Privacy policy

Privacy policy

Introduction

The Company with the corporate name "TRЀS MONOPROSOPI IKE" and the English corporate name "TRЀS SINGLE MEMBER P.C.", with registered offices in the city of Thessaloniki, Greece, Municipality of Thessaloniki,

registered in the General Commercial Registry (GEMI) under GEMI No 160626606000 is the owner of this website and will be hereinafter referred to as the "Company". Users or

visitors of the Company's Websites are referred to as "Users". This statement concerns both Users served by the Company and ordinary visitors of its websites.

The Company strictly adheres to a specific security policy, including the Data Processing and Privacy Policy. The Company takes all appropriate technical and organisational measures to ensure the confidentiality of its contacts with the Users and to protect the Personal Data that they have provided to the Company in accordance with the relevant applicable law and the applicable Regulations that it adheres to. The Company does not guarantee the security of the data transmitted via networks, to the extent that their protection is not achieved by taking the appropriate security measures imposed by the relevant institutional and/or regulatory framework.

If a visitor / user does not agree with the terms of data processing provided for in this section, he/she must not use the services of this

Website and delete the account (if any) that he/she maintains with us.

Our company currently acts as the controller of your personal data and we consider the safety and protection of your personal data to be our highest priority and we take your rights related to the protection of your personal data seriously, as well as our legal obligations regarding them. To achieve this purpose, we take the appropriate technical and organisational measures every day, in accordance with the latest technological standards and applicable legislation, in order to ensure that the processing of your personal data, either by us or by third parties on our behalf, is lawful, appropriate and has the appropriate level of security to prevent any unauthorised or accidental access, processing, erasure, alteration or other use thereof.

Relevant Legislation

Our Company has fully complied with the General Data Protection Regulation No 2016/679/EU and with the applicable Law 4642/2019, as well as with the generally applicable national and European legislative and regulatory framework and consistently applies the ten Processing

Principles of Article 5 of the Regulation (legality, objectivity, transparency, purpose limitation, data minimisation, accuracy, storage time limitation, integrity, confidentiality and accountability) with the aim of protecting your eight Rights regarding the use of your Personal Data (information, access, rectification, erasure, restriction of processing, portability, objection and non-automated decision-making based on profile, as specified in Greek law). The above apply without any distinction to all processing carried out.

We invite you to read this Privacy Policy of our Company. By using our website and signing the relevant consent statement, where required, you unconditionally accept the practices described herein, the terms of which govern hereafter our contractual relationship and are incorporated into the terms of use of each of our services.

Object of this text

This Privacy Policy aims to inform you about which of your personal information may be collected by our Company as a Controller when you use our website, as well as the way in which we collect, use, store, protect and generally process it. Extensive information is also provided regarding your rights regarding the protection of your personal data.

The use of the second person plural herein refers to all natural persons and associations of persons with or without legal personality that use the services provided through our website or gain access to information and

services provided by us.

Data we collect

More specifically, our Company collects, in the following indicative cases that relate to the cases of Article 6 (1) of the GDPR, the following of your personal data:

your basic identification data (e.g. name and surname) and your contact details (e.g. e-mail address, telephone number), when filling in the application form on our website for using our services or voluntarily registering in printed or online catalogues so that you receive information material or other marketing material in printed format, online or by SMS, renew your preferences, or finally for your participation in contests, questionnaires and promotional actions, etc., as long as the above are provided by our Company at the given time;

(payment) information as part of the transaction required to provide our services, such as the available payment method you have selected. It should be clarified that we have no access to your bank card details nor are such data registered on our website, instead, in order to complete your payment, you are forwarded to a secure environment of the partner bank, where all security measures are observed and advanced encryption systems are used;

information about your computer collected when you visit and navigate our website, such as your Internet Protocol (IP) address, operating system you use, your browser type and version, your geographic location, etc.;

information about browsing and safely accessing the secure areas of our website, including the services you use and the transactions you make on the website, the language you have selected, the duration of the visit, etc., as well as regarding your transfer from other websites or to our partner website and other statistical information generally for advertising purposes. All the above information is collected and

analysed anonymously, through cookies, exclusively upon your express consent, which you can withdraw at any time;

any other information you may voluntarily provide to us, e.g. by contacting us by any means for further assistance with our services or for feedback; comments, reviews of stores and services, etc.

How your personal data are collected and processed

We collect your personal data when you send them directly to us (e.g. by filling out the contact form on our website), when you use our services (e.g. by filling out the necessary personal information in order to complete your booking), as well as when using cookies. In any case, we ask from you the minimum personal data as required by law in order to provide you with our services.

As regards a third party's personal data, before you disclose any

personal information thereof, you must obtain that person's consent with respect to the disclosure and processing of their personal information in accordance with this

policy.

Purposes of collection and processing of your personal data

The personal information submitted to us is used for the purposes specified in this policy on the website’s relevant web pages. For example, we use your personal data for:

1. the management of the website and our business and its proper functioning;

2. the personalised configuration of the website for you;

3. the ability to provide the booking services available on our website;

4. the payment of the fee to perform the service contract. Your booking is completed only after the successful payment of the total amount of the

booking fee. Payment is made on a specially configured page of our application through the secure payment system of our provider "Stripe". Our Application does not store your payment details (cards);

5. sending notifications by email about the completion of your booking request (email confirmation) and generally managing requests and complaints submitted by you through the available communication platform;

6. sending advertisements, updates and other offers, if and when they are available at the given time and on the necessary condition that you have previously agreed to that. This applies to both non-personalised (sent to all

customers) as well as personalised newsletters sent only to you electronically (email, SMS, promotional messages) based on an analysis of your personal data that you have either expressly made available to us or resulted from the use of our website. As

mentioned above, the usage data (collected via Google's cookies) constitute

information about the number of times you visit our website, the number of your bookings, etc., and result in the analysis of your profile in order to determine your preferences

and therefore which services best suit your preferences. You can, of course, inform us at any time if you no longer wish to receive the newsletter, as well as advertising communications and promotions. Please note that the withdrawal and the subsequent changes apply only for the future and will take effect or be implemented no later than 48 hours after withdrawal.

7. providing statistical data of our users to third parties (not being able to identify any user from such information);

8. maintaining the security of the website and preventing any fraud;

9. confirming your compliance with the terms and conditions of use of our website.

Legal bases for processing your personal data

We are committed to protecting your privacy and handling your data transparently, therefore we process your personal data in accordance with the GDPR and the Greek data protection legislation when at least one of the following reasons applies:

Performance of contract

We process personal data in order to provide you with our services based on the stated terms of use, and in order to fulfil our obligations to you and our partners. The purpose of personal data processing

depends on the use you make of our website, such as submitting a reservation request at a court of your choice, submitting comments and reviews on the contact form and, in general, your service and support.

Compliance with our legal obligation

Our Company is bound by certain legal obligations arising from the applicable laws and regulations related to the fight against situations such as money laundering, tax violations, improper

protection or violation of personal data etc. In this context, we must cooperate with the Authorities and apply their rules and instructions. These obligations and requirements oblige us to process your personal data in order to be able, in the event of a suspicious event, to perform identity verification, comply with court orders/warrants, report fraud to authorities or acts of money laundering;

acts to prevent threats to national security or public safety at the request of a public body or to prosecute criminal offences, etc.

Protection of legal interest

We process personal data to ensure the legal

interests pursued by us or by third parties which are based on a business or commercial ground, such as carrying out checks to prevent fraud in the course of transactions or malicious use of our Company's services or for the smooth operation and security of our systems, sending advertisements, informational or promotional communications to you, the pursuit of legal claims and the preparation of our defence in litigation unless your interest not to have your data processed prevails, taking measures and procedures to ensure the security of our systems and to prevent possible

criminal activities, developing new services and expanding/managing our activities and communicating them to our customers, providing technical support, etc.

Your consent

Where you have given us your express consent to process your personal information (other than for the reasons set out above), the lawfulness of such processing is based on that consent. You have the right to withdraw your consent at any time, by going to the relevant field of our website where the above consent was given and changing your selection or in general in the same way as it was given from the beginning. However, any processing of personal data carried out prior to receipt of your withdrawal is not affected.

More specifically, if you give your consent to the use of technologies such as cookies,

information is automatically collected about you to offer you a top personalised experience so you can more easily find what you are looking for or to analyse our traffic. You will find more information for the use of cookies in the "Cookies Policy" below.

Duration of retention of personal data

Your personal data that we process for any purpose are kept only for the period of time necessary for that purpose, i.e. to fulfil of our contractual obligations, always taking into account the applicable statutes of limitations. In the event that we enter into a contract with you, we may

retain your data even after the conclusion of the contract 1. to the extent required by law and, in particular, the applicable financial, banking, tax, telecommunications and other

legislation; 2. if we believe that the documents may relate to any legal process in force, and 3. for the purpose of establishing, exercising or defending our legal rights (including providing information to third parties for the purpose of fraud prevention, reduction of credit risk or our compliance with instructions from Public or Independent Authorities).

However, in the event that a User requests the erasure of their data and there is no pending

legal or other dispute or our legal interest or legal obligation arising from the provision of our services, your data will be anonymised.

Protection of legal minority

Protecting the safety and privacy of children is very important to us.

In compliance with applicable law, we will not consciously collect or use personal data from persons under the age of eighteen (18). By using our website, you confirm that you are at least (18) years old.

Cookies Policy

During any user visit to our Company's Website, the pages the user sees along with the cookies they may contain are downloaded to the user's device. Cookies are text files with a unique identification code, through which the Company's server recognises the user's computer. Cookies only record the

areas of the site that the computer in question has visited and for how long.

The cookies we use are from Google (Analytics) and their purpose is to record the traffic of the persons concerned and of those who are detailed in the paragraph "Purposes of Collection and Processing

of Personal Data" herein.

The cookies that will be used during your browsing depend solely on whether you will provide your consent when entering our website, which of course you may withdraw in whole or in part.

If you wish to block the use of cookies, you can go to the following links:

Block: https://www.cookielawinfo.com/ways-to-block-cookies-in-different-browsers/ Clear: https://www.lifewire.com/how-to-delete-cookies-2617981

Moreover, Users may block the use of cookies from a special pop up that will appear at the initial loading of our Website.

Blocking all cookies will negatively affect the functionality of many websites. If you block cookies, you will not be able to use all functions of our website.

We draw attention to the fact that deleting all cookies will also have a negative effect on the functionality of many websites.

Disclosure to third party recipients of your personal data

Your personal data are collected and further processed with full respect for your privacy. When you use our website and provide us with your personal information, we do not pass on or share your information with third parties, except to the extent necessary to fulfil our contractual obligations and requests regarding our other services or to suggest ways to improve your overall experience as part of the services provided.

As part of identifying and processing our main service provided, i.e. the booking or for the settlement of any issue arising in relation to the User's reservation or in order to notify the User, if deemed necessary, we disclose the

necessary personal information of the User to the Partnered Clubs, i.e. full name, phone number, reservation code, reservation content, etc. We also ask the partnering companies to use said information solely for the execution of the service provided and not store it for purposes beyond that.

However, please be reminded that this Privacy Policy applies only to the processing of personal data collected by the Company from you. When we disclose information to third party businesses, the restrictions on use and disclosure contained in this Privacy Policy do not apply to them. Although we encourage our partners to

comply with the applicable data protection legislation, we do not control and are not responsible for any (deviant) privacy practices, privacy policies or actions of third parties. Any complaints or questions regarding the use of your personal data by the store you have chosen should be directly addressed to

its representatives. Some of our partners may also operate their own websites. Our Company is not responsible for the way the latter may collect and process your personal information independently and voluntarily through their own websites. For more information on how an associated undertaking may collect and process your personal data through its website, please refer to the privacy policy of the respective website.

As part of the execution of our other services (such as satisfying your requests for providing further information about our services, receiving and sending contact messages, data analysis, advertising services and promotional actions or performing other tasks, etc.), the following categories of our partners may be recipients of your personal data:

• providers of analysis and performance measurement services of our website, such as Google etc. Your data may be transferred outside the European Area and in particular to the USA by these companies;

• payment service providers;

• data network service providers to connect our infrastructure to the internet;

• partnering communication companies as part of managing our communication with you through the contact form. Your data may be transferred outside the European Union and in particular to the USA by these companies.

In our Company, we select reliable providers for the above and try to set contractual restrictions on third parties receiving your personal data, to ensure that they use them in accordance with this Policy and the laws on data protection that apply in Europe (GDPR 2016/679) and internationally. But under no circumstances can we guarantee that they will not use or disclose those data without your permission. For this reason, we recommend that you carefully review the

data protection practices of any third party providers, whose services you will

use through our website. In addition, the third party providers may contact you, when necessary, to obtain additional information about any

of your services, payments or bookings.

Finally, we may transfer or disclose your personal information to official, domestic or foreign, government and supervisory bodies (e.g. police, Bank of Greece, international tax authorities, etc.), when required to comply with the applicable law, with court order or prosecutorial order or in order to prevent illegal actions against us and against our customers (e.g. fraud, money laundering, etc.),

in fulfilment of our legal obligations or rights.

Security of personal data

Recognising the importance of protecting your privacy and all of your personal

information, our Company has appropriate security policies and uses appropriate technical, physical, legal and operational tools and we take the required precautions at a technical and organizational level, such as anonymisation, establishing access levels, authorised employees, periodic checks etc., in order to ensure that the processing of your personal data, whether by us or by third parties on our behalf, will be lawful, appropriate and have an appropriate level of security to prevent any unauthorised or accidental access, processing, erasure, alteration or other use of your personal data.

More specifically, we store your data on secure (password and firewall protected) servers (shared servers). Moreover, any of our partners with access to your personal information, is carefully selected to present convincing assurances of expertise, reliability and available resources, as well as appropriate technical and organisational security measures within the specifications and to ensure that it will use your personal data solely to serve the aforementioned purposes under our guidance. We share the information you give us only in the ways

described in this Policy and in accordance with your express and specific consent per type of processing which you can freely withdraw at any time by contacting us.

However, since no one can guarantee that data transfer over the Internet or any electronic data storage system is 100% secure, if you have any reason to believe that your interaction with us is no longer secure, please notify us immediately. In any case, as soon as our Company becomes aware of any form of breach of your data, it undertakes to immediately inform both the competent supervisory Authorities and you, provided the breach puts you at serious risk.

Links to third-party websites

Links on this site may take you to external - related websites. The linked websites are not under the control of the company and our company shall not be held liable for the contents of any linked website or any link contained in a linked website, or any changes or updates to such websites. Our company is not responsible for network broadcasts or any form of transmission received from any linked website. Our company provides these links to you only as a convenience and the inclusion of any link does not imply endorsement by us.

Your data protection rights

For the protection of your personal data held by us, you have the following rights:

Access to your personal data. This enables you, for example, to be informed by us about the purpose of the processing, the type of your data that we keep, their recipients, how long we store them, whether automated decision-making takes place, but also about your other rights, such as rectification, erasure of data, restriction of processing and submission of a complaint to the Hellenic Data Protection Authority. You also have the right to receive a copy of the personal data we keep for you and check that we are processing them legally. To receive the

relevant copy, you can contact our Company at the contact details referred to at the end of this Privacy Policy.

Rectification of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you rectified.

Erasure of your personal information ("right to be forgotten") You have the right to request that we erase your personal data when there is no valid reason to continue processing them or when the personal data have been processed unlawfully, or in other relevant cases under this chapter.

Object to the processing of your personal data, when we do rely on our legitimate interest but there is something special about your condition that makes you want to object to the processing for that reason. If you object, we must no longer process your personal data unless we can

prove compelling legitimate grounds for the processing, which override your

interests, rights and freedoms, or that we need to process your data to establish, exercise or defend our legal claims. You also have the right to object at any time in cases where we process your personal data for direct marketing purposes. This also includes profiling to the extent related to direct marketing. If you object to processing for direct marketing purposes, then we will stop processing your personal data for these purposes.

Restriction of the processing of your personal data. This allows you to ask us to restrict the processing of your personal data, i.e. to use them only in certain cases, if:

A) they are not accurate (until we take the necessary steps to correct or verify their accuracy);

B) they have been used illegally, but you do not wish us to erase them;

C) they are no longer needed for the purposes of the processing, but you need said data to establish, exercise or defend legal claims;

D) you have already asked us to stop using your personal data, but you are waiting for us to confirm whether we have legitimate reasons to use them.

Before any removal of the processing restriction you have requested, you will be informed by us personally.

To obtain a copy of your personal data in a structured, commonly used and machine-readable format, in order to transmit such data to other organisations. You also have the right to request that your personal data be transferred directly from us to other organisations designated by you (right to data portability).

Withdrawal of the consent you have given us regarding the processing of your personal data at any time. At this point, you should know that any withdrawal of consent does not affect the lawfulness of the processing which was based on the consent before it was withdrawn by you.

If you exercise the rights of rectification, erasure and restriction of your data, such requests will also be forwarded to the third party recipients to whom such data may have been disclosed by us, as part of providing our services.

To exercise any of your rights or if you have any other questions or concerns about our use of your personal data, you can contact us at the contact details listed at the end of this Privacy Policy. Please note that in order to exercise any of your above rights, we have the right to request verification of your identity and we reserve the right to charge you with a fee where permitted by law.

When you submit a request, our Company must respond within 1 month at the latest and will either satisfy the request or reject it with reasons. In the event of delay, especially due to the complexity of the request, and/or the large volume of requests, the deadline cannot exceed three (3) months from the time of submission of the request, while our response should be accompanied (whether it has been accepted or rejected) by special reference and reliance on the reason and circumstances that resulted in the delay.

Contact Details of our Company

For any questions, clarifications or requests regarding the processing of the User's personal data, please contact our Company, whose full contact details are:

Corporate Name: TRЀS SINGLE MEMBER P.C.

Postal address: 44 Achillea Samothraki Street, GR-54655, Thessaloniki

Contact Phone: +30 2310 427987

email: info@tiebreakers.gr

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by sending us an e-mail at: info@tiebreakers.gr

Right of Termination

If the Users consider that their request was not sufficiently satisfied by the Company

and the protection of their personal data continues to be affected in any way, they may appeal to the Hellenic Data Protection Authority, using the following contact details:

Website: www.dpa.gr

Postal Address: 1-3, Kifissias Avenue, GR-11523 Athens

Call Centre: +30 210 6475600

Fax: +30 210 6475628

E-mail: complaints@dpa.gr

Updates to our Privacy Policy

We change this policy from time to time. We will not limit your rights under this Privacy Policy without your express consent. We always indicate the date the last changes were published and provide access to archived versions so you can review them. If the changes are extensive, we will provide a more prominent notice (including, for some of our services, an email notification regarding changes to the Privacy Policy).

This privacy policy was last modified on 18/11/2021