Introduction
This Personal Data Protection Policy is adopted by the company under the trade name “TOURIST TRANSPORT AND HOTEL ENTERPRISES HORIZON Single Member S.A” («ΤΟΥΡΙΣΤΙΚΕΣ ΜΕΤΑΦΟΡΙΚΕΣ ΚΑΙ ΞΕΝΟΔΟΧΕΙΑΚΕΣ ΕΠΙΧΕΙΡΗΣΕΙΣ ΟΡΙΖΩΝ ΜΟΝΟΠΡΟΣΩΠΗ ΑΝΩΝΥΜΟΣ ΕΤΑΙΡΕΙΑ») and the distinctive title «HORIZON TRAVEL» (hereinafter “our Company” or “we”) which is engaged in the sectors of travel organization (incentive, corporate travels), organization of conferences, events, excursions, yacht chartering etc.
Our Company uses its best efforts to provide high quality services to its customers globally. We greatly appreciate our customers and partners as well as the trust they display in our company and we procure so that all the information they provide to us in order to receive our services is securely kept.
This Policy has been designed in accordance with the statutory provisions of the General Data Protection Regulation of the European Union (Regulation 2016/679) (hereinafter “GDPR”) which entered into force on May 25, 2018, L. 4624/2019 and the other European and national legislation and describes our practices and policies regarding the personal information we collect from you or for you through our website, through written or oral communication with you, through your participation in conferences, events and travels we organize or from other sources (hereinafter the “Personal Data”) and the way we process, use, disclose, transfer and protect them.
By providing your Personal Data to our Company (either directly or allowing another person to do so on your behalf), you accept the way in which our Company uses your Personal Data and you consent to the collection, transfer, processing, use and disclosure of your Personal Data, as described in this Policy. In case that you do not agree with any part of this Policy, you must not provide your Personal Data. However, if you do not provide your Personal Data or withdraw your consent, we may not be able to provide further services to you or the services provided be significantly inferior to the expected.
This Policy does not in any way cover your relations in your capacity as customers of our Company or users of our Company’s website horizon.gr (hereinafter the “Website”) with other companies that are not subject to the control or owned by our Company.
If you have any question regarding this Policy you may contact with our Company by sending a letter to the registered office address of our Company (50, Praxitelous Street, Kallithea, Attica P.C. 176 74) or via e-mail using the following e-mail address: dpo@horizon.gr
Links to other sites
Our Website may contain links to third parties or include third party websites. This Policy does not apply to these websites and our Company is not in any way responsible for the privacy policies or practices of such websites. If you choose to visit a linked site, you agree that our Company is not responsible for the availability of this site and does not control, sign or is responsible in any way whatsoever for the way in which your Personal Data are addressed in these websites or the content of such websites.
Collection -Use – Purposes of Procession of your Personal Data
Α. Our Company collects your Personal Date in one of the following ways:
(a) by using the services of its Website or sign in its Website for upcoming events/conferences/travels by completing a relevant application/contact form/registration form and choose to receive marketing/informative/promotional letters from our Company (hereinafter the “Newsletters”);
(b) by using our Company’s services (participation in travels/conferences/events/excursions etc.);
(c) by entering into an agreement with our Company;
(d) by contacting our Company either through its Website or through another way of communicating written or verbal;
(e) through third parties cooperating with our Company for the purpose of organizing conferences, events, travels, etc. (e.g. tourist agencies, public organizations, companies).
Β. In the above-mentioned context, our Company may collect, store and process the following types of your Personal Data:
• information you may provide in order to contact with our Company, sign in or apply for participating in upcoming events/conferences/travels and generally (information you may provide) in order to use our Company’s services;
• any other information you may choose to disclose to our Company (either through our Website or otherwise) which is pertinent to the fulfilment of your personal requests and fall within our scope of business (travel organization (incentive, corporate travels), organization of conferences, events, excursions, yacht chartering, ticket issuance etc. ). In this instance, this information may extend to your accompanying family members;
• any information you may disclose to our Company in the context of signing and performing an agreement with our Company;
• information which our Company may receive by third parties (e.g. companies, tourist agencies, public organizations) within the context of co-operation and provision of information.
Particularly, the information that our Company may collect in the abovementioned ways is the following:
• Personal Details (e.g. Name, Surname, Address, Contact Number, E-mail address, Passport Number)
• Financial Data (e.g. Credit Card Information, Bank Account Information)
• Employment Data (e.g. Employment, Position / Title, Employment Location)
• Family Details (e.g. personal details of family members, age of minor children if necessary to proceed with ticket reservations, hotel rooms reservations etc.)
C. Our Company uses and processes your Personal Data for the following purposes:
• in order to provide to you the services requested and fulfil your requests regarding the services provided by our Company;
• in order to inform you about the services provided and new offers/categories of services by sending to you Newsletters through e-mails unless you have requested not to receive such Newsletters;
• in order to answer to questions and requests you may address to us;
• for internal purposes of our Company and in order to secure the quality of services provided;
• for our Company’s proper execution/performance of a concluded agreement;
• for other purposes as provided or required by law (e.g. our Company’s compliance with its legal obligations or for the protection of its or yours vital interests or in cases that the processing is necessary to defend our legal rights or establish, exercise, defend and execute our legal claims).
Processing of sensitive data
In some cases, we might process special categories regarding your Personal Data (“sensitive data”). Sensitive data are defined as Personal Data that reveal your gender or national origin, political beliefs, religious or philosophical beliefs, participation in trade union organizations, genetic data, biometrics data with the purpose of identifying a physical person, health and sexual life or sexual orientation. For example, we may process sensitive data that you have made publicly available. We may also process sensitive data, on occasion, for the support, exercise or defense of legal claims. We may also process your sensitive data if you have previously given your explicit and special consent, in a specific context for a specific purpose.
Protection of your Personal Data
Our Company takes appropriate legal, organizational and technical measures in order to protect your Personal Data in accordance with the applicable legislation for privacy and data security. Our Company implements various security technologies and procedures in order to protect your Personal Data from any illegal destruction, loss, misuse or modification, as well as against any unauthorized or illegal processing, use or disclosure.
Our Company processes your Personal Data for as long as is necessary to fulfil the purposes for which your Personal Data were collected and we will delete or re-identify your Personal Data once we no longer require it for the provision of our services and/or for our business purposes and/or for the performance of a contract we have entered into and/or for legal purposes, or as otherwise required by the applicable legislation for the protection of Personal Data from time to time.
Common Use – Non Disclosure of your Personal Data to Third Parties
Without prejudice to any contrary provision in this Policy, our Company bounds:
(1) not to sell, rent or otherwise publish or disclose your Personal Data to any third party and
(2) not to disclose your Personal Data to third parties (individuals or legal entities) unless:
a) you have provided explicit written consent and (i) the third party (individual or legal entity associate/ supplier/ service provider of our Company) has provided sufficient guarantees in respect of the technical and organizational measures governing the processing to be carried out and (ii) the third party (individual or legal entity associate/ supplier/ service provider of our Company) has entered into a written contact with our Company which imposes on the third party obligations identical to those imposed on us under the provisions of Personal Data protection legislation;
b) it is required for our Company’s compliance with the respective legislation and only to any competent tax authority, public prosecutor, police, criminal investigation and judicial authorities in response to their requests;
c) in connection with any legal/judicial proceedings or prospective legal/judicial proceedings;
d) for the purposes of establishing, exercising, defending or executing our legal rights and legal interests–including information to regulatory, prosecution οr other authorities for the purposes of fraud prevention and anti-counterfeiting, unauthorized use and illegal activities-.
Our Company bounds not to transfer your Personal Data in third countries outside the European Union without your prior written consent unless our Company and the recipients of your Personal Data have entered into and use the standard contractual clauses approved by the European Commission and annexed to the Commission Decision of 5th February 2010 on standard contractual clauses for transfer of personal data to processors established in third countries (2010/87/ΕU).
Your Rights
You shall have the following rights, as specified by the provisions of GDPR and the applicable legislation which implements or supplements GDPR or otherwise is related to the processing of individuals’ Personal Data together with the binding directives and Codes of Practice issued from time to time by the respective supervisory authorities:
(a) The right to be informed and the right of access
You shall have the right to be informed about the processing of your Personal Data by our Company, as well as the right to access to your Personal Data and the information relating to their processing and the right to obtain a copy of your Personal Data undergoing processing.
(b) The right to rectification
You shall have the right to obtain from our Company the rectification or completion of your Personal Data, if your Personal Data are inaccurate or incomplete.
(c) The right to erasure
You shall have the right to obtain from our Company the erasure of your Personal Data. We shall satisfy your request where one of the following grounds applies:
• the Personal Data are no longer necessary in relation to the purposes for which they were collected;
• you withdraw your consent and there is no other legal ground for the processing;
• you exercise the right to object to the processing (see below (f)) and there are no overriding legitimate grounds for the processing;
• your Personal Data have been unlawfully processed;
• your Personal Data have to be erased for compliance with a legal obligation.
(d) The right to restriction of processing
You shall have the right to obtain from our Company restriction of processing. We shall satisfy your request where one of the following applies:
• when you contest the accuracy of your Personal Data, for a period enabling us to verify the accuracy of your Personal Data;
• when the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of their use instead;
• you exercise the right to object to the processing (see below (f)) pending the verification from our Company whether the legitimate grounds for the processing override your interests, rights and freedoms.
(e) The right to data portability
You shall have the right to receive your Personal Data in a structured, commonly used and machine-readable format, as well as the right to request to transmit those data to you or another controller that shall proceed to their processing.
(f) The right to object
You shall have the right to object to
• the processing of your Personal Data by our Company for our legal interests or legal interests of third parties;
• the processing of your Personal Data for direct marketing purposes;
• the processing of your Personal Data for statistical purposes;
For any question you may have or in order to exercise all the above mentioned rights you may contact with our Company either (a) through the respective contact form or by sending e-mail to the following e-mail address dpo@horizon.gr or (b) by sending a letter to the address set out in the first part of this Policy.
You are also entitled to withdraw at any time the consent you have provided regarding the processing of your Personal Data (without retroactive effect) following one of the aforementioned ways.
(g) The right to lodge a complaint
Ιn case that you consider that any of your rights or any of our Company’s legal obligations with respect to the processing of your Personal Data is violated, you may lodge a complaint before the competent supervisory authority, i.e the Data Protection Authority, as below:
Data Protection Authority
Address: 1-3, Kifisias Avenue, P.C. 115 23, Athens
Contact Number: (0030) 210 6475600
Fax: (0030) 210 6475628
E-mail: contact@dpa.gr
Applicable Law
The processing and protection of your Personal Data is governed by the terms of this Policy, the provisions of GDPR and the applicable Greek legislation which implements or supplements GDPR or otherwise is related to the processing of individuals’ Personal Data together with the binding directives and Codes of Practice issued from time to time from the respective supervisory authorities (see European Commission).
Changes in this Policy
Our Company reserves the right to update this Policy from time to time and post the most up-to-date version on its Website at any time without announcement. If substantial changes have been made our Company reserves the right to either post on its Website a relevant announcement relating to the amendments or inform you by sending a notification via e-mail and/or sms. We encourage you to check the Website at regular intervals in order to verify whether there have been any amendments, as well as to review from time to time this Policy in order to keep informed about the way in which our Company protects your Personal Data.
If you proceed with the use of our Website, you agree with this Policy and any updates. If you do not agree with the terms for the protection of Personal Data provided in this Policy you must not use our services.
This Policy was updated in March, 2024.