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Corporate Data Protection Policy

Magna Travel \ Corporate Data Protection Policy

Corporate Data Protection Policy

MAGNA GROUP ANONIMI ETAIRIA-GRAFIO GENIKOU TOURISMOU-NAVLOSI AEROSKAFON KAI SKAFON ANAPSICHIS
Andrea Papandreou Street 108, Glyfada 16674, Attica
Tel: +302109605555
info@magnatravel.gr & info@magna-aviation.com

PRIVACY POLICY
By the Regulation (EU) 2016/679, on the protection of natural persons concerning the processing of personal data (GDPR) of the company under the name MAGNA GROUP ANONIMI ETAIRIA-GRAFIO GENIKOU TOURISMOU-NAVLOSI AEROSKAFON KAI SKAFON ANAPSICHIS and the distinctive title "MAGNA AVIATION", as Controller and/or Processor of Personal Data.

 

  1. Overture
MAGNA GROUP ANONIMI ETAIRIA-GRAFIO GENIKOU TOURISMOU-NAVLOSI AEROSKAFON KAI SKAFON ANAPSICHIS company with the distinctive title "MAGNA AVIATION", based in Glyfada, Attica, and legally represented herein as "MAGNA AVIATION", acknowledges the fundamental significance of safeguarding personal data. It has fully complied with its obligations as a Data Controller as mandated by the General Data Protection Regulation (EU) 2016/679 (GDPR) of the European Parliament and of the Council concerning the protection of natural persons in relation to the processing of personal data.
MAGNA AVIATION collects and processes personal data pertaining to individuals for the purpose of delivering its services, fulfilling its legal obligations, and serving its legitimate interests. The protection of Personal Data (PD) constitutes a principal concern of MAGNA AVIATION.
This Policy, in accordance with Article 13 of the EU General Data Protection Regulation 2016/679 (GDPR) and the relevant Greek legislation in force at any given time, informs you: a) about the personal data concerning you that MAGNA AVIATION collects and processes, b) the legal basis for their processing, c) the purposes for processing your personal data, d) how they are used and protected, and e) the options and rights you have under the aforementioned legal framework.
This Policy is addressed to any natural person who transacts with and/or comes in any way in contact with MAGNA AVIATION. Because this Policy may be amended from time to time to always be updated and in accordance with the applicable provisions, please regularly visit the websites of MAGNA AVIATION, www.magna-aviation.com, and www.magnatravel.gr, to ensure that you are aware of any changes. This PD protection policy will also be available at the reception points of MAGNA AVIATION customers.
 
  1. Personal Data – Basic Definitions
    1. According to the General Data Protection Regulation:
      1. “personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
      2. “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
      3. “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data
      4.  “processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
      5.  “consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
    2. The protection concerns all personal data that have come or will come to the knowledge of MAGNA AVIATION in the context of its lawful operation and the provision of its services.
    3. The scope of MAGNA AVIATION is the activities of travel agencies and the chartering of aircraft and yachts. MAGNA AVIATION provides services of organized tours (travel packages), tourist promotion and visitor information services, sale services of air tickets for the carriage of persons with commission, booking services for vehicle rental, travel agency services for transportation reservations, services for the sale of foreign steamship tickets with commission, sale services of steam tickets for the transportation of persons with commission, travel agency services for accommodation, cruises and package travel reservations (travel packages), booking services for package travel (travel packages), other reservation service activities and related activities, tourist guide services, rental services of third party owned passenger ships with crew, rental services of pleasure boats (yachts, yachts, gas boats, etc.) with crew, rental services of air equipment transportation of passengers with an operator, etc.
    4. This Policy is applicable to your utilization of our Services, irrespective of whether electronic means are employed.  
    5. Please note that in relation to your online activity, while browsing the websites of MAGNA AVIATION, we want to inform you about the processing of personal data and your rights as a data subject. For detailed information, please refer to the Privacy policy of each website: www.magna-aviation.com & www.magnatravel.gr.
    6.  MAGNA GROUP SA, in order to operate in accordance with the prevailing legislative framework, has undertaken a series of requisite actions, implementing appropriate technical and organizational measures for the lawful maintenance, processing, and safeguarding of personal data files. This is to ensure and protect the processing of personal data against loss, leakage, alteration, unlawful transmission, or any other form of unlawful processing.
  2. Data Controller Information
    1. MAGNA GROUP ANONIMI ETAIRIA-GRAFIO GENIKOU TOURISMOU-NAVLOSI AEROSKAFON KAI SKAFON ANAPSICHIS company with the distinctive title "MAGNA AVIATION", based in Glyfada, Attica, is the Controller of the Personal Data you have provided to us or which we collect about you, in accordance with this Policy.
    2. The employees, with any employment relationship at MAGNA AVIATION, who process personal data are "persons acting under the supervision of the controller" (as defined in Article 29 of the GDPR)
    3. MAGNA AVIATION is exempted from the obligation to appoint a Data Protection Officer (DPO) (Article 37 GDPR).
  3. What purposes do we process data for?
We collect and process personal data to manage your business relationship and offer you, our services. Some personal data is collected to provide you with personalized and improved services. We collect personal data to:
 
    1. The provision of tourist services and chartering of aircraft and pleasure craft, in particular:
      1. Creation and storage of legal/tax documents by applicable law
      2. Booking, purchasing and issuing tickets of all means of transport on your behalf.
      3. Booking hotels, buying accommodation and managing your access to and stay in them.
      4. We manage lists with customers' personal data for operational/organizational reasons, such as nominal lists of participants in group trips.
      5. Facilitating the issuance of travel documents (visas)
      6. The termination of a Travel Insurance Agreement for excursionists concerning personal accidents and health shall be executed in accordance with the stipulations outlined in each individual contract. Furthermore, in the event of an incident that triggers the insurance coverage (whether it be an accident or illness), the insured party is required to provide consent for the transmission of all requisite documentation to the insurance company in order to facilitate compensation. For travelers under the age of 15, consent must be secured by holding parental responsibility.
      7. Chartering means of transport and VIP transfers in accordance with the terms of the providers of these services.
      8. Booking, purchasing, and issuing tickets for all forms of transport; booking hotels; securing accommodations; and managing access and lodging for groups of business personnel.
      9. The provision of Check In services
    2. Enhancing our services.
      1. To customize our products and services to meet your needs better
      2. We use your personal data in marketing programs for promotional purposes and to better understand your needs and preferences.
      3. We would like to inform you of our special offers and newly introduced services.
    3. The compliance of MAGNA AVIATION with Greek law and European regulations.
    4. Processing for Other Purposes.
MAGNA AVIATION may engage in additional processing of personal data for purposes distinct from those for which the personal data was initially collected. In such instances, we shall furnish you with all requisite information regarding this new purpose and any other relevant information before the commencement of any further processing.
  1. What personal data do we collect
    1. Information you provide directly to us:
Information we are obliged to request from you and/or your family members is the following:
      1. Contact information (e.g., last name, first name, father's name, passport number, ID card details, phone number, home address, email)
      2. Personal Information (such as date of birth, nationality, and place of birth)
      3. Information about your children (e.g. name, date of birth, passport number)
      4. Billing information (e.g. credit card number, VAT number)
      5. Loyalty Program Membership Number (the number associated with a third-party loyalty program, such as an airline's)
      6. Preferences and interests (e.g. non-smoking room, preferred floor, type of bed, sports, cultural interests, pet details, etc.)
      7. Dietary preferences and habits.
      8. Medical information pertaining to your health, including but not limited to allergies, medical reports and certificates, results from medical examinations, and data concerning pathological diseases.
      9. Comments and questions made during or after our provision of services are welcome.
      10. The Personal Data we collect relating to individuals under the age of 16 is limited to Name, Surname, Nationality and Date of Birth and may only be provided to us by an adult guardian. We are grateful for any action you take to ensure that your children do not send us personal data without your consent (especially over the Internet). If you send us such information, you can contact the company "MAGNA AVIATION" to schedule the deletion of this information.
      11. Furthermore, Personal Data, including but not limited to your passport copy, recreational activities, hobbies, any health issues you may experience, dietary habits, and smoking status, may be classified as sensitive information. We will only process such information if it has been provided by you for your own use or on behalf of individuals for whom you hold custody (or parental responsibility), in compliance with applicable laws, or if you have explicitly granted your consent to us or a third-party partner. This includes circumstances where such information is necessary to provide appropriate services or recommend a customized package of services that meets your specific needs.
      12. The collection of information directly from you takes place when you contact us by phone or with physical presence at our premises, our communication via email, short text messages (sms), internet telephony applications (Voice over IP eg. Skype, whatsapp), collecting information during your visits to our websites and our online communication, viewing our online content, subscribing to our Newsletter, online expression of interest in booking or using our other services.
      13. Some of our Services enable you to provide information directly to us by allowing the users to create online accounts. In conjunction with these Services, we may ask you to provide certain information about yourself in order to set up your account. For example, you may submit certain information about yourself, such as your name and email address, when you subscribe to our business newsletter or fill out our online contact form.
    2. Information from third parties:
      1. We may collect information from other sources, including commercially available sources or public sources (sources open to the public, such as, for example, an internet telephone directory or public directories of members of professional associations, associations, associations, and professional sectors), as permitted by law. Examples of information we may collect from other sources are your Name and Email Address.
      2. We may combine all the information we have gathered about you and from you to enhance our communication and develop high-quality products and services.
      3. We might also obtain information about you from third-party social networking services when you opt to connect to those services.
    3. The provision of personal data to us is primarily a contractual obligation or requirement for concluding a contract, and in some cases, it is our legal obligation. If you choose not to provide us with the Personal Data listed above, we may not be able to provide you with our services.
 
  1. Social media links / Social plug-ins.
    1.  MAGNA AVIATION's websites include links to social media such as Twitter, TikTok, YouTube, Facebook, and Instagram, as well as links to websites of other bodies and organizations in Greece. HTML links have been incorporated into this website, which enable easy access to social media platforms and third-party websites. Any connection of MAGNA AVIATION's websites  (www.magnatravel.gr and www.magna-aviation.com/) through special links (links, hyperlinks, banners) with any other website does not imply that MAGNA AVIATION assumes any responsibility for the policy followed on this website regarding the protection of personal data.
    2. For more information on the purpose and extent of data processing and the further use of your personal data by providers and their websites, as well as on your rights and possible privacy settings, please refer to the data protection information of the respective service provider.
 
Twitter: https://twitter.com/en/privacy
Facebook: http://www.facebook.com/policy.php
Instagram: https://help.instagram.com/519522125107875
Tik Tok https://www.tiktok.com/legal/page/eea/privacy-policy/en
YouTube https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/
 
  1. Terms of Third-Party Access to Your Personal Data
    1. The information we collect from you is not transferred, sold, leased or in any other way disclosed to unauthorized third parties without your information and approval.
    2. The recipients or third parties to whom we may disclose personal data are primarily the following:
      1. Employees of MAGNA AVIATION. To provide you with the best possible service, we provide access to your personal data or to specific categories of your personal data, to our appropriate and authorized staff, regardless of whether they are located at MAGNA AVIATION's headquarters or its branches. In this case, we make sure to obtain contractual commitments from employees (such as confidentiality clauses) to protect your personal data and comply with the confidentiality of your personal information.
      2. Other natural or legal persons who process personal data on behalf of MAGNA AVIATION as "processors" (as defined in Article 4 No. 8 GDPR). We may disclose your personal data to agents or service providers who work for us or provide services to us, such as accountants, IT companies, companies that send bulk emails on our behalf, banks, law firms, mail service companies, etc. In any case in which any of our direct partners during the performance of the contract between us acquires access to personal data processed by MAGNA AVIATION, then under the responsibility of MAGNA AVIATION, a confidentiality agreement is drawn up, the terms of which are binding and form an integral element of the main contract.
      3. To your travel sponsor. Our services to you are provided in accordance with the terms of your employer's or travel sponsor's service agreements. We transmit your data in order to enable them to exercise permissible and appropriate control over the organization and implementation of business trips they undertake to offer you.
      4. Travel suppliers and other travel service providers as well as aircraft and yacht suppliers. We share information with travel suppliers, such as airlines and hotels, and travel service providers, like ticket distribution systems and travel app providers, along with their partners, as needed to book travel and provide services to you or your travel sponsor. We do not sell information to third parties in a way that enables them to promote their own products or services directly to you.
      5. Business partners. We may also share your personal data with trusted business partners, who will use your information to deliver the services you have requested, in accordance with our contract that we cannot fulfill directly on our own.
      6. In addition to the disclosures outlined in this Policy, we may transfer information about you to third parties if you explicitly request it in writing and provide your consent purpose.
      7. Finally, we may disclose your information to government entities, courts, commercial or other dispute resolution bodies, supervisory and regulatory authorities to comply with applicable law, in cases where we believe that such disclosure is permitted or required by law or by regulatory or legal process, or to defend the interests, rights, property, or safety of our business others.
 
  1. Your marketing options
We may use your data to promote our products and services to you. We respect your preferences regarding how you wish to receive marketing communications from us issues.
    1. In particular, regarding emails used for the direct promotion of products and services similar to those already provided by us, our company complies with the privacy rules governing the Protection of Personal Data and privacy in the electronic communications sector (Law 3471/2006), which takes precedence over the General Regulation EU 679/2016 due to its specificity. Under this provision, we will use the data from an email contact or telephone number, lawfully obtained during the sale of products or services or in our dealings with you, to directly promote similar products or services of ours or to pursue similar purposes. If you do not agree with the use of your contact details for this purpose, you have the opportunity to clearly express your disagreement with the collection and use of your electronic contact information by visiting the respective websites: www.magna-aviation.com & www.magnatravel.gr
    2. If you choose to subscribe to our newsletter, you will provide contact information (email) so we can send you informative content. Your choice is made through your action, which is deemed a declaration of consent by checking the information option in the appropriate field on our website or by giving us your clear consent in a relevant form at our offices.
 
  1. Cookies, Beacons and Similar Technologies
    1.  As you navigate a website, certain information may be passively collected (i.e., aggregated without your active input) through various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, and navigation data collection. We, along with certain third parties that provide content, advertising, or other functionality on our services, may utilize these technologies in specific areas of our platform Services.
    2. For more information, you can refer to our Cookie Policy and check our Cookie Settings Panel for detailed information about cookies and other tracking technologies used on our website [see Cookies Policy]. This policy also provides information on how to disable cookies and tracking technologies if you do not agree to their use. If you do not disable any cookies or other tracking technologies, we will infer your consent to their use.
 
  1. Protection of Personal Data during International Transfer
    1. If you choose to travel abroad, your personal data will be transferred to third parties, within or outside the EU, in countries that offer different levels of personal data protection, depending on where you are destination, in order to provide you with the services you have chosen, otherwise for the performance of our contract and with your consent.
    2. Please note that the data protection and other laws in the countries you are traveling to, and to which your personal data may be transferred, might not be as protective as those in your country. The transfer will be made in accordance with the legislation regarding the processing of personal data to ensure adequate protection of your personal data.
    3. Our company takes appropriate measures to ensure the safe transfer of your personal data to an external recipient in a country that provides a different level of protection than that required by the General Data Protection Regulation (GDPR).
 
  1. Retention of your personal information
    1. Access to your personal data will be deleted or blocked when the time related to their storage purpose has elapsed. Furthermore, storage for a longer duration is possible if it is stipulated by European and national legislation in union law regulations or other provisions to which MAGNA AVIATION, as Data Controller, is subject. The blocking of access or deletion of data also occurs after the retention period defined in the individual policies adopted by MAGNA AVIATION has expired. However, the continued retention of personal data is deemed lawful when necessary for exercising the right to freedom of expression and information, compliance with a legal obligation, performance of a task carried out in the public interest or exercise of official authority vested in the controller, reasons of public interest in public health, archival purposes in the public interest, scientific or historical research purposes, statistical purposes, or for establishing, exercising, or supporting legal rights claims.
    2. When processing is performed on a contractual basis, your data is stored for as long as necessary for the performance of the contract and for the establishment, exercise, and/or support of legal claims under the contract. In addition, we will retain your PD for as long as it is still required until the statute of limitations of any claims expires.
    3. MAGNA AVIATION, in compliance with its legal obligations, retains personal data only for the duration necessary for the purposes of its processing, as defined by applicable regulations law.
    4. Since the processing of your Personal Data relies on your prior consent, your Personal Data will be retained until you withdraw the explicit consent you have provided. You may withdraw your consent at any time. The withdrawal of consent does not impact the legality of processing based on consent during the period prior to withdrawal. For instructions on how to withdraw your consent, please refer to paragraphs 13 and 14 of this.
 
  1. Information Security
    1. MAGNA AVIATION has implemented reasonable organizational and technical measures to protect your personal data collected in connection with its services, particularly any sensitive personal data. Our IT partners adhere to international standards and practices to ensure the security of our facilities and data encryption. However, while we take reasonable steps to safeguard your personal data, security cannot be absolutely guaranteed against all threats.
 
  1. Your Rights
    1. Data subjects retain all rights under applicable Greek and EU provisions, noting that the GDPR does not eliminate obligations from other legal provisions. Specifically, in accordance with the legislative framework for personal data protection, as it stands at any given time, each data subject is granted the following rights:
    2. Right to Information: You have the right to be informed about how your personal data is collected and used.
    3. Right of access: You have the right to obtain from MAGNA AVIATION confirmation as to whether or not your personal data are being processed, and if so, you have the right to access your personal data in a short, intelligible, transparent, and easily accessible format.
    4. Right to Rectification: You may request that MAGNA AVIATION promptly correct any inaccurate or incomplete Personal Data, including through a supplementary statement.  
    5. Right to erasure: You have the right to request the deletion of your Personal Data from MAGNA AVIATION without undue delay, and we are obligated to carry out the deletion under the conditions set by law.
    6. Right to restriction of processing: You have the right to request MAGNA AVIATION to restrict processing activities only to specific purposes, under the conditions set by law.
    7. Right to object: You have the right to object, at any time and for reasons related to your particular situation, to the processing of your personal data. MAGNA AVIATION will no longer process your personal data unless it demonstrates compelling legitimate grounds for the processing that overrides your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
    8. Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, as well as the right to request the transmission of such data to another controller without objection, under the conditions set by law.
    9. Withdrawal of Consent: If the processing of your personal data is based on your prior consent for one or more specific purposes, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
    10. All information provided pursuant to Articles 13 and 14 of the GDPR and any communication, as well as all actions taken pursuant to Articles 15 to 22 and Article 34 of the GDPR, shall be provided free of charge. If your requests, as a data subject, are manifestly unfounded or excessive, in particular, due to their repetitive nature, MAGNA AVIATION may either:
(a) charge a reasonable fee, considering the administrative costs of providing the information or communicating or carrying out the action requested; or (b) refuse to act on the request.
    1. MAGNA AVIATION does not subject your Personal Data to automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
    2. MAGNA AVIATION will fulfill your requests in accordance with the conditions set by law. The ability to exercise a right granted to you by law does not always mean it can be completely satisfied, especially when other legal provisions impose limitations. If we are unable to fulfill your request, we will inform you of the reasons.
 
  1. How you can exercise your rights
    1. MAGNA AVIATION respects your rights concerning personal data and assists you in exercising them. Any request, question, or complaint regarding your personal data and the exercise of your rights should be submitted in writing to MAGNA AVIATION.
Contact:
MAGNA GROUP ANONIMI ETAIRIA-GRAFIO GENIKOU TOURISMOU-NAVLOSI AEROSKAFON KAI SKAFON ANAPSICHIS and the distinctive title "MAGNA AVIATION",
Address: Andrea Papandreou 108, 
P.C. 16674, Glyfada, Attica,
Ôçë: 2109605555
Fax: 2109602565
info@magnatravel.gr & info@magna-aviation.com
    1. Once the legality of your request has been verified, we will respond to it within thirty (30) days of receipt. If an extension of the above deadline is required for the investigation and/or processing of your request, we will inform you, accordingly, explaining why extending the deadline is necessary.  
 
  1. Right to Complain
    1. In any case, if you feel that the protection of your personal data has been violated in any way, you have the right to lodge a complaint with the Hellenic Data Protection Authority (www.dpa.gr)
 
  1. Update
    1. This Policy may be amended in accordance with applicable law or to achieve best practices. The most current version of the Policy will always be on our business websites www.magna-aviation.com & www.magnatravel.gr. By accessing or using our Services after we have posted such an updated version of the Policy, you agree to the new practices contained in the update.
    2. A printed copy of this Policy is available at the reception points of MAGNA AVIATION customers.
 
  1. Questions and Contact
    1. For any questions about this policy or the protection and security of data in our business, please contact our company's Legal Coverage Department at the following: address:

MAGNA GROUP ANONIMI ETAIRIA-GRAFIO GENIKOU TOURISMOU-NAVLOSI AEROSKAFON KAI SKAFON ANAPSICHIS with the distinctive title "MAGNA AVIATION",
Address: Andrea Papandreou 108, 
P.C. 16674, Glyfada, Attica,
Ôçë: 2109605555
Fax: 2109602565
info@magnatravel.gr & info@magna-aviation.com

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