3. You acknowledge that our Business may delete, cross-check, supplement or modify the information provided by you on the basis of information lawfully supplied by third parties. In such a case, our Business will notify you accordingly in compliance with the lawful procedure.



11.4. By using the Website, you confirm that you are over sixteen (16) years of age. If you are under sixteen (16), you are required to refrain from any use of the Website and from providing any personal data without the approval of the person exercising parental responsibility over you. If you fail to comply with the above obligations, you must immediately notify our Business. In any case, by using the Website, you acknowledge that our Business bears no responsibility for any violation of the above obligations on your part to the extent that, even after making reasonable efforts, it is unable to verify your age or the consent of the person exercising parental responsibility over you.



12. COOKIES



12.1. Our Website operates using cookies. For more information, please visit the relevant page regarding our use of cookies [hyperlink].



13. JURISDICTION AND APPLICABLE LAW



13.1. Any dispute arising between our Business and Users of the Website in relation to this Privacy Policy and its subject matter shall fall within the jurisdiction of the courts of Athens and shall be governed by Greek law, without regard to its conflict-of-law rules.



13.2. If any provision of this policy is declared unlawful, invalid or unenforceable by a decision of a competent court, this shall not affect the remaining provisions, which shall continue to remain in force and be applied normally.



14. BUSINESS DETAILS AND CONTACT



14.1. The services of the travelbrands.gr Website are provided by the business under the trade name “Travel Brands”. The details of our Business are as follows:



  • Company Name: TRAVEL INTERNATIONAL BRANDS EE
  • Trade Name: Travel Brands
  • Registered Office: 8 Ivis Street, Marousi, 151 24
  • VAT Number: 801085795
  • Tax Authority: AMAROUSIOU


14.2. For any further information or request concerning this Privacy Policy, you may contact our company at the following details: Travel International Brands, 8 Ivis Street, Marousi, Postal Code 151 24, Greece, TEL: 2103219 545