DATA SAFETY
A. WHO WE ARE
GEORGIOS GLAVAS & SIA L.P.
Owner & Manager: Georgios Glavas
Address: Vouno 82102 Chios – Greece
Email: georgiosglavas@grmtours.com
Website: https://www.grmtours.com.
Telephone: +30 6931 384 283
EUID: ELGEMI.168463759000
B. PROTECTION OF PERSONAL DATA.
1. Introduction
The Company GEORGIOS GLAVAS & SIA E.E., known as GRMtours, (hereinafter “the Company”) informs you, in accordance with Regulation (EU) 2016/679 and the provisions of the relevant current Greek legislation on the protection of personal data, in its capacity as processor and controller, that it processes your personal data in accordance with the following.
2. What personal data can the Company collect and process?
a) Your identification data: full name, father’s name, occupation, details of your motorcycle.
b) Your contact data: home address, email address, contact numbers (landline and mobile).
3. Purposes of data processing
The processing of the data under 2. serves purposes such as: Communicating with you, informing you about the services offered by the Company, as well as sending you information forms regarding offers, excursions, events , corporate news, promotional material and other non-personalized information.
4. Who has access to your data?
a) The employees of the Company who are responsible for the Company’s communication with you.
b) Entities to whom the Company entrusts the execution of specific tasks on its behalf (executing the processing) such as, indicatively but not limited to, lawyers, providers of IT products and/or services and/or support of all kinds of information and electronic systems and networks, companies that provide administrative support, telephone service companies, or other natural or legal persons who process data, provided that the security and privacy conditions are observed in each case.
5. Data retention period
Your personal data will be respected throughout the Company’s communication with you.
6. Data protection rights
You have the following rights:
a) Be aware of the categories of your personal data that we keep and process, their origin, the purposes of their processing, the categories of their recipients, their retention time, as well as your relevant rights (right of access).
b) Request the correction and/or completion of your personal data, so that it is complete and accurate (right to correction), by providing any necessary document from which the need for correction or completion arises.
c) Request the restriction of the processing of your data (right to restriction).
d) Object to any further processing of your personal data held by us (right to object).
e) Request the deletion of your personal data from the files we keep (right to be forgotten).
f) Request the transfer of your data from the Company to any other controller (right to data portability).
g) Submit a complaint to the Personal Data Protection Authority (www.dpa.gr), if you believe that your rights are violated in any way. Please note the following in relation to your above rights:
i. The exercise of the right to portability (above under f) does not entail the deletion of the data from the Company’s records, which is subject to the conditions of the immediately preceding paragraph.
ii. The exercise of the above rights acts for the future and does not concern already performed data processing.
7. Security of personal data protection
The Company is committed to ensure the security of your personal data. To prevent unauthorized access or disclosure, the Company has technical and organizational measures to safeguard and protect your personal data. All Company staff and third parties to whom the Company entrusts the processing of your personal data are obliged to respect the confidentiality of your data.
8. Communication – Exercise of rights
In case you have additional questions regarding the processing of your data, you can contact the Company or send your request by email to the address …………………. To exercise your rights, you can write to the Company at its contact details as listed below. The Company will make every effort to respond to your request within thirty (30) days of submission. The above service is provided by the Company free of charge.
C. INSTRUCTIONS AND TERMS FOR THE PROCESSING OF PERSONAL DATA DURING THE TOURS
1. The present conditions do not refer to photography or video recording carried out privately on their own behalf by natural persons – participants in the organized excursion. The Company has no relation and therefore bears no responsibility for these processings.
2. To comply with the General Data Protection Regulation (2016/679/EU) – GDPR and the Greek Legislation (N.4624/2019) appropriate organizational and technical measures should be taken which include obligations such as: 1. Informing the individuals for these initiatives, before taking photos or videos. 2. Obtaining the consent of natural persons to use the material for any purpose other than simple photography or video recording. 3. Ensuring the rights of natural persons to their personal data. 4. Anonymization of personal data. 5. Informing Natural Persons. The GDPR requires that before receiving personal data, the natural person knows and understands the processing of his personal data (principle of transparency).
3. Each participant, together with the declaration of participation and the declaration of information that he completes, is also informed that there will be photography/videography coverage of the entire excursion. The natural person’s participation in the excursion, after first being informed, as ensured by the above actions, is taken as his consent, and therefore the first registration is justified.
4. Each participant can express his objection at any time and request relevant protection (within the subject’s rights to update, correct, delete, and limit the processing of personal data, as provided for in the General Data Protection Regulation 2016/679 /EU and in Law 4624/2019). Any other processing of photos and video requires additional consent as described below.
5. The Company may use the photographic/video material beyond simple recording, and for this reason each participant, if he wishes, will sign an express consent form for the use of the photographic or video material, for its posting on the website of the Company, processing, distribution and for any other legal.
6. If the above consent is not obtained from all the participants in an excursion – event, then general images will be taken without distinguishing personal characteristics (anonymization technique). Consent will be limited to a minimum number of natural persons who are of particular importance to the event (eg the organisers). In the case where consent is requested and not given, techniques are used to separate the natural persons so that the photographers or videographers can distinguish the cases: Such techniques may be indicatively based on ideas such as: • Placing those who have given consent in specific positions in the space • The blurring of faces and bicycles and other elements of persons who did not give consent, etc.
7. Anonymization of personal data: The Company wishes in any case that general shots of each excursion are taken for the purposes of illustrating the excursions, promotion, etc. even without consent being possible. In this case, techniques will be used to capture or display images (photos and videos) and either low-resolution images will be taken, so that the faces of the participants cannot be distinguished, or in the case of close-up shots, face-blurring techniques will be used for those without consent , or a remote shot will be taken (long shots, shot with a drone from above, etc.) where it is proven that no faces can be seen.
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