“S.T.T. Synopsis Travel Technologies Limited” having its registered office in Limassol, Cyprus, Vasileos Konstantinou str. 92A, (“Synopsis”, “us”, “we”, or “our”) may provide travel services to its clients (indicatively or such as : tickets, hotel reservations, car rentals).
Any client may enter its requests on the platform for any of the services provided herein for the account of its crew members/employees/executives/managers/partners/externals/customers (hereinafter the “subjects”) and fill in the required for the respective service - as per case - subjects’ personal data.
Synopsis is committed to maintaining client’s confidence and trust with respect to the privacy of the processed personal data. This privacy policy explains how we collect, use, share and, in general, process the personal information/data you provide to us, via the platform.
About our privacy policy
This privacy policy applies to the platform and the personal data processed through it and may be supplemented by terms or notices provided to you.
Synopsis being the owner of the platform, as identified therein, acts as the Controller, under the meaning of Regulation (EU) 2016/679, of the subjects’ personal data/information provided to it via the platform. Synopsis, fully complying with the applicable legislative and regulatory framework, limits the access to the data collected exclusively to respectively authorized persons (officers, employees, associates) and takes enhanced data security measures to secure data against -among others- loss, mishandling, unauthorized access, alteration or disclosure.
Applicable Laws/Legislation with regard to the protection of personal data
Synopsis complies with any provision of Law with regard to the processing of personal data in private life and security, including, but not limited to, Regulation (EU) 2016/679, Law N 4624/2019 as in force or any other applicable laws or laws replacing the above international or national Laws relating to the protection of personal data as well as the relevant regulations, directives or the Guidelines of the competent Public Authorities such as the Cypriot Data Protection Authority (CDPA).
Information we collect
Α. We collect information directly from you through your input on the platform of the subjects’ data required for the travel arrangements and the services you have requested/ordered.
The kind of personal information that we collect directly from you depends on the content and features of the kind of service you select to use and how you otherwise interact with us and shall include:
For Corporate Travelers |
|
For Crew Members |
|
Β. Device data
The Service may automatically collect information about how you and your device interact with the platform, such as:
- Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, unique device identifier and other technical identifiers, we collect this data through our server(-s).
How we use the personal data you provide
Grounds for processing
When we collect from you any personal information within the scope of European data protection laws, we do so:
- where necessary to provide the Service, fulfill a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
- where necessary for our compliance with applicable law or other legal obligation;
- where necessary for the performance of a task carried out in the public interest;
- where applicable, with your consent; and/or
- as necessary to operate our business, protect the security of our systems, customers and users, detect or prevent fraud, or fulfill our other legitimate interests as described in the sections above, except where our interests are overridden by your privacy rights.
- Satisfy your requests addressed to Synopsis or investigate any complaints made
- Notify you about changes, updates and other announcements related to the platform;
- Provide technical, product and other support and help to keep the platform working, safe and secure;
- Comply with our legal and regulatory obligations, resolve disputes and enforce our agreements.
Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.
We shall not use the personal data you provide on the platform to identify usage trends or develop data analysis, including for the purposes of research, audits, reporting and other business operations, or determine the effectiveness of any promotional/advertising campaigns or provide you with relevant promotional messages and other information about products, events and services of ours, our group companies and third parties such as societies and sponsors;
Legal basis for data processing
The processing of the personal data entered on the platform is necessary in order to fulfill the above purposes. The legal basis for the processing of such data is:
(a) processing is necessary for the fulfillment of our contractual relationship with you
(b) processing is necessary for Synopsis’ compliance with its legal and regulatory obligations
(c) processing is necessary for the purposes of the legitimate interests pursued by Synopsis
(d) the subject has given his/her explicit consent to the processing of above personal data. In such case, the data subject has the right to withdraw his/her consent at any time, notifying accordingly Synopsis by filing a respective request either at Synopsis offices or electronically at hello@synopsis.travel
The withdrawal of the consent given does not affect the lawfulness of processing based on consent before its withdrawal.
Sharing of the personal data provided on the platform – Recipients
We may share the personal data provided on the platform in the following ways and contexts and transmit them to the following categories of recipients, so as to provide the requested service, complete a transaction or fulfill your request in compliance with this privacy policy and any other appropriate confidentiality and security measures :
Α. With our business partners
We are headquartered in Cyprus
We also have business partners that perform business operations for us. For example, we shall partner with other companies in Cyprus, Greece and worldwide to organize your travel, arrange hotel accommodations, air tickets, car rentals, process your payments and in general to proceed all the services requested for the subjects.
We may share sufficient personal data about you with these partners, before, after or during the subjects travel in order to improve our services. These companies have their own privacy policies which you should refer to if you choose to use their services.
- With Suppliers and service providers (Ιndicatively: airline companies, hotels, shipping agents, car rental companies, payment processors, IT service providers)
In the context of a transaction we share your personal data with suppliers, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a travel transaction.
- To protect our rights or the rights of a third party:
We may share your personal data and transmit them to recipients in order to identify, investigate, contact you, if we believe in good faith that disclosing this personal data is necessary to protect our rights or the rights of a third party C. Legal reasons
We also will disclose the personal data you enter on the platform if such disclosure is necessary to
- meet any applicable law, regulation, legal process or other legal obligation;
- detect, investigate and help prevent security, fraud or technical issues; and/or
- protect the rights, property or safety of Synopsis, its employees or directors;
- comply with a judicial decision
and as part of a corporate transaction or an acquisition by or merger with another company.
We may provide certain personal data to governmental and recognized law enforcement agencies as required by law or other third parties where we believe necessary to comply with a legal or regulatory obligation.
We are required to cooperate with government and law enforcement agencies and public authorities of any country in your itinerary, including customs and immigration authorities. Personal data may be shared with government authorities if we are legally obliged.
Transfer of personal data to third countries or international organizations
Synopsis may transfer personal data to a third country or an international organization if the European Commission has decided that this country or international organization ensures an adequate level of protection and in any case, only under the conditions that the prerequisites set by Regulation (EU) 2016/679 are met.
Rights to access and Control your personal Data
The personal data subjects have the following rights:
- Right of information and access to the personal data processed, as well as to their origin, the processing purposes, the recipients or categories of recipients and the period of their storage.
- Right to rectify inaccurate data and complete incomplete data kept.
- Right to erase the personal data subject to Synopsis ’s obligations and legal rights to retain them for a minimum time period, pursuant to the current legislative and regulatory framework.
- Right to restrict the processing of personal data if either the accuracy of said data is contested or their processing is unlawful, or the purpose of the processing is eliminated and provided that there is no legitimate reason to retain them.
- Right to the portability of personal data to another controller, provided that the processing is based on the subject’s consent and is carried out by automated means. This right shall be exercised subject to Synopsis’ legal rights and obligations to retain the data and to perform a task which is carried out in the public interest.
- Right to object to the personal data processing, on grounds relating to the subject’s particular situation, in case personal data are processed to perform a task carried out for reasons of public interest or for the purpose of legitimate interests which are pursued by the Synopsis or any third party.
If you wish to exercise any of these rights please contact our GDPR department at the email hello@synopsis.travel and we will consider your request in accordance with applicable laws. To protect your privacy and security, we may require you to verify your identity
You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.
Data retention
We retain the personal data you enter on the platform for as long as we have an agreement with you to provide our services as travel agents so as to fulfill the transactions/services you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.
Data security
All data shall be encrypted and stored in a cloud-based central database at a third-party provider’s location in Germany and Finland.
We take precautions to safeguard the personal data you provide against loss, theft and misuse and unauthorized access, disclosure, alteration and destruction through the use of appropriate technical and organizational measures. Furthermore, we ensure that all associates and third parties/providers with which we cooperate during and in the framework of the data processing apply also the appropriate technical and organizational measures to ensure the confidentiality and lawful retention, processing, protection and safe storage of your personal data against any illegal or unlawful processing, accidental or unlawful destruction, loss, alteration, prohibited dissemination or access.
These measures are subject to continuous development in accordance with technological progress and are periodically reviewed to comply with all applicable privacy laws.
We have lawfully ensured that any processors of your personal data acting on our behalf meets all requirements pursuant to the current legislation and provides sufficient assurance regarding the implementation of the appropriate technical and organizational measures, so that the processing of your personal data occurs in a way that the protection of your rights is ensured.
Changes
We will update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. If we make any revisions that materially change the ways in which we process your personal data, we will notify you of these changes before applying them to that personal data through special notices or by other means.
Contact
If you have any questions, comments, complaints or requests regarding this privacy policy or our processing of your information, please contact our GDPR department at the email hello@synopsis.travel
You also may lodge a complaint with the Cypriot Data Protection Authority (CDPA). You need first make an effort to exercise your rights to Synopsis, as the Data Controller.
For the Authority's responsibilities and how to file a complaint, you can visit its website (www.dataprotection.gov.cy > Information For The Public > Lodge A Complaint) where detailed information is available.
Limassol, March 01st, 2024