PRIVACY POLICY ATOB TRANSFER LTD

At ATOB TRANSFER LTD, we take privacy seriously, therefore we take all necessary actions to safeguard the privacy of our customers, partners, and associates and to comply with the national and European legislation. Since May 25, 2018, all entities established and operating within the European Union, controlling personal data, have become subject to the General Data Protection Regulation (GDPR), which introduces the framework on how all entities must process, manage, and protect personal data. The General Data Protection Regulation (GDPR) (EU) 2016/679 (hereinafter to as the “GDPR”) is the EU regulation on data protection and privacy for all individuals within the European Union and the European Economic Area, and ATOB TRANSFER LTD, being such an entity, has adopted the highest standard of the industry.

Because we know that privacy is important to you, ATOB TRANSFER LTD invites you to devote some of your time to understand how ATOB TRANSFER LTD is collecting, processing, managing, and protecting your privacy.

ATOB TRANSFER LTD is incorporated and existing under the laws of the Republic of Cyprus with registration number HE 41255, having its registered address and headquarters at Ayiou Nikolaou 33, Egkomi 2408, Cyprus with the following contact details [email protected], phone number +35724030588, (hereinafter referred to as the “Company”, “We”, “Us”, “Our”) and We are the controllers of Your Personal Data.

We provide the following services: taxi service, an hourly car hire with driver service, tour packages (hereinafter referred to as the “Transportation Services” or “Services”).

The Company is the sole owner and/or the operator of the website (atobtransfer.com) and/or of any application connected and linked and/or anyhow connected to the mentioned website (website and/or application hereinafter to be referred to as the “Platform”). Whereas We through the Platform arrange Transportation Services for the users of the Platform who are seeking for such services through the Platform.

This Privacy Policy is intended to inform the Users of Our Platform (hereinafter referred to as the “Traveller(s)”, “You”, “Yours”, “User”) about what information We collect about You, what We do with it and what rights You have in relation to any of Your personal data being processed by Us.

The present Privacy Policy is our very first privacy policy and it is in force since the 26.01.2021.

This Privacy Policy is in accordance with the GDPR and with all national legislation (legislation of the Republic of Cyprus). We would like to assure You that any future amendments to the applicable regulatory framework either national or European will be incorporated in this Privacy Policy in a timely manner. Thus, We do reserve the right to update this Privacy Policy and any other supplemental privacy notice (if any) at Our sole discretion, from time to time. The amended version of the Privacy Policy shall come into effect upon posting of the same on Our website. We recommend reviewing the Privacy Policy on a regular basis. If You have any queries for the current version of the Privacy Policy, we strongly suggest to contact Us.

By continuing to use Our Services by any means, You accept automatically and unconditionally the current and/or modified  Policy to its entirety. If You shall not agree with any aspect and/or term and/or condition of the current and/or modified version of the Privacy Policy, You should not use Our Services and/or Platform and shall not provide Us with Your personal data. Please note that You may exercise any of your rights as those are described in Section (V).

We, ATOB TRANSFER LTD are the Data Controller of Your personal data. That means that We are the ones who are receiving, processing, and managing your personal data.  Personal data, as defined by the GDPR, is any information related to an identified or identifiable natural person (“data subject”); an identifiable natural person is the one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

What personal data do we collect?

While using Our Services to book a transfer and/or buy a service and/or a product from Us and particularly through Our Platform, We collect the following personal data:

• Full name including nicknames;
• Contact information such as Your home or business address, email address, and telephone number;
• Payments data such as Your bank card number, the expiration date of the

card, the CVV, etc;

• Transportation data (History) such as the total number of Transfers or the details of the Transfers You have booked through Us;
• Technical/device data such as IP address, login information, browser type and version, operating system and platform, and other technology on the devices that You use to access our Platform, etc;
• Login data such as when You log in to Your account in the Platform which is Your email and password;
• Other data You have provided Us with, such as flight numbers, personal preference, and other nonessential information for the comprehensive completion of the booking and, in general, any information that You have provided Us with in order to facilitate your booking in a more efficient manner;
• IP address, geolocation
• Demographic data such as age, city, Postal Code, etc;
• Cookie data such as number of visits to the Platform, visitor interaction with the Platform (see analytically Cookies Policy);
• Customer service data;

How and when do We collect personal data?

We collect directly from You the following personal data:

• When You open your account on Our website and book a taxi transfer,
• From Your communication with Us;
• While conducting payments for Our Services.

In addition, Our website/Platform may use cookies and other similar means and technologies that allow Us to collect and/or create data about Your preferences, your interaction with Us, the type of Transfer that You book, the search terms You’ve entered or the links You clicked on the Platform, etc.

How and why do We use Your personal data?

We use Your data for the sole purpose of You receiving the Services. This kind of usage is not limited to:

• You opening and operating an account at the Platform;
• Communicating with You;
• Identifying You;
• Receiving payments from You;
• Arranging and/or providing and/or managing and/or executing Your taxi transfer/requested Services;
• Managing and/or handling and/or processing Your request;
• Meeting any contractual obligation We may have towards You;

We may use Your personal data for marketing purposes but only after You give prior consent to it.

To whom do We send Your personal data?

Primarily Your personal data is shared only with the necessary employees and/or associates and/or departments of the Company who are managing and/or processing Your request and/or Services.

Further for the provision of the Services and for meeting our contractual obligation and for the operation of the Platform, We may cooperate with third-party service providers. When we do cooperate with third-party service providers We share with them the minimum necessary data needed for their services. Further, we bind third-party service providers not to use Your personal data for any other reason and also we dictate how the third-party service providers process, use, manage, protect your data.

More specifically, we may share your personal data with:

• Drivers;
• Our lawyers and other professionals;
• Data analysis companies;
• Research companies;
• Third-party email marketing companies acting in the name and on our behalf to send You the newsletter;
• Advertising and marketing companies;
• Providers of technology services,

We reserve the right to disclose Your personal data to a third party that we choose to transfer all or part of Our business.

As a general rule, We do not transfer Your personal data out of the EU and EEA unless such transfer is necessary for the provision of Services to You and for the operation of the Company. When Your data is to be transmitted to third countries outside the European Union and European Economic Area, all the appropriate safeguards are taken for the protection of Your Personal Data.

Measures, taken to protect your personal data and privacy.

We maintain the highest standards of the industry to secure and protect your personal data. We have in place all the necessary and appropriate technical and organizational measures, safeguards, protocols, and systems that allow Us to protect Your personal data from unauthorized disclosure, use, conversion, or destruction and, at the same time, We ensure that only some employees and/or associates and/or departments and/or third-party service providers have access to the required personal data for the sole purpose of providing You with the Services and for the operation of the Company.

How long do We keep Your personal data?

We will retain information about You for the period necessary to fulfil the purposes for which the information was collected. After that, Your account on our Platform along with Your personal data will be deleted.

After 5 (years) from Your last use of Our Services, Your account along with your personal data will be deleted.

If you allow us to use your personal data (for example, for marketing purposes), we may keep your personal data until the withdraw of your consent or until You inform us otherwise.

You have the right to request deletion of the information. Sometimes, we are legally obliged to retain the information for a greater period.

To exercise Your right, please, visit the relevant Section in this Privacy Policy.

We reserve the right (in certain circumstances) to anonymize Your data for research or statistical purposes so that it cannot be associated with an identifiable person, therefore we reserve the right to use this information for an indefinite period.

Hereby, we state some of Your rights you might have in connection to Your personal data we hold about you:

• Request Us to give You access to it;
• Request Us to rectify, update, or erase it;
• Request Us to restrict Our use of it (in certain circumstances);
• Object Us using it (in certain circumstances);
• Withdraw Your consent for Us using it;
• Opt-out You data to be used for direct marketing;
• Complain about the supervisory authority in Your country (if there is one).

We strongly advise You to visit the European Union official website, where you can be informed comprehensively about your rights. For your convenience,  We hereby attach the link to the GDPR, and further, we inform you that CHAPTER III of the GDPR is devoted to the Rights of the Data Subject.

We offer You easy ways to exercise these rights, by calling at Customer Support Team or by sending an email at [email protected]

Our mobile application and/or Our platform might also send You to push messages/notifications, for instance about Offers or Services. You can disable these messages/notifications through the settings in Your phone or the Platform.

Limitations and conditions may apply to some of Your rights.