Personal Data Protection Policy
According to the General Regulation (EU) 2016/679, for the protection of natural persons against the processing of personal data (GDPR) of the company under the name MAGNA GROUP SA – OFFICE OF GENERAL TOURISM-AIRCRAFTS & RECREATIONAL CRAFT CHARTERING, under the trading name “MAGNA GROUP SA”, as Processing Manager and/or Processing Executioner of Personal Data
The company MAGNA GROUP SA – OFFICE OF GENERAL TOURISM-AIRCRAFTS & RECREATIONAL CRAFT CHARTERING, under the trading name “MAGNA GROUP SA”, with registered office at Glyfada, Attica and legally represented (hereinafter “MAGNA GROUP SA”) has fully complied with the obligations as a Data Processing Manager under the General Data Protection Regulation (EU) 2016/679 (GDPR) of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data (GDPR).
MAGNA GROUP SA collects and processes personal data concerning you, in order to provide services, to fulfil its legal obligations and to service its legal interests. The protection of personal data (PD) is a key concern for MAGNA GROUP SA.
The current Personal Data Protection Policy in accordance with the Article 13 of the General Data Protection Regulation of the EU 2016/679 (GDPR), but also the applicable Greek legislation, informs you: a) about the personal data that concerns you and that is collected and processed by MAGNA GROUP SA, b) the legal basis of their processing, c) the purposes of the processing of your personal data, d) the way it uses and protects your personal data and e) the possibilities and rights you have under the aforementioned legal framework.
The current Personal Data Protection Policy is addressed to any natural person who trades and / or comes in any way in contact with MAGNA GROUP SA and the affiliated companies Magna Travel, Magna Concierge and Magna Aviation. As the current Protection Policy might be amended from time to time and at any time in order to be up-to-date and in accordance with the applicable provisions, please visit the MAGNA GROUP SA website http: //www.magnatravel.gr regularly to ensure that you are aware of any changes. This PD protection policy will also be available at the customer service points of MAGNA GROUP SA.
2. Personal Data-basic definitions
2.1 According to the General Regulation for the Personal Data Protection
2.1.1 “Personal data“: is any information concerning an identified or identifiable natural person (“data subject”), such as name, email address, VAT number, etc. Identifiable is defined as a natural person whose identity can be verified, directly or indirectly, in particular by reference to an identifier such as name, ID number, location data, online identity (IP address, e-mail etc…) or one or more of the factors specific to his physical, physiological, genetic, psychological, economic, cultural or social identity.
2.1.2 ‘’Processing’’: is any operation or series of operations performed with or without the use of automated media, on personal data, such as the collection, registration, organization, structure, storage, customization, modification, retrieval, information retrieval, use, transmission to third parties, dissemination, association, combination, restriction, deletion and destruction of personal data.
2.1.3 ‘’Processing manager ‘’ of personal data, is the physical or legal person, public authority, service or other body that individually or in conjunction with others, determines the purposes and manner of personal data processing.
2.1.4 “Processing executioner” of personal data, is the physical or legal person, public authority, service or other body that processes personal data on behalf of the processor.
2.1.5 ‘’Consent’’: The data subject’s consent is any indication of a free, specific, explicit and fully informed will, in which the data subject indicates that he/she agrees, with a statement or a clear affirmative action, to the processing of personal data concerning him/her.
2.2 The protection concerns all personal data, which have come or will come to the knowledge of MAGNA GROUP SA and its affiliated companies, in the context of the legal operation and the provision of services of the Company
2.3 The object of MAGNA GROUP SA is the travel agencies activities. MAGNA GROUP SA provides services of organised travels (Travel Package), Tourist Promotion and Visitor Information Services, Airline Ticket Sales Services for individuals transportation with a commission, Vehicle renting Services, Travel agencies services for transportation reservations, Steamboats ticket sales for individuals transportation with a commission, Travel agency services for accommodation, Cruises and package tours, package tours services, tour guides services, Rental services for passenger ships owned by third parties with crew, Rental services for recreational crafts (yachts, pleasure yachts, gasoline vessels, etc.) with crew, rental services of air transportation means with operator.
2.4 The protection policy applies to your use of our Services with or without the use of electronic means
2.5 Please note that for your online business browsing on MAGNA GROUP SA and / or its affiliates and your information on the processing of personal data and your rights as a data subject, you should refer to in the Protection Policy of each website http: // www.magnatravel.gr
2.6 MAGNA GROUP SA, in order to comply with the applicable legal framework has taken a series of actions required, implementing the appropriate technical and organizational measures for the legal maintenance, processing and secure storage of personal data files, so that to ensure and protect in any way the processing of personal data from loss or leakage, alteration, illegal transmission or in any other way their improper processing.
3. Processing Manager
3.1 MAGNA GROUP SA – OFFICE OF GENERAL TOURISM-AIRCRAFTS & RECREATIONAL CRAFT CHARTERING, under the trading name “MAGNA GROUP SA”, with registered office at Glyfada, Attica is the Processing Manager of Personal Data provided or collected for you, according to the current Protection Policy and Personal Data Protection.
3.2 Employees, with any labour relationship, in MAGNA GROUP SA, who process Personal Data, are “persons acting under the supervision of the processing manager” (according to the definition of article 29 of the GDPR).
3.3 MAGNA GROUP SA is exempt from any obligation to appoint a Data Protection Officer (DPO) (Article 37 of the Code of Civil Procedure).
4. For What Purposes Do We Collect Data?
We collect and use personal data to manage your relationship with our business and to be able to offer you our Services. Some personal data is collected to provide you with personalized and improved services. We collect personal data for the purpose of:
4.1 Provision of tourist services, specially:
4.1.1 Creation and storage of legal/tax documents in accordance with the applicable law
4.1.2 Reservation, purchase and issue of tickets for all means of transport on your behalf.
4.1.3 Hotel reservation, purchase of accommodation and management of your access and accommodation.
4.1.4 We manage lists of personal customer data for operational / organizational reasons such as lists of participants in group tours.
4.1.5 The issue of travel documents (visa)
4.1.6 The Conclusion of Travel Insurance Contract of the travellers for personal accidents & health, according to the terms of the respective contracts. Also, in case of an incident included in the insurance contract (accident or illness) you must give your consent for the transfer to the insurance company of all the necessary documents, in order to be reimbursed. For minors under the age of 15, there must be the consent of the parent.
4.1.7 The chartering of means of transport & VIP transportation, according to the terms of the providers of these services.
4.1.8 The reservation, purchase and issuance of tickets for all means of transport, hotel reservation, accommodation purchase and management of access and accommodation in them for groups of business personnel.
4.1.9 Check-in services
4.2 The improvement of the offered services
4.2.1 in order to adapt our products and Services as to meet your requirements
4.2.2 We process your personal data through marketing programs for the purpose of marketing and promote actions, and in order to better understand your requirements and desires.
4.2.3 We inform you on special offers and new Services
4.3 The compliance of MAGNA GROUP SA with the Greek and European Law
4.4 Processing for other reasons: MAGNA GROUP SA might further process your personal data for another reason than the reason for which the data was collected. In this case, we provide any necessary information before any further processing.
5. What personal data do we collect?
5.1 Information directly provided us:
5.1.1 Contact details (e.g. surname, first name, fathers name, passport number, ID details, phone number, home address, email)
5.1.2 Personal Information (e.g. date of birth, nationality, place of birth)
5.1.3 Information about your children (e.g. name, date of birth, passport number).
5.1.4 Invoicing data (e.g. credit card number, TIN)
5.1.5 Loyalty Program Member Number (the membership number for a third party loyalty program such as that of an airline)
5.1.6 Preferences and interests (e.g. non-smoking room, preferred floor, bed type, sports, cultural interests)
5.1.7 Nutritional preferences and habits
5.1.8 Medical data related to your health such as allergies, medical opinions and certificates, results of medical examinations, data of pathological diseases, etc.
5.1.9 Questions and comments asked during or after the provision of our services.
5.1.10 The Personal Data we collect that relates to persons 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 caregiver. We are grateful for any action you take to ensure that your children do not send us personal information without your consent (especially online). If, however, such information is sent, you can contact to firstname.lastname@example.org to schedule the erasure of this information.
5.1.11 In addition, Personal Data, such as a copy of your passport, your leisure activities, your hobbies, any health problems you may have, your eating habits, or whether you are a smoker or not, may be considered sensitive. We only process such information if you have provided it solely for yourself or for the persons you have the right of custody (or the parental responsibility), if required by the applicable law or if you have given us your express consent (e.g. in order to provide the appropriate Service, or to offer you a package of services which meets your needs).
5.1.12 The collection of information directly from you takes place when you contact us by phone or personally at the facilities of our company, our communication via e-mail, text messages (sms), internet voice applications (Voice over IP e.g. Skype), the collection of information during your access to our websites and our online communication, the promotion of our online content, your subscription to our Newsletter, or the use of other services.
5.1.13 Some of our Services enable you to provide information directly to us by enabling users to create online accounts. In combination 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 company newsletter or fill out our online contact form.
5.2 Third party information
5.2.1 We may collect information from other sources, including commercially available sources or from public sources (sources open to the public such as, for example, phonebooks, the Internet, professional associations public lists, organizations, associations, professional branches) according to what is allowed by law. Examples of information we may collect from other sources are Your Name and Email Address.
5.2.2 We can combine all the information we have collected about you and from you in order to improve our communication and develop high quality products and services.
5.2.3 We may also receive information about you from third-party social networking services when you access these services.
5.3 The provision of Personal Data is primarily a contractual obligation or requirement for the conclusion of a contract and in some cases is our legal obligation. If you choose not to provide us with the aforementioned Personal Data we may not be able to provide our services.
6. Links with social media/Plug-in of social media
6.1 The websites of MAGNA GROUP SA include links to social media such as twitter, Facebook and instagram, as well as links to websites of other institutions and organizations in Greece. In this website there are integrated HTML links, which make it easy to access social media platforms and third-party websites. Any connection of the websites of MAGNA GROUP SA (http://www.magnagroup.gr/, http://magna-concierge.gr/, http://www.magnatravel.gr/, http: // magna-aviation .com /) through special links (links, hyperlinks, banners) with any other website does not imply the assumption by MAGNA GROUP SA of any responsibility for the policy pursued on this website regarding the protection of personal data.
6.2 For further information on the purpose and extent of data processing and the further use of your personal data by the providers and the websites, as well as your rights and possible privacy arrangements, refer to data protection information of the respective service provider.
7. Terms for third party access to your personal data
7.1 The information collected from you is not transferable, sold, leased or otherwise disclosed to unauthorized third parties without your previous notice and approval.
7.2 Those to whom we might disclose your personal data are the undermentioned categories :
7.2.1 Employees of MAGNA GROUP SA. in order 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 authorized staff, regardless of whether they are employed at the headquarters of MAGNA GROUP SA or at the branches. In this case, we make sure that we obtain from the employees contractual commitments (such as confidentiality clauses) for the protection of your personal data and the observance of the confidentiality of your personal information.
7.2.2 Affiliated companies: Your personal data may be shared with affiliated companies of our company.
7.2.3 Other natural or legal persons that process personal data on behalf of MAGNA GROUP SA as “performers of the processing” (as defined in article 4 no. 8 of the GDPR.). We may disclose your personal data to affiliated companies, agents or service providers who work for us or provide services to us, such as Accountants, IT companies, companies that send chain emails on our behalf, banks, law firms, postal service companies, etc. In any case any of our direct partners during the execution of the contract, has access to personal data processed by MAGNA GROUP SA, then under the responsibility of MAGNA GROUP SA, a confidentiality contract is drawn up, the terms of which are legally binding and are an integral part of the main contract.
7.2.4 To your travel sponsor. Our services are provided in accordance with the terms of the service agreements of your employer or travel sponsor. We transmit your data in order to enable the above to exercise the permissible and proper control of the organization and realization of business trips that they undertake to offer you.
7.2.5 To travel providers and other travel service providers. We share information with travel providers (for example airlines and hotels) and travel service providers (for example, ticket distribution systems and travel app providers), as well as their partners, as required for travel booking and the provision of travel services to you or to your travel sponsor. We do not sell information to third parties in a way that allows them to promote their own products or services directly to you.
7.2.6 Business partners. We may also share your personal information with trusted business partners, who will use your information to provide you with the services requested, in accordance with our agreement, which we aren’t able to provide you directly.
7.2.7 In addition to the notifications described in this Protection Policy, we may disclose your personal information to third parties upon your express and written request and with your consent
7.2.8 Finally, we may disclose your information to government agencies and bodies, courts, commercial or other dispute resolution bodies, supervisory and regulatory authority, for our compliance with applicable law, in cases it is considered permitted or required by the law, or by regulatory or legal process or in order to defend the interests, rights, property or security of our business or others.
8. Your marketing choices
We may use your data to promote our products and services to you. We respect your choices on how you wish us to communicate with you on marketing issues.
8.1 More specifically regarding the emails used for the direct promotion of products and services, similar to the services already provided, our Company observes the privacy rules regarding the Protection of Personal Data and privacy in the field of electronic communications (Law 3471/2006), which prevails over the General Regulation of the EU 679/2016 as more specific. Pursuant to the above provision, we will use the legally acquired e-mail contact details in the context of the sale of our products or services or any other transaction with you, for the direct promotion of our similar products or services or for similar purposes. If you disagree with the use of your contact information for this purpose you have the opportunity to express your disagreement for the collection and use of your electronic contact information by visiting: www.magnatravel.gr
9. Cookies, beacons and similar technologies
9.1 While visiting a Website, certain information may be collected passively (that is, collected without you actively providing this information), using a variety of technologies and media, such as web addresses, cookies, Internet tags, and navigation data collection. We, as well as certain third parties that provide content, ads or other features to our Services, may use such technologies in certain parts of our Services.
10. Protection of Personal Data during International Transfer
10.1 If you choose to travel abroad, your personal data will be passed on to third parties, inside or outside the EU, in countries that offer different levels of personal data protection, depending on your destination, in order for us to provide the services you have chosen, for the execution of our contract and upon your consent.
10.2 You should take into consideration that data protection and other laws in the countries you travel to and therefore may transfer your personal data may not be as protective as in your own country. The transfer will be made in accordance with personal data processing legislation, in order to ensure adequate protection of your personal data.
10.3 Our company implements appropriate measures to ensure the secure transfer of your personal data to an external recipient located in a country that offers a different level of protection than that required by General Data Protection Regulation (GDPR).
11. Retention of your personal information
11.1 Erasing or blocking access to your personal data occurs when elapses the time of storing. In addition, storage for a longer period is possible, if this is provided by the European and national legislation in Union law or other provisions to which MAGNA GROUP SA is subject, as the Controller. Blocking or erasing data is also realised after the end of the retention period, as defined in the partial policies adopted by MAGNA GROUP SA. However, the further retention of personal data is considered lawful when it is necessary for the exercise of the right to freedom of expression and information, for the compliance with a legal obligation, for the performance of a public interest duty or for the exercise of public authority by the controller, for reasons of public interest in the field of public health, for the purposes of archiving for the public interest, for the purposes of scientific or historical research or statistical purposes, or for the establishment, exercise or support of legal claims.
11.2 When processing is executed under contract, your data is stored for as long as is necessary for the execution of the contract and for the establishment, exercise, and / or support of legal claims under the contract. In addition, we will storage your personal data for as long as is still required until the period of any claims lapses.
11.3 MAGNA GROUP SA, in compliance with its legal obligations, retains the personal data, only for the period required for their processing, as defined in the applicable legislation.
11.4 As the processing of your personal Data is based on your prior consent, your personal data is held until the consent, expressly given, is revoked. You can do this at any time. Withdrawal of consent does not affect the legitimacy of the processing based on your consent in the period prior to its withdrawal. For the procedure of revoking your consent, refer to paragraphs 13 & 14 hereof.
12. Information Security
12.1 MAGNA GROUP SA has taken reasonable organizational and technical means to protect your personal data and in particular any sensitive personal data that may be collected. Our IT partners follow international standards and practices in order to ensure the security of our facilities and the encryption of data. However, while we take reasonable steps to protect your personal data, security cannot be fully guaranteed against all threats.
13. Your rights
13.1 The data subjects retain all the rights deriving from the applicable Greek and EU provisions, taking into account that the GDPR does not abolish obligations arising from provisions of other laws. In particular, in accordance with the legal framework for the protection of personal data, as in force from time to time, each data subject has the following rights:
13.2 Right to information: You have the right to be informed about the collection and use of your personal data
13.3 Right to access: You have the right to receive confirmation from MAGNA GROUP SA whether or not your personal data is being processed and, if so, you have the right to access your personal data in a concise, comprehensible, transparent and easily accessible format.
13.4 Right to correction: You can also request and MAGNA GROUP SA to ensure that without undue delay it will correct inaccurate or incomplete Personal Data, through a complementary statement.
13.5 Right to erasure: You have the right to request from MAGNA GROUP SA the deletion of the Personal Data that concern you, without undue delay and we are obliged to proceed with the erasure, under the conditions set by law.
13.6 Right to restrict processing: You have the right to ask MAGNA GROUP SA to restrict processing activities only to specific purposes, under the conditions set by the law.
13.7 Right to objection: 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 GROUP SA will no longer process personal data, unless it demonstrates compelling and legitimate reasons for processing that outweigh your interests, rights and freedoms or to establish, exercise or support legal claims.
13.8 Right to data portability: You have the right to receive your personal data, 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.
13.9 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 prejudice to the legitimacy of the processing based on your prior consent.
13.10 All information provided in accordance with Articles 13 and 14 of the GDPR and any notification as well as all actions taken in accordance with 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, especially due to their recurring nature, MAGNA GROUP SA may either:
(a) impose a reasonable fee, taking into account the administrative costs of providing the information or notification or execution of the requested action; or (b) refuse to comply with the request.
13.11 MAGNA GROUP SA does not submit your Personal Data to automated processing, including profile training, which produces legal results that concern or significantly affect you.
13.12 MAGNA GROUP SA will satisfy any of your requests according to the conditions set by law. The possibility of exercising a right granted to you by law does not always imply the possibility of being fully satisfied, especially when there are other legal provisions that may set a limit. If we are not able to satisfy your request, we will inform you of the reasons.
14. How to Exercise your rights
14.1 MAGNA GROUP SA respects the rights you have as far as your personal data is concerned and facilitates your exercise. Any request, question or complaint regarding your personal data and the exercise of your rights must be addressed in writing to MAGNA GROUP SA.
MAGNA GROUP SA – OFFICE OF GENERAL TOURISM-AIRCRAFTS & RECREATIONAL CRAFT CHARTERING, under the trading name “MAGNA GROUP SA”,
Adress: 108, Andrea Papandreou Str.
16674. Glyfada, Attica
14.2 After verifying the legitimacy of your request, we will respond to it within thirty (30) days after having received it. In case an extension of the above deadline is required for the investigation and / or processing of your request, we will inform you, explaining the reasons why the extension of the deadline is necessary.
15. Right of Complaint
15.1 In any case, if you feel that the protection of your personal data has been violated in any way, you have the right to file a complaint to the Hellenic Personal Data Protection Authority (www.dpa.gr)
16.2 You can find a printed version of this Policy at the secretary desk of our company and at reception desk areas.
17. Question and Contact
17.1 For an question as far as the current policy and generally the protection and security of you data , you can contact the …………………………..department at the undermentioned address:
MAGNA GROUP SA – OFFICE OF GENERAL TOURISM-AIRCRAFTS & RECREATIONAL CRAFT CHARTERING, “MAGNA GROUP SA”