Privacy Policy

This personal data processing/protection policy (hereinafter “Policy”) provides information on the collection, storage, processing and use of your personal data.

The company under the name “TSBK TRANSFER.”, seated in Athens, VAT number 802029170, contact email address tsbk@tsbktransfer.gr, acting as the Data Controller, collects, stores, uses and generally processes your personal data.

1. What is personal data?

The term “personal data”, refers to information of natural persons, such as, but not limited to, full name, postal address, email address, contact telephone number, etc., which identifies or can identify you, hereinafter referred to as “Personal Data or Data”.

2. What is the Processing of Personal Data?

Any operation or set of operations performed, with or without the use of automated means, on Personal Data or on sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, alignment or combination, restriction, erasure or destruction.

3. What Data do we collect from you?

We take care to collect only Data that is strictly necessary to serve the purpose for which it was provided and is used solely for the purposes for which it was collected. With the exception of any Data collected by Cookies, the Data is limited to what you have expressly provided yourself for a specific purpose and where you have given your consent. We also collect Data when you visit our website and if you have consented to this, consent which is presumed by filling in the relevant fields.

– Identity/passport data, such as first name, surname, patronymic, date of birth, driving license, personal identification number, VAT number.

– Contact/shipment data, such as postal address, e-mail address, telephone number.

– Payment details, such as credit/debit card number, PayPal, bank account number.

– Identification details, such as username, IP address.

4. How do we use your Data?

The processing of your Data is carried out either by the specially authorized personnel of our Company, or through computer systems and electronic devices by our Company and exceptionally by third parties, who, having contractually committed to our Company for the confidentiality and protection of your Data, process them exclusively and only for the purposes for which they have been provided to us.

In general, your Data are processed in order to provide you with the following services:

– Submission of an offer: The Company processes your Data for the purpose of submitting an offer for a short or long-term car rental.

– Car rental: The Company processes your Data, in order to fulfil its contractual relationship with you, which is the rental of cars with or without a driver, to provide services (such as maintenance, repair, vehicle replacement etc.), to comply with legal obligations, to oppose, raise or exercise legal claims.

– Comply with applicable legislation: The Company processes your Data in order to be able to comply with its legal obligations, in particular related to compliance with tax and insurance legislation or vehicle insurance coverage under an active insurance contract.

– Sending a newsletter: The Company provides you with the opportunity to choose, if you wish, to be informed at your e-mail address about promotional/advertising activities of the Company (e.g. for new products or services available on the market, any offers, operation of new car rental stations, tourist offices, etc.)

– Information services on the Website: The Company provides information services for its customers

– Communication: The Company uses your Data to respond to the requests/queries you submit indicatively through the Contact Center and contact forms.

5. What is the purpose for which we process your Data?

We collect your Data for the purposes of the products and/or services provided indicatively for:

a) the evaluation of your request for the submission of an offer on the one hand and for the conclusion of the vehicle rental contract with or without a driver on the other hand.

b) managing the rental of the vehicle you have chosen, e.g. communicating and informing you about availability, the execution of the contract, the provision of maintenance, fitting, repair, replacement, vehicle pick-up services, etc., sending the necessary documents for any products you may have purchased or services you may have been provided, managing your debts to the Company, making refunds, etc.

c) complying with obligations imposed by the applicable legislation e.g. tax and insurance legislation.

d) monitoring, improving and adapting to your preferences and choices regarding our products and/or services,

e) sending, by e-mail, information about the Company’s products and/or services,

f) to survey our customers’ satisfaction, to promote our products and/or services, to send newsletters about our products and/or services.

6. What is the lawful basis for the processing of your Data by the Company?

The processing of your Data is carried out in accordance with:

1. the terms of our contractual relationship,

2. your consent, where required,

3. the Company’s obligations under the law,

4. the legitimate interest of our Company.

7. Who are the recipients of your Data?

TSBK TRANSFER warrants that it will not transfer, disclose, share, assign, etc. your Data to third parties (other than those mentioned herein) for any purpose or use unless this becomes mandatory by applicable law or is required by public/judicial bodies/authorities.

Access to your Data is granted to the Company’s strictly necessary personnel, who are bound by confidentiality obligations, and to our affiliated companies, which process your Data as Joint Controllers or as Processors on our behalf and in accordance with our instructions.

The Data may be processed by natural and/or legal persons, established in or outside EU Member States, acting on behalf of the Company and in accordance with specific contractual obligations. In addition, they may be processed by employees or associates of our Company, only with the permission of our Company and in order to serve our customers and to comply with the Personal Data Protection Regulation and in the context of our Company’s commercial transaction and operational specialization.

The Data may be disclosed to third parties in the context of compliance with legal obligations, such as for the performance of payment services through credit cards and other financial institutions, as well as for the execution of an order of public authorities or for the exercise of the Company’s rights before judicial authorities. The Company’s third parties who may process Personal Data on our behalf comply with the security and protection requirements in accordance with the GDPR.

8. How do we ensure that Processors & Processors respect your Data?

Processors processing on our behalf have agreed and contractually committed to the Company:

• to maintain confidentiality,

• not to send your Data to third parties without the Company’s permission,

• not to disclose your Data to third parties without the permission of the Data Controller, without disclosing your Data to the Company, and not to disclose your Data to any third party without your permission,

• to comply with the legal framework for the protection of personal data and in particular Regulation 679/2016/EU (otherwise GDPR).

It is possible that the Processors, in the performance of their duties, may employ other persons, who are called Sub-Processors. In this case, the Data Controller must have given an authorization to handle all or part of the processing of the Data. The consequence of this is that the sub-processor has the same obligations and rights as the Processor, as detailed in this Policy and always within the scope of his/her assigned responsibilities.

9. When do we delete your Data?

We retain your Data only for as long as necessary to fulfill the purpose for which you have provided us with your Data and in compliance with the applicable legal provisions. Your declaration of consent for sending a newsletter is kept for as long as you receive a newsletter from the Company, unless you choose to stop receiving it.

10. Is your Data safe?

TSBK TRANSFER is committed to safeguarding your Data. Recognizing the importance of the security of your Personal Data, we have taken all appropriate organizational and technical measures which are constantly being improved based on technological evolution with the sole purpose of ensuring the security and protection of your Data from any form of accidental or unlawful processing. These measures are reviewed and modified when necessary.

11. What are your rights?

You have the right to access your personal Data. This means that you have the right to be informed by us if we process your Data. If we process your Data, you can request to be informed about the purpose of the processing, the type of your Data we hold, who we give it to, how long we store it, whether automated decision-making takes place, and your other rights, such as rectification, deletion of Data, restriction of processing and filing a complaint with the Data Protection Authority. You have the right to correct inaccurate Personal Data. If you find that there is an error in your Data, you may submit a request to us to correct it (e.g., correcting your name or updating a change of address). You have the right for the erasure of your Data and/or the right for them to be forgotten. You can ask us to delete your Data if it is no longer necessary for the processing purposes listed above or you wish to withdraw your consent where this is the only lawful basis. You have the right for the portability of your Data. You may request to receive in a readable form the Data you have provided or request us to transfer it to another controller. You have the right to restrict processing. You can ask us to restrict the processing of your Data for as long as your objections to the processing are pending. You have the right to object to and withdraw consent to the processing of your Data. You may object to the processing of your Data and we will stop processing your Data unless there are other compelling and legitimate reasons that override your right. If you have consented to the collection, processing and use of your Personal Data, you may withdraw your consent at any time with future effect.

12. When do we respond to your Requests?

We will respond to your Requests free of charge and without delay, and in any case within (1) one (1) month of receiving your request. However, if your Request is complex or there are a large number of Requests, we will let you know within the month if we need to obtain an extension of another (2) two months within which we will respond to you. If your Requests are manifestly unfounded or excessive in particular because of their repetitive nature, the Company may impose a reasonable fee, taking into account the administrative costs of providing the information or performing the requested action, or refuse to follow up on the Request.

13. Where can you contact for the progress of your Requests?

For information on the progress of your Request, you may email tsbk@tsbktransfer.gr

14. Social network

TSBK TRANSFER operates official accounts on the following social networks: Facebook, Twitter, Google, Instagram, Linkedin, Youtube. The reason for processing all Personal Data we collect for you by using the aforementioned social networks (social networking platforms), whether anonymously or not, is to provide updates with regard to our content or to contact you by replying to your messages. The legal basis of this process is your consent.

Your consent is given when you click like or follow to our pages and may be revoked by the same way, namely by clicking unlike or unfollow. By giving your consent, you accept our data protection policy, which is displayed in a visible and accessible point on each page. If you do not agree with our policy, you shall revoke your consent accordingly (by unlike or unfollow). Our Company is considered to be a Controller jointly with the social network platform. Administering social network is part of our Personal Data protection internal policy and, thus, in order to protect them, we apply a series of appropriate technical and organizational measures, such as to delimit the people having access to social network administration, so that we ensure secure processing of your Data.

Important note: we are not responsible for the way or the means each of these platforms process your Data. Keep yourself updated for such platforms policy by the relevant links: Facebook, Twitter, Google, Instagram, Linkedin, Youtube.

In addition, we do not control the content of the comments submitted by users of such platforms, however, we use best efforts to ensure a safe online environment and towards that purpose, we have the right to remove any kind of content or comment violating the terms of use of the Website, such as abusive, vulgar, pornographic, threatening, advertising or intellectual property infringing or containing a false statement as to the persons face, while retaining the ability to block users who submitted.

15. Cookies

The Website uses cookies and similar technologies during your access and navigation. Cookies are small files that are stored on the hard disk of the computer or other electronic device used by the user to access the Website. Cookies are unique for each web browser (e.g. Google Chrome, Mozilla Firefox, etc.) and contain anonymous information, in relation to the websites you visit and use.

16. What is the applicable law when we process your Data?

The applicable law is Greek law, as formulated in accordance with the General Data Protection Regulation 2016/679/EU, and in general the applicable national and European legislative and regulatory framework for the protection of personal data. The competent courts for any arising disputes related to your Data are the competent Courts of Athens.

17. Where can you appeal if we violate the applicable law for the protection of your Personal Data?

You have the right to lodge a complaint before the Personal Data Protection Authority (postal address 1-3 Kifissia Street, P.K. 115 23, Athens, tel. 210. 6475600, e-mail address (e-mail) contact@dpa.gr), if you believe that the processing of your Personal Data violates the applicable national and regulatory framework for the protection of personal data.

18. Questions/Contact us

If you have any questions about our Privacy Policy or the way we process your Data in general, you can contact us by sending an email to tsbk@tsbktransfer.gr

19. How will you be informed of any amendments to this Policy?

This Privacy Policy applies to the Website. Any amendments will be effective as soon as they are posted on our Website. Where such amendments are material, we will notify you and obtain your consent where required by applicable law.