Privacy Policy | Digital Assistant "Pythia"

1.    Categories of Personal Data 

1.1.      When you use the Digital Assistant through the Website and/or the Communication Application, we collect and process certain personal data, so that you may benefit from the functions and services provided through the Digital Assistant.

1.2.      Specifically, when you use the Digital Assistant, we process technical data regarding your access and use of the Digital Assistant including data and time of access, timestamps that you have read the Digital Assistant’s messages, data volume transmitted, status of transmission, browser type, version and language, browser plug-in types and versions, your internet protocol (IP) address, information about about the clicks and the links you click, and other information about how you use the Digital Assistant. When you use the Digital Assistant through the Communication Application, which is provided by third parties (e.g., WhatsApp LLC, Meta Platforms Inc.), we also process information collected from these third-party integrations: third parties allow us to have access to and process additional information about your interaction with their services as it relates to your use of the Digital Assistant such as your identification data as a user, namely your username, Messenger ID, Instagram ID, the telephone number you may use as a user of the Communication Application (in case that you access and use the Digital Assistant via the Communication Application "What's app"). In any case we will also process the content of your conversation with the Digital Assistant, which might contain personal data of yours.

1.3.      It is clarified that the Digital Assistant does not need or ask you to disclose your personal data during your conversation, and that as users you must not submit, disclose, communicate and / or in any way share any personal data (including special categories of data according to the definitions of the applicable legislation, such as health data, religious beliefs, sexual preferences, etc.) in the content of your conversation with the Digital Assistant, in compliance with the Digital Assistant Terms of Use. The content of your conversation with the Digital Assistant may contain personal data of yours only if you disclose them breaching the Terms of Use of the Digital Assistant.

1.4.      The processing of your personal data is limited to the strictly necessary data you provide us (e.g. “username” when you use the Digital Assistant through the Communication Application) that allow us to contact you and respond to your request/query through the Digital Assistant by providing you with the information you requested. Under no circumstances, does our Company aim at any other and / or further collection and processing of your personal data. Under no circumstances does our Company intend and does not knowingly collect or process special categories of your personal data according to the definitions of the applicable legislation (e.g. health data, biometric data, data about your sex life, your religious beliefs). According to Terms of Use of the Digital Assistant you are obliged not to share, register, disclose, communicate and/or in any way make available special categories of personal data of yourself or third parties when using and chatting with the Digital Assistant.

1.5.       The Digital Assistant does not need to process your personal data to respond to your requests/queries. The Digital Assistant provides information according to the search criteria that you enter in the Digital Assistant, without you having to share your personal data to receive such information. For example, you can ask the Digital Assistant to inform you about the available "French cuisine restaurants in the center of Athens", without disclosing any personal information (e.g. your name, the details of your tablemates). The Digital Assistant will respond to your question/request and will provide you with the relevant information according to the criteria you have set, without asking you any personal information/data.

1.6.       As a user, you are obliged to make lawful use of the Digital Assistant and to comply with the applicable legislation and the Terms of Use of the Digital Assistant, according to which you are obliged, inter alia, not to disclose, transmit, process in any way personal data of yours or any third natural persons (e.g. identification data such as full name, contact data such as telephone details) and especially special categories of personal data (e.g. health data,  data concerning sex life or sexual orientation, data revealing political opinions or religious beliefs) through the Digital Assistant during the whole period of such use. For more detailed information, we always recommend that you refer to the Digital Assistant Terms of Use before any use. These Terms of Use are available here: Terms of Use of the Digital Assistant.

2.    Purpose of Processing

2.1.       The purpose of processing your personal data is to respond to your communication, to your request /query that you submit through the Digital Assistant.

2.2.       Our Company does not aim to collect and process your personal data through the Digital Assistant in a manner incompatible with the above purpose. Any processing of your personal data by our Company is limited to the minimum possible extent: for example, we process only the appropriate, relevant, and necessary personal data, such as your user details (e.g. username) when you use the Digital Assistant through the Communication Application.

2.3.       Our Company does not use your personal data for other purposes, such as for marketing purposes, profiling, personalized advertising.

3.    Legal Basis for Processing 

3.1.      The use of the Digital Assistant is optional.

3.2.      The legal basis for the processing of your personal data by our Company, as their categories are described in terms 1.1. and 1.2. above, is the performance of the contract between us in accordance with article 6 par. 1 (b) of the General Data Protection Regulation (EU) 679/2016. As we have already explained, our Company does not aim to collect and process your personal data through the Digital Assistant. The processing is limited to the minimum data (e.g. user details when you use the Digital Assistant from the Communication Application, content of conversation, metadata such as timestamp) that are strictly necessary for the operation of the Digital Assistant.  In plain words, we collect and process your absolutely necessary personal data in order to provide you through the Digital Assistant with the information you ask and to respond to your contact request.

3.3.      As we clearly explain herein as well as in the Terms of Use of the Digital Assistant, MARKETING GREECE does not intend nor does it ask you through the Digital Assistant to provide your personal data. We urge you to comply with the Terms of Use of the Digital Assistant and not to disclose under any circumstances personal data of yourself or third parties during your communication/conversation with the Digital Assistant, including special categories of personal data (e.g. health data, religious beliefs, sex life, as defined by applicable law). ). If, however, you provide us with additional personal data, including special categories of personal data, as content of your conversation with the Digital Assistant, the legal basis for processing them will be your consent, in accordance with Article 6 para. 1 (a), as well as Article 9 para. 2 (a) for special categories, of the General Data Protection Regulation (EU) 679/2016. You have the right to request at any time the withdrawal of your consent and the deletion of such personal data from the content of your conversation with the Digital Assistant. 

4.    Transfer to third parties or outside the EU/EEA 

4.1.      MARKETING GREECE may engage external/third parties as service providers, who act as data processors of MARKETING GREECE, to provide certain services to MARKETING GREECE. When providing such services, the external service providers may process your personal data acting as "Data Processors" in accordance with the applicable legislation. Examples of such providers are internet service providers or service providers that provide technical and operational support (e.g. for your convenience and our more effective communication through the Website and the Digital Assistant) [hereinafter "Data Processors»]. Data Processors may process your personal data to provide their services to our Company.  Data Processors are bound to our Company, under a relevant contract to protect your personal data in accordance with the conditions and guarantees of the applicable legislation. They are obliged, inter alia, contractually and in accordance with the applicable legislation, not to process your personal data for their own purposes or to proceed with further processing, nor to transmit your personal data to third parties, unless they have our written permission.

4.3.      MARKETING GREECE may disclose your personal data to judicial and/or prosecuting authorities, independent authorities, governmental authorities in accordance with the terms of applicable law.

4.4.      MARKETING GREECE transfers personal data in accordance with applicable laws. To the extent that, in the context of and for the needs of the above-mentioned purposes, your personal data is transferred outside the EU/EEA, such data transfer will take place in accordance with applicable legislation and MARKETING GREECE will ensure an adequate level of data protection. By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses, which are accessible upon request at [email protected], or taking other measures to provide an adequate level of data protection, MARKETING GREECE establishes or confirms that all data recipients will provide an adequate level of protection for your personal data.

4.5.      In this regard, the Digital Assistant Provider is based outside the EU and acts as a Data Processor on behalf of our Company, in accordance with applicable law. In particular, the Digital Assistant Provider processes your personal data under a relevant contract, under the orders and instructions of our Company, in accordance with the terms and guarantees of the applicable legislation. The Digital Assistant Provider has undertaken, pursuant to our agreement, a set of contractual obligations, in accordance with the Standard Contractual Clauses for the international transfer of personal data in accordance with the applicable implementing decision of the European Commission, for the protection of your personal data, such as, but not limited to taking appropriate technical and organizational security measures, restricting the training of the Digital Assistant to anonymous data (and not to your personal data), working with secure subcontractors/sub-processors with similar contractual privacy commitments (such as WhatsApp LLC, Meta Platforms Inc. for the provision of the Digital Assistant through the Communication Application).

4.6.      We do not sell or share your personal data with third parties for the purposes of promoting products or services.

5.    Retention Time Personal data

5.1.      Your personal data will be retained for as long as it is necessary to achieve the purpose of their processing, that is, for as long as it is required in order to provide you with the functions of the Digital Assistant and the content/information material/answer you requested with your question/request to MARKETING GREECE through the Digital Assistant.

5.2.      Once the purpose of processing your personal data has been achieved, we will either delete your personal data or anonymize it, unless there are legitimate grounds for retaining it (e.g. retention is necessary in order to meet our legal obligations under applicable law, including any national and European legislative provision governing our activity;  or in order to support our legal claims in pending litigation between us).

5.3.      We may process anonymized statistical data for any purpose, in particular for statistical purposes and for improving the services – information provided on the Website and our Digital Assistant. Although this data may derive from your personal data (e.g. entered or disclosed when using the Digital Assistant), it is not considered personal data, as it is anonymized in such a way that it does not directly or indirectly reveal your identity (for example, we may collect statistical and anonymous data on the use of the Digital Assistant).

6.    Personal Data Security

6.1.      Taking into account the latest developments, the cost of implementation and the nature, scope, context and purposes of processing, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing.

6.2.      The Digital Assistant Provider has contractually undertaken a number of commitments to protect your privacy. More simply, the Digital Assistant Provider has ensured that the design, operation and technical support of the Digital Assistant do not need to process your personal data. 

6.3.      The training of the Digital Assistant as an artificial intelligence platform is carried out by the Digital Assistant Provider utilizing anonymous, statistical data, without using your personal data, which you are obliged under the Terms of Use of the Digital Assistant not to disclose, register in any way to the Digital Assistant throughout its use and communication between you and the Digital Assistant.

6.4.      The Digital Assistant is limited to communicating with you and viewing information material you request and does not make decisions with consequences for you, nor does it draw up user profiles.

6.5.      If you use the Digital Assistant through our Website, your conversation with the Digital Assistant is deleted from your browser's cache immediately after you leave our Website by closing the relevant tab from your browser. After this deletion, the Digital Assistant cannot refer to any of your previous conversations, nor does it retrieve or otherwise "remember" the information and its content.

7.    Your Rights

7.1.       Pursuant to the applicable data protection law you may have the following rights for the protection of your personal data:  

• Right of access: You may contact MARKETING GREECE to explain to you if and which data retains for you, as well as the way we process such data. You may also request a copy of your personal data which MARKETING GREECE retains for you.
• Right to rectification: If you believe that your data are not accurate or need to be updated, you have the right to obtain the rectification of inaccurate personal data and to have incomplete data completed. 
• Right to erasure: Under certain circumstances, e.g. the personal data are no longer necessary, you withdraw consent, you have the right to obtain the erasure of personal data. 
• Right to restriction of processing: If you believe that your data are not accurate or their processing is unlawful or you think that MARKETING GREECE does no longer need your data or you have objections to automated processing, you have the right to obtain the restriction of processing.
• Right to object: You have the right to object to processing of your personal data from MARKETING GREECE on grounds relating to your particular situation, unless, among other reasons, if there are compelling and legitimate grounds for the processing which override your interests, rights and freedoms. You also have the right to object when a decision concerning you is based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you (the law provides exceptions which apply). 
• Right to data portability: You have the right to receive the data concerning you in a structured, commonly used and machine-readable format, as well as the right to transmit those data to another entity (controller), indicated by you to MARKETING GREECE.
• Right to consent withdrawal: If you have provided your consent with regard to specific collection, process and use of your personal data (e.g. to receive communication for direct marketing of products and services), you may withdraw that consent at any time. The previous mentioned withdrawn of consent applies only for the future.
• Right to obtain human intervention: At any time you have the right to request the human intervention of a representative of MARKETING GREECE by selecting the relevant icon with the word indication " Right to ask Human Intervention - Contact a Representative " available in the Digital Assistant, or by requesting it in writing from the Digital Assistant clearly (e.g. by indicating in your communication "I wish to contact a representative"). You may also stop using the Digital Assistant at any time and contact us by post, email, or telephone using our contact details available in our Terms of Use and on our Website.
• Right of appeal to a supervisory authority: If you consider that we have not satisfied any of your rights or that the processing of your personal data is contrary to the applicable legislation, you have the right to appeal to the Personal Data Protection Authority (Kifisias 1-3, Athens PC 115 23, https://www.dpa.gr/ ).

7.2.       To exercise your rights, please contact us in writing via email or by post using our contact details listed herein, which are also available on our Website.

7.3.       We must respond without delay and no later than one month after we receive your request to exercise any of your above rights. The one-month deadline may be extended by two months according to the applicable legislation.  For any extension of the response time, you will be in any case informed within one month of your request.  As a rule, your requests are submitted and fulfilled free of charge. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee or refuse to act on such requests according to the applicable legislation. In case of rejection of your request, MARKETING GREECE informs you of the reasons for the rejection of the request and of your right to appeal to the Personal Data Protection Authority or the courts.

7.4.       More information regarding the processing of your personal data when using our services and the Website, as well as on your related rights, can be found in the Privacy Policy of MARKETING GREECE, which is also posted on its Website. You can refer to it via the following link: https://www.discovergreece.com/privacy-policy .

This policy may be amended from time to time. Any newer version of this Policy will be posted on this Website and will be effective as of the date of its publication.  Please review the Digital Assistant Privacy Policy regularly, each time you access the Digital Assistant.

This Digital Assistant Privacy Policy was posted on 24/05/2024.