Privacy Policy

Last Updated: 01/05/2023

We at MMS P.C. (hereinafter “MMS”, “the Company”, “we”, “our” or “us”), value your privacy and are strongly committed to protecting any information we obtain from you, or about you. This Privacy Policy describes our practices with respect to Personal Data we collect from or about you, in the course of our business activities, when you use our website and/or our online or offline offerings (collectively, the “Services”). It is meant to help you understand how we collect, use and share your personal data, and to assist you in exercising the privacy rights available to you.

SCOPE

Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to a specific identifier such as a name, an identification number, location data, an online identifier or any other characteristic pertaining to the physical or physiological, genetic, mental, economic, cultural or social identity of that natural person.

The purpose of the present Privacy Policy (hereinafter the “Policy”) is to define the principles governing the data processing activities performed by the Company and the basic procedures that we follow, within the Company, to implement an appropriate level of protection for your personal data. Please read our Privacy Policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal data.

Note that this Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services.

MMS will only process your personal data in accordance with the national data protection laws applicable to its establishments, including the General Data Protection Regulation, hereafter referred to as the “GDPR” (Regulation 2016/679), as in force.

For any matter relating to the processing of your personal data, you may directly contact MMS’s competent department by e-mailing privacy@mms.com.

Data Controller

MMS acts as a “data controller” of the personal data provided to, collected by, or processed in connection with our Services. Where the Company engages a third party service provider who collects, uses, stores or otherwise processes Personal Data owned by the Company on behalf and under the instructions of the Company, that service provider shall act as “data processor” of your information. In all such cases, the Company ensures that a data processing agreement is in place. The purpose of this data processing agreement is to ensure that the service provider only process personal data in accordance with applicable legislation, and its execution shall take place before the service provider accesses your personal data.

1.What personal data do we collect from users of our Services?

MMS collects data that can be used, alone or in combination with other information in our possession, to identify you. These fall into the following categories:

Personal Data you provide to us: When you communicate with us to inquire about our Services or request information about our Services, MMS will collect the personal data necessary for us to fulfil your request, such as:

Communication Information: If you communicate with us, we will collect your name and contact information, and the contents of any messages you send to us via the contact form available on our website (“CommunicationInformation”). This includes, but is not limited to:

i) Basic identification data – your name, surname and title
ii) Contact details – your phone number and email address

iii) Any other information you chose to disclose to us via the free text box on the contact form (your message)

Information that is necessary for us to fulfil our contract with you and deliver our Services. This includes:

i) Your name, surname and title
ii) Your phone number and email address

iii) Your tax identification number, your postal address, the company you work for and your position/occupation

iv) Copies of documents you provide to us to prove your identity, where the law requires this or where this is necessary as part of a transaction executed on your behalf in the course of delivering our Services, such as a copy of your passport or equivalent ID document. This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
v) Details of your yachting preferences.
vi) Information relating to transactions that are necessary for the provision of our Services, such as your billing address, payment methods and/or other financial information.

Social Media Information: MMS has an active presence on social media sites like Instagram, Facebook and LinkedIn. When you interact with our social media pages, we only collect the Personal Data that you chose to provide to us, such as your social media username(s), your contact details, and any other personal data you choose to include in your message (collectively, “Social Information”), to respond to your comments, questions or feedback. In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.

Your communication preferences regarding marketing materials.

Personal Data we receive automatically from your use of our Services: When you visit, use, and interact with our website, we receive the following data about your visit, use, and/or interactions (“Technical Information”):

- Log Data: Information that your browser automatically sends whenever you use our website (“log data”). This includes your Internet Protocol address, your browser type and settings, the date and time of your request, and how you interacted with our website.
- Usage Data: Information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, computer connection, IP address, and the like.
- Device Information: This includes the name of the device, the operating system, and the browser you are using. The information collected may depend on the type of device you use and its settings.
- Cookies: We use cookies to operate and administer our website, and improve your experience with it. Cookies are small text files placed in your computer browser whenever you load a particular website. Cookies help users navigate websites efficiently, store their preferences and perform certain functions. Most browsers will allow you to block and delete cookies. However, disabling cookies may, in some cases, prevent you from using, or negatively affect the display or function of, a website or certain areas or features of a website. You can find out more about cookies by visiting https://www.allaboutcookies.org.
- Analytics: MMS may use a variety of online analytics products that use cookies to help us analyse how users use our Services, to assess the speed, accuracy and/or security of our Services, diagnose technical issues and generate usage reports.

2. When do we collect your personal data?

We collect data from you on the following occasions:

When you visit our website or submit your data via the website.
When you contact us by any means with queries, feedback etc.
When you ask our Company to send you information about a yacht or a Service.
When you request the provision of a Service or otherwise do business with us.
When you book any kind of appointment or meeting with us.
When you engage with us on social media.
When you fill in any forms that are necessary for the provision of our Services.

In addition, we may collect data from publicly available sources where the information is made public as a matter of law.

3. How do we use your personal data?

Depending on the purpose for which MMS may be required to process your personal data from time to time, these will fall into the following categories:

To allow us to fulfil our contract with you and deliver our Services. In particular:

To provide to you our Yacht Agency & Port Operations Services (berth reservations, customs & clearance, bunkering, crew sign on & sign off, waste disposal, diver services)
To provide to you our Provisioning & Supplies Services
To organise events for you, make restaurant and hotel reservations and book tickets on your behalf
To rent transportation on your behalf
To offer to you our Concierge Services, On-board Entertainment and Chauffeur Services
To accommodate any other need you communicate to us.
To process your billing information for products or Services purchased by you.

To communicate with you, and to allow you to communicate with us

MMS will process your personal data to reply to your inquiries, handle and comply with your requests, provide information requested by you, and manage your suggestions for the improvement of our Services.

To provide you with additional content and Services, for example to:

Contact you with promotional materials, personalised offers, products, and Services and other information that may be of interest to you, including new services.

If you do not wish to receive these communications, you may unsubscribe at any time by clicking on the ‘Unsubscribe’ button at the bottom of each communication, or by notifying us by any other means, at any time.

To allow you to connect with us

If you contact us via social media, we will process the personal data you submit to us for the purpose of answering to your questions or otherwise responding to your messages.

To comply with the law

In some cases, we will be required by law to process your personal data to comply with legal obligations and regulations. This may be the case, for example, with tax-related obligations. In order to comply with relevant laws and regulations, we may need to disclose your personal data in response to a request or order of a regulatory agency or other supervisory authority.

To analyse and improve our Services, for example to:

Improve customer experience;
Allow our website administrators to manage the performance and functionalities of our website;
Ensure the security of our IT systems, architecture, and networks;
Enforce our terms and conditions.
Aggregated or De-Identified Information. Any aggregate data used to analyse the effectiveness of a Service, to improve or add features to a Service, or for any other similar purpose, will be maintained and used in an anonymous or de-identified form, exclusively.

Other purposes

MMS will process your personal data to comply with internal operations and procedures such as order management, invoicing, accounting, and pricing, implementation of business controls, management of customer directories, and other archiving and insurance policies.

The use of your personal data by data processors

When an external party that provides services to us processes your personal data following MM’s instructions, it acts as a ‘data processor’ with regard to that processing activity. Prior to interacting with such parties, MMS enters into a Data Processing Agreement with them. This agreement includes obligations to ensure that your personal data is being processed by the data processor in a secure and lawful manner, to afford you the same level of protection as that afforded to your data by us.

3. What is the legal basis for the processing of your personal data?

MMS processes your personal data on the basis of your CONSENT, and our contractual obligations to you.

Please note that, by:

accepting the terms and conditions of our Services, or
contacting us by any means to request a Service, or
sending us emails or other communications or by completing forms requesting for information or one or more of our Services,
subscribing to our electronic catalogues for the purpose of receiving informational material or other promotional material, or by renewing/changing such preferences,

YOU ARE CONSENTING to the processing of your personal data by MMS, in accordance with this Privacy Policy.

You can withdraw your consent any time by contacting us at privacy@mms.com.

We will only collect the personal data that is necessary for the delivery of our Services and/or the performance of the contract between you and MMS.

4. Do we disclose your personal data to third parties?

Your personal data are only accessible by a limited number of authorised staff and service providers that act on our behalf, on a need-to-know basis.

Disclosure of your personal data to external parties

MMS only discloses your personal data to third party vendors and service providers that support us in delivering our Services, assist us in meeting business operations needs, and help us respond to customer inquiries and requests, update our marketing catalogues, analyse data, and comply with our legal duties. Pursuant to our instructions, these parties will access, process, or store your personal data only in the course of performing their contactual obligations to us.

These include:

IT and related service providers that provide to us cloud services, email communication software and newsletter services, web analytics and other technical and operational maintenance services;
ISPs and ICT service providers
Payment service providers
Business Partners with whom we jointly offer products or Services
Advertising Partners (we may share your personal data with third-party advertising partners to market our Services, provided that you have opted-in to receive such communications through your Account or our website).

Legal Requirements

MMS will disclose your personal data:

Where such disclosure is required by law or other applicable regulation;
In response to a request or order of a regulatory agency or other supervisory authority (including port authorities);
Where such disclosure is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) defend and enforce our legal rights, (iii) protect against legal liability, (iv) to avert unlawful acts against our company and our clients.

When MMS acts on your behalf, as an intermediary between you and a third party for the provision of a Service requested by you, MMS will disclose, where necessary, the personal data required by that third party for the purpose of executing any transaction preliminary to the provision of that Service.

We choose reliable Partners and take all appropriate contractual, technical and organisational measures to ensure that your personal data are processed by external parties only to the extent necessary for the purposes set out in this Privacy Policy and in accordance with applicable legislation.

Transfers outside EEA

All of our external partners are currently located in countries inside the European Economic Area (EEA). Your personal data will not be disclosed to external parties outside the EEA, save where such disclosure is required by law.

If your personal data are transferred to a recipient in a country outside the EEA that does not provide an adequate level of protection in accordance with the GDPR, we will take all necessary measures to ensure that your personal data are adequately protected, for example, by entering into EU Standard Contractual Clauses with the recipient of your data. 

5. Your rights as a data subject

Right of access:
You have the right to submit a request for confirmation by MMS as to whether or not your personal data are being processed. You also have the right to access your personal data and receive additional information about how we process it, to verify the legitimate nature of the processing.

Right to rectification:
You have the right to correct any data held by us, if you believe them to be inaccurate, and to complete, update or modify your personal data, by contacting MMS at the email address set out above.

Right to erasure:
In certain cases, you have the right to request the deletion of your personal data (for example, when the processing is based on your consent). You may contact us at any time to learn more about your right to erasure.

Right to restriction of processing:
You have the right to request that we restrict the processing of your personal data in the following cases: (a) when the accuracy of the personal data is contested and until such accuracy is verified, (b) when you oppose the deletion of your personal data and request a restriction of their use instead, (c) when your personal data are no longer needed for processing purposes; they are however necessary for the establishment, exercise, or defence of a legal claim by us, and (d) when you object to the processing of your personal data and a decision on the matter of your objection is still pending.

Right to object to processing:
Under certain conditions, you have the right to object to the processing of your personal data. If you exercise your right to object, we will be legally obligated to terminate any processing operations, unless we can show that the processing is necessary to protect our legitimate interests as data controllers, or to establish, exercise, or defend a legal claim.
Right to data portability:
Under certain conditions, you have the right to receive your personal data, free of charge, in a format that allows you to access, use, and edit them with commonly used editing methods. You may also request the transmission of your data directly to another controller, provided that this is technically feasible.

Right to withdraw your consent:
Where the processing is based on your consent, you have the right to withdraw it at any time, without, however, affecting the lawfulness of the processing that was carried out prior to its withdrawal.
In order to exercise any of the above rights, or to learn more about your rights, email MMS’s competent department at privacy@mms.com.

Right to lodge a complaint with a Supervisory Authority
If you believe that the processing of your personal data is unlawful, or that your rights have been violated, you have the right to lodge a complaint with the Hellenic Data Protection Authority, by completing the complaint form posted on the following webpage: www.dpa.gr > My rights > Submit a complaint.

Hellenic Data Protection Authority

Switchboard: +30 210 6475600

Fax: +30 210 6475628

e-mail: complaints@dpa.gr

You can also lodge a complaint with the supervisory authority in the Member State of your habitual residence or your place of work.

6. How do we protect your personal data?

MMS implements appropriate technical, physical, legal, and organisational measures to ensure that your personal data is collected, used and stored in compliance with internationally recognised data security standards and in accordance with the terms set forth in this Policy, as well as applicable data protection legislation.

We use a variety of technical measures, such as access controls, encryption, pseudonymisation and firewalls, to ensure the ongoing confidentiality, integrity, and security of your personal data, and to protect your data against loss, misuse, and unauthorised access, disclosure, alteration, or destruction.

We perform periodic security checks and our staff is regularly trained to comply with data protection and information security practices.

Whenever MMS delegates processing activities to a third party data processor, to be carried out on our behalf, we make sure that they possess adequate resources and the necessary know-how to carry out the processing activities in a lawful and secure manner and in accordance with the legal requirements set out in the GDPR.

If you have any reason to suspect that your interactions with us are no longer secure, please contact us immediately.

7. How long will your personal data be stored for?

Your personal data will be retained for no longer than is necessary to fulfil the purpose for which it was collected, save where the data is required for the purpose of resolving legal disputes, establishing legal defences, conducting audits, enforcing our contractual agreements, or complying with applicable laws, and in any case having due regard to the relevant statutory limitation periods.

For example:
Where your personal data is necessary for the provision of our Services, the data will be stored for as long as you use our Services.

Please note that, as long as you use our Services, MMS will keep a record of your requests, to inform any future communication and to allow us to demonstrate how we communicate with you throughout our relationship. We do this on the basis of our contractual obligations to you, our legal duties and our legitimate interest in offering to you our best service based on your personal experience.

Your personal data will be deleted or made anonymous when they are no longer necessary for the purpose for which they were collected. Note, however, that certain legal provisions (for example, tax legislation) require us to keep certain data for longer periods.

8. Changes to our Privacy Policy

We reserve the right to update and/or revise our Privacy Policy from time to time.

Αny amendment to our Privacy Policy will be notified to you via email. We will also update the “Last Updated” indication at the top of this page to let you know about the date on which any such changes shall become effective.

In any case, we urge you to check for updates from time to time, by clicking on the relevant section “Privacy Policy” on our website.

You understand and acknowledge that your continued use of our Services after we publish or notify you about the changes to this Privacy Policy means that the collection, use, storage and transfer of your personal data is subject to the updated Privacy Policy, as of its effective date.

9. How can you contact us?

If you have any questions about the way we process your personal data, please read this Privacy Statement first. For additional questions or complaints, please contact:

MYKONOS MARITIME SERVICES P.C.

Thesi Argyraina, Mykonos, 84600 Greece

+30 697 0976838 | +30 694 3932348

privacy@mms.com