Policies regarding the processing of your data in accordance with current legislation and European Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Regulation on Data Protection).
Data Protection Officer
At first, we present information about our company, which is according to the law in force the controller of your personal data, and about our Data Protection Officer (DPO), who has been appointed by our company in order to carry out the following tasks:
- a) to inform and advise us for our obligations arisen by the relevant data protection regulatory framework
b) to monitor our compliance with the personal data protection legislation, through the assignment of responsibilities, awareness-raising and training of staff involved in processing operations, and through the related audits
c) to provide information, where requested, especially regarding the data protection impact assessment, ,
d) to cooperate with the HELLENIC DATA PROTECTION AUTHORITY and any other competent authority
e) to act as the contact point for the supervisory authority on issues relating to processing,
COMPANY NAME: SEA AIR LAND SERVICES EPE
ADRESS: Akti Andrea Papandreou Kamara 1, 19009 Rafina Attiki
PHONE: +30 22940 25222, +30 22940 24333
NAME AND CONTACT DETAILS OF (DPO): Kountouri Stavroula +30 22940 25222
- Which of your personal data we process?
- What is the purpose of your personal data processing?
- In which cases is your consent necessary for the processing of the data?
- Which personal data that we collect are directly provided to us by you?
- Which personal data we receive from third parties?
- With which third parties we share your personal data?
- How long we keep your personal data?
- Which are your rights regarding the processing of your personal data?
- Which of your personal data we process?
According to current legislation, personal data constitutes any information concerning an identified or identifiable natural person. An identifiable natural person is one whose identity can be verified, directly or indirectly, in particular by reference to an identifier, such as name, ID number, position data, linear ID, or one or more factors similar to physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person. Special categories of personal data, the processing of which is prohibited in principle (unless there is a legal exception), are the data regarding racial or ethnic origin, political views, religious or philosophical beliefs or participation in a trade union organization, the genetic, biometric data, health data or data on the sexual life of a natural person or his or her sexual orientation. Our company declares that does not process any personal data that falls within the aforementioned special categories of data.
Specifically, our company processes the following categories of data:
Data regarding your identity: This category includes data such as your name, username and password, in case of use of our application as a registered user or a similar ID, through which you use the application as a visitor ( The term “user” refers to either the registered user or the visitor), your date of birth, your gender, your passport or ID number, your place of birth, your nationality, the expiration date of the passport or of your identity, any numbers, numbers of discount cards (e.g. in case you have a unique Island number), etc. Our company may process third party identity data, even minors. The user may disclosure to us third parties’ data following their authorization. Minors’ data are disclosed only by their guardians or by people acting under their authorization.
Financial data: This category includes information about your payment of the provided services (e.g. proof of payment). In simple terms, this category of data refers to information about the services you purchased through our digital platform or our application. It is clarified that our company does not process the details of your payment cards, which you enter in our application to pay for the purchased services. The facilitation provided in the application regarding the storage of your card details (e.g. you save time, as there is no need to re-enter your card details each time you wish to do so a reservation), does not mean that we process the full details of your card. Your card details are stored within the application pseudonymized (for this reason the full number of the payment card does not appear on your screen), as sent to us by the respective payment institution that clears the relative transaction.
Technical data: These are data related to and serving your navigation in the digital platform or the application, such as Internet Protocol (IP) address, login details, navigation program you use, time zone and location, navigation / usage details in the application, operating system and its version, the size of the screen, the name of the device and its manufacturer, the IMEI code of the device, the version of the application in use, etc.
Advertising and usage data: This category includes information related to promotional material that a customer receives from us, his preferences and analysis of his behavior within the digital platform or the application, such as recent user searches, the frequency of use of the application, the frequency of purchasing similar services (e.g. booking tickets with similar passengers, frequency of similar trips), its “clicks”, time per screen, the home page through which it visits the digital platform or the the application, etc.
Which are the purposes for the procession of your personal data?
We process your data in accordance with the law, and only in the following cases:
- a) When you expressly consent to the procession of your personal data for one or more specific purposes, by explicitly stating it, within the application (e.g. when you register in our company’s newsletters, when you contact us through the application, when you consent to receive from us promotional material, in order to be informed about the range of travel services that may interest you and are provided through the application),
- b) processing is necessary for the execution of a contract (e.g., we process any data needed for the provision of our services or any data concerning your transactions, in order to ascertain the payment of the service you buy through the application),
- c) processing is necessary to comply with a legal obligation binding both of us,
- d) processing is necessary to safeguard your vital interest or that of another natural person,
- e) processing is necessary for the execution of a duty performed in the public interest,
- f) processing is necessary for the purposes of the legitimate interests we pursue, unless your interests or fundamental rights and freedoms prevail over those interests which require the protection of your personal data (especially if the data subject is a minor).
Which personal data that we collect are provided directly by you?
We collect data, provided directly by you, in case you consent to data procession or in case the relevant data are necessary for the use of the digital platform or the application or when the relevant data are necessary for the execution of your contract (e.g. for booking a trip, for the issuance of a ferry ticket). Data provided directly by you are for example data such as: name, surname, gender, address, passport or ID number, place of birth, nationality, date of birth, contact details (such as your e-mail or phone number), information about your discount cards (e.g. holder of Unique Islander Number, Loyalty card number), pricing information (e.g. TIN, name, address, Tax Office .), technical data concerning your device (such as IP address, time, location, version of the application) data relating the services that you purchase within the digital platform or application and the use of our services (travel data, recent searches, fellow travelers, etc.).
Which personal data we receive from third parties?
Your personal data that we collect from third parties are particularly technical data, relating to the data of your device (e.g. manufacturer, model, display features, operating system, etc.), or financial data (e.g. token with 4 last numbers of your payment card which you use for the payment of the desired services – remember that we do not process the full details of your payment card, your card details stored to the application only as a pseudonymized token, in order to make easier your future transactions through the application), as well as statistics or data of your behavior (e.g. clicks, selections).
Which third parties we share your personal data with?
Our company disclosures your personal data to the Third Providers (e.g. shipping companies, hotels), as they are listed in our digital platform and application, for the implementation of the provision of the services, which you have selected (e.g. to issue your ferry tickets, for a hotel booking, or a car rental), as well as to commercial partners performing data processing activities on behalf of our company (e.g. internet service providers, advertising service providers or technical support providers, such as customer services and services regarding our communication with the Third Providers.
How long we keep your personal data?
The procession of your data are secured, as we have adopted appropriate organizational and technical safeguard measures for the conformity of the data processing with the personal data applicable legislation and the decisions, opinions, guidelines of the Hellenic Data Protection Authority. In case you are a registered user, we keep your personal data for as long as your account in our digital platform or application remains activated, so that we can respond more effectively to any of your requests (e.g. in case of registration you choose to view your booking history, or the names of your fellow passengers in order to facilitate faster performance of similar future bookings). In any case, you have the right to delete your personal data at any time within the term of our contract between us. Also, in any case, we keep your data for as long as necessary in accordance with T&C of each service and the relevant applicable law. Especially for the trackers we use, the storage time of the collected data is set in a table that follows in the Trackers Policy listed below.
Which are your rights regarding the processing of your personal data?
According to the applicable data protection law, your rights as data subjects are the following:
Your right to transparent information: You have the right to be informed clearly by us about any processing of your personal data. Only after your clear information we can secure your lawful consent where this consent is required.
Your right to consent: Your right to consent to the processing of your data is freely revocable, which means that you may revoke your consent at any time.
Your right of access: You have the right to ask us for copies of your personal information.
Your right to rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction: In some cases you have the right to ask us to restrict the processing of your personal data.
Your right to object to the processing: In some cases, you have the right to object to the processing of your personal data.
Your right to data portability: In some cases, you have the right to request that we transfer the personal information you provided from one organisation to another, or give it to you.
If you make a request, we have one month to respond to you.
In case our response does not satisfy you, you have the right to file a complaint before the Hellenic Data Protection Authority based in Athens on Kifisias Avenue 1 (PC 115 23), with telephone number 2106475600. Before filing a complaint, consult the official website of the Authority “www.dpa.gr”, to check that your complaint can be legally admitted.