TERMS OF USE

ANASA PRIVACY POLICY (“Policy”)

LAST UPDATED: 20 OCTOBER 2019

1. OUR PROMISE TO YOU

We are committed to maintaining our customrs' privacy. We take great care to safeguard the personal information that we collect to ensure that our customers' privacy is maintained. We have provided this notice to you to describe our information collection and use practices as well as the choices you can make about the way your information is collected, used, and shared. This notice applies to any information collected by us through the use of our website and any other interactions with us as described below.

Your personal information is any information that can be used to directly or indirectly identify you. This includes information such as your name, email address and phone number. We may also collect personal information that does not directly identify you by name or contact information, but which may be used to identify that a specific computer or device has accessed our website or online services.

2. WHO IS IN CONTROL OF YOUR INFORMATION?

Throughout this Privacy Policy (policy’), ‘we’ or ‘Anasa’ means ‘MIL P.C.’, who is the controller and is responsible for processing your personal data.

By accessing and using this website and providing personal information to us, or by purchasing any services with us, you agree and consent to the collection, use and disclosure of your personal information as outlined in this policy.

3. COLLECTING INFORMATION ABOUT YOU

Information we collect from you

• Log information refers to information that is automatically sent by your web browser or device (or otherwise automatically collected by us) each time you view or interact with our online services and ads.

• Log information may include the online service(s) requested; date and time of your request; referring URL (i.e., the website you came from); browser type; browser language; device operating system; device hardware and other characteristics; information regarding your use of our online services (e.g., pages viewed, features used, number of clicks, time spent on a particular page); and related device and usage data.

• Log information is automatically recorded by our servers each time you view or interact with our online services and ads.

• Device information refers to device-specific information that we automatically collect when you view or interact with our online services and ads.

• Device information may include your device type and model; device operating system and version; unique device and advertising identifiers; mobile network information; and related device information.

• To learn more about the information your device may make available to us, please check the policies of your device manufacturer or software provider.

Information we collect from your use of our services

• Log information refers to information that is automatically sent by your web browser or device (or otherwise automatically collected by us) each time you view or interact with our online services and ads.

• Log information may include the online service(s) requested; date and time of your request; referring URL (i.e., the website you came from); browser type; browser language; device operating system; device hardware and other characteristics; information regarding your use of our online services (e.g., pages viewed, features used, number of clicks, time spent on a particular page); and related device and usage data.

• Log information is automatically recorded by our servers each time you view or interact with our online services and ads.

• Device information refers to device-specific information that we automatically collect when you view or interact with our online services and ads.

• Device information may include your device type and model; device operating system and version; unique device and advertising identifiers; mobile network information; and related device information.

• To learn more about the information your device may make available to us, please check the policies of your device manufacturer or software provider.

Information we collect online: Cookies and Similar Technologies

We use Cookies on this website. A 'Cookie' is a file in your web browser that enables us to recognise your computer when you visit the site and make using our website quicker and easier (e.g. login fields may be pre-filled with your email address). Cookies are also essential to the functioning of certain parts of the site and we use them to collect information about how the site is used, such as how many people visit and return and what products are being viewed. We may also use Cookies for marketing and to give you a more personalised experience on our website. For a complete list of the cookies we use and how we use them, please see our Cookie Policy.

Google Analytics 

Some of our online services may use Google Analytics, a web analytics service provided by Google.  Google Analytics utilizes cookies and similar technologies to collect and analyse non-identified information (i.e., data that does not identify a specific individual) about the performance and use of our online services and ads. More information on Google Analytics can be found here.  If you would like to opt-out of having your information collected and used by us and our online partners as described herein, please use the Google Analytics opt-out available here.

Information about other individuals 

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can give consent to the processing of their personal data and you can receive any data protection notices on their behalf.

Individuals associated with a business

If you are an individual associated with a business or other organisation that is our customer, then your personal data may include your business or organisation details, your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent); your contact details within that business.

Aggregated data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Your privacy and shared computers

If you log in to the website from a shared computer, such as in an internet cafe or from a colleague’s computer at work, Cookies may cause your email address to display in the login field to anyone who uses the site on that computer after you.  You can avoid this by clearing the Cookies stored by the web browser. The option to do this can normally be found within your browser ‘tools’ preferences. 

Information we obtain from external companies

We collect data that is publicly available. For example, information you submit in a public forum (e.g., a blog or social network) can be read, collected or used by us and others, and could be used to personalise your experience. You are responsible for the information you choose to submit in these instances.

From time to time we may supplement the information we hold about you with data from other commercially-available sources like the electoral roll and companies that collate and update data. This helps us keep our records up to date and learn more about our customers so we can continue to improve our products and services.


4. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a number of different purposes. Some are essential for us to provide the services you use or to fulfil our legal obligations; some help us run our business efficiently and effectively; and some enable us to provide you with more relevant and personalised offers and information. In all cases we must have a reason and a legal ground for processing your personal information. Some of the most common legal grounds we rely on are briefly explained below:

To confirm your marketing preferences – ie. when you sign up to newsletters or enter a competition. The lawful basis of processing is your 'Consent'. All of the details such as why we collect your data and how it will be used will be provided at the time of asking you for your consent. You can always opt-out of marketing communications using the ‘Unsubscribe’ links at the bottom of any of our emails.

To register you as a new customer and enable you to make bookings. Also to enable us to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you. The lawful basis of processing is the 'Performance of a contract' with you.

To manage payments, fees, charges and to collect and recover money owed to us. The lawful basis of processing is the 'Legitimate interests' to process financial information to keep payments secure and necessary for the performance of our contract with you.

To protect you against fraud when transacting on our website and ensure our websites and systems are secure. The lawful basis of processing is the 'Legitimate interests' to protect Anasa and its customers from fraudulent activities and compliance with a legal obligation.

To ensure our marketing is relevant to you. The lawful basis of processing is the 'Legitimate interests' to electronic direct marketing of similar products and services to that which you have acquired using our Website or, when such is not applicable, your Consent.

Note: Our Legitimate Business Interests do not automatically override your interests - we will not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law. Additionally, when we rely on 'Legitimate Interest', we will carry out a legitimate interest assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws.

To prevent criminal activity or help detect criminal activity. The lawful basis of processing is the 'Legal obligation' to disclose, potentially on occasion, your personal data with forces such as the Police, if requested. Where possible we will notify you when processing your data due to a legal obligation, however this may not always be possible. This is done in a safe and secure manner and you may not be notified.

• Providing our products and services. We use your personal information to provide our products and services, respond to queries and comments and provide you with the best possible level of customer service.

Our own internal purposes. We may use your personal information to improve our products and the effectiveness of our services, conduct analysis and to perform other business activities as needed.

• Marketing and advertising. We may analyse your personal information, including the products you view and buy, your browsing habits and other ways you interact with us, to evaluate the effectiveness of our advertising and help us provide more relevant offers and content. Rest assured, however, that we will only send you marketing material if you’ve agreed that we can, as outlined above. You can change your mind about receiving marketing material from us at any time by clicking the link at the bottom of any email we have sent you. Please be aware that due to our technical platform constraints, you may still receive material from us for up to 24 hours.

Research. From time to time we may invite you to take part in market research activities such as customer surveys, questionnaires, or focus groups. The lawful basis of processing is the 'Legitimate interests' in running our business and improve our Website and your experience.

5. SHARING YOUR INFORMATION 

Companies that provide services on our behalf

We may share your personal information with companies who provide services on our behalf that are related to our business. These tasks may include analysing site data, email services and other media services. These may also include necessary tasks to deal with any booking enquiry/request being made by or for you and to perform and administer any booking for you or other contract with or in respect of you.

Third party service providers only receive your personal information as required to perform their role and we instruct them not to use it for any other purpose.to third parties (including intermediaries) as 

Examples of the functions that may be carried out by external companies:

• Payment provider

• Companies that do fraud and money laundering checks

• Companies that provide web hosting, analytics, content providers, email marketing and competition.

• Data storage facilities

• IT services and support

• Yacht leasing

• Printers

• Companies that cleanse data

• Insurance companies

• Complaints investigation and response

We may work with other companies who place cookies, tags, and web beacons on our websites. These companies help operate our websites and provide you with additional products and services. We may also use third party advertising networks to serve advertisements on our behalf. The cookies received with the banner advertisements served by these networks may be used to collect and build behavioural profiles by these companies to deliver targeted advertisements on our website and unaffiliated websites.

Sharing data outside of the European Economic Area (EEA)

The EEA comprise of Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Swedenand the UK. Personal data can be transferred, processed and stored within these countries safely and securely as they offer an adequate level of protection to personal data.

There are number of additional countries that can also offer an adequate level of protection these are Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland and Uruguay.

Currently Anasa Experiences stores some of our data in the United States. If your information is to be sent outside EEA, we make sure it will be subject to standards of protection and security that are as high as those used here in the EEA. 

We take your data very seriously therefore we will always conduct a full review of all of our supplies processes and procedures including storage solutions for our data. In order to ensure adequacy when sending your data outside of the EEA we put in place contracts based on the Standard EU Model Contract Clauses which are designed by the European Commission to guarantee adequacy for any data transfer and processing of this nature.

Can I opt out of having my data shared?

As your data is stored safely and securely both inside and outside of the EEA we cannot offer alternative storage solution. If you wish to opt out of having your data stored outside of the EEA you will need to opt-out of our marketing.

Legal obligations

We may share your Personal Information with third parties where required or permitted by law, if we believe we need to do so to protect our rights and interests, or to comply with legal proceedings. In such cases, we will always do so legally and with due regard to your privacy.

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. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Changes to our business

If ownership of all or part of our business changes or we undergo a reorganisation, we will transfer your personal information to the new owner or successor company so we can continue to provide our services and we will notify you of the new data controller.


6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain documents (including electronic documents) containing personal data: (a) to the extent that we are required to do so by law; (b) if we believe that the documents may be relevant to any on-going or prospective legal proceedings; and (c) in order to establish, exercise or defend our legal rights (including providing information to others for purpose of fraud prevention and reducing credit risk).


7. LINKS TO OTHER WEBSITES

Our website may include links to third-party websites, 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. When you leave our Website, we encourage you to read the privacy notice of every website you visit.


8. SOCIAL MEDIA AND ADS

We engage with guests on multiple social media platforms (e.g., Facebook and Instagram). If you contact us on one of our social media platforms or otherwise direct us to communicate with you via social media, we may contact you via direct message or use other social media tools to interact with you. In these instances, your interactions with us are governed by this privacy policy as well as the privacy policy of the social media platform you use.

We may display targeted ads to you through social media platforms and other websites. These ads are sent to groups of people who share traits such as likely commercial interests and demographics. For example, we may target guests who have expressed an interest in shopping for yacht holidays in Greece.

If you have provided us with your email address and you consented to receive e-marketing, you may see ads that are tailored to your interests, based on the information we hold about you. For example, your location or the products you have browsed on our website. See the policies of each social media platform for additional information about these types of ads.


9. SOCIAL MEDIA PLUG-INS

Our online services may use social media plug-ins (e.g., the Facebook "Like" button) to enable you to easily interact with certain social media websites (e.g., Facebook, Instagram) and share information with others.  When you visit our online services, the operators of the available social media plugins can place a cookie on your device enabling such operators to recognize individuals who have previously visited our online services. If you are logged into these social media websites while visiting our online services, the social media plugins allow the relevant social media websites to receive information that you have visited our online services or other information. 

The social media plugins also allow the applicable social media websites to share information about your activities on our online services with other users of the social media website.  For example, Facebook Social Plugins allow Facebook to show your "Likes" and comments on our online services to your Facebook friends.  Facebook Social Plugins also allow you to see your friends' Facebook activity on our online services.  We do not control any of the content from the social media plugins. For more information about social media plugins from other social media websites, please refer to those websites' privacy and data sharing statements.


10. OUR "DO NOT TRACK" POLICY

We respect enhanced user privacy controls. We support the development and implementation of a standard "do not track" browser feature, which signals to websites that you visit that you do not want to have your online activity tracked. Please note that at this our website does not interpret or respond to "do not track" signals. However, you may set your Web browser to not accept new cookies or web beacons, be notified when you receive a new cookie, or disable cookies altogether. Please note that by disabling these features, your experience will not be as smooth and you will not be able to take full advantage of our website's features. Please see the Help section of your browser for instructions on managing security preferences.


11. MINORS

We recognize the importance of protecting children’s privacy online. Our website and services are intended for a general audience and are not directed at children. We do not knowingly collect personal information from children under the age of 13 (and 18 in Republic of Ireland).

If you are under the age of 18 and are a registered user of the site, you may request that we remove content or information that you have posted on our site or in our community. Please note that responding to your request may not ensure a complete or comprehensive removal (e.g., if the content or information has been reposted by another user.) To request removal, please contact us info@anasaexperiences.com.


12. YOUR RIGHTS IN RELATION TO YOUR DATA

We respect the fact that your personal information is your information, and we will always make it easy for you to update or change your personal details or marketing permissions. Please help us to help you by letting us know if your contact details change or if you spot any errors in the information we hold about you.

Your right of access:

If you would like a copy of the information Anasa Experiences holds about you or have any queries about the way we handle your personal information, please contact us at info@anasaexperiences.com.

Your right to request correction:

You may wish to request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data you provide to us. Please contact us at info@anasaexperiences.com to request that your data is corrected.

Your right to request deletion:

While you remain a customer we will process and retain your data as described in this policy. Once you cease to be a customer we will hold your data as described in the data retention section. You do have a right to request that we delete your personal data we hold. This is not an automatic right, depending on the type of data that we hold about you will depend on what we are able to delete. Please contact us at info@anasaexperiences.com to request that your data is deleted.

Your right to restrict or object processing:

You have to right to request that we stop certain data processing activates that involve processing your personal data. This can be processes such as collecting your name to deliver services to you, among other examples given above. A restriction to processing may be more appropriate if you contest the accuracy of your personal data or when you no longer need the information but we require it to establish, exercise or defend a legal claim. Depending on the type of data that we hold about you and the reasons for it, we may not be able to stop processing all your data. Please contact us at info@anasaexperiences.com to exercise your right to object or restrict the processing of your data.

Your right to data portability:

You have the right to 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. 

Your right to withdraw consent:

You have the right to 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.


13. CHANGES TO THIS PRIVACY POLICY

We may update this policy from time to time so we recommend that you check back here occasionally. If we make changes we think may affect you significantly, we’ll provide you with a prominent notice by the most appropriate medium so you know about the changes before they happen. We will always note the effective date of the latest version at the bottom of this notice.


14. HOW TO CONTACT US:

If you have questions or concerns about your privacy, you may contact our Data Protection Officer on info@anasaexperiences.com or by telephone on +30 23210 55696 (International call rates may apply if you’re not based in Greece). Alternatively, you may write to us by post at Anasa Experiences, Edessis 2, 62122, Serres, Greece. If you believe your privacy rights have been violated, you can file a complaint with the Data Protection Officer. You also have the right to complain to your local Data Protection Authority. If you are located in Greece, you may contact the HDPA, by accessing this link.

Copyright © 2019 Anasa , All rights reserved.