Privacy Policy

Privacy and Personal Data Protection Policy – Pleiades RIB Cruises

The company operating under the name “Pleiades RIB Cruises”
headquartered in Agios Konstantinos in the municipality of Kammeni Vourla, takes
your personal data very seriously and therefore respects your privacy by complying
with the applicable provisions of Law 4624/2019, as currently in force, as well as
Regulation (EU) 2016/679 of the European Parliament and of the Council of April
27 th , 2016, on the protection of natural persons with regard to the processing of
personal data and on the free movement of such data, (General Data Protection
Regulation—GDPR) and agree to comply with this privacy policy (“ Privacy
Policy”), which describes the information we collect about you, including how we
collect it, how we use it, and with whom we may share it.
This Privacy Policy applies to information collected from our website at
www.pleiadesribcruises.gr (the “Website”), as well as our social media applications
(the “Applications”; together with the “Website,” they constitute the “System”).

It also covers the use of personal data of visitors and users of our aforementioned
website, visitors and users of our applications, and, more generally, users of the
System, as well as the owners or providers of services or goods. It also covers the use
of personal data of all those who interact with us in any other way, through
relationship and loyalty programs, recruitment and human resources interactions, as
well as through social media.
This privacy policy is an integral part of any contractual relationship that “Pleiades
RIB Cruises” may have with its users, customers, and partners.
“Pleiades RIB Cruises,” which is committed to respecting the rights and freedoms of
individuals, is dedicated to protecting personal data.

I. PERSONAL DATA COLLECTED
“Pleiades RIB Cruises” collects certain information from you or about you that may
be used to identify you (“Personal Information”). We collect Personal Information
from various sources, including information you provide directly and information we
collect automatically when you access and use the System and the Applications.

Information You Provide to Us: You may provide information about yourself to us
and our third-party service providers through the System, including your contact
information, such as your name, email address, phone number, address, and similar
contact information, as well as usernames and passwords, and any personal data you
provide in your transactions with “Pleiades RIB Cruises” (phone number, free-text
comment fields, email, card details).
Please note that the information you enter in the free-text comment fields must be
objective, never excessive or offensive, and must not contain data considered
sensitive (racial or ethnic origin, political, philosophical, or religious views, union
membership, data related to health or sexual life, criminal offenses, convictions, or
security measures).
If you have any doubts, you may contact “Pleiades RIB Cruises” via email at
[email protected] to ensure that you are not infringing on the rights of
the company or its partners.
We may also collect your gender, date of birth, boat operator’s license, and any other
form of identification, such as a driver’s license. Finally, we and our third-party
service providers may collect transaction details, such as payment card information,
bank account details, and billing address.
Information Collected Automatically: We and our third-party service providers may
automatically collect information from you when you visit and use the System. This
information includes the following.

Usage Information: We may collect information about how you interact with the
System. This may include information such as the dates and times you visit the
System, the pages you view, referring/exit URLs,
browser type, and the domain name of your Internet service provider.

In some cases, we may collect this information through cookies and similar
technologies. Due to frequent and rapid changes in technology, as well as the
legislature’s efforts to keep the law up to date with these changes, please consult our
Cookie Policy to learn more about these technologies. If a visitor or user disagrees
with this policy, they must discontinue and refrain from browsing the website.

Device Information: We may collect information about the devices you use to access
the System, including your device’s brand and model, your IP address, inferred
geographic location information, operating system, and unique device identifiers.
II. INFORMATION REGARDING THE PROCESSING OF PERSONAL
DATA

“Pleiades RIB Cruises” carries out all processing of its personal data in accordance
with the applicable regulations in this area, specifically:

• The General Data Protection Regulation No. 2016/679, which entered into force on
  May 25, 2018 (hereinafter “GDPR” or “General Data Protection Regulation”),
• Law No. 462402019, concerning the “Personal Data Protection Authority” and
  measures for the implementation of Regulation (EU) 2016/679 of the European
  Parliament and of the Council of April 27, 2016, on the protection of natural persons
  with regard to the processing of personal data, and the transposition into national law
  of Directive (EU) 2016/680 of the European Parliament and of the Council of April
  27 th , 2016, and other provisions,” as currently in force,
  In the context of the activities carried out through the System, “Pleiades RIB Cruises”
  acts as the data controller, as the company determines the purposes and means of the
  processing carried out within the framework of the System and as described below in
  this Policy.

The processing of personal data carried out in connection with the operation of the
System adheres to the principles of fairness, lawfulness, and transparency.
Consequently, “Pleiades RIB Cruises” undertakes to provide clear, complete, and
easily accessible information regarding the methods used to carry out such processing.

“Pleiades RIB Cruises” collects your personal data only when it is absolutely
necessary and lawful. We are committed to collecting only the minimum amount of
personal information necessary for the purposes covered by this Privacy Policy.

If you wish to delete your account, you may need to provide personal information,
such as your email address, username, and previous password, in order to verify your
identity and your authorization to manage the account.

If we need to use your personal data for purposes not covered by this Privacy Policy,
we will ask for your additional consent. Please note, however, that your consent will
not be required if our processing of your personal data is justified by a legitimate
interest, provided that such use does not adversely affect your rights and interests.
You have the option to refuse to provide us with your personal data. However, when
the data is necessary to respond to your request and you do not provide this
information, your request cannot be processed or its review may be delayed.
If you provide us with a third party’s personal data, you must inform that person and
ensure that you have their permission and consent to do so.

You may refuse to provide us with your personal data. The System is intended to
exclude minors under the age of 18. We do not knowingly collect information from
children, nor do we intend to knowingly sell products to them. In accordance with the
Children’s Online Privacy Protection Act, we do not knowingly collect information
from children under the age of 18.

“Pleiades RIB Cruises” is committed to not processing sensitive personal data that
reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or
trade union membership, nor to process genetic data, biometric data intended to
uniquely identify a natural person, or data concerning a natural person’s health, sex
life, or sexual orientation.

In the event that, during transactions with the customer, individual, or user of the
System, such information is disclosed by one of the parties, it will not be recorded by
“Pleiades RIB Cruises” in its database.

The scope of use and management of the System, as well as relationships with end-
user customers, partner merchants and providers/suppliers of services or goods, or
even with prospective clients, lead “Pleiades RIB Cruises” to carry out the processing
of personal data described in the table below:

Purpose of processing: Creation and management of the user account on the “Pleiades
RIB Cruises” platform (website and app)

Personal data provided to “Pleiades RIB Cruises”: First name, last name, mailing
address, email address, gender, date of birth, photo, boat driver’s license, as well as
any information regarding the user’s interests.
Legal basis for processing: Consent.
Purpose of processing: Billing management for reservations and payments on the
“Pleiades RIB Cruises” platform.
Personal data transferred to “Pleiades RIB Cruises”: First name, last name, customer
account, email address, mailing address.
Legal basis for processing: Service agreement.
Purpose of processing: Management of customer reviews and comments
Personal data transferred to “Pleiades RIB Cruises”: First name, last name, any
information provided by the customer in the open comment field.
Legal basis for processing: Legitimate interest.
Purpose of processing: Customer relationship management (verbal or written
communications).
Personal data transferred to “Pleiades RIB Cruises”: Full name, telephone recordings,
email addresses, and free-form text provided by the customer.
Legal basis for processing: Legitimate interest.
Purpose of processing: Creation and management of marketing campaigns (push
notifications).
Personal data transferred to “Pleiades RIB Cruises”: First name, last name, phone
number, email address.
Legal basis for processing: Consent.
Purpose of processing: Creation and management of marketing campaigns (targeted
ads).
Personal data transferred to “Pleiades RIB Cruises”: User browsing history.
Legal basis for processing: Legitimate interest.
Purpose of processing: Creation and management of a marketing campaign
(newsletter).
Personal data transferred to “Pleiades RIB Cruises”: First name, last name, email
address.
Legal basis for processing: Legitimate interest.
Purpose of processing: Dispute resolution.

Personal data transferred to “Pleiades RIB Cruises”: First name, last name, mailing
address, email address, phone number, date of birth, gender, boat license, customer
account.
Legal basis for processing: Legitimate interest.
Purpose of processing: Management of applications.
Personal data transferred to “Pleiades RIB Cruises”: First name, last name, mailing
address, email address, phone number, photo, resume, cover letter.
For individuals who are not Greek citizens: a residence permit allowing them to work
in Greece.
For individuals undergoing an interview: the possibility of recording telephone
interviews.
Legal basis for processing: Consent, Legitimate interest.
Regarding the retention periods for your data, “Pleiades RIB Cruises” retains it for as
long as we deem necessary for the purposes for which it was collected, or even for a
longer period in order to comply with legal and regulatory obligations.

III. HOW WE USE THE INFORMATION WE COLLECT.

“Pleiades RIB Cruises” collects and uses Personal Information for the following
purposes, which include, but are not limited to:

• To provide you with our products and services,
• To operate and provide the System.
• To improve our products and services, the System, the user experience, and our
  business.
• For security purposes, including monitoring, risk assessment, resolving issues
  related to the System’s integrity and security, and preventing or combating fraud and
  crime.
• To provide you with information you request from us, including responding to
  inquiries or requests for information regarding or from “Pleiades RIB Cruises.”
• To send you promotional or marketing materials regarding “Pleiades RIB Cruises.”
• Other commercial purposes, including, but not limited to, verifying your identity,
  age, and/or payment information; investigating complaints regarding the System;

conducting research and analysis; marketing; advertising, customer preferences and
purchasing trends, and dispute resolution.

• In connection with a merger or similar consolidation of “Pleiades RIB Cruises” into
  or with another entity.
• To comply with law enforcement authorities, government agencies, or a government
  order.
• To comply with “Pleiades RIB Cruises” policies and all applicable legal
  requirements, or to the extent permitted by them.
• Participation in other activities provided for in this privacy policy or by “Pleiades
  RIB Cruises” at its discretion.

IV. STORAGE OF YOUR DATA

“Pleiades RIB Cruises” stores your personal data to enable you to continue using the
System for as long as necessary to achieve the purposes described above.
The data collected by “Pleiades RIB Cruises” is stored on its servers located at its
headquarters in Agios Konstantinos, Fthiotida. “Pleiades RIB Cruises” undertakes to
take all necessary measures to ensure the security and confidentiality of the data you
provide.
You can close your account at any time by sending a request to “Pleiades RIB
Cruises” support at the email address: [email protected] or by going to
the “My Information” page of your account and using the “Delete My Account”
button, which allows you to perform this action.
Upon your request, “Pleiades RIB Cruises” will delete all personal data it holds in
your personal account, with the exception of data necessary to fulfill its contractual or
legal obligations, particularly accounting-related obligations. The data will be deleted
after the expiration of the statute of limitations applicable to that specific area.

V. DISCLOSURE AND RECIPIENTS OF YOUR DATA

“Pleiades RIB Cruises” is committed to safeguarding all personal data collected
through the System and to sharing it only in specific cases and in accordance with the
provisions of Law 4624/2019 on information technology, records, and civil liberties.

“Pleiades RIB Cruises” does not sell your personal data and shares it only as set forth
in this privacy policy or as required by law. We do not rent, distribute, or sell your
personal information to third parties unless you have expressly authorized us to do so
in advance. We ensure that your data is accessible only to the authorized internal or
external recipients listed below.
“Pleiades RIB Cruises” may provide access to your personal data to service providers
for the purpose of performing services related to the System, such as maintenance,
analysis, marketing, communication, data processing, payment, distribution of emails
or postal mail, management of promotional campaigns or contests, etc. These service
providers will have access to your data solely for the purpose of performing these
services and will be subject to the same security and confidentiality obligations as
“Pleiades RIB Cruises,” which will remain the data controller with respect to you.
“Pleiades RIB Cruises” may share your data to prevent, detect, investigate, and take
action against potentially prohibited and illegal activities, situations that threaten the
safety or other rights and interests of users or any individual, and violations of the
terms of use, provided that this is permitted or required by law and provided that
“Pleiades RIB Cruises” believes in good faith that it is necessary to share your data.
“Pleiades RIB Cruises” may also transfer your personal data to comply with legal
proceedings of any kind, court orders, or any legal proceedings or law enforcement
measures required by the competent authorities.

“Pleiades RIB Cruises” may share your data for other purposes and may allow its
partners to send you information when you use the System (and to allow us to fulfill
our contractual obligations to them), subject to your express prior consent.

We may share personal information with our subsidiaries or other third parties, such
as business partners and trusted service providers, to help us provide the System, offer
our services, deliver advertisements or marketing, process payments, conduct
statistical analyses, send you correspondence, provide customer support, protect
against potential fraud or investigate fraudulent or illegal activity, or perform any
other function consistent with the operation of the System and our services.

We may also share Personal Information with professional advisors, such as
attorneys, auditors, bankers, and insurers, in connection with the professional services
they provide to us.
These third parties have agreed to comply with appropriate provisions regarding data
protection and confidentiality.

For strategic or other business reasons, “Pleiades RIB Cruises” may decide to sell or
transfer some or all of its operations.
As part of such an assignment or transfer, we may transfer the information we have
collected and retained (including personal data) to any person or entity involved in the
transaction. In the event of a merger, acquisition, sale, or transfer of all or part of our
business, your data may be disclosed to the relevant parties or entities.

VI. STORAGE OF YOUR PERSONAL DATA

“Pleiades RIB Cruises” may store your personal data (and therefore transfer it to
subcontractors) for the following purposes:

• System hosting management.
• IT resource management and System maintenance.
  In this context, “Pleiades RIB Cruises” undertakes to verify their compliance with
  personal data protection rules and to ensure the implementation of an exclusive
  contractual framework, under the conditions required by the aforementioned rules.

“Pleiades RIB Cruises” may also transfer certain information to authorized
individuals and entities internally (employees, executives, and staff of the company)
and externally, particularly to authorized third parties pursuant to legal,
administrative, or judicial mandates.

Except in these cases, “Pleiades RIB Cruises” does not transfer your personal data to
third parties without first obtaining your consent.

VII. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION

• Transfers of personal data outside the European Union.

“Pleiades RIB Cruises” may transfer personal data outside the European Union.
In the event of a transfer of personal data outside the European Union, “Pleiades RIB
Cruises” will apply the necessary regulatory framework tailored to the circumstances
of the transfer in question, ensuring:
that the transfer of your personal data takes place to a country with an adequate level
of protection, or,
that Standard Contractual Clauses (SCCs) proposed by the European Commission are
signed, or,
any other safeguards deemed appropriate under the General Data Protection
Regulation (GDPR).
“Pleiades RIB Cruises” may transfer your personal data to certified organizations that
have publicly committed to respecting personal data protection standards.

VIII. THE SECURITY OF YOUR PERSONAL DATA

“Pleiades RIB Cruises” is committed, through a contractual obligation, to
implementing all measures aimed at ensuring the security of your Personal Data.
To this end, “Pleiades RIB Cruises” is committed to implementing all technical and
organizational measures required by the GDPR (GDPR), which will ensure the
confidentiality, integrity, and availability of personal data and, consequently, an
adequate level of protection for such data.
“Pleiades RIB Cruises” and its partners have received training and awareness-raising
regarding the protection of personal data, including the adoption and implementation
of these measures.

IX. AUTOMATED DECISION-MAKING

We do not engage in any automated decision-making regarding our services.

X. EXERCISING YOUR RIGHTS

Under the law, you have the right to request, at any time, the exercise of your
individual rights and, in particular, to request:

• Access to your personal data in a clear and understandable format, so that you know
  what information “Pleiades RIB Cruises” processes about you,
• Rectification, which results in the correction of any incomplete or incorrectly
  processed personal data by “Pleiades RIB Cruises.”
• The erasure of your personal data under conditions predetermined by applicable
  regulations.
• Restriction of the processing of personal data under conditions predetermined by
  applicable regulations.
• The right to object to data processing, citing the legitimate grounds for which such
  objections must be upheld.
• The portability of personal data in a clear and machine-readable format, with the
  ability to transfer it to another entity.
• Determining the fate of your personal data in the event of loss, by providing specific
  instructions to “Pleiades RIB Cruises.”
  Please be advised that the exercise of your rights to object, deletion, and data
  portability, as well as the right to restrict processing, is subject to certain conditions
  and may be rejected by Clickandboat if requests to exercise these rights do not
  correspond to the situations provided for by data protection regulations.
  It should also be noted that, if you object to receiving marketing communications, we
  will nevertheless continue to send you notifications regarding the activities for which
  you have registered (games, contests, surveys, analyses, etc.).

Requests must be submitted to “Pleiades RIB Cruises”:

• By email to: [email protected] , or
  Once it has verified that you are the individual to whom the requested data pertains or
  their legally authorized representative (identity verification), “Pleiades RIB Cruises”
  will endeavor to respond to your request as soon as possible.

“Pleiades RIB Cruises” undertakes to process any request regarding the exercise of
your individual rights within thirty (30) days of receipt. This deadline may be
extended by an additional sixty (60) days if the investigation of the request is
particularly complex. In this case, “Pleiades RIB Cruises” undertakes to keep you
informed and to monitor such requests.

Users of the “Pleiades RIB Cruises” website also have the option to file a complaint
with the National Commission for Information Technology and Liberties (CNIL)
online, in the section dedicated to complaints.

XI. RELATED WEBSITES

For your convenience, certain hyperlinks may be posted on the System that refer to
other websites not controlled by us. We are not responsible for, and this Privacy
Policy does not apply to, the privacy practices of such websites or pages that are not
under our control or of any companies that we do not own or control. We do not
endorse any of these websites or pages, the services or products described or offered
on such websites or pages, or any content appearing on such websites or pages.

II. CHANGES TO THE PRIVACY POLICY

We may amend this privacy policy at any time. The most recent version of the
Privacy Policy is indicated by the effective date at the top of this Privacy Policy. All
amendments to this Privacy Policy will take effect immediately upon notification,
which may be provided by any means, including the publication of a revised version
of the Privacy Policy or other notification on the System.

XIII. Cookies

“Pleiades RIB Cruises” uses “cookies” to make our website easier to use. “Cookies”
are small data/text files stored on your computer’s hard drive by your browser and are
necessary for using our website.
We use “cookies” to better understand how our website is used and to provide you
with a better browsing experience.
Cookies help us, for example, determine whether you have already visited a page on
our website. Cookies can also tell us whether you have visited our website in the past
or if you are a new visitor.

The “cookies” we use do not store personal data or personal information that could be
used to identify the individual to whom they relate and that has been collected by
other means.
If you do not wish to have information collected via “cookies,” please configure your
web browser to delete all existing “cookies” from your computer’s hard drive, block
all future “cookies,” and receive a warning before a “cookie” is stored (Read more in
the Cookie Policy).
XIV. CORRESPONDENCE

We appreciate your questions and comments regarding the System and invite you to
send us your messages at [email protected] or through our website.
When you correspond with “Pleiades RIB Cruises,” we may collect information,
including the content and metadata related to any correspondence you provide to us.
We may share your messages with individuals within our organization who are best
positioned to address the issues raised in your message.

XV. Newsletters
“Pleiades RIB Cruises” sends out newsletters at regular intervals to its registered
users, based on their interests.
We provide the newsletter service to visitors/users who wish to receive it, after they
have filled out a form with their email address and/or full name, provided they wish to
do so and only then.
In this way, visitors/ users subscribe to the Newsletter service without this in any way
implying that they acquire any intellectual property rights, which are in any case
protected by the relevant provisions of Greek law and international conventions and
belong exclusively to the company.
In every newsletter you receive through our automated platform, you have the option
to unsubscribe or update your personal information via a link at the end of the email.
“Pleiades RIB Cruises” reserves the right to remove any recipient from its newsletter
lists without providing a reason.
The administrators of “Pleiades RIB Cruises” make every effort to ensure the smooth
operation of the newsletters; however, technical or organizational issues may arise at
any time.