privacy notice| Aegean Travel Packages

1. About us

1.1 Welcome to Aegean Travel Packages privacy policy. We respect your privacy and are committed to protecting your personal data. This privacy policy informs you about how we look after your personal data as an Aegean Travel Packages 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.

1.2 We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO at the following contact details.

Contact details:

Aegean Travel Packages
Email address: service-israel@packages.aegeanair.com

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 policy and your duty to inform us about changes

This version was last updated on the May the 17th 2018 and historic versions can be obtained by contacting us. This policy replaces all previous disclosures we may have provided you about our information practices. We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted by law. If there are material changes to this policyor 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. Please keep us informed if your personal data changes during your relationship with us.

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.
Health Data provided by you to serve you better and meet your particular needs (for example, the provision of disability access).

4. How we collect your information

We collect personal data about you whenever you use our services (whether services provided directly by us or by other companies or agents acting on our behalf), when you travel with us, when you use our websites, or when you use our call centers or mobile applications.

5. Why we process your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data only:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
When you have provided us with your explicit consent to do so.

In case we rely on consent as a legal basis for processing your personal data, please note that you have the right to withdraw your consent at any time by contacting us using the contact details set out at paragraph 1 above.

6. Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer, user (My Account), member (Miles+Bonus)	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to take part in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop products and services Based on consent with regards to direct marketing and in order to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Based on your consent, however, where permitted by applicable law we may lawfully use your personal data where necessary for our legitimate interests, which include promoting our products and services, special offers and promotions which may be of interest to you. Based on your consent. In this case AEGEAN Group might apply automated procedures in order to analyze your behavior and your preferences, so as to identity and suggest services and goods that might be of your interest. *In regards to the Miles + Bonus Members, the specific procedures and actions, are carried out on the basis of fulfillment of the terms of the contract, between the Company and the Members of the Program.

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 policy of the third party.

9. Cookies, Web beacons and other similar technologies

Our Website uses “cookie” and “web beacon” technology. We use cookies and web beacons to distinguish you from other visitors, track your IP address and usage of our site, and to indemnify the name of the website from which you linked to our website. This information is used for fulfilling contracts with our business partners, and to help us serve you better by improving our website design, as well as our products, services and promotions. We do not otherwise track any information about your use of other websites. Non-personal data or anonymised / pseudonymised information obtained through cookies and web beacons may be shared with or obtained by service providers on our behalf.

A cookie is a small data file that is placed on the hard drive of your computer when you visit a website. A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available. A web beacon is a small string of code that represents a clear graphic image and is used in conjunction with a cookie.

When you visit our website, we may use both a session and a persistent cookie. This AEGEAN Group-placed cookie may contain information (such as a unique user ID) that is used to track your usage of our website and in some cases, your email address. Your email address is only saved in this AEGEAN Group-placed cookie if you register with us. The web beacon allows us to capture certain additional types of information about a visit’s actions on a website, such as a visitor’s cookie number, the time, date, duration and number of page views, a description of the page where the web beacon is placed, and the details about any items that were purchased.

If you register with us, this AEGEAN Group-placed cookie allows us to recognise you when you return to our website and provides you with access to your account information. If you save your information with or purchase flights from us, we may also use cookies to monitor and maintain information about your use of our website. If you have not saved your information with or ordered from us, we may monitor and maintain information about your use of our website in a manner that does not identify you.

We may use Flash Cookie (also known as Local Stored Objects) or other similar technologies. A Flash cookie is a small data file placed in a computer using Adobe Flash technology that may be built into your computer or downloaded by you to your computer. We use these technologies to personalise and enhance your online experience, facilitate processes, personalise and store your settings. Flash cookies may help our website visitors to, for example, set volume preference associated with a video experience. They help us improve our sites by measuring which areas are of greatest interest to customers. We do not use Flash cookies for marketing or behavioural targeting purposes. Flash cookies are different from browser cookies and the cookie management tools provided by your browser will not remove Flash cookies. If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain features and services that make your online experience more efficient and enjoyable.

You can disable cookies at any time by using your browser options; however, if you turn off cookies, we will not be able to track your purchases or enable you to make a purchase from our Website. In addition, we will not be able to recognise you as a registered user to allow you access to your account information.

10. My Account

AEGEAN Group provides for a user-friendly and personalized web experience through "My Account". Users might be registered in this Account, by providing identity and contract personal data, in order to experience a quick and easier use of the website. Apart from that users might participate in the AEGEAN Group loyalty program, i.e. Miles+Bonus. The Miles+Bonus program is a reward program that provides offers, benefits and services to passengers who fly frequently through the collection, the purchase and redemption of miles. AEGEAN and Olympic Air are joint controllers with regards to personal data they collect from their Miles+Bonus members. Members will be required to provide additional data, such as boarding passes data and tickets receipts, in order to use the program, collect and redeem miles. Additionally, AEGEAN Group will be required to share (send and receive) your personal data, with all third parties participating in this program, in order to manage miles accrued in your account. In any case you are able to access “My Profile” Section in our website in order to manage or/and edit your data. In case you provide with your explicit consent for receiving marketing material as a Miles+Bonus member, such material might include suggestions and offers from all parties participating in the program.

11. 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 policy. We provide a link to this policy 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.

12. 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.

13. 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 the AEGEAN Group.

In particular and in order to facilitate your travel arrangements, we will often need to share your personal data with third parties such as airlines, accommodations, airport operators, customs, immigration authorities and travel agents involved in making your travel arrangements. We also share your personal data with third parties who deliver services either to you or to us, such as companies that provide airport assistance.

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 policy.

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.

14. Countries having access to your information

Our servers, storing and keeping your information secure, are located in the European Economic Area. However, we have a number of AEGEAN Group 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.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

15. Data Security

We have put in place appropriate security measures (incuding encryption, anonymization or/and pseudonymization procedures where required) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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.

16. 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.

17. Your rights

You have the right to:

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.
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.
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.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of 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.
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.
Withdraw 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.

18. 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.

19. 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.

20. 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.

ANNEX I

Definitions

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.!

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