PRIVACY POLICY
The management and protection of your personal data as a visitor/user of the Beach Booking are governed by
the present Privacy Policy, the Terms of Use, the provisions of Greek Law (Law 2472/1997 as currently in force,
and the regulatory provisions) and the Decisions, Directives and Regulations of the Hellenic Data Protection
Authority (www.dpa.gr).

Without prejudice to the provisions of the following paragraph, the personal data will not be communicated to
any third party other than the Provider, unless applicable law requires the disclosure of such data to the
competent Authorities and only to them.

The aforesaid data may be stored and processed by Beach Booking for communication and statistical purposes
as well as for the improvement of the services on offer. By using this Application, you provide your consent for
the use of such data by Beach Booking and the Providers.

This Application contains special connections (links, hyperlinks, banners) to other websites operated by third
parties. Should you choose to follow the links to third party websites, Beach Booking shall not be responsible in
any event for the terms concerning the management and protection of personal data, applied to the connected
websites.

Moreover, as visitors/users of the Application you have the right to access the data related to you and you have
the right to object to the processing of such data.

BEACH BOOKING PRIVACY POLICY

The company under the name “TILTOM PC”, with registered seat at 57 Apostolopoulou, Chalandri, Greece, PC
15231, with VAT no 801579574, Tax Office Cholargos (to be henceforth called “TILTOM”) is the sole and exclusive
owner of an application under the brand Beach Booking, designed for the online reservation of beach beds and
umbrellas in beaches, as these are registered and appear in the application (to be henceforth called “Beach
Booking”, the “Application” and the “Service” respectively).

Use of the Application is enabled either through registered beaches’ website or /and social media accounts or
through the application Beach Booking for mobile phones.

This privacy policy is governed by Greek Law 2472/1997 regarding the processing of personal data and intends
to inform you of how Beach Booking handles the personal data which it processes for you. If you do not agree
with any part of this Privacy Policy, then Beach Booking cannot provide the Application to you, and you should
stop accessing the Application and deactivate your account. You can find out more about how to deactivate your
Beach Booking account at Delete Account section.

DEFINITIONS

When the definition of a term does not appear in this Privacy Policy, it is deemed to mean the definition as
outlined in the Terms of Use.

"Data Controller" is Beach Booking which is responsible for the use and the processing of personal data.

"Personal Data" is information in relation to a living individual who is or might be identified either from that
information or from that information in conjunction with other information that is in, or it is likely to come into,
the possession of the Data Controller.

WHAT TYPES OF INFORMATION DOES BEACH BOOKING GATHER ABOUT
ITS USERS?

1. Data you give.

Beach Booking receives, stores and processes data that you make available when accessing or using the
Application. For example, it collects personal data, when you:

o fill in any form on the Application, such as when you register or update the details of your user account,
o access or use the Application, to search for available amenities, make bookings, pay for amenities and

services, book or pay for any associated services which may be available,
o link your account on a third-party (e.g. Google or Apple) with your Beach Booking account, in which case

Beach Booking will obtain the personal data that you have provided to the third-party, to the extent this
is allowed by your settings in the third-party and to the extend you allow that,

o communicate with Beach Booking.


2. Mobile Data

When you use certain features of the Application, through Beach Booking mobile and /or other applications,
Beach Booking may receive, store and process different types of data regarding your location, including
general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based on the
functionality on mobile devices used to access the Application or specific features of the Application). If you
access the Application through a mobile device and you do not want your device to provide location-tracking
information, you can disable the GPS or any other location-tracking functions on your device, provided that
your device allows you to do this. Please check your device manufacturer’s instructions for further details.

3. Log Data

Beach Booking may also receive, store and process Log Data, which is information automatically recorded by
the servers of Beach Booking whenever you access or use the Application, regardless of whether you are
registered in Beach Booking or logged in to your Beach Booking account, such as your IP Address, the date
and time you access or use the Application, the hardware and software you are using, referring and exit pages
and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent
on specific websites.

4. Cookies and other Tracking Technologies

Beach Booking uses cookies and other similar technologies on the Application (please see below in detail).
Beach Booking may also allow its business partners to use their cookies and other tracking technologies on
the Application. As a result, when you access or use the Application, you will provide or make available certain
data to Beach Booking and to its business partners (please check the Cookie Policy below).

HOW BEACH BOOKING USES AND PROCESSES THE DATA YOU PROVIDE
OR MAKE AVAILABLE

Beach Booking uses and processes data regarding you for the following general purposes:

o to enable you to access and use the Application,
o to operate, protect, improve and optimize the Application, the business of Beach Booking, and the users’

experience, such as to perform analytics, conduct research, and for advertising and marketing purposes,
o to create and maintain a trusted and safer environment for the Application, such as fraud detection and its

prevention, conducting investigations and risk assessments, verifying the address of your listings, verifying
any identifications provided by you, and conducting checks in databases such as public government
databases,

o to send you service, support and administrative messages, reminders, technical notices, updates, security
alerts, and information requested by you,

o in case Beach Booking has your consent, to send you marketing and promotional messages and other
information that may be of your interest, including information sent on behalf of its business partners that
Beach Booking considers you may find interesting. YOU WILL BE ABLE TO UNSUBSCRIBE OR OPT-OUT FROM
RECEIVING THESE MESSAGES,

o to administer payments, surveys, sweepstakes, contests, or other promotional activities or events sponsored
or managed by Beach Booking or its business partners, and

o to comply with its legal obligations, resolve any disputes that Beach Booking may have with any of its users,
and enforce its agreements with third parties.

WHEN BEACH BOOKING DISCLOSES OR SHARES PERSONAL DATA AND TO
WHOM

IMPORTANT: When you use the Application, your data will remain within the European Union.

Your Personal Data may be disclosed as follows:

If you choose to provide a review, your review may be public on the Application.

You recognize, approve and agree that Beach Booking may have access, keep and reveal your account
information, if it is forced to do so by law or if, pursuant to good faith, this access, keeping or revelation is
reasonably necessary in order for Beach Booking (a) to respond to claims against it (b) to comply with the legal
procedures (e.g. summonses and warrants) (c) to apply and manage its agreements with the users, as per the
Terms of Use (d) to prevent a fraud, to evaluate risks, for the investigation, for the support of clients, for the
development of products and for avoiding eavesdropping or (e) to protect the rights, the property or the personal
safety of Beach Booking, its users or its public members.

Beach Booking may also publish, disclose and use aggregated data and non-personal data for industry analysis,
demographic profiling, marketing and advertising and other business purposes.

TRANSFER OF BUSINESS BY BEACH BOOKING

If Beach Booking transfers its business (which may include the transfer of your personal data to a third-party),
Beach Booking shall notify you accordingly before your personal data is communicated to any third-party and
becomes subject to a different privacy policy.

HOW TO CHANGE OR DELETE YOUR DATA, OR CANCEL YOUR BEACH
BOOKING ACCOUNT

YOU MAY REVIEW, UPDATE, CORRECT OR DELETE THE PERSONAL DATA IN YOUR BEACH BOOKING ACCOUNT
BY LOGGING IN TO YOUR ACCOUNT. IF YOU WANT TO CANCEL YOUR BEACH BOOKING ACCOUNT ENTIRELY,
YOU SHOULD SEND YOUR REQUEST WITH YOUR DETAILS AT [email protected] .

Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly
available on the Application under your name, even after your Beach Booking account is cancelled.

KEEPING YOUR PERSONAL DATA SECURE

Beach Booking has implemented reasonable administrative, technical, and physical security measures to protect
your Personal Data against any unauthorized access, destruction or alteration of your data.

YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND
RESOURCES

The Application will contain links to other websites not owned or controlled by Beach Booking. Beach Booking
does not have any control over third-party websites. These other websites may place their own cookies, web
beacons or other files on your device, or collect and request personal data from you. They will have their own
rules regarding the collection, use and disclosure of personal data. We kindly encourage you to read the terms
of use and privacy policies of the other websites that you visit.

GOT FEEDBACK?

Your opinion matters to us! If you would like to provide us with your feedback regarding this Privacy Policy, please
contact us at [email protected] .

FOR USERS RESIDING IN THE EU ONLY: YOUR RIGHTS TO REVIEW AND
UPDATE DATA

As per Article 12 of Greek Law 2472/1997, you may request in writing copies of your personal data held by Beach
Booking. Beach Booking will provide you with a copy of the personal data held as soon as practicable and, in any
event, no later than 15 days after the request in writing.

If Beach Booking does not respond to your request within this period, you may address your request to the
competent Authority which is the “Hellenic Data Protection Authority”. There may be a charge to access your
personal data in accordance with the charge imposed by the Hellenic Data Protection Authority. This charge is
returned to you in case your request for data change or delete is valid. Beach Booking may also request proof of
identification to verify your access request. All requests should be addressed to ([email protected]).

Beach Booking tries to keep your information accurate, complete and up to date. If your personal data held is
inaccurate, please inform the company and Beach Booking will make the necessary amendments, erase or block
the relevant data and notify you within 15 days of your request based on which the relevant action has been
taken.

As per Article 13 of Law 2472/1997, you may also request the correction or erasure or temporary not use of your
personal data if you believe Beach Booking is in breach of the relevant data protection legislation. All requests
should be addressed to Beach Booking and specifically to this address: 57 Apostolopoulou, Chalandri, Greece, PC
15231. In addition, Beach Booking is obligated to respond to your request within 15 days. There is no charge for
making such a request.

COOKIE POLICY

A “cookie” is a small text file, which is sent to and stored on your computer or any other device you may use to
access the Internet, each time you visit a website, without collecting any information about the documents or
files on your device.

Beach Booking uses “cookies” for many different reasons, aiming to create a safer and more efficient
environment for you. Beach Booking mainly uses “cookies”, which are necessary for providing the services
offered through the Application, as well as “cookies” used for statistical purposes and matters relating to the
functionality of the Application (e.g. number of visitors, how many return, frequency of visits, user preferences
etc.).

Internet web browsers are usually set by default to accept “cookies”. Consequently, if you wish to modify how
your browser operates, either to notify you of the use of “cookies” or to block “cookies”, you must change your
browser’s settings.

Please note that the non-acceptance of “cookies” may limit certain services and information provided by Beach
Booking.

COOKIES USED BY BEACH BOOKING AND COOKIES USED BY THIRD
PARTIES

Beach Booking may place cookies on your device through the Application. Therefore, the Privacy Policy of Beach
Booking will also apply to the processing of the data Beach Booking obtains via cookies.

Beach Booking may also allow its business partners to place cookies on your device. As it is further explained
below, third parties may also place cookies on your device for advertising purposes.

There are two types of cookies used on the Application, namely “persistent cookies” and “session cookies”.

Session cookies will normally expire as soon as you close your browser, while persistent cookies will remain on
your device after you close your browser, and they can be used again the next time you access the Application.

USES OF THIRD-PARTY COOKIES

The cookies used by the partners of Beach Booking intend to obtain data to provide services to Beach Booking.
For example, third party companies and individuals providing services to Beach Booking may track your behavior
on the Application to market and advertise Beach Booking listings or services to you on the Application and third-
party websites. Third parties that use cookies and other tracking technologies to deliver targeted advertisements
on the Application and/or third-party websites may offer you a way to prevent such targeted advertisements by
opting out at the websites of industry groups such as the Network Advertising Initiative
(http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance
(http://www.aboutads.info/choices/). You may also be able to control advertising cookies provided by publishers,
for example Google’s Ad Preference Manager (https://www.google.com/settings/ads/onweb/). Please note that
even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the
Application – it just will not be tailored to your interests.

In addition, Facebook places a cookie via the Application that allows Facebook to obtain aggregated, non-
Personal Information to optimize its services. For example, if a user clicks on an advertisement for the Beach
Booking mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user
(who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also
inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app.

CHANGES TO THIS COOKIE POLICY

Beach Booking can change this Cookie Policy at any time. If Beach Booking proceeds to material changes to the
Cookie Policy, it will let you know either by posting the changed Cookie Policy on the Application or by sending
you an email. It is important that you review the changed Cookie Policy. If you do not wish to agree to the changed
Cookie Policy, then Beach Booking cannot continue to provide the Application to you, and your only option is to
stop accessing the Application and deactivate your Beach Booking account.

OTHER TECHNOLOGIES

The Application may also use other technologies with similar functionality to cookies, such as web beacons and
tracking URLs to obtain Log Data about users. Beach Booking may also use web beacons and tracking URLs in its
messages to you to determine whether you have opened a certain message or accessed a certain link.