Last updated: Μay 24th, 2018
PrivateTour by Delphini Agency (“PrivateTour,” “we,” or “us”) knows that you care how information about you is used and shared, and we are committed to protecting the privacy of your “personal information”. Like every service provider, PrivateTour also collects, processes and uses data to allow us to provide travel and tourist services (the “Services”) when you (“you”, “the User”, “the Customer”) access www.privatetour.gr (the “Site”, the “website”), contact us by email, phone, or visit our offices.
For the purpose of the General Data Protection Regulation (“GDPR”), other data protection laws applicable in Member states of the European Union, and other provisions related to data protection, the Data Controller is:
Delphini Agency ltd
Delphini Agency ltd
43, Anastaseos St.
Holargos, Athens 15561
Personal data means any information relating to an identified or identifiable natural person, in accordance with the GDPR. This may include information such as your name, gender, age, email address, or your phone number. Generally, the type of personal information we collect about you is limited to any information which is necessary to enable the provision of any services you purchase from PrivateTour, such as your travel arrangements and bookings, or to arrange the provision or purchase of ancillary services and/or products on your behalf from 3rd party suppliers, or to provide information about such services.
- WHAT INFORMATION DO WE COLLECT?
1.1. Data Processing to Enable the Use of the Website:
When you visit our Site, we may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information. This statistical data about our users’ browsing actions and patterns does not identify any individual.
1.2. Data Processing to Enable the Use of the Services:
We may collect and process some or all of the following Personal Data that you provide directly when you choose to:
fill out a form,
enquire for further information or for our services,
book or purchase our services,
contact us via email,
contact us by phone, or
subscribe to our newsletter.
You may be asked, as appropriate, to provide your full name, date of birth, age, e-mail address, mailing address, postal or zip code, phone number, the hotel in which you are staying, company name, or position within that company, payment details (such as credit card number, card expiry date, card verification code).
In some circumstances, we may collect personal information about you from a third party. This includes where a person purchases or reserves any Service from PrivateTour on your behalf, such as (but not limited to) a family or group reservation, or a reservation made for you by a travel agent. Where this occurs, we will rely on the authority of the person purchasing the Service to act on behalf of any other traveler on the reservation.
1.3. Sensitive Personal data:
Sometimes, in particular when you wish to purchase certain of our Services (including, but not limited to, our Food Tour, or the Workouts) we may require that you provide more information (“sensitive personal data”), in order to ensure the safety and/or proper provision of our Services. Below is a description of some of the extra information we may require:
Dietary Restrictions / Preferences: We understand that many of you prefer or are required to follow certain diets. We try to accommodate these choices and needs whenever possible. To accomplish this, your dietary preferences need to be recorded. This information is then transferred to our guides, who contact the various restaurants and hotels we work with to ensure that your requirements can be met.
Health Condition: We may need information about your age, gender and general health so that we can assist in safeguarding your personal health and safety.
We will only collect sensitive information with your explicit consent, when it is reasonably necessary, and in connection with facilitating your request.
1.4. Data Retention Period
PrivateTour retains your information as long as it is necessary and relevant for its operations. In addition, we may retain information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes and take other action permitted by law.
1.5. Data collected by third party providers
PrivateTour uses a variety of third party service providers to help us provide our own Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, the information collected through such means is disclosed to and gathered directly by these service providers as listed below, and any service provider’s use of such information is subject to the service provider’s privacy policies, and not PrivateTour’. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
- a) Travelotopos ltd,
Our Services can be booked in advance and purchased online via our Site. To that end, we use a 3rd party booking management platform, developed, managed, provided and hosted by Travelotopos ltd, 20 Themistokli Dervi St, Myrna Court, 3rd floor, office 302 Nicosia Cyprus. Customers who book any of our Services online will be requested to provide the necessary Personal Data and payment information to Travelotopos, which will collect and store Personal Data for the purpose of purchasing our services and collect Cardholder Data for the purpose of paying for the aforementioned services. Travelotopos does not store Cardholder Data on their server(s); Travelotopos is integrated with third party payment processing services that store Cardholder Data in compliance with PCI DSS tier 1 standards. Travelotopos transfers Cardholder Data over a 2048-bit Secure Sockets Layer (SSL) data encrypted connection.
- b) Payments Processing Providers
For your purchase-related transactions, PrivateTour uses several 3rd party payment processing services, listed below. At no point in the booking and payment process does PrivateTour collect, store, or transmit Cardholder Data or any other payment-related information. All such related data is either collected by Travelotopos or by our payment processing partners below:
- WHAT TRACKING TECHNOLOGIES DO WE USE?
PrivateTour uses, or our 3rd party advertising partners use, various tracking technologies, such as cookies, web beacons, tags, scripts, analytics software or other similar technologies, that help us better manage, operate, administer maintain, develop, analyze and support our Site and the Services provided by PrivateTour.
2.1. Facebook Pixel
2.2. Google Analytics
You may refuse to have cookies stored on your device by appropriately configuring your browser or by using a privacy plugin. Furthermore, you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available here: https://tools.google.com/dlpage/gaoptout?hl=en-GB. Further information on the data processing in the context of Google Analytics is available under: https://policies.google.com/privacy?hl=en
2.3. Google AdWords Conversion and Remarketing
We also use Google Analytics to evaluate data from the Google services AdWords for statistical purposes. This way, in order to improve our services, we can analyse what happens after a user has clicked on one of our ads, e.g. whether a user has ordered a product or has viewed the ad from a mobile device. Furthermore, you may receive interest-based ads through these services. You can opt out of such interest-based ads via the Google Ads setting pages: https://adssettings.google.com.
2.4. Google Tag Manager
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to uniquely identify your browser or to store information or settings in your browser.
Cookies can be used to recognize you when you visit PrivateTour, remember your preferences, and give you a personalized experience that’s in line with your settings. Cookies also make your interactions with PrivateTour faster and more secure.
Our cookie table below lists some of the third party cookies on our Site. Please note that the names of cookies, pixels, and other technologies may change over time.
Cookie Name Description Expiration
_ga Google Analytics cookies are used to collect anonymous information about how visitors use our website. We use the information to compile reports and help us improve our website. The information collected is anonymous and includes the number of visitors to the website, what pages they visited and where they have come to the website from. 2 years
_gid 24 hours
_gat 10 minutes
_uetsid Bing cookie are used to gather anonymous information on how visitors are using our website. 30 minutes
_uetmsclkid 90 days
Additionally, you can deactivate the use of 3rd party cookies for interest-based advertising via the European Interactive Digital Advertising Alliance at: http://www.youronlinechoices.com/uk/your-ad-choices, or the Advertising Initiative by following the instructions under http://optout.networkadvertising.org. Please note that any cookies that you may find may have been stored by your browser by visiting sites other than PrivateTour’ website.
- HOW DO WE USE COLLECTED INFORMATION?
PrivateTour may use your information to:
Create, process, modify, and manage reservations for our Services;
Provide the Services you have purchased, including where necessary to inform external service providers (such as hotels, restaurants, etc), agents and subcontractors for the purposes of providing aforementioned Services. In this case, we disclose only the personal data that is necessary for the third party to deliver the Service;
Adapt our Services to your needs and preferences, and to offer you a personalized customer experience;
Communicate with you by email and/or SMS for administrative or operational reasons related to Services you have purchased from PrivateTour, including but not limited to, send you confirmations of your bookings and/or payments, inform you about your tour schedule, meeting point, or changes to your itinerary;
Issue tickets, vouchers, and book any service or product from suppliers included in our Services;
Evaluate and respond to your inquiries, requests or questions;
Improve Customer Service: Your information helps us to more effectively respond to your customer service requests and support needs;
Operate, evaluate and improve our business (including developing new products and services; managing our communications; performing market research and data analytics; determining and managing the effectiveness of our advertising and marketing; analyzing our products, services and websites; administering our websites; and performing accounting, auditing, billing, reconciliation and collection activities);
Customize your experience with our Site, such as by providing personalized information;
Verify your identity;
Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
Process payments or other types of financial transactions, such as refunds;
Further to the above, in the case you have provided explicit consent and opted-in to receive marketing communications from PrivateTour, we may use your information to:
Administer surveys and questionnaires;
Tell you about and provide information about various PrivateTour products, services, events and promotions, with periodic emails (newsletters), which may include marketing communications;
PrivateTour will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to:
Prevent fraud, unauthorized activities, or anything else that may create liability;
Comply with applicable laws and reasonable requests of law enforcement;
Exercise or protect the rights, property, or personal safety of PrivateTour, our Users or others;
- YOUR RIGHTS TO INFORMATION
Under Data Protection regulations, you have a number of important rights regarding your personal data that you may exercise at any time by contacting us at [email protected] These Rights are as follows:
Right of access: you have the right to access your personal data and supplementary information, such as obtaining confirmation that your data is being processed.
Right to rectification: you have a right to request that inaccurate personal data is rectified, or completed if it is incomplete.
Right to be forgotten: in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing: where certain conditions apply, you have a right to restrict the processing of your personal data.
Right to data portability: – you have the right to have the data we hold about you transferred to another organization.
Right to object: you have the right to object to certain types of processing such as direct marketing.
PrivateTour will respond to any appropriate request to access, correct, update or delete your personal information without excessive delay. Before we proceed with any request, we will take steps to verify the identity of the person making the request. We will promptly fulfill your request to delete your personal data unless this data is required to be retained by law. Also, we will not be able to delete information that is required to maintain our business purpose or that is required to facilitate your contract with us.
- YOUR CONSENT TO PROVIDE PERSONAL INFORMATION
- OTHER PROVISIONS
Protection of Minors
Links to Third Party Web Sites
Terms and Conditions
This policy was last modified on May 25th, 2018
Delphini Agency ltd
43, Anastaseos St.
Holargos, Athens 15561