Introduction
The use of the "ExplorePAMTH" Platform [hereinafter referred to as the "Platform"] provided through our website www.explorepamth.gr [hereinafter referred to as the "Website"] and through the corresponding application available through Google Play Store or App Store [hereinafter referred to as the "Application"] is subject to the TERMS & CONDITIONS OF LICENSING & PROVISION OF SERVICES (link) and this PRIVACY POLICY ("Privacy Policy").
By using our Platform and services, you unconditionally declare that you have read, understood, and accepted all the terms contained in the Terms & Conditions of Licensing & Provision of Services and in this Privacy Policy. If you do not agree with any of the terms contained in the Terms & Conditions of Licensing & Provision of Services and/or the Privacy Policy, you must refrain from visiting and using the Platform and its services.
The Privacy Policy may be subject to modifications and adjustments from time to time, whenever deemed necessary and without prior notice to you, which will be effective from the date of their publication on the Platform. Therefore, we recommend that you check the Privacy Policy regularly.
The Privacy Policy describes how our Company, as "Data Controller" in accordance with the definitions of applicable personal data protection legislation [General Data Protection Regulation (EU) 2016/679 or simply "GDPR" , Law 4624/2019], collects and processes personal data and other information about you, the users of our Platform, Website, and services, as well as how our Website and Platform use cookies and any other identification technologies.
Company Details
The full details of the Company, which acts as the Data Controller of your personal data, are as follows:
Name: Rodopi Development Development Anonymous Company O.T.A.
Headquarters/Postal Address: K. Palama & K. Antoniadi, Komotini
Tax Identification Number: 094195984
Contact Telephone Number: 2531034073
Email: anro@anro.gr
Scope & Purpose of the Privacy Policy
The Company is committed to safeguarding the confidentiality of your personal data. The Privacy Policy is intended to help you understand, among other things, the following:
- the purpose for which we process your personal data,
- the categories of personal data we collect and process,
- the period for which we retain your personal data,
- the categories of recipients of your personal data, if any,
- whether we transfer this data to a country outside the European Union (EU)/European Economic Area (EEA),
- whether we make automated decisions or profiling, and
- the rights you have in relation to the processing of your personal data, as well as how you can exercise them.
The Privacy Policy is categorized into the following distinct sections/chapters for your convenience:
- When and why do we collect and process your personal data?
- What categories of your personal data are processed in each case?
- What are the legal bases for processing your personal data?
- How long do we retain your personal data?
- To whom do we disclose and/or transfer your personal data?
- How do we ensure the security of your data?
- What rights do you have in relation to your personal data?
- Links to Third Party Websites
- How can you contact us?
- When does this Privacy Policy apply?
1. When and why do we collect and process your personal data?
1.1. Simple browsing of the Website: Our Company does not collect any of your personal data when you simply browse our Website, unless you have consented to the use of specific categories of cookies in accordance with our Company's Cookies Policy, in which case we process the data collected through these cookies.
1.2. Communication: When you contact us directly for any reason (e.g., through our Website, the Platform, or based on any other contact details), we process certain categories of your personal data in order to respond to your communication.
1.3. Creating a Personal Account: To register on the Platform, you are given the option to create a personal online account, through which you can access certain services (hereinafter referred to as "Personal Account" or "User Account"). If you create a Personal Account, we will process certain categories of your personal data to complete and manage your registration.
1.4. Newsletter subscription: Users who wish to be informed about news and articles on our Website can subscribe to our newsletter via the Website. When you subscribe to our newsletter mailing list, we process specific categories of your personal data in order to provide you with the relevant material.
1.5. Services: When we provide you with our services through the Platform, we process specific categories of your personal data in order to fulfill the contractual/transactional relationship between us.
2. What categories of your personal data are processed in each case?
2.1 "Personal data" means data relating to you as an identified or identifiable natural person, i.e. a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name.
2.2 Data we collect directly from you: The personal data we process is provided to us directly by you. Specifically:
2.2.1. Simple browsing of the Website: When you simply browse our Website, you do not provide us with your personal data, as no personal data is collected or processed during this activity in accordance with clause 1.1. above, unless you have consented to the use of certain categories of cookies in accordance with our Company's Cookie Policy, in which case we will process the data collected through these cookies.
2.2.2. Communication: When you communicate with us as described in clause 1.2. above, we collect and process certain categories of your personal data for communication purposes, such as to respond to your questions or requests for information. Specifically, when you communicate with us in any way (e.g., via email, via any available contact form), we collect and process the information you provide us directly, which may include: your name, email address, telephone number, and the message you send us.
2.2.3. Creating a Personal Account: In order to register as a user on the Platform and create a Personal Account in accordance with clause 1.3. herein, we collect and process the following personal data: your email address and password for user identification and access to your personal account. If you wish to register your full name, we will also collect this data. In addition, for as long as you keep your Personal Account active and use it, we further process information about its content and the actions you perform through it (e.g., information about the digital material you use, time of logging in and out of your Personal Account, information about any request you make to recover your Personal Account password, the content of your Personal Account).
2.2.4. Newsletter subscription: When you subscribe to our newsletter by filling out the relevant form on the Website in accordance with clause 1.4 above, we collect and process your email address in order to send you the relevant material.
2.2.5. Services: When we provide you with our services through the Platform, we process certain categories of your personal data, such as: your identification details (name), contact details (email address, telephone number), information about the contract between us, the services you have ordered, information about the pricing of the services provided (e.g. user subscription details to specific content on the Platform). We may also process data related to your location when using the Platform if you provide us with your consent (e.g. when you ask us to show you the nearest tourist attractions or when you plan tour activities through the Platform).
2.3. Data collected using cookies and other tracking technologies: We also use cookies and collect information about how you use the Website, technical information, including information about access time, volume of data transmitted, transmission status, browser type, version and language, browser plugin type and version, IP address, operating system and system interface, time zone, and
Please see in detail our Website Cookies Policy, which is available at www.explorepamth.gr/privacy-policy. The Cookies Policy is an integral part of this Policy and also governs your use of the Website and the Platform.
2.4. Data collected by third parties: We receive some of the aforementioned technical data, concerning the details of your device (e.g. manufacturer, model, screen characteristics, operating system, etc.), or behavioral data (e.g. clicks, choices), from analytics providers such as Google.
2.5. Anonymous - statistical data: We may process anonymized and statistical data for any purpose, in particular for statistical purposes and to improve the services - information provided on the Website. Although this data may be derived from your personal data, it is not considered personal data if it does not directly or indirectly reveal your identity (for example, we may collect anonymous, statistical data about the use of the Website in order to calculate the percentage of users who access certain elements of the Website).
3. What are the legal bases for the processing of your personal data?
3.1. We process your personal data when the law allows us to do so, i.e. when there is a legal basis in accordance with applicable law, such as in the following cases:
3.2. Performance of a Contract: Processing is necessary for the performance of a contract between us in accordance with paragraph (b). 1 of Article 6 of the GDPR, such as in the case of the execution of your orders through the Platform and the provision of the Services in accordance with conditions 1.5 and 2.2.5 above. Also, pursuant to case (b) of para. 1 of Article 6 of the GDPR, the processing is necessary for taking measures at your request prior to entering into a contract, such as when you request information or a price offer regarding services/subscriptions of the Platform with a charge.
3.3. Consent: You have provided your consent in accordance with case (a) of par. 1 of Article 6 of the GDPR, for the processing of your personal data for one or more specific purposes such as. 3., 2.2.3. above, when you subscribe to our newsletter according to terms 1.4., 2.2.4. above, when you consent to the processing of your location data when providing services, as well as to the installation and use of specific, optional types of cookies (see more details in the Cookies Policy).
3.4. Legal Obligation: The processing of your personal data is necessary for the fulfilment of our legal obligations under (c) of para. 1 of Article 6 of the GDPR, e.g. in case we are requested by a competent judicial authority to access your personal data, or when we provide you with fee-based services via the Platform and we have to comply with the requirements of tax law (e.g. processing of data necessary for the issuance of the tax document required by law).
3.5. Legitimate Interests of our Company: Processing is necessary for the purposes of the legitimate interests pursued by our Company, provided that your fundamental rights do not override those interests, in accordance with point (f) of para. Such legitimate interests include.
3.6. Please note that we do not use automated decision making without human intervention, including profiling, in a way that produces legal results that affect you or significantly affects you.
4. How long do we keep your personal data?
4.1. In general, we retain your personal data for as long as required by law, depending on the purpose and type of processing.
4.2. More specifically, your personal data will be kept for as long as necessary to achieve the purposes for which we collect it, e.g. for as long as necessary to provide you with the functions of our Website and Platform and the requested services. Once the purpose for which the data is processed has been achieved, we will delete your personal data or anonymise it, unless there are legal reasons to retain it. In particular:
We retain your personal data that we collect from you when you communicate and/or interact with us through our Website or any other available means of communication for the necessary period of time until the final resolution of the relevant issue for which you have contacted us (e.g. submitting a request or enquiry), and until any relevant claims are time-barred.
We retain your personal data that we collect from you when you subscribe to your Personal Account or Newsletter, for as long as you remain registered and we delete them in case you withdraw your consent and request the deletion of your Personal Account and unsubscribe as a member of our Newsletter mailing list.
We retain the personal data we collect from you when you enter into a contract with us for the duration of the contractual relationship between us, as well as for the maximum period of time required from its termination for the fulfilment of our legal obligations under the legislation governing our Company's activity (e.g. keeping tax documents) and until any relevant claims become statute-barred.
4.4. As regards the times/duration of cookies, please refer to our Website's Cookies Policy, which is available here. The Cookies Policy forms an integral part of this Policy and also governs the use of the Website and the Platform.
5. To whom do we disclose and/or transmit your personal data?
5.1. Our Company may appoint external/third party service providers (e.g. internet service providers, advertising service providers, Website and Platform technical support, email, data hosting) who will provide support services to us and who may process certain categories of your personal data in the course of providing the services, acting as "Processors" in accordance with applicable data protection legislation. Our Company ensures that third party service providers are contractually bound to protect your personal data in accordance with applicable law.
5.2. Other recipients: Our Company may disclose, in compliance with applicable data protection legislation, your personal data to judicial and/or prosecutorial authorities, independent authorities, governmental authorities, if required by applicable legislation.
5.3. Data transfers outside the European Union/European Economic Area: If, to the extent, within the scope and for the purposes of the aforementioned purposes, your personal data needs to be transferred outside the European Union, the transfer of such data will be carried out in accordance with applicable law and our Company will ensure an adequate level of data protection. By entering into appropriate data transfer agreements based on Standard Contractual Clauses, which are accessible to you upon request at anro@anro.gr or by taking other measures to provide an adequate level of data protection, our Company ensures or confirms that recipients provide an adequate level of protection for your personal data.
6. How do we ensure the security of your data?
Taking into account the latest developments, the implementation costs and the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity to the rights and freedoms of natural persons from the processing, we implement appropriate technical and organisational measures to ensure a level of security commensurate with the risks of the processing.
7. What rights do you have in relation to your personal data?
Subject to the conditions set out in applicable legislation, you have the following rights in relation to your personal data:
7.1. Right of access: you can contact us to let us know and explain if and what personal data we hold about you and how we process it. You can also request a copy of your personal data if it is processed.
7.2. Right to rectification: if you believe that your data is inaccurate or needs updating, you have the right to request the rectification of inaccurate personal data and the completion of incomplete information.
7.3. Right to erasure: Under certain circumstances, e.g. when the data is no longer necessary, you have withdrawn your consent, the data has been unlawfully processed, you can ask us to delete it.
7.4. Right to restrict processing: If you consider that your data is inaccurate or the processing is unlawful or you consider that the data is no longer necessary by us or you object to automated processing, you have the right to request the restriction of processing.
7.5. Right to object: you may object to the processing of your personal data by us on grounds relating to your particular situation, unless, inter alia, there are compelling legitimate grounds for the processing which override your interests, rights and freedoms. You also have the right to object where a decision concerning you is based solely on automated processing, including profiling, and that decision produces legal effects or significantly affects you (legitimate exceptions apply).
7.6. Right to data portability: you can request to receive your data in a structured, commonly used and machine-readable format, as well as to transfer your data to another organisation (controller) that you indicate to us.
7.7. Right to withdraw consent: if the processing of your personal data is based on your consent (e.g. in the case of a subscription to our newsletter or the creation of a Personal Account), you have the right to withdraw it at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out prior to such withdrawal.
7.8. Right of appeal: Please be informed that you have the right of appeal to the Hellenic Data Protection Authority (Hellenic Data Protection Authority) for issues related to the processing of your personal data. The Hellenic Data Protection Authority is located in Athens (Kifissias 1-3, P.O. Box 115 23).
7.9. Exercise of rights: to exercise your rights you can contact us in writing by email or at our postal address.
8. Links to Third Party Sites
The Website (and/or the Platform) may contain links to other websites, platforms and/or applications that we do not control (hereinafter "Third Party Sites"). The Privacy Policy does not cover information collected from Third Party Sites that you visit through links that may be present on the Site. The aforementioned Third Party Sites have their own Privacy Policies and terms of use. We encourage you to read them before browsing and/or using these Third Party Sites.
9. How can you contact us?
We remain at your disposal for questions and clarifications. Please contact us at our contact details:
Email: anro@anro.gr
Phone: 2531034073
Postal address: K. Palamas & K. Antoniadis, Komotini
10. When does this Privacy Policy apply?
The Privacy Policy has been published and is effective as of 2/2/2025.
