Personal Data Protection Policy

We have, as our main priority, the protection of your personal data that we process, whilst we are continuously complying with the applicable legislation relating to Personal Data Protection.

We invite you to review the present personal data protection policy carefully, so as to be sufficiently informed about the type of data that we process.

1. General Information and data controller

The company “ATHENS MARINA S.A.”, which has its registered seat at Faliron Marina, Neo Faliro 18547, Piraeus, with Tax Identification Number 998180820, as legally represented by Mr. Stavros Karnakis, is the data controller in respect of the collection, storage and processing, in general, of the personal data of the users of the present website, as collected and stored through it, as well as through the social media webpages that are associated with it. The aforementioned company will be hereinafter referred to as the “Company”.

2. What personal data do we collect about you and how do we do so?

We collect and process your personal data as follows:

– Information when you contact us

If you visit our website and have an inquiry or some remark, you can submit it to our Company by filling in the relevant contact form that is available on our website. You will be asked to fill in your name, email address and phone number, as well as information regarding your request/inquiry/remark. We will use this information only in order to respond with regard to your inquiry/remark. We will proceed to filing your requests, inquiries/remarks and our corresponding replies, as well as any other actions that may be taken in view of addressing your request/communication. All this information will be retained for 6 months following the settlement of your inquiry or complaint, or the closing of the matter.

– Booking a berth at the Athens Marina

Should you wish to book a berth at the Athens Marina, you will need to fill in the contact form that is available on our website. You will be asked to state your full name, email address and phone number, as well as some information regarding your yacht and the dates of its berthing. We will use this information in order to handle your request. All this information will be retained for 24 months following the completion of the berthing of your yacht in our marina or for the time period that is necessary for meeting the legal obligations of the Company vis-à-vis administrative authorities (such as, for example, tax authorities) or for its protection against legal actions.

– Information regarding your visit and use of our website

We collect certain information when you visit our website, such as your IP address, the webpages that you visit, the category of the device that you use, your web browser and the type of web browser that you use, your clicks and views. The information relating to your use of our website and services enables us to make categorizations, meaning that we can set up groups of visitors to our website or customers with certain common characteristics, such as age group, gender or region. It is possible that we might add you to one of our categories. We use these categories for the purposes of individualizing our website and, for instance, in order to change the order in which search results appear or the position where certain offers are displayed, thus making it more likely that you would view them. We may also use these categories in order to show electronic advertisements that we believe are relevant to you, as well as in order to send you commercial emails. We use this personal data as required, and in the context of our legitimate interests, so as to be able to promote our products and services to the customers and visitors of our website, in order to have the possibility of attracting more customers and improve the sale of our products and services. We retain personal data for a maximum period of 12 months.

– Marketing

In certain cases, we combine information relating to your electronic searches (clicks and views), your settings on our website, your requests to customer services and you contact history. This information allows us to use different channels for the management of our relations and the marketing of our services to you via email, direct mail, social media, phone or internet advertising, which may include the individualization of the content and offers of our website, so as to cater to your preferences. You may opt out of receiving our newsletter, direct mail, social media and phone calls and you may object to the use, on our part, of your personal data for the purposes of direct marketing (for more information on this process, please consult the paragraphs that follow in the present policy). We use this personal data as required, and in the context of our legitimate interests, so as to be able to promote our services to the customers and visitors of our website, as well as in order to have the possibility of attracting more customers. We retain personal data as stipulated in accordance with the relevant purposes for which the personal data has been collected (for example, when you contact us, when you visit our website, for the purposes of booking a berth, etc.) Personal data is deleted or made anonymous usually within a maximum time period of 12 months.

– Maintenance and optimization of our website

Your personal data is also used for the maintenance and analysis of our website, with the aim of resolving performance issues, improving availability and user experience. We record each use of our website. The use of your personal data, on our part, for these purposes is necessary in the context of our legitimate interests, and the information is retained for a maximum time period of 12 months. The web log files of our website shall be deleted within 12 months of their creation.

3. Purposes of processing

a. Support of IT systems/improvement of services provided: We use your personal data in order to detect server problems and so as to ensure the sound operation of our website. The Company uses the personal data of users that it collects through the website in order to offer new services via the website or improve the services already provided.

Legal basis for processing: the legitimate interest of the Company to secure the smooth operation of its website and improve the services provided through it.

b. Compliance with our legal obligations: When we are in receipt of relevant court orders or orders from public authorities, we process your personal data in order to respond to these demands. We are under a legal obligation to pass on data relating to bookings to the port authorities.

Legal basis for processing: Compliance with our legal obligations.

c. Handling of a booking request for the berthing of a yatch at the Athens Marina: We process the personal data that you submit through the corresponding electronic form for the handling of your request.

Legal basis for processing: Initially, your consent and, once the agreement is signed, the execution of the berthing agreement.

d. Promotion of the products and services of the Company: The information relating to the use of our website and services enables us to create sections that group visitors to our website and customers with common characteristics, such as age, gender and region. These sections are subsequently used in order to adjust our webpage and change, for instance, the order in which your search results appear or so as to show you an advertisement that we believe would be of interest to you.

Lastly, we process your data in order to send you informational emails/our newsletter, when you have granted us relevant consent or when you have concluded a berthing agreement with us.

Legal basis for processing: the legitimate interests of the Company.

e. Legal protection of the Company: Ensuring the application of the terms and conditions for the use of our website and protection of our legal rights.

Legal basis for processing: the legitimate interests of the Company.

4. Cookies

A large part of the information mentioned in the present Privacy Policy is collected through the use of cookies and similar techniques. Cookies are small text files that contain small quantities of data that is uploaded and may be stored on your user device, such as, for example, on your personal computer, smartphone or tablet. The techniques that we use, which may be similar to cookies, are tracking pixels, Java scripts and web beacons. These cookies and the techniques similar to them are required from time to time in order to save your account settings, your language and country, whilst they also allow us to measure and analyse your activity on our website and to show you individualized advertisements on our internet site or on the websites of third parties. Where necessary, your consent for the use of cookies will be requested.

5. Rights of access, rectification, erasure, restriction of processing and portability of data

You have the right to review your personal data undergoing processing by us or on your behalf. You have the right to rectify, erase or restrict the processing (where applicable) of your personal data. You may exercise this right by contacting us via using the email address info@athens-marina.gr and submitting a relevant request.

Please bear in mind that, in case of requests that do not meet the requirements set by the applicable legislation or the guidelines of the Company, it may be required that they be redrafted or they may be rejected, as well as that certain personal data may be exempted from such access, rectification and erasure requests, pursuant to the applicable laws on data protection and other laws and regulations.

You have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format and, in some cases, we shall transmit your data, upon your request, to another controller, provided this is technically feasible.

6. Right to put forward objections

You also have the right, in certain cases, to ask that we stop the processing of your personal data but, should there be compelling legitimate grounds for doing so, we shall continue processing your personal data. In any case, you have the right to object to the use, on our part, of your personal data for the purposes of direct marketing, including profiling, and, provided that you do so, we shall fulfill your request.

In the event that you have granted us consent for using your personal data, you have the right to withdraw such consent, without this affecting the lawfulness of our processing of your data before the withdrawal of your consent.

The requests pertaining to the aforementioned user rights can be sent to the Data Protection Officer (“DPO”) of the Company, at the email address: info.gdpr@jp-avax.gr.

Users may also submit complaints to the Hellenic Data Protection Authority regarding the exercise of their rights (www.dpa.gr). According to the website of the Hellenic Data Protection Authority, complainants must initially submit their complaint to the Data Controller or the Data Protection Officer.

7. Retention of personal data

The personal data of users is kept solely and exclusively for the time period that is necessary for the fulfillment of each purpose for which it has been collected, in full compliance with the applicable legislation. When the purpose of processing your personal data has been fulfilled, said data shall be erased. The specific periods of retention for each of the relevant processing purposes are set out below.

8. How and with whom we share your personal data (receivers of personal data)

Your personal data is processed internally in our Company by those employees for whom it
is absolutely necessary to have access to it, so as to be able to carry out their duties.
We may have to share your personal data with third parties, in order for them to help us
provide you with our services and products, but also so as to manage our website. The third
parties in question are:

• Companies that we work with for the operation/technical support of our webpage
• Service providers, where necessary, who provide a service to us, as well as for the provision of data analysis services
• Service providers who assists us in organizing our campaigns and promotional activities
• First and third party advertising companies
• Media agencies for the purposes of marketing and research

In the event that Athens Marina S.A. sells to third parties all or part of its assets or shares, to whom personal data has been transmitted, your personal data may be provided to these third parties.

The third parties in question may have their resident seat in the European Union or in other countries of the European Economic Area or elsewhere in the world. When we store personal data outside the European Economic Area, we ensure an adequate level of
protection of the data transferred. If we are going to transmit your personal data to a third country, meaning a country outside the European Economic Area or to an international organization, you shall be informed prior to their transmission, pursuant to the provisions of Article 13(1)(f) of the GDPR.

We require that all service provides take appropriate measures for the protection of confidentiality and personal data security.

We may also have to provide personal data to law enforcement agencies or administrative authorities, in order to comply with a legal obligation or court order.

9. Data security

The company assures users that it takes all appropriate technical and organizational measures for the security of their personal data, for ensuring the confidentiality of their processing and their protection against accidental or unlawful destruction/loss/alteration, unauthorized disclosure or access and any other form of unauthorized processing.

Even though we make every effort towards the protection of personal data, the Company cannot guarantee the security of data that is transmitted on its website, as the transmission of data over the internet can never be completely secure.

Our website may contain links to other websites. We are not responsible for the personal data protection practices, the content and security of other websites that do not fall under the present Personal Data Protection Policy; for this reason, we advise you to always review the Personal Data Protection Policies of these websites carefully. Moreover, if you choose to share information from our website through social media, we advise you to review the Personal Data Protection Policies of said social media carefully.

10. Applicable Law

For any dispute that may arise from the use of the present website, the Courts of Greece shall have exclusive jurisdiction.

11. Amendments

The present Personal Data Protection Policy has been drafted pursuant to the provisions of the General Data Protection Regulation (GDPR) (EU) 2016/679. In case of updating, all changes shall be published on the official website of the COMPANY and shall bear the date of the revision thereof.

12. Data Protection Officer

You can contact the Data Protection Officer of the Company “ATHENS MARINA A.E.” for matters relating to the processing of your personal data, at the email address info.gdpr@jp-avax.gr