INFORMATION WE COLLECT 

There are three general categories of information we collect. 

Information You Give to Us. 

Information that is necessary for the use of the ADR Hellenic Center Website. 

We ask for and collect the following personal information about you when you use the ADR Hellenic Center Website. This information is necessary for the adequate performance of the contract between you and us  and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all  the requested services. 

∙ Account Information. When you sign up, we require certain information such as your first name, last  name, email address, and date of birth. 

∙ Profile and Listing Information. To use certain features of the ADR Hellenic Center Website, we may  ask you to provide additional information, which may include your address, phone number, and a  profile picture. 

∙ Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID  card, or driving license, as permitted by applicable laws) or other authentication information.

∙ Payment Information. To use certain features of the ADR Hellenic Center Website we may require  you to provide certain financial information in order to facilitate the processing of payments. 

∙ Communications with ADR Hellenic Center. When you communicate with ADR Hellenic Center or use  the ADR Hellenic Center Website to communicate, we collect information about your communication  and any information you choose to provide.

Information you choose to give us. 

You may choose to provide us with additional personal information in order to obtain a better user  experience when using ADR Hellenic Center Website. This additional information will be processed based on  our legitimate interest or when applicable, your consent. 

∙ Additional Profile Information. You may choose to provide additional information as part of your ADR  Hellenic Center profile (such as city, and personal description). Some of this information as indicated  in your Account settings is part of your profile page. 

∙ Other Information. You may otherwise choose to provide us information when you fill in a form,  update or add information to your ADR Hellenic Center Account, respond to surveys, post to  community forums, participate in promotions, communicate with us, share your experience with us  or use other features of the ADR Hellenic Center Website. 

Information that is necessary for the use of the Payment Services. 

The Payments Data Controller needs to collect the following information necessary for the adequate  performance of the contract with you and to comply with applicable law (such as anti-money laundering  regulations). Without it, you will not be able to use Payment Services: 

∙ Payment Information. When you use the Payment Services, the Payments Data Controller requires  certain financial information in order to process payments and comply with applicable law. 

∙ Identity Verification and Other Information. The Data Controller may require identity verification  information (such as images of your government issued ID, passport, national ID card, or driving  license) or other authentication information, your date of birth, your address, email address, phone  number and other information in order to verify your identity, provide the Payment Services to you,  and to comply with applicable law. 

Information We Automatically Collect from Your Use of the ADR Hellenic Center Website. 

When you use the ADR Hellenic Center Website, we automatically collect personal information about the  services you use and how you use them. This information is necessary for the adequate performance of the  contract between you and us, to enable us to comply with legal obligations and given our legitimate interest  in being able to provide and improve the functionalities of the ADR Hellenic Center Website. 

∙ Usage Information. We collect information about your interactions with the ADR Hellenic Center Website such as the pages or content you view, bookings you have made, and other actions on the  ADR Hellenic Center Website. 

∙ Log Data and Device Information. We automatically collect log data and device information when  you access and use the ADR Hellenic Center Website, even if you have not created a ADR Hellenic  Center Account or logged in. That information includes, among other things: details about how  you’ve used the ADR Hellenic Center Website (including if you clicked on links to third party  applications), IP address, access dates and times, hardware and software information, device 

information, device event information, unique identifiers, crash data, cookie data, and the pages  you’ve viewed or engaged with before or after using the ADR Hellenic Center Website. 

∙ Cookies and Similar Technologies. We use cookies and other similar technologies when you use our  Website, or engage with our online ads or email communications. We may collect certain  information by automated means using technologies such as cookies, web beacons, pixels, browser  analysis tools, server logs, and mobile identifiers. In many cases the information we collect using  cookies and other tools is only used in a non-identifiable without reference to personal information.  For example, we may use information we collect to better understand website traffic patterns and to  optimize our website experience. In some cases, we associate the information we collect using  cookies and other technology with your personal information. Our business partners may also use  these tracking technologies on the ADR Hellenic Center Website or engage others to track your  behavior on our behalf. 

∙ Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage  technologies to collect or receive information from our websites and elsewhere on the internet and  use that information to provide measurement services and target ads. For apps, that third party,  including Facebook, may collect or receive information from your app and other apps and use that  information to provide measurement services and targeted ads.  

∙ Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the  ADR Hellenic Center Website currently does not respond to a “Do Not Track” signal in the HTTP  header from your browser or mobile application due to lack of standardization regarding how that  signal should be interpreted. 

∙ Payment Transaction Information. ADR Hellenic Center collects information related to your payment  transactions through the ADR Hellenic Center Website, including the payment instrument used, date  and time, payment amount, payment instrument expiration date and billing postcode, PayPal email  address, IBAN information, your address and other related transaction details. This information is  necessary for the adequate performance of the contract between you and ADR Hellenic Center. 

Information We Collect from Third Parties. 

ADR Hellenic Center may collect information, including personal information that others provide about you  when they use the ADR Hellenic Center Website and the Payment Services, or obtain information from other  sources and combine that with information we collect through the ADR Hellenic Center Website and the  Payment Services. We do not control, supervise or respond for how the third parties providing your  information process your Personal Information, and any information request regarding the disclosure of your  personal information to us should be directed to such third parties. 

∙ Third Party Services. If you link, connect, or login to your ADR Hellenic Center Account with a third party service (e.g. Google, Facebook), the third-party service may send us information such as your  registration, friends list, and profile information from that service. This information varies and is  controlled by that service or as authorized by you via your privacy settings at that service. 

∙ Other Sources. To the extent permitted by applicable law, we may receive additional information  about you, such as demographic data or information to help detect fraud and safety issues, from  third party service providers and/or partners, and combine it with information we have about you.  For example, we may receive background check results (with your consent where required) or fraud  warnings from service providers like identity verification services for our fraud prevention and risk  assessment efforts. We may receive information about you and your activities on and off the ADR  Hellenic Center Website through partnerships.

Children’s Data. 

Our website is not directed to children under 16 and we do not knowingly collect any personal information  directly from children under 16. If you believe that we are processing the personal information pertaining to  a child inappropriately, we take this very seriously and urge you to contact us using the information provided. 

HOW WE USE INFORMATION WE COLLECT 

We may use, store, and process personal information to (1) provide, understand, improve, and develop the  ADR Hellenic Center Website, (2) create and maintain a trusted and safer environment (such as to comply  with our legal obligations and ensure compliance with ADR Hellenic Center Policies) and (3) provide,  personalize, measure, and improve our advertising and marketing. 

Provide, Improve, and Develop the ADR Hellenic Center Website. We may use the personal information to  provide, improve, and develop the ADR Hellenic Center Website such as to: 

∙ enable you to access and use the ADR Hellenic Center Website, 

∙ enable you to communicate with us, 

∙ operate, protect, improve, and optimize the ADR Hellenic Center Website and experience, such as by  performing analytics and conducting research, 

∙ provide customer service, 

∙ send you service or support messages, updates, security alerts, and account notifications, 

We process this personal information for these purposes given our legitimate interest in improving the ADR  Hellenic Center Website and our users’ experience with it, and where it is necessary for the adequate  performance of the contract with you. 

Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and  maintain a trusted and safer environment such as to: 

∙ detect and prevent fraud, spam, abuse, security incidents, and other harmful activity, ∙ conduct security investigations and risk assessments, 

∙ verify or authenticate information or identifications provided by you, 

∙ conduct checks against databases and other information sources, including background or police  checks, to the extent permitted by applicable laws and with your consent where required, 

∙ comply with our legal obligations, 

∙ enforce our policies, and 

∙ in connection with the activities above, we may conduct profiling based on your interactions with the  ADR Hellenic Center Website, your profile information and other content you submit to the ADR  Hellenic Center Website, and information obtained from third parties. In limited cases, automated 

processes may restrict or suspend access to the ADR Hellenic Center Website if such processes  detect activity that we think poses a safety or other risk to the ADR Hellenic Center Website, or third  parties. If you challenge the decisioning based on the automated process, please contact us as  provided in the Contact Us section. 

We process this personal information for these purposes given our legitimate interest in protecting the ADR  Hellenic Center Website, to measure the adequate performance of our contract with you, and to comply with  applicable laws. 

Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal  information to provide, personalize, measure, and improve our advertising and marketing such as to: 

∙ send you promotional messages, marketing, advertising, and other information that may be of  interest to you based on your preferences (including information about ADR Hellenic Center) and  social media advertising through social media Websites such as Facebook or Google, 

∙ personalize, measure, and improve our advertising, 

∙ Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional  activities or events sponsored or managed by ADR Hellenic Center, 

∙ conduct profiling on your characteristics and preferences (based on the information you provide to  us, your interactions with the ADR Hellenic Center Website, information obtained from third parties,  and your search and booking history) to send you promotional messages, marketing, advertising and  other information that we think may be of interest to you, 

∙ Enrolling in an email subscription will not affect the frequency of administrative emails that we may  send in connection with any ADR Hellenic Center Account. No fee is charged for sending promotional  emails to you, but third-party data rates may apply.  

We will process your personal information for the purposes listed in this section given our legitimate interest  in undertaking marketing activities to offer you products or services that may be of your interest. 

How the Data Controller uses the Personal Information Collected (Payments). We may use the personal  information as a part of Payment services such as to: 

∙ Enable you to access and use the Payment Services. 

∙ Detect and prevent fraud, abuse, security incidents, and other harmful activity. ∙ Conduct security investigations and risk assessments. 

∙ Conduct checks against databases and other information sources. 

∙ Comply with legal obligations (such as anti-money laundering regulations). 

∙ Enforce the Payment Terms and other payment policies. 

∙ With your consent, send you promotional messages, marketing, advertising, and other information  that may be of interest to you based on your preferences. 

The Data Controller processes this personal information given its legitimate interest in improving the  Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of  the contract with you and to comply with applicable laws.

Your Choices 

You have choices on the promotional messages that you choose to receive. 

∙ You can limit the information you provide to ADR Hellenic Center. Participation in promotions and  marketing programs is voluntary. 

∙ You can limit the communications that ADR Hellenic Center sends to you. 

o To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of  any marketing email we send you or access the notification settings in your ADR Hellenic  Center Account. 

o Please note that even if you opt-out of marketing communications, we may still need to  contact you with important transactional information about your account. For example,  even if you opt-out of emails, we may still send you activity confirmations or fraud alerts. 

SHARING & DISCLOSURE 

Advertising and Social Media; Sharing with Your Consent. 

Where you have provided consent, we share your information, including personal information, as described  at the time of consent, such as when you authorize a third-party application or website to access your ADR  Hellenic Center E-learning Account or when you participate in promotional activities conducted by ADR  Hellenic Center. 

Where permissible according to applicable law we may use certain limited personal information about you,  such as your email address, to hash it and to share it with social media Websites, such as Facebook or Google,  to generate leads, drive traffic to our websites or otherwise promote our services or the ADR Hellenic Center Website. These processing activities are based on our legitimate interest in undertaking marketing activities  to offer you products or services that may be if your interest. 

The social media Websites with which we may share your personal information are not controlled or  supervised by ADR Hellenic Center. Therefore, any questions regarding how your social media Website service provider processes your personal information should be directed to such provider. 

Please note that you may, at any time ask ADR Hellenic Center to cease processing your data for these direct  marketing purposes by sending an e-mail to info@adrhellenic.com 

Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights. 

ADR Hellenic Center may disclose your information, including personal information, to courts, law  enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we  are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our  legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against ADR  Hellenic Center, (iii) to respond to a valid legal request relating to a criminal investigation or alleged or  suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal (iv)  to enforce and administer our Terms of Service, the Payment Terms, or (v) to protect the rights, property or  personal safety of ADR Hellenic Center, its employees, and its users. For example, if permitted due to the  forgoing circumstances, Host tax information may be shared with tax authorities or other governmental  agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or  another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the  ADR Hellenic Center Website secure, preventing harm or crime, enforcing or defending legal rights,  facilitating the collection of taxes and prevention of tax fraud or preventing damage. 

Where appropriate, we may notify users about legal requests unless: (i) providing notice is prohibited by the  legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice  would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or  increase a risk of fraud upon ADR Hellenic Center’ property, its users and the ADR Hellenic Center Website. In  instances where we comply with legal requests without notice for these reasons, we may attempt to notify  that user about the request after the fact where appropriate and where we determine in good faith that we  are no longer prevented from doing so. 

Service Providers 

ADR Hellenic Center has third-party service providers to help us provide services related to the ADR Hellenic  Center Website.  

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud  prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow  the provision of the ADR Hellenic Center Services through third party Websites and software tools (e.g.  through the integration with our APIs), (vi) provide customer service, advertising, or payments services.  These providers have limited access to your personal information to perform these tasks on our behalf, and  are contractually bound to protect the personal information and only use the personal information in  accordance with our instructions. 

ADR Hellenic Center will need to share your information, including personal information, in order to ensure  the adequate performance of our contract with you. 

OTHER IMPORTANT INFORMATION 

Analyzing your Communications 

We may review, scan, or analyze your communications on the ADR Hellenic Center Website for fraud  prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics,  and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze  messages to mask contact information and references to other websites. In some cases, we may also scan,  review, or analyze messages to debug, improve, and expand product offerings. We use automated methods  where reasonably possible. However, occasionally we may need to manually review some communications,  such as for fraud investigations and customer support, or to assess and improve the functionality of these  automated tools. We will not review, scan, or analyze your messaging communications to send third party  marketing messages to you, and we will not sell reviews or analyses of these communications. 

These activities are carried out based on ADR Hellenic Center’ legitimate interest in ensuring compliance with  applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate  performance of our services. 

YOUR RIGHTS

Consistent with applicable law, you may exercise any of the rights described in this section before your  applicable ADR Hellenic Center Data Controller. Please note that we may ask you to verify your identity  before taking further action on your request. 

Managing Your Information. 

You may access and update some of your information through your Account settings. If you have chosen to  connect your ADR Hellenic Center Account to a third-party application, like Facebook or Google, you can  change your settings and remove permission for the app by changing your Account settings. You are  responsible for keeping your personal information up-to-date. 

Rectification of Inaccurate or Incomplete Information. 

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which  you cannot update yourself within your ADR Hellenic Center Account). 

Data Access and Portability. 

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information  held by us. You may also be entitled to request copies of personal information that you have provided to us  in a structured, commonly used, and machine-readable format and/or request us to transmit this information  to another service provider (where technically feasible). 

Data Retention and Erasure. 

We generally retain your personal information for as long as is necessary for the performance of the contract  between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have  all your personal information deleted entirely.” Please note that if you request the erasure of your personal  information: 

∙ We may retain some of your personal information as necessary for our legitimate business interests,  such as fraud detection and prevention and enhancing safety. For example, if we suspend a ADR  Hellenic Center Account for fraud or safety reasons, we may retain certain information from that  ADR Hellenic Center Account to prevent that Member from opening a new ADR Hellenic Center Account in the future. 

∙ We may retain and use your personal information to the extent necessary to comply with our legal  obligations. For example, ADR Hellenic Center and ADR Hellenic Center Payments may keep some of  your information for tax, legal reporting and auditing obligations. 

∙ Because we maintain the ADR Hellenic Center Website to protect from accidental or malicious loss  and destruction, residual copies of your personal information may not be removed from our backup  systems for a limited period of time. 

Withdrawing Consent and Restriction of Processing. 

If we are processing your personal information based on your consent you may withdraw your consent at any  time by changing your Account settings or by sending a communication to ADR Hellenic Center specifying  which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the  lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some  jurisdictions, applicable law may give you the right to limit the ways in which we use your personal 

information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing  is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal  information for the purposes of the processing, but you require the information for the establishment,  exercise or defense of legal claims; or (iv) you have objected to the processing pursuant and pending the  verification whether the legitimate grounds of ADR Hellenic Center override your own. 

Objection to Processing. 

In some jurisdictions, applicable law may entitle you to require ADR Hellenic Center not to process your  personal information for certain specific purposes (including profiling) where such processing is based on  legitimate interest. If you object to such processing ADR Hellenic Center will no longer process your personal  information for these purposes unless we can demonstrate compelling legitimate grounds for such  processing or such processing is required for the establishment, exercise or defense of legal claims. 

Where your personal information is processed for direct marketing purposes, you may, at any time ask ADR  Hellenic Center to cease processing your data for these direct marketing purposes by sending an e-mail to  info@adrhellenic.com 

Lodging Complaints. 

You have the right to lodge complaints about our data processing activities by the “Contact Us” section or by  sending an email to info@adrhellenic.com 

SECURITY 

We are continuously implementing and updating administrative, technical, and physical security measures to  help protect your information against unauthorized access, loss, destruction, or alteration. Some of the  safeguards we use to protect your information are firewalls and data encryption, and information access  controls. If you know or have reason to believe that your ADR Hellenic Center Account credentials have been  lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized  use of your ADR Hellenic Center Account, please contact us following the instructions in the Contact Us  section. 

CHANGES TO THIS PRIVACY POLICY 

ADR Hellenic Center reserves the right to modify this Privacy Policy at any time in accordance with this  provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the ADR  Hellenic Center Website and update the “Last Updated” date at the top of this Privacy Policy. We will also  provide you with notice of the modification by email at least thirty (30) days before the date they become  effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel  your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of  the ADR Hellenic Center Website will be subject to the revised Privacy Policy.