PRIVACY
STATEMENT
GDPR
STATEMENT
GDPR
1. GENERAL
1.1 This privacy policy describes what information Little Owl collects about you and how it will be used. Please read this Privacy Policy carefully.
1.2 Little Owl is responsible for processing your personal data. Little Owl, Aidiniou 11, 18533 Piraeus, Greece. E-mail: [email protected]
1.3 Little Owl is committed to protecting your privacy in accordance with their obligations under data protection legislation. The current data protection law is found in the regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. The General Data Protection Regulation (GDPR) is applicable from 25 May 2018.
1.4 In compliance with the GDPR, personal data is any information relating to an identified or identifiable natural person (‘data subject’). Information relating to entities is not considered as personal data.
1.5 We, Little Owl, ensure that any personal data shared with us or the personal data that we get from other organizations will be kept safe and will not be used for any purposes that you have not agreed to. Also, we want to inform you that any personal data we are collecting will be used for Little Owl purposes only and will not be shared with any third-party organizations.
1.6 In this policy where we talk about our website, we are referring to www.littleowl.tours
1.7 If you have any concerns or questions regarding this privacy policy, please contact Little Owl [email protected].
2. WHERE AND HOW WE COLLECT YOUR INFORMATION
2.1 Information you provide directly when you book and/or buy any product we sell online and offline, or through our approved resellers.
2.2 We will ask for your personal information in order to process your bookings purchased on our website or through our resellers. This information may include, but not limited to, contact and address details, payments information and any other information required only for the purpose of completing your transaction.
2.3 Little Owl uses Google Analytics to analyze the data but we do not collect any personal information. We use this tool to understand how our visitors are using and interacting with our website. This analysis helps us to make improvements to our web services and your online experience.
2.4 In some circumstances, we may collect personal information about you from a third party.
3. WHAT INFORMATION WE COLLECT
Little Owl will collect information on you for different purposes outlined below:
3.1 Contact data
Little Owl collects and uses information that you provide to us. When you make an online/offline booking with us or with our business partners or alliances for any product(s) that we sell, you are (as a minimum) asked for Name, Email, Contact data, Address, and Payment information.
3.2 Social Media
While you are getting in touch with us through another avenue such as social media, we also collect information about you from there too.
3.3 Other Sources
There are also other instances where you will provide us with information. For example, if you’re browsing with your mobile device, you can enable our analytics to see your current location or grant access to your contact details – this helps us provide you with the best possible service.
3.4 Third Parties
We may also receive information about you from affiliate partners and other independent third parties. Any data we receive from them might be combined with information provided by you.
Little Owl 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”).
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. WooCommerce, as an e-commerce platform
b. Mollie, as payment processing provider
c. PayPal, as payment processing provider
d. IDEAL as payment processing provider
e. Bancontact as payment processing provider
f. Giropay as payment processing provider
3.5 Your choice
You always have a choice as to whether and how you want to receive communications about our work, products and services. If you do not want us to use your contact details to contact you in the future, you can opt out anytime. If you choose not to be contacted by us, we will never send you personalized marketing communications, but we will keep your details on a ‘suppression list’ to ensure you aren’t contacted.
3.6 Legal basis for processing your personal data
Legitimate interests: We may use your information for our legitimate interests, such as to provide you with the best suitable content of the website, emails and newsletters, to improve and promote our products and services and the content on our website, and for administrative, fraud detection and legal purposes.
3.7 Consent
We may rely on your consent to use your personal information for certain direct marketing purposes. You may withdraw your consent at any time by contacting us at the addresses at the end of this Privacy Statement.
3.8 Retention
In accordance with European data protection laws, we hold your information for only as long as necessary for the purpose needed.
3.9 Under 18’s/Children
The services offered by Little Owl. are not directed at children under 18 years old. The use of any of our services is only allowed with the valid consent of a parent or a guardian. If we receive information from a child under 18 years old, we reserve the right to delete it.
3.10 Image rights
When you embark on a Little Owl. tour, you may have your photograph taken for marketing purposes. We will always ask for your consent to take a photograph or video.
4. WHY WE COLLECT YOUR INFORMATION
We collect personal information about you so that we can perform our business activities and functions and to provide the best possible quality of customer service.
4.1 We may collect, hold, use and disclose your information for the following purposes:
a. Administering services we are providing to you such as arranging your tour booking
b. Manage our relationship with you, including updates about your tour booking and handling complaints to contact you in the event of an emergency
c. Combining information collected from you at different times for the purpose of research and analysis to provide a better customer experience, including customising online content for you
d. to seek your interest in taking part in research projects, such as surveys and interviews, to assist us in providing better services and to enhance your customer experience, including your website experience
e. to identify and tell you about services we think you may be interested in, including sending email newsletters
f. Providing relevant information, which may include sensitive personal information, to insurers, their agents and medical staff in circumstances where we/they need to act on your behalf or in an emergency.
g. to make improvements to our site and make it easier to find the information you are looking for
h. for identification of fraud or error or for regulatory reporting and compliance
4.2 We are only permitted to store your personal information for as long as necessary having regard to the purposes for which it was collected or a related or ancillary purpose. We may therefore delete your personal information after a reasonable period of time and, if you have not used our services for some time, you may have to re-enter or re-supply your personal information to us.
4.3 We will not disclose your personal information otherwise than as described in this Privacy Policy without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), disclosure is authorised or required by law or disclosure is otherwise permitted by applicable privacy laws.
5. TRACKING TECHNOLOGY
Little Owl 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, analyse and support the Website and the services provided by Little Owl.
a. Facebook Pixel
The Website contains tracking technology by Facebook. This may include cookies. Facebook collects and stores usage data in pseudonymous profiles for the purposes of web analysis and interest-based advertising. You can opt-out of such data collection and storage at any time with effect for the future by visiting https://www.facebook.com/ads/preferences/ or by setting an opt-out-cookie on your device via the website of the EDAA. You will find further information on the data processing by Facebook in the privacy policy of Facebook (https://www.facebook.com/privacy/explanation).
b. Google Analytics
The Website uses Google Analytics, a web analytics service by Google. Google Analytics uses cookies in order to analyse your use of this Website. The information about your use of this Website collected using cookies is usually transferred to and stored on servers of Google in the US. On behalf of the website provider, Google will use this information to analyse your use of the Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. 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.
c. 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. The Website uses the remarketing feature of Google. Essentially, this serves to present interest-based advertisements to visitors to a website belonging to the advertising network of Google. To enable this, cookies are stored on your computer. When you visit our site and then call up a website belonging to the advertising network of Google, you may therefore be shown advertisements of Little Owl. According to Google, it does not collect any personal data in this process. If you, nevertheless, do not wish to use the Google remarketing feature, you can deactivate this by changing the appropriate settings under https://adssettings.google.com. You can find further information about Google remarketing and the Google Privacy Policy under: https://policies.google.com/technologies/ads.
d. Google Tag Manager
This website uses Google Tag Manager to manage website tags. A tag is a JavaScript snippet that can be used to send information from a website to a third party, in particular in the context of web tracking. The tool Google Tag Manager itself does not collect personal data. Rather, the tool triggers other tags that may collect data (such as the tag of Google Analytics).
e. Cookies
Generally speaking, cookies are small text files that are placed in your device’s browser, then stored on the device, and that can be used to help recognize that browser across different web pages, websites, and browsing sessions. Cookies can be used to recognise you when you visit the Website, remember your preferences, and give you a personalised experience that’s in line with your settings. Cookies also make your interactions with the Website faster and more secure.
6. USE OF THE COLLECTED PERSONAL DATA
Any use of your personal data by Little Owl is consistent with this Privacy Policy. We may use your information to:
a. process your online requests and bookings/orders and provide you with the requested services and information offered through the Website;
b. verify and carry out financial transactions in relation to payments you make;
c. audit the downloading of data from the Website;
d. improve and customise the Website, our products, services and our business in general, such as by tracking your preferences, history and interactions with the Website;
e. identify visitors to the Website;
f. carry out data analytics, market research and data enrichment, such as by analysing your preferences, shopping history and interactions with the Website together with data collected from third parties, such as data that you agree to share with us on social networks (e.g., Facebook, Instagram, etc.) and/or that we may collect from publicly accessible databases;
g. correspond with you to resolve your queries or complaints; and send you marketing communications containing news, information and updates about our products and services, offers, promotions and special events, and other marketing communications that may be of interest to you by email or telephone, and customise your experience with us to your interests and shopping habits and improving our services, notably via profiling.
h. Whenever we process your personal data, we act on the basis of a lawful “justification” (or legal basis) for such processing. In the majority of cases, the processing of your personal data will be justified on one of the following bases:
• processing is necessary to perform a contract with you or take steps that you have requested in order to enter into a contract by filling the online booking form (e.g. sale contract);
• processing is necessary for us to comply with a legal obligation;
• processing is in our legitimate interests as a business, and our interests are not overridden by your interests, fundamental rights or freedoms. Our legitimate interests may include our interest in using customer and Website user personal data to conduct and develop our business activities with current and potential customers and Website users; and in establishing, exercising or defending legal claims; or
• processing is based on your prior explicit consent, such as segmented and customised marketing activities. This consent can be expressed by clicking the check box with the consent clause.
7. DISCLOSURE OF PERSONAL DATA
7.1 We may disclose your personal data to our service providers who assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in performing other tasks, as appropriate. Furthermore, your personal data may be disclosed to an insurance company affiliated with us to guarantee the safety of our customers during the tours and to the tour guide. In case of wine and gastronomy tours certain categories of your personal data, such as your name and your allergies may be disclosed to the restaurants.
7.2 Your personal data will be accessible by authorised personnel of Little Owl, and service providers acting on our behalf on a need-to-know basis.
7.3 We may also share your personal data with third parties in connection with potential or actual sale of our company or any of our assets, or those of any associated company, in which case personal data held by us about our users may be one of the transferred assets.
7.4 We will also respond to requests for personal data where required by to do so by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.
8. SECURITY
8.1 We place great importance on the security of all personal data associated with our users. We have adopted security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access. For the best possible protection of your personal data outside the limits of our control, your device should also be protected (such as by installing an updated antivirus system) and your internet service provider should take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
8.2 While we take all reasonable steps to protect your personal data, we cannot guarantee that the personal data you disclose to us will be 100% secure, nor that any data breach will not occur.
8.3 You accept the inherent security implications of dealing on-line over the Internet and will not hold Little Owl or their processors responsible for any data breach unless it is due to our gross negligence. In particular, Little Owl excludes any liability for damage or loss suffered by the Website’s user as a result of the inadequacy, dysfunction or incompatibility of the user’s equipment with the Website and/or failure by the user to implement reasonable and necessary protection against harmful programs, devices or communications.
9. YOUR RIGHTS
9.1 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:
a. Right to be informed: you have the right to be informed about the collection and use of personal data.
b. Right of access, rectification and erasure: you have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances.
c. Right of data portability: under certain conditions, you have the right to receive all such personal data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
d. Right to restriction of processing: you have the right to restrict our processing of your personal data where:
• you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
• the processing is unlawful but you do not want us to erase the data;
• we no longer need your personal data for the purposes of the processing, but you require such data for the establishment, exercise or defence of legal claims; or
• you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have overriding compelling legitimate grounds to continue processing.
• Where personal data is subject to restriction in this way, we will only process it with your consent or for the establishment, exercise or defence of legal claims.
e. Right to object to processing justified on legitimate interest grounds: where we are relying upon legitimate interest to process personal data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a justification for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
f. Little Owl 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.
10. YOUR CONSENT TO PROVIDE PERSONAL INFORMATION
10.1 Any service that Little Owl provides to you is purely voluntary. You are not required to provide any personal or/and sensitive information to us unless you choose to access features of the tour/service that requires such information. If you do not agree with the terms of this Privacy Policy or Little Owl’s Terms & Conditions related to our services, then do not provide us with personal information, exit from the Website, and discontinue using our services.
10.2 Accordingly, by accessing, visiting, using any of the functionalities on the Website (including, but not limited to, booking services online or filling out the Contact Form), you expressly consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy and in Little Owl’s Terms & Conditions.
11. OTHER PROVISIONS
11.1 Protection of minors Children and adolescents with limited legal capacity are as a matter of principle not allowed to transfer any personal data to the Website without prior consent of their parents or legal guardian. Little Owl will in no way knowingly collect personal data from children or adolescents with limited legal capacity, use these data in any form, or divulge these data to third parties without authorisation. If you are under 18, please do not give us any Personally Identifiable Data. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personally Identifiable Data on the Website without their permission. If you have reason to believe that a minor has provided Personally Identifiable Data to Little Owl through the Website, please contact us, and we will endeavour to delete that information from our databases.
a. Links to third party websites
The Website may provide links to other third party websites (“Third Party Websites”). This Privacy Policy applies only to the Website and not to any Third Party Websites. We suggest that you contact those sites directly for information on their privacy, security, data collection and distribution policies.
b. Newsletter & emails
If you have purchased on the Website, there is a good chance you will receive emails from us. We will only send you emails which you have signed up to receive, or which pertain to the services we provided to you. To send you emails, we use the name and email address you provide us. The Website also logs the IP address you used when you signed up for the service to prevent abuse of the system. No identifiable information is otherwise tracked outside this Website except for the email address.
c. Terms of Service
Please also visit our Terms & Conditions section establishing the use, disclaimers, and limitations of liability governing the use of the Website, a link to which can be found at the bottom of this page.
d. Updates and changes to our Privacy Policy
We may occasionally change this Privacy Policy, for example, to comply with new requirements imposed by the applicable laws or technical requirements. We will post the updated Privacy Policy on the Website. We may also notify you in case of material changes and seek your consent to those changes, where required by applicable law. You are thus encouraged to periodically review this page for any changes. This Privacy Policy was last modified on July 17th, 2019.
e. If there are any questions regarding this Privacy Policy you may contact us at [email protected] or send mail to:
Little Owl
Aidiniou 11
Piraeus 185 33
Greece
