Notification concerning the Processing of Personal Data for ANEK SMART members transferring their points and tier to Seasmiles
Controller
We hereby notify you that ATTICA HOLDINGS S.A., registered office in Kallithea, 1-7 Lysikratous Street& Evripidou Street (here in after “ATTICA GROUP”), for the purpose of transferring points and tiers from ANEK Smart’s loyalty programme to Seasmiles, will process the personal data to be registered in relation thereto, in accordance with applicable national legislation and European Regulation 2016/679 for the protection of individuals with regard to the processing of personal data and the free movement of such data (General Data Protection Regulation, hereinafter the “Regulation”) as in force, and, for this reason, shall act as controller of member personal data.
Data Protection Officer
For any matter concerning the processing of personal data, please contact us via e-mail at DPO@atticagroup.com or via letter sent to the above postal address.
How and why do we use your personal data?
Given that having a Seasmiles account is a requirement in order to transfer any point balance and tier from the ANEK Smart loyalty programme to the Attica Group Seasmiles loyalty programme, interested ANEK Smart members/holders, after gaining access to their existing Seasmiles account or registering now for the first time, in accordance with the relevant procedure, will have the option of entering the following details separately for the purpose of identifying themselves, and the subsequent automatic transfer of their points and tier to the Seasmiles programme.More specifically, the information we will process for the above purpose is the following:
- ANEK Smart card number
- First and Last Name
- Date of Birth or email address or mobile telephone number, whichever information the member chooses to enter
- ANEK Smart point balances and Tiers to be automatically transferred to Seasmiles
It should be noted that members will be able to do this on the Seasmiles website and via call centre. Inthe latter case, the member’s postal address is also requested for the purpose of identification.
Legitimate reason for processing personal data:
The legitimate reason for processing your personal data is the conclusion of a contract regarding the continued provision of services and privileges, henceforth through the Seasmiles programme, to the members of the ANEK Smart programme, as the latter shall cease operating on 28/02/24.
Where are your data shared?
Your data are shared with an external partner, if and when the need arises, who provides technical support for the sound operation of the management platform we use internally for the programme.ATTICA GROUP has lawfully ensured that for the latter case of the data processor on its behalf, the conditions are met and sufficient assurances are provided for the implementation of suitable technical and organisational measures, so that the processing of your personal data ensures the protection of your rights. There is no transfer of member personal data to non-EU third countries.
Data Storage Period
It should be noted that for the above purpose of identification, the only data to be stored will be the ANEK Smart card number, which shall be retained until 31/12/2024, a period of time that is necessary in order to grant Seasmiles members their privileges on future trips they have booked with their ANEKSmart card. All other identification details provided for this purpose are checked in real time and are not stored, while the details of those who have now become Seasmiles members are subject to the specific provisions of the relevant notification.
Further information
You have the right to access, rectify, erase, restrict or oppose processing, the right to portability, and the right to lodge a complaint with the HDPA. To exercise the rights provided for by Regulation (EU)679/2016 (GDPR), you can send an email to DPO@atticagroup.com or a letter to the postal address: Lysikratous Street 1–7 & Evripidou Street, GR-17674, Kallithea, Greece.More information about your rights and the processing of personal data that takes place in the context of the Seasmiles loyalty programme is available here:
Privacy Statement for the Attica Group ‘Seasmiles’ Loyalty Programme