By way of introduction, the details of our company, which under the current legal framework is responsible for the processing of your personal data, as well as the details of the Data Protection Officer appointed by our company to perform, among others, the following tasks:

1. a) The Data Protection Officer informs and advises us of our obligations regarding the protection of your personal data,

(b) monitor our compliance with applicable legislation regarding the protection of personal data, through the delegation of responsibilities, awareness raising and training of our employees involved in processing operations, and related audits,

(c) advise us, when requested, on the impact assessment on the protection of your personal data,

(d) cooperate with the Hellenic Data Protection Authority (hereinafter “HDPA”) when circumstances so require,

(e) act as our person of contact with the “HDPA” on issues related to the processing of personal data.

The name of our company is: LIMNIOS DIMITRIOS SON OF ANGELOS

Address: 3 AKTI TZELEPI, PIRAEUS ATTICA, P.O. 18531

Contact telephone number: +30 210-4114005

E-mail address: info@justferry. gr

Contact details of the Data Protection Officer: dataprotection@justferry. gr

Privacy Policy

This Policy applies to the online platform “justferry. gr” (hereinafter “online platform”), owned by the sole proprietorship “DIMITRIOS LIMNIOS SON OF ANGELOS”, located in Piraeus, Attica, on 3, Akti Tzelepi Street, with Tax ID 164602433, Tax Office A’ Piraeus and was established on 05 February 2021.

The Privacy Policy describes important aspects concerning our processing of your personal data, which we receive in the context of communication between us and the provision of services to you by our company, which operates as a travel agency (operating license number 0207E60000796101 of the Ministry of Tourism – General Secretariat for Tourism Policy and Development – General Directorate of Tourism Policy – Regional Attica Tourism Service) for the sale of ferry tickets and as an intermediary of travel services (travel insurance, hotel, car rental, etc. ), in accordance with the Terms of Use.

With this Policy you are able to understand the following issues:

-What kind of data do we collect about you?

-For what purpose do we process them?

-In which cases is your consent necessary for the processing of your data?

-What data do we collect directly from you?

-What data do we collect from third parties?

-To which third parties do we transfer your data?

-How long do we store your personal data?

-What are your rights regarding the processing of your personal data?

What kind of personal data do we process?

First of all, we should clarify that, according to the applicable legislation, personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one whose identity can be verified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier or one or more factors that approximate the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

Special categories of personal data, the processing of which is in principle prohibited (unless there is a legal exception), are data revealing racial or political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data, data concerning health or data concerning the sexual life of a natural person or his or her sexual orientation. Our company clarifies that it does not process personal data that fall under the mentioned special categories of personal data.

In particular, our company processes the following categories of your personal data:

Data relating to your identity: this category includes data such as your name details (full name), username and password, in case you use our application after registration or similar identifier, through which you use the application as a visitor (the reference “user” refers to either the registered user or the visitor), your date of birth, your gender, your passport or identity card number, your place of birth, your nationality, the expiry date of your passport or identity card, any discount card numbers (e. g. if you have a Unique Islander number), etc. Our company may process identity data of third parties, including minors. A user who provides us with third party data must have obtained the authorisation of such third parties for the use of their data within the application.

Financial data: this category includes in particular information about your payment for the services provided to you. In simple terms, they relate to information about the services you have purchased through our online platform or application. It is clarified that our company does not process the payment card details that you enter in our application to pay for the desired services. The fact that you have the option to save your card in order to facilitate any similar transactions through our application (e. g. to save time, rather than re-entering your card details each time you wish to make a reservation), does not mean that we process your full card details.

Your card details are stored upon selection in the app (which is why the full card number does not appear on your screen), as sent to us by the payment institution that clears the transaction (e. g. a transaction institution – such as Everypay).

Technical data: this is data that relates to and serves your navigation on the web platform and the application, such as your internet protocol (IP) address, login details, the browser you use, time zone and location, details of navigation/application usage, operating system and its version, screen size, device name and manufacturer, the IMEI code of the device, the version of the application in use, etc.

Advertising and usage data: this category includes information related to the receipt of promotional material to a customer, their preferences and the analysis of their behavior within our online platform or application, such as the user’s recent searches, frequency of use, frequency of purchase of similar services (e. g. booking tickets with similar passengers, frequency of similar trips), clicks, time per screen, the source page through which they visit our online platform or application, etc.

For what purpose do we process your data?

We process your data in accordance with the law, and only in the following cases:

(a) When you expressly consent to the processing of your personal data for one or more specific purposes, by explicitly stating this within the application (e. g. when you subscribe to our company’s newsletter, when you communicate with us through the application, when you consent to the sending of promotional, advertising material in order to be informed about the range of travel services that may be of interest to you and provided through the application),

(b) the processing is necessary for the performance of the contract (e. g. we process any data necessary for the provision of the services to you, or data relating to your transactions, in order to ascertain the payment for the service you purchase through the application),

(c) the processing is necessary for compliance with a legal obligation,

(d) the processing is necessary to safeguard your vital interests or those of another natural person,

(e) the processing is necessary for the performance of a task carried out in the public interest,

(f) processing is necessary for the purposes of the legitimate interests pursued by us, unless such interests are overridden by your interest or fundamental rights and freedoms which require the protection of your personal data (in particular if the data subject is a child).

What personal data do we collect directly from you?

We collect from you data that have been provided to us with your consent, either data necessary for the use of our online platform and our application or data necessary for the execution of the desired contract (e. g. for booking a travel route, issuing the corresponding ferry ticket, renting a hotel or a car). The information collected directly from you includes:

your first name, surname, gender, address, passport or identity card number, place of birth, nationality, date of birth, contact details (such as your e-mail or telephone number), information about your discount vouchers (e. g. holder of Unique Islander Number, Loyalty card number), billing details (e. g. VAT number, name, address, tax office), technical data concerning the device (e. g. computer, smart-phone, tablet) through which you use our services (e. g. IP address, time, location, browser, application version) data related to the purchase and use of our services (travel data, recent searches, travel companions, etc. ).

What personal data do we collect from third parties?

Your personal data that we collect from third parties are in particular technical data, concerning the details of your device (e. g. manufacturer, model, screen characteristics, operating system, etc. ), or financial data (e. g. token 4 last details of the card through which you pay for the purchase of the desired services of the application -remember that we do not know the full details of your card, your card is stored under a pseudonym in order to facilitate future transactions through the application), as well as statistics or data of your behaviour (e. g. clicks, choices).

Who do we share your personal data with?

Our company transmits your personal data to Service Providers (e. g. ferry companies, hotels), as they are listed in our company’s online platform and application, in order to implement the services purchased on your behalf (e. g. to book a travel itinerary, to rent a hotel or a car), and to partners processing on behalf of our company (e. g. internet service providers, advertising service providers or service providers providing technical support, such as for customer service and to enable us to communicate more effectively with Service Providers.

How long do we keep your data?

We process your data securely, having adopted the appropriate organizational and technical security measures, so that the processing is carried out in accordance with the applicable legislation on the protection of personal data and the decisions, recommendations, guidelines of the Hellenic Data Protection Authority. In case you are a registered user, we keep them for as long as your account is active on our online platform or our application, in order to be able to respond more efficiently to any requests you may have (e. g. in case of registration you choose to see your booking history or any friendly names of your fellow passengers, in order to facilitate faster implementation of similar future bookings). In some cases you have the right to have your personal data deleted during the duration of the contractual relationship between us. We also keep your data for as long as necessary in accordance with the contractual terms of each service and the relevant applicable legislation. Specifically for the trackers we use, the retention period of the data they collect is set out in a table in the Tracker Policy below.

What are your rights regarding your personal data?

Under data protection legislation, you have rights such as:

Your right to transparent information: you have the right and we have an obligation to inform you clearly about any processing of your personal data in order to ensure your lawful consent where required.

Your right to consent: your right to give your consent to the processing of your data is freely revocable, which means that you can withdraw your consent at any time.

Your right of access to your data: you have the right to ask us for copies of your personal data that we process.

Your right to amendment: you have the right to ask us to correct personal information that you believe is inaccurate. You also have the right to ask us to fill in any information you consider incomplete.

Your right to erasure: In certain circumstances you have the right to ask us to erase your personal information.

Your right to restriction of processing: in certain cases you have the right to ask us to restrict the processing of your personal data.

Your right to object to processing: in certain cases, you have the right to object to the processing of your personal data.

Your right to data portability: in some cases, you have the right to request that we transfer the personal information you have provided to us to another organisation.

Upon your request to exercise any of the above rights, we have in principle one month, with the possibility of extension, to respond to you regarding their possible fulfillment.

In case you believe that we have unjustifiably failed to satisfy any of the above rights or in case you believe that we have unlawfully processed your personal data, you are entitled to lodge a complaint with the Hellenic Data Protection Authority (HDPC), located in Athens, on A. Kifissias 1 Avenue (P. O. Box 115 23), with contact phone number +302106475600. Before submitting a complaint, please consult the official website of the HDPC “www.dpa.gr”, in order to check that your complaint may be validly submitted to the HDPC as detailed therein.

Tracker policy

What are trackers?

This Tracker Policy governs the use of trackers (cookies and other tracking technologies) by our company on its online platform and application. By reading this Policy you understand what personal data we process through cookies (or any other tracking technologies), why we choose to use cookies and for how long they are stored. We also explain how you shall turn them off, although this may degrade your experience of using our online platform and application, making some features unavailable.

Trackers (e. g. cookies) are small text files placed on your computer by websites you visit. They are widely used to make websites work or work more efficiently, as well as to provide information to website owners. The tables below describe the trackers (mainly cookies) we use and why. In case you wish to learn more about cookies, you can visit “www.aboutcookies.org” or “www.allaboutcookies.org“.

The categories of trackers are as follows:

(A) Essentials

The lack of this category affects the functioning of the website to a great extent. Without such trackers (e. g. cookies), functions such as logging in as a member to a website, online shopping for products or online payments are not possible

(B) Performance

Performance trackers (e. g. performance cookies) are related to the collection of information about the behaviour of users while they are browsing the website and store anonymous information about usage statistics, performance, etc. Their purpose is to collect information that improves the operation of the website.

(C) Usability

Usability trackers (e. g. usability cookies) store usage data to JUST FERRY and our partners, which will facilitate the user’s next visit to the website. The data may be anonymous and not available when the user is browsing other websites.

(D) Advertising

They are used to select and display ads tailored to the user’s interests.

(E) Analysis

We use Google Analytics cookies to help us improve our app by collecting information about how you use it. These cookies collect information in a way that does not directly identify you.

In particular, based on the above categories we use the following trackers:

TRACKERS

The trackers we use (e. g. cookies) make it easier for you to purchase services through our online platform and application (e. g. by reducing the number of clicks needed to book a ferry ticket), and help us to understand whether you are a user and whether you are logged in to your registered account in order to provide you with any additional services. It also facilitates your access to your personal data, as you have the right to automatically view all the transactions you have made using our online platform.

In case to avoid doing something without your consent, the first time you visit or register on our online platform or application we specifically ask you to give your consent to the use and storage of cookies files on your computer, after being informed by a special banner, which contains a summary of information described in more detail in this Policy.

You can change your preferences for cookies and other trackers at any time by clicking on the “Cookies” icon within the application, selecting “Active” or “Inactive”, and then clicking “Save and close”. You may need to refresh your page for your settings to take effect. Alternatively, most browsers (Google Chrome, Microsoft Edge, Mozilla Firefox, Microsoft Internet Explorer, Opera, Apple Safari) allow you to control most cookies through their settings. Disabling cookies will result in no more usability information being recorded for you and therefore certain relevant functions of the application will be disabled. As a company, we recommend that you do not deactivate cookies, because the operation of the application, its interaction with other pages, as well as the ability to provide you with personalized information may be degraded.