Privacy Policy

1. About Us

Welcome to Marathon Airlines S.A. privacy notice. Marathon Airlines S.A. (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

MARATHON AIRLINES SOCIETE ANONYME

registered office is at 14 Lontou Street, Glyfada-Attica, P.C. 16675, a company registered in Greece under company number 144347201000 [GEMI Number].

We act as the data controller when processing your data. Our designated Data Protection Officer is Anastasia Papadopoulou who can be contacted at the email a.papadopoulou@flymarathon.aero

2. Information That We Collect

Marathon Airline S.A. processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

The personal data that may we collect are:

• Identity Data, such as full name data, if applicable marital status, date and place of birth, nationality, passport or ID data;
• Contact Data, such as billing address, delivery address, telephone numbers, email addresses and any other contact data requested by you;
• Financial Data, such as Bank Account Data and Payment Card Details

We collect information in the below ways:

• Online forms
• Hardcopy forms
• Telephone
• Email
• Mail
• Verbally on 1on1 meetings
• Interviews
• Event registrations

3. How We Use Your Personal Data (Legal Basis for Processing)

Marathon Airlines S.A. takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice below. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.

The purposes and reasons for processing your personal data are in generic detailed below, except in case individually in a signed agreement a specific purpose is mutually agreed:

• To register you as a new contract counterparty/customer/user of our services
• To perform an agreement signed or to provide a service and to ensure that orders are completed and can be sent out to your preferred address
• As part of our legal obligation for business accounting and tax purposes
• To administer and protect our business and the website
• To make suggestions and recommendations to you about goods or services that may be of interest to you

4.Your Rights

You have the right to access any personal information that Marathon Airlines S.A. processes about you and to request information about:

• What personal data we hold about you
• The purposes of the processing, if this is not clarified to you under the above
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• If we have not collected the data directly from you, information about the source
• If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

If you have any further questions about this policy or how we handle your personal information, please get in touch with us by writing to our appointed person at a.papadopoulou@flymarathon.aero

5. Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Marathon Airlines S.A. may use third-party partners to provide their services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

6. Safeguarding Measures

Marathon Airlines S.A. takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorized access, alteration, disclosure, or destruction and have several layers of security measures in place, including:

• SSL & TLS encryptions
• IT authentication (included restriction access),
• Firewalls
• Anti-virus/malware etc.

7. Consequences of Not Providing Your Data

You are not obligated to provide your personal information to Marathon Airlines S.A. however, as this information is required for us to provide you with our services/deliver your products/legitimate interests, we may not be able to offer some or all of our services without it.

8. How Long We Keep Your Data

Marathon Airlines S.A. will only retain your personal information for as long as is necessary to fulfill the purposed we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Details of retention periods for different aspects of your personal data should be available in the specific agreement signed between us or within the order form you submit us. If such is not the case, you can ask us to confirm the retention period by sending an email to following email address: a.papadopoulou@flymarathon.aero

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

9. Marketing

Occasionally, Marathon Airlines S.A. would like to contact you with the specify products/services/promotions that we provide via Post/Email/Telephone/Text Message (SMS)/ Automated Call etc. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting Marathon Airlines S.A. directly.

LEGITIMATE INTERESTS EXAMPLE

Marathon Airlines S.A. will occasionally send you products/services/promotions by email/SMS/post that have been identified as being beneficial to our contract counterparts and/or customers and in our interests. Such information will be relevant to you as a contract counterpart and/or customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

10. Lodging A Complaint

Marathon Airlines S.A. only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

In Greece this is the Hellenic Data Protection Authority, details of which can be found via the following link: www.dpa.gr . In any case we would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance using contact data below:

Marathon Airlines S.A.

In Att. to: a.papadopoulou@flymarathon.aero

14 Lontou Streer – Glyfada-Attica, PC 16675