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SeaBlue Travel Terms Of Use



    • 1. Description of Transport Services
    • 2. Legal Status of the Company
    • 3. Policies of Transport Services
    • 4. Declarations of Travellers
    • 5. Company’s rights- Limitation of Liability
    • 6. Charges and Payment Policy
    • 7. Travellers’ opinion
    • 8. Disclaimer
    • 1. Copyright
    • 2. Τechnical Support
    • 3. External links
    • 4. Contact
    • 5. Final Terms
    • 6. Waiver
    • 7. Invalidity of Term
    • 8. Assignment
    • 9. Applicable Law/Jurisdiction


The following General Terms and Conditions of Use of the Platform and Service (hereinafter
referred to as the «General Terms of Use» or «General Terms» ) have been established by the
Limited Liability Company under the name “SeaBlue Tours LTD Sti.” , which operates and
manages the web platform under the trade brand name “SeaBlue Tours” , through which
tourists/travellers (hereinafter “Travellers” , “You” , “Yours”,
“User” ) make a booking of a transport service as defined herein (hereinafter “Transport Services”)
operated by drivers of Private and Public Use Vehicles who have an Account in the Platform
(hereinafter the “Drivers” ) through which they receive by Us, acting as intermediary between
You and the Drives, notifications and requests for the provision of Transport Services to You
(hereinafter “Service ”).

The following General Terms of Use of the Platform and the Service (hereinafter “Terms of
Use” , or “General Terms of Use” ) constitute the legally binding terms and conditions applicable
to Your access and use of the Platform and the Service, including any use of software, services,
features, functions, content, website(s) and hyperlinks and / or any other applications provided
from time to time by the Company in the Platform and/or in the Service.

Before any use of the Platform and the Service, You are advised to read the present Terms of
Use and make sure You agree with them. In case You disagree with any term and / or all of
them, You should not use the Platform and the Service. In case You have any inquiries or You
need any clarification and/or information regarding the Terms of Use, or You have any prejudice
or relevant inquiry, You can contact Our Customer Support Team at the phone numbers shown
in the website or via the email [email protected], before
any use of the Platform. By using the Platform you warrant and acknowledge that You have
reviewed, understood and accept these General Terms of Use unconditionally and without any
prejudice and that You are bound by them.

Our Company reserves the right to amend, modify, renew, delete, add or restrict unilaterally (a)
these Terms of Use in whole or in part; (b) its Policies; (c) the Service; (d) the Technical
Specifications of the Platform or other (hereinafter referred to as the “Changes” ) at its sole
discretion and / or when any amendment, as above, is required by law, possibly without Your
prior notice or consent, nevertheless within the context of the business ethics and limits set forth
by law. The Company undertakes the obligation to notify You any Changes, through the
Platform by a prominent notice when the Users enters the Platform. Any Changes will be
effective from the date of their posting. It is clarified that any change to these Terms of Use does
not cover bookings or other transactions and uses of the Platform and the Service which have
been made before the entry into force of the Changes and been accepted by our Company.
However, in case the Users wish any clarification or information regarding the Changes, or in
case they have any dispute, reservation or enquiry related to these Changes, prior to any action
made by them on the Platform, they should contact Our Customer Support team. Any action,
use or transaction made by the Users on the Platform, including the use of the Service itself,
following the Changes, is considered as an unconditional acceptance thereof.

It should be noted that any information / clarification granted by the Customer Support regarding
the Terms of Use does not constitute a replacement, substitution or any modification of these
Terms of Use, as they are provided solely for the purpose of assisting the Users whilst the
Terms Use constitute our sole and exclusive agreement.

The Company reserves the right at any time, without providing any justification and without prior
notice to the User, to cancel, suspend or terminate the operation of the Service, to revoke or
customize the Platform, or certain features of the Platform and the Service. The Users are solely
and exclusively responsible and liable with regard to the use of the Platform and the Service.
You acknowledge and understand that You must comply with the Terms of Use of the provider
which co-operating with Your device (referred to hereinafter as the “Provider’s Terms of Use”).
The Provider’s Terms of Use are considered to be incorporated herein. The Users are solely
and exclusively responsible and liable as far as the obligation to determine the Provider’s Terms
of Use applicable to their Device is concerned.


1. Description of Transport Services to Travelers

1.1 Booking a Transport Service with Us, means that a Driver will become the person who will
greet and welcome You to their city, and / or will transfer You during Your stay.

In particular, the transport services that You can book through the Platform, are the following
(hereinafter referred to as ” Transport Services ” or “Pickups” or “Transfer” ):

  • 1.1.1 Travellers’ Transport from and to airports, ports, train stations, bus stations.
  • 1.1.2 Travellers‘ Transport from and to place of residence.
  • 1.1.3 Travellers‘ Transport from and to sightseeings.
  • 1.1.4 Travellers’ Transport from and to a point of interest in the city, including stop(s) over (for
    food, activity, photos, etc.).
  • 1.1.5 Travellers’ Transport while in tour and transport from and to places of activities based on
    their interests.
  • 1.2 At the point You will be welcomed by the Driver, You will receive products that You may have
    purchased from Us. and/or products that the We distribute free of charge (souvenirs, local
    sweets, city maps, etc.).
  • 1.4 To make Your pick ups a personal experience for You, We will forward You the Driver’s
    name, surname and their mobile phone and/or their photo in case We have been provided with

We are not a licensed private hire operator, nor a transportation carrier and WE DO NOT
provide the Transport Services. We act solely as an intermediary between You and the
Driver. By booking Your Pickup through the Platform, You enter into a direct and legally
binding contractual relationship with the Driver who accepts Your Pickup. The Company
provides information and a method to facilitate the Transport Services, but does not intend to
provide Transport Services or act in any way as a transportation carrier, therefore has no
responsibility or liability for any Transport Services provided to You by the Drivers.

2. Legal Status of the Company

2.1 Our Company provides electronic or telephone mediation services for the transport of
Travellers. As an e-mediator body in the Transport Service that Drivers carry out, we act solely
as intermediaries between the Travellers and the Drivers. Through its Platform, the Company
provides mediation services for the provision of Transport Services from Drivers to Travelers.
Actually, the Company does not itself provide nor could it be considered to provide the Transport
Services by itself, since it is not a licensed transport operator. In case that You make a booking
of a Transport Service through the Platform, You acknowledge that you are entering into a
contract for the provision of the Transport Service solely with the Drivers and You and the Driver
bear sole liability for the fulfillment of the provision of the Transport.

2.2 The Company does not provide transport services, and it is not involved in the relationship
between You and the Driver who Picks You Up, as the contractual relationship for the provision
of Transport Service, is established exclusively between You and the Driver who undertakes to
provide You with Transport Services. In no way does the Company participate as a contracting
party in these contracts, nor does it obtain any rights or obligations deriving from such contracts.
The Company assumes no responsibility for the Travelers’ transport, for which Drivers are solely
responsible. As a result, the Company, its representatives, employees and assistants are not
liable in any way for the risks associated with the conclusion, execution and completion of the
transactions between the Travelers and Drivers and are not liable in any way for any damages
deriving from such transactions. Besides, the choice of whether to book a Pick Up through the
Platform, is at Your sole discretion. However, if You accept it, You are bound and warrant that
You will meet all obligations arising out of these Terms of Use.

2.3 The Company does not represent You or the Driver, so it does not provide any guarantees
regarding the quality of the Transport Services, the completion of the Transfer, Travelers’ and
Drivers’ behavior. In addition, the Company does not represent or act on behalf of any transport

2.4 Please note that Drivers do not have an employment relationship with the Company or its
partners. The Platform constitutes a method of linking You to Drivers. In addition, the Company
does not provide any insurance to Drivers or to their vehicles and assumes no liability if You
lose Your staff while on a Pick Up.

2.5 The Company may refer Drivers to You for the provision of the Transport Services. It will not
evaluate the suitability, legality or ability of any Driver and You expressly waive and relieve the
Company of any and all claims, liabilities or damages arising from, or are in any way related to,
the Driver. The Company shall not be part of any dispute between You and the Drivers. By
booking Transport Services, You acknowledge that the Company has no involvement in the
contractual relationship between the Driver and You, however the Transport Services are
governed by these General Terms.

2.6 The inter-Mediation services We provide are only available for personal, non-commercial
use. Therefore, it is not permitted to resale, distribute through deep-link, use, copy, track (e.g.
through spider, scrape), display, download or reproduce any content or information, software,
products or services available at the Platform, for any commercial or competitive activity or

3. Policies of the Transport Services

3.1 Booking Policy

We do not operate Our Service in every city. To find out if We can serve You in Your destination,
You have to check with Us.

To book Your transfer, You need to provide Us with some information such as Your personal
details and contact points (email – mobile), the Pick Up place, date and time, Your place of
destination, flight number in case You arrive by plane so We can make arrangements in Your
favor in case there is a delay, the number of passengers and their pieces of luggage in order to
arrange for the right Vehicle to pick You up, and also Your payment information. You have to
accept Our Terms of Use and Privacy Policy, should You wish to make a booking for Your
transfer with Us.

When a booking transfer is placed with Us, You will receive a confirmation email of receipt of
Your booking transfer and We will provide You with Your Booking code and the meeting point at
the Pickup place. We will examine whether We can serve the Transfer as a whole, or We
have grounds to reject it, according to the provisions of the present General Terms of
Use. Once a Welcome Driver has been assigned to operate your Transfer we will provide You
with their name Important Legal Notice: Please note that completion of the online
booking process along with the acknowledgement email We send to You, does not
constitute Our acceptance of Your offer to book a Transfer through Us, even though on
the acknowledgement email of Your offer, the Booking code is depicted. Our acceptance
of Your offer to provide through Our Platform with a Transfer, will take place only when
We take payment from You (i.e. when Your card or PayPal account is credited). We
reserve the right to decline a Booking Order for any reason, including legal and
regulatory reasons. If we cannot provide You with the Transport Service, We will not
process Your order, We will inform You as soon as possible and, if You have already
paid for the products we cannot deliver, refund You in full in a timely manner.

You are solely responsible for submitting Us Your real personal data when booking a
pick up with through Us. You also warrant and represent that Your are the holder or
have legal rights on the payment cars/ accounts details You provide Us with and that
there is enough money to cover the value of the Transfer Service. We may proceed
(however, are not obliged to) in an examination process of the payment details You
provide Us with when choosing credit card as a payment method or via Online
Providers. In case an error, misleading statement or other problem occurs, We may, at
Our sole discretion reject Your Order.

3.2 Traveller Cancellation Request Policy

You have the right to cancel a Transfer already booked through Us, at any time by
contacting  the Company either by phone call at the phone number provided in the
confirmation email or in the website or email sent to [email protected]

If a cancellation request is received by Us up to 24 hours prior to the
scheduled pick up time,
you have the following options:

a) reserve the amount paid to be used for any future Transfer in the cities we operate.
In this case, You get a coupon equal to this amount, which can be used by You or
You can even pass it to another Traveller, and can be used for a limited period of
12 months from the day of your cancellation request. If the coupon amount is
higher the cost of the new booking, there is no refund for the difference, the total
cost of the new booking is covered by the coupon. If the coupon amount is less than
the cost of the new booking, the Traveller will have to proceed with a payment
of the difference. The coupon is issued for a single use and can not be canceled.

b) proceed with cancellation. In this case, there is a cancellation fee of 20% of the
amount paid which will be held by Us. The rest 80% is refunded to You.

If a cancellation request is received by the Company within less than
24 hours prior to the scheduled pick up time, it is considered as a last minute
and non refundable cancellation, resulting in a 100% cancellation fee and
NO refund to the Traveller.

3.3 Traveller Change Request Policy

You can contact the Company via a phone call at the phone number provided in the
confirmation email or in the website or email at [email protected] and ask to change
any of the booking details up until 12 hours prior the scheduled pickup time.

Depending on the changes requested, the Transfer price might change. On that occasion, the
new Transfer price will be communicated to You, and the new Transfer details will be in effect
once there is payment confirmation of the new Transfer price where applicable. If the new
Transfer price is less, the Company shall partially refund You. If the new Transfer price is more
You should give us Your consent to charge Your card with the additional amount (if any) due to
the change request.

The Company cannot accommodate any changes to the details of Transfers requested within
less than 12 hours prior to the scheduled pickup time. I n this occasion, the Transfer will either be
operated as initially booked, or the You can proceed with a cancellation request, as per the Traveller
Cancellation Request Policy.

3.4 Complimentary Waiting Time Policy

Your Welcomer will be waiting for You at the Pick Up place at the time that is scheduled in the
Booking Order, subject to the provisions of this Complementary Waiting Time Policy and Extra
Waiting Time Policy, so You must make sure that You show up in time, to avoid as being
marked as a non-show where all the Terms of the Travellers’ No – Show Policy apply.

The Company offers the following complimentary waiting times, depending on the type of
Transfer booked:

  •  Airport: 60 minutes
  •  Port, Train Station, Bus Station: 30 minutes
  • Other pickups (incl. Sightseeing Rides): 20 minutes

The complimentary waiting time starts counting from the scheduled pickup time.

More specifically, for an airport/port pickup where the scheduled pickup time is other than the
flight/ship arrival time and the flight/ship is delayed and expected later than the scheduled
pickup time, the new arrival time becomes the pickup time.

For an airport/port pickup where the scheduled pickup time is the flight/ship arrival time and
there is a flight/ship delay, the complimentary waiting time starts from the moment the flight/ship
arrives provided the Traveller has provided correct and adequate flight/ship details to allow for
the tracking of the arrival. The above is true for up to 8 hours of flight/ship delay. If the flight/ship
is delayed more than 8 hours, the Transfer is cancelled and the entire Transfer fee is refunded
to the Traveller.

For an airport/port pickup where the pickup time is the flight/ship arrival time and the flight/ship
arrives earlier than the scheduled time, the scheduled pickup time remains the initial scheduled
pickup time.

For an airport pickup where the Travellers are arriving with more than one flights, the Company
considers the scheduled pickup time to be the one declared by the Traveller as the arrival time
during the booking, or an updated arrival time as per the Traveller Change Request Policy. Any
notes left by the Traveller during the booking mentioning several flights do not constitute a
scheduled pickup time adjustment. In the occasion where a group of Travellers arriving with
multiple flights landing at different times have booked one Transfer, it is suggested that they add
in the flight details the flight arriving last.

3.5 Extra Waiting time Policy

Extra waiting time is defined as an amount of time in addition to the complementary waiting time
offered by the Company for which the Traveller asks the Driver to wait for them.

You can ask for the Driver to wait for You longer than Company’s complementary waiting time
as per the Complementary Waiting Time Policy, either in advance (before the Transfer is
operated) or the latest by the end of the complementary waiting time. You can do so by
contacting Company’s Customer Support either by a phone call at the phone number provided
in the confirmation email or in the website or by sending an email at
[email protected] The Company can guarantee only the complimentary waiting time
as additional waiting time for the Traveller if the extra waiting time has not been asked for at
least 12 hours before the scheduled pickup time.

If You request an extra waiting time and the assigned Driver can accommodate this, an extra fee
will be charged to You for every 15 minutes of extra waiting time, as follows:

  • For a Pickup where a Sedan car-type is assigned: EUR 6.00 / 15 min
  • For a Pickup where a Minivans car-type is assigned: EUR 9.00 / 15 min
  • For a Pickup where a Minibus car-type is assigned: EUR 12.00 / 15 min

The Company does not charge any additional commissions to these fees.

When the extra waiting time request can be accommodated by the Driver, You have to consent
on the additional applicable fees either over a phone call with the Company or by completing the
transaction by Yourself in the link that the Company shall send to You . Payment of the fee can
be made either in cash directly to the Driver before the start of the Transfer, or electronically to
the Company.

3.6 Traveller No-Show Policy

Traveller No-Show (TNS) is defined as a Traveller not being at the pickup location by the end of
the complimentary waiting time, or the extra waiting time if that has been agreed between the
Traveller, the assigned Driver and the Company as per the Complementary Waiting Time Policy
and the Extra Waiting Time Policy .

The pickup location is defined as the place where the Traveller has asked to be picked up from.
In case of airport/port pickup, the Company notifies You via the booking confirmation email the
exact pickup location where the Driver will be waiting for You (i.e. Arrivals hall, Departure hall,

In the occasions where the Traveller fails to appear at the pickup location by the end of their
complementary waiting time, or the end of the extra waiting time, or if an “Extra Waiting Time”
request has not been able to be accommodated by the Driver, the Transfer is marked as a
“Traveller No Show” (“TNS”). In this case no amount is refunded to the Traveller. If an extra
waiting time was agreed with the Traveller as per the Extra Waiting Time Policy, the Traveller
must pay the extra waiting fee as well.

If You are not at the pickup location at the scheduled pickup time, and the Pick up place is an
Airport, Port, Train Station or Bus Station, the assigned Driver will try to contact You via
text/Whatsapp/Viber or he will try to call You on Your Mobile. By booking a Transfer You consent
to Us providing Your mobile phone number to Your Welcomer.

A possible TNS will be reported by Your Welcomer to the Company, at the following times:

  • For airport pickups by 45 minutes of a Traveller’s delay to appear at the pickup location
    after the scheduled pickup time
  • For Port, Train Station, Bus Station pickups by 15 minutes of a Traveller’s delay to
    appear at the pickup location after the scheduled pickup time
  • For Sightseeing Rides and other Transport Services by 5 minutes of a Traveller’s delay
    to appear at the pickup location after the scheduled pickup time

Upon a Driver’s notification of a possible TNS, the Company will try to contact the You (via call
and/or text/Whatsapp/Viber and/or email) in an effort to locate You. These efforts will be carried
out until the end of the Your complimentary waiting time as per these present Terms of Use.

By the end of Your complimentary waiting time, the following will happen:

  • If You have not been reached (have not replied) , We must “release” the Driver. In this
    occasion, the Transfer is marked as a “TNS”.
  • If You have been reached and have communicated that You will be at the pickup
    location by the end of the complimentary waiting time, We must inform the Driver to wait.
    If You fails to appear by the end of the complimentary waiting time, We will make one
    final effort to reach out to You, and depending on the outcome, either release the driver
    immediately, or follow Company’s Extra Waiting Time Policy accordingly.
  • If You have been reached and You have asked for extra waiting time, We will contact
    the Driver whereas the Extra Waiting Time Policy will apply accordingly.

You have 24 hours to dispute a TNS by contacting Welcome’s Customer Support. In the
occasion You dispute a TNS, if the Driver was at the pickup location between the scheduled pick
up time and the end of the complimentary waiting time (or extra waiting time if applicable), there
is sufficient evidence to assume the Driver was at the pickup location as per Company’s
policies. If there is sufficient evidence to assume that both You and the Driver were at the
pickup location but failed to meet each other and the Transfer was not operated, You will be
refunded 80% of the Transfer price, whereas the 20% will be kept by Us in order to cover
partially Driver’s fee, since the Company is responsible to pay them their fee.

3.7 Driver No-Show Policy

The Driver must be at the pickup location by the scheduled pickup time. If the Driver is to be up
to 10 minutes late, they will contact and notify the Traveller (via call and text/Whatsapp) as
much in advance as possible, and the latest by the scheduled pickup time. If the Driver is to be
more than 10 minutes late, they will contact and notify Company ’s CS as much in advance as
possible, and the latest by the scheduled pickup time. Company ’s CS will contact the Traveller
and notify them of the expected Driver delay.

3.8 Baggage Allowance Policy

When booking the Transfer, You are requested to declare the number of pieces of luggage You
will be carrying with them during the Transfer.

One piece of luggage is considered to be

  • A medium to large sized backpack
  • An average suitcase, whether it’s a carry-on or checked-in type (volume not to exceed

Should You carry additional items such as baby carriages, pet carriers, sports equipment,
foldable wheelchairs, musical instruments, etc. You must declare one piece of luggage for each
one of those items and add a note to the booking describing them. The Company might contact
You for clarifications and adjust the booking details accordingly in order to ensure the proper
car-type is assigned to operate the Transfer.

The Transfer price and the car-type assigned to operate the booked transfer are calculated
amongst other factors based on the number of Travellers and pieces of luggage declared. If You
appears with more travellers and/or carrying more pieces of luggage than declared, and the
assigned Driver cannot safely and legally accommodate these, the Driver will contact
Company’s CS before the start of the Transfer explaining the situation, and assist You in hailing
another Vehicle. In that occasion the Driver will only carry the number of Travellers and pieces
of luggage declared in the Transfer booking.

If You appear with more Travellers and/or carrying more pieces of luggage than declared, and
the assigned Driver can safely and legally accommodate these (i.e. in the case where a Minivan
car-type accepted a Sedan car-type Transfer), the Driver must contact the Company’ before the
start of the Transfer explaining the situation. If the additional number of Travellers and/or
luggage combination yield a different Transfer price, the Company will recalculate this and
notify You accordingly. If You consent to paying the additional charges, the Driver will
accommodate the additional passengers and/or pieces of luggage. Otherwise, the Driver will
kindly assist You in hailing another vehicle and carry the number of Travellers and pieces of
luggage declared in the Transfer booking.

The Company will not bare the cost of any other means of transportation used by You.

3.9 Traveller Refund Policy

Transfer fee paid by a Traveller will be offered as an open date coupon (as mentioned in article
3.2 Traveller Cancellation Request Policy) in the following occasions:

  • If the booked Transfer is
    canceled by the Company for operational capacity reasons
  • If the booked Transfer is
    canceled due to a force majeure incident (strike, demonstration,
    natural disaster, accident, etc.)
  • If the Transfer is canceled
    due to a flight/ship delay over 8 hours as per the
    Complimentary Waiting Time Policy

Other cases:

  • If the Company receives a
    Traveller cancellation request up to 24 hours prior to the scheduled pickup time, as per the
    Traveller Cancellation Request Policy,
    there is a
    cancellation fee of 20% of the amount paid which will be held by Us. The rest 80% is refunded.
  • If the Company receives a
    Traveller cancellation request within less than 24 hours prior to the scheduled pickup time, as
    per the Traveller Cancellation Request Policy,
    it is considered as a last minute and non refundable cancellation,
    resulting in a 100% cancellation fee and NO refund to the Traveller.

In the occasion of a Traveller-disputed “Traveller No-Show”, if there is sufficient evidence
to assume that both the Traveller and Driver were at the pickup location but failed to meet
each other and the Transfer was not operated, the Traveller will be refunded 80% of the
Transfer price as per the Traveller No-Show Policy.

4. Travellers’ Rights and Obligations – Representations –

4.1 TRAVELLERS’ REPRESENTATIONS-WARRANTIES : By using the Platform, You agree:

  • to provide true, accurate, complete and updated information about yourself at the
    booking form, and update them whenever necessary. The Company is not obligated
    to monitor or control the accuracy of information provided by You. If any information
    provided by You is not in accordance with these provisions or if the Company has
    reasonable grounds to suspect that such pieces of information do not agree, the
    Company has the right to refuse Your registration, and suspend or terminate
    immediately, regardless of notice, the registration of Your account and refuse any and
    every use, present or future, of the Services that require registration. In this case, You
    shall not be entitled to any indemnity or compensation for the refusal, suspension or
    cancellation of Your registration.
  • that You will not use the Platform: for any unlawful purpose; in any way that interrupts,
    damages, impairs or renders the Company less efficient; to transfer files that contain
    viruses, trojans or other harmful programs; to access or attempt to access the
    accounts of other users or to penetrate or attempt to penetrate any security
    measures; to disseminate any content which is defamatory, obscene, or may have the
    effect of being harassing, threatening or abusive to an individual or group of
    individuals on the basis of religion, gender, sexual orientation, race, ethnicity, age or
    disability or otherwise; to advertise or promote third party or Your own products or
  • to refrain from doing anything which we reasonably believe to be disreputable or
    capable of damaging our reputation
  • and acknowledge that we have limited control over the nature and content of
    information received by You or other users of the Platform. Although we reserve the
    right to do so, we do not monitor such content in the usual course of business and will
    not be liable for any such content. If You have a complaint about another user please
    contact us via the Platform;
  • to comply with all applicable laws from Your home nation, the country, state and city in
    which You are present while using the software or Service;
  • to treat Drivers introduced to You through the Platform with respect and not to cause
    damage to their Vehicle;
  • to compensate and defend us fully against any claims or legal proceedings brought
    against us by any other person as a result of Your breach of this agreement.
  • that the email (e.g [email protected]) that You use to register on the Platform shall not
    resemble to Company’s company name. Also log in passwords deemed offensive
    may be deleted, as well as containing a URL or email address.
  • that You shall not use the Service or software to cause nuisance, annoyance or
  • that by accessing and using the Services via mobile devices, or by using certain
    mobile features, You may incur fees from the provider or carrier of the mobile services
    that You use (“Carrier”) and You are solely responsible for the payment of such fees.

4.2 You acknowledge and agree that You must avoid any action that may cause traffic safety
problems. Particularly, You warrant and represent that You will:

  • not in any way hinder the Driver from driving safely during Your transfer,
  • not attempt to disembark or board the vehicle when it is moving,
  • not smoke,
  • not open windows and doors without the Driver’s consent;
  • be decent, courteous and not display inappropriate, abusive, provocative or threatening
    behavior in any way during the Transfer;
  • not take any action that may cause damage to the Driver’s Vehicle,
  • take care that the children, animals and objects to be transferred are done so with
  • Not throw objects inside or outside the Vehicles or pollute them in any way,
  • Carefully observe the instructions for traveling with young children and for the
    transport of infant and kid strollers, luggage, bicycles and pets,
  • not consume food and drinks throughout Your Transfer and until the end of the Transfer.
  • not embark on a Vehicle with dirty or contaminated clothing

4.3 In cases where You carry animals and/or objects during the Transfer and the Vehicle is
damaged/destroyed or gets dirty somehow due to them, You undertake the obligation to pay for
any such damages.

4.4. You also warrant that You have fully read and understood these Terms of Use, the Policy
of Acceptable Uses, the Privacy Policy and accepts them fully and unconditionally and
that You meet all the legal requirements for the acceptance of these Terms.

4.5 You warrant and represent that at Your own responsibility and expense, You shall
immediately take all necessary measures and in any case fully compensate, indemnify
and hold harmless the Company, its Affiliates and its Partners and any third party that
derives rights therefrom (partners, employees, administrators, suppliers, agents,
representatives of the same and its associates) for any claim, loss, damage, cost,
expenses, liabilities, deviations, penalties, fines, lawyer fees We have suffered as a
result of (a) any violation by You of these Terms of Use and / or the Policy of Acceptable
Uses, of Your representations and warranties under this Agreement, of intellectual
property or other rights of the Company; (b) any other action or omission that is illegal
while using the Service; (c) violation of applicable law on Your behalf.

5. Company’s Rights

5.1 Definite deactivation (deletion) of the Platform: Save as provided in these General
Terms the Company expressly reserves the right to delete the Platform and the Service
respectively, in the following cases at the Company’s absolute discretion: a) in case You
violate the Acceptable Use Policy of the Platform, and / or b) violates any term or provision
mentioned and at the Company’s absolute discretion this violation causes immediate
risk-loss to the Company and / or to any other User of the Platform c) has committed, at the
Company’s absolute discretion, a penal or other offence, during the use of the Platform
and the Service and / or the Transport Services and/or d) for any other important reason
referred to herein.

5.2 In the above cases, the Platform/Service is deactivated immediately and automatically,
without the Company providing to the Traveller the right to remove the violation, expressly
reserving all its legal rights, including the right to compensation for any damage that may
have been suffered by the acts and / or omissions of its Users according to the above

5.3 Temporary de-activation (deletion) of the Platform : Save as provided in these General
Terms regarding the deactivation (deletion) of the Platform, the Company expressly
reserves its right at its sole discretion to temporarily deactivate the Platform/Service,
directly and without any penalty in the event that it considers that the Traveller has
breached or has violated any applicable law and until the Traveller removes the breach
within the time period drawn by the Company, at its sole discretion. In the event of the
Traveller’s non-compliance, the Company may definitively deactivate the Platform for the
Traveller, expressly reserving all its lawful rights, including the right for compensation of any
damage suffered by the User’s actions and / or omissions in accordance with the above

5.4 It is expressly agreed that in the event of a permanent or temporary deactivation (deletion)
of the Platform as per articles 5.1 and 5.2 above is based on automated means, the user is
not entitled to claim compensation of any damage caused by the deactivation of the
Platform/Service, in accordance with the above provisions, even if the evidence on which
the Company was based for the deletion of the Platform was incorrect since the user
acknowledges and accepts that the automated means used by the Company to identify any
illegal or contract breaching actions of users are based either on generalised / automated
electronic commands of a software program that may include and / or make errors or on
complaints by other Users.

5.5 Termination of the Platform s Function: The Company reserves the right, for technical
reasons, maintenance and / or upgrade of the Platform, to discontinue the function of the
Platform/Service temporarily and at regular intervals. In the event that this interruption lasts
more than a reasonable period of time at the absolute discretion of the Company or such
interruption has already been scheduled by the Company, the latter will notify its Users. It is
expressly agreed that Users may not raise any claim against the Company for any loss or
damage whatsoever arising out of this reason even if the Company, at its sole discretion,
does not give notice of such interruption.

5.6 Except as expressly set forth herein, the Company may at any time terminate, change,
suspend or discontinue any particular function of the Platform, including the availability of
the Service itself, provided that it notify Travellers in writing within reasonable notice period
before the termination date as per this article.

5.7 Limitation of warranties: The Company, its directors, shareholders, employees, providers,
partners always act in good faith in the context of the law and the present General Terms of
Use. Hence it has take all technical and other measures and uses its best endeavours to
ensure that (a) the Platform operates continuously and properly without any problems,
interruptions, delays, errors or mistakes; (b) defects and/or mistakes are corrected, (c )
data/information transferred through the Platform (d) the technology used by the Company
or the Servers, through which the Service is made available to the Users, does not contain
viruses or other harmful components, however THE COMPANY DOES NOT PROVIDE
ANY RESPECTIVE WARRANTIES for all of the above mentioned.

5.8 In addition, the Company does not provide any warranty for (a) the appropriate, effective,
and efficient function of the Platform with regard to the purpose for which the Traveller uses
it; (b) the compatibility of the Platform with third party software that Driver may use, unless
these (software) are provided by the Company and only to the extent the Company has
guaranteed for them in the relevant licenses provided to the Travellers (c) the proper and
efficient execution of the Drivers’ transaction Obligation.

5.9 Limitation of Obligations: The Platform and the Service is provided “as it is and is made
available” and in a fully automated manner and does not include the importation by the
Company of any element in the Service’s system nor any customisations on an ad hoc
basis. The Application may in the future be parameterised, at the sole discretion of the

5.10 The Company shall take all necessary technical and other measures to ensure that
Travellers comply with the present Terms of Use, however, as a Provider of Information
Society Services, it has no general nor statutory obligation to (a) control, (b) actively seek
for facts or circumstances that indicate that Traveller has engaged in an unlawful or
contract breaching activity while using the Platform/Service, (c) provision of technical
support and/or education of the Travellers.

5.11 Limitation of Liability. In addition to what is expressly stated herein, the Company has no
civil, penal and bears no liability towards the Traveller, any Authorised Users, their Affiliates,
Employer or employee and / or any third party rendering rights whatsoever, in case that any
of these persons, during using the Service, suffer any damage, loss, direct or indirect,
incidental or damage for loss of profits, business, income, reputation, sales of products and
frequency of services’ provision, or any other direct, indirect or repayable, economic or
otherwise, loss of profits, due to:

5 .11.1 Delayed or inappropriate sending, transmission, maintenance, retention,
downloading of any data, information or /and Content and / or loss and destruction
of such data due to mistakes, omissions, malfunctions or dysfunctions of
telecommunication Networks, the Internet, the website, Internet Service Providers.

5.11.2 Any permanent or temporary disabling of the Service, any termination of the
Service or its individual functions, or any technical collision of the Service in
accordance with the terms herein.

5.11.3 Events, situations, acts, actions and / or omissions by the Company or third
parties including the Users/Authorised Users for which the Company does not
provide any warranties and is not bound by the terms herein.

5.11.4 Use by the Drivers or third parties of Travellers’ data (including any personal
data) for purposes other than the use of the Service

5.11.5 Infringement of applicable law on the protection of personal data or other
applicable legislation which relates, for example, to the use of the Service

5.11.6 Infringement of the ACCEPTABLE USE OF THE PLATFORM POLICY , the
present Terms of Use by the Travellers or other users of the Application.

5.11.7 Any discrepancy between the time system of the Service and an officially defined
time system.

5.11.8 Events of force majeure.

5.11.9 Drivers mis conduct and/or breach of any laws on their behalf. Drivers non show,
or delays other than as assumens herein.

5.11.10 Loss of staff during the transfer or any accident.



5.14 In any case, it is expressly agreed that the Company is liable only for direct damages that
result from deception or gross negligence on its part. Subject to mandatory legal provisions,
the liability of the Company for direct loss due to gross negligence irrespective of legal
reason is expressly excluded. The Company’s liability for indirect or consequential
damages, irrespective of reason, is completely and explicitly excluded. Subject to the
limitations set forth herein and to the extent permitted by law, any liability of the Company is
limited to the total amount corresponding to the total cost of the Transport Service.


5.16 Provision of Information : The Company, if so requested by a competent prosecution,
supervisory, judicial or other Authority, is obliged to transmit the data of the Users and/or of
Third Parties, including any personal data of Authorised Users provided to the Company in
accordance with the present General Terms, as well as any other data and any other
information provided by them without their prior notice or consent, on the grounds of
necessary protection measures against risks to state and public security as well as for
prosecution reasons, including tax crimes and offences.

6. Charges and Payment Policy

The Company facilitates pre-payment via PayPal, Braintree, Checkout or Shopify, Checkout or
Shopify of a Traveller’s Transfer, The cost of a Transfer (“Transfer Cost”) is the amount shown
to You when You get a quote via the Platform or the amount shown to You before payment.
Transfer cost includes Driver’s fee and Company’s revenue. The Company’s Revenue is
calculated on a percentage basis or may be a fixed fee and its calculation may change without
any previous notice to You and according to the Company’s will and as it is deemed necessary
for Company’s business.

The Driver is solely responsible for providing a printed receipt to the Traveller and abiding with
local tax regulations on the income generated by the Transfer. We do not hold any responsibility
whatsoever for tax compliance of the Driver and/or Traveller with local tax authorities.

Refunds: The full amount of the Transfer Cost (including the Company’s Revenue), is charged
immediately following completion of such election to the Traveller’s authorized PayPal,Braintree,
Checkout or Shopify account and transferred (less the Company’s Revenue) to such Driver’s

About the Refund Policy please see section II. 3 -Policies of Transport Services.

Promotional Offers: The Company, at its sole discretion, may make available promotional offers
with different features to any of Travellers.

Facilitation of Payments: All Donations or Charges, as applicable, shall be facilitated through
PayPal or Braintree or Checkout or Shopify, Company’s third-party payment processing service.

7. Traveler Opinions

7.1 Only the Travellers who have received the Transport Service may rate / comment the
Transport Service, the Drivers, their vehicles or whatever else they deem appropriate and
worthwhile of annotation or of positive or negative remark.

7.2 In particular, the Company, upon completion of the Transport, sends an email to the Traveler
in order to invite them to rate the Driver who carried out the Transport, and the Company. The
Traveler rates the Driver by setting a score from one (1) up to five (5) stars. For a score of three
or less stars, the Traveler should choose one of the reasons presented to them to justify their
negative feedback. In any case the Traveler has the right to send to the Company comments
regarding the Driver, the Company, the Transport and / or anything else.

7.4 The Company does not indemnify or reward Travelers who have sent their rating / feedback.
Travelers’ review, rating and comments may be used by the Company at its absolute discretion
to inform Travelers for marketing purposes and for purposes of its own evaluation of the Drivers.

7.5 Travelers have the right to publish ratings / comments in public media, for example, social
media or websites such as FB, TRIPADVISOR and it is at the discretion of the Company
whether to consider these ratings / comments too, as part of Your evaluation by the Company
and how these are managed in general.


By entering into this agreement and using the software, the Platform or Service, to the extent
permitted by law, You agree that You shall defend, indemnify and hold the company, its licensors
and each such party’s parent organizations, subsidiaries, affiliated companies, distributors,
affiliate (distribution) partners, shareholders, officers, directors, employees, representatives,
members, attorneys, licensees, agents, or others involved in creating, sponsoring, promoting, or
otherwise making available the software and its contents harmless from and against any and all
claims, costs, damages, losses, liabilities and expenses (including attorneys’ fees and costs)
arising out of or in connection with: (i) any punitive, special, indirect or consequential loss or
damages, any loss of production, loss of profit, loss of revenue, loss of contract, loss of or
damage to goodwill or reputation, loss of claim, (ii) any inaccuracy relating to the (descriptive)
information (including personal data, comments, and ratings) of the users as made available on
our software, (iii) the services rendered by the driver, (iv) any (direct, indirect, consequential or
punitive) damages, losses or costs suffered, incurred or paid by You (including attorneys’ fees
and costs), pursuant to, arising out of or in connection with the use, inability to use or delay or
virus of our software and/or the server that the software is hosted, or (v) for any (personal)
injury, death, property damage, or other (direct, indirect, special, consequential or punitive)
damages, losses or costs suffered, incurred or paid by You, whether due to (legal) acts, errors,
breaches, (gross) negligence, willful misconduct, omissions, non-performance,
misrepresentations, tort or strict liability by or (wholly or partly) attributable to the user (its
employees, directors, officers, agents, representatives or affiliated companies)(including
attorneys’ fees and costs), including any (partial) cancellation, double-booking, strike, force
majeure or any other event beyond our control (vi) any information on this software sometimes
linked to external sites over which our services have no control and for which we assume no
responsibility (vii) any user violation or breach of any term of this agreement or any applicable
law or regulation, whether or not referenced herein.



1. General

We take privacy seriously and We respect and protect Your personal data. We are “Seablue Turizm Tasimacilik LTD.STI.” headquartered Merkez Mah. Abide-i Hürriyet Cad. Bolkan Center, A-B-C Blok No:211/64 Sisli – İstanbul, with the following contact details: email: [email protected] (hereinafter
the “ Company ”, “ We” , “ Us, ” “ Our ”) and We are the controllers of Your Personal Data.

This Privacy Notice tells Travellers (hereinafter the “Traveller(s)”, “You”, “Yours”, “User”)
what information about You We collect, what We do with it and what rights You have in relation
to any of Your personal data being processed by Us. . Click on “f ind out more” in each section
for further information.

2. Amendments

This is the first version of Our Privacy Policy and is in force since the 25t h of May 2018. This
Privacy Policy is in accordance with the Regulation 2016/697 for the protection of individuals
from the processing of personal data and any other European Community law relating to the
protection of Your personal data. Any future amendments to the applicable regulatory framework
will be incorporated in this Policy. Therefore, we reserve the right to update this Privacy and any
supplemental privacy notice at Our sole discretion, from time to time. We will notify you of the
changes where required by law to do so. Should You not agree with the changes, or have any
dispute, reservation or question about them (changes), You can contact Us at
[email protected] Please note that any information / clarification given to you in
connection with any changes to this Policy does not constitute a substitution, or any modification
of this Policy.

By continuing to use Our Service by any means, You accept automatically and unconditionally
the modified terms of this Policy. In the event that You do not agree with the modifications, You
should not make any action or use of the Platform, and provide us Your personal data and you
are entitled to terminate the contracts between us and request the deletion of Your Account and
Your data, to the extent permitted by applicable law. For any information or clarification, You can
contact us and in any case You have the right to exercise Your rights as detailed in Section V

3. Content of the Privacy Policy

Our Privacy Policy includes:

  • information about the Data Controller information on how to conduct Us for any issue
    regarding Your personal data.
  • the type of personal data that we collect for You and methods of collection
  • the purpose of collection, the processing activities of Your personal data and the legal
    ground for the processing;
  • security measures that we undertake for the protection of Your personal data and Our
    data retention policy;
  • Your rights and the ways to exercise them and any options You may have regarding
    processing of Your personal data
  • information about the protection and storage of Your personal data by our Company


1. Who is the Data Controller?

Data Controller of Your personal data is the company under the name “W ELCOME
TRAVEL TECHNOLOGIES HOLDINGS LTD” , with no 10879236, headquartered in c/o
Harrison Beale & Owen Seven Stars House, 1 Wheler Road, Coventry CV3 4LB, UK
with VAT np: 289 0786 46 (“ Company ”, “ us, ” “ our ,” and “ we ”).

2. Questions and Comments

If You have any questions, or wish to exercise any of Your rights, You can conduct Us at
the following contact details: email: [email protected] If Your country has a
data protection authority, You have a right to contact it with any questions or concerns. If
We cannot resolve Your questions or concerns, You also have the right to seek judicial
remedy before a national court.


1. WHAT personal data do we collect and HOW we collect them

We collect some of Your personal data when You use the Service and book Your
transfer, or buy a product from or through Us. We collect different types of personal data
either directly from You or from third parties through automatic means such us

  • Identity data: You grant us when You get a price quote i.e Your pick up address, when
    you book a transfer, Your name, surname, email, telephonel etc.
  • Communication Data: You provide Us with Your mobile phone number and Your email,
    a means to either Us or the Driver who picks You up, to communicate with You about the
  • Payment Data You provide Us with Your bank card number, the expiration date of the
    card, the CVV etc. in order to pay for the Transfer and Your email and/or full name when
    You pay via Paypal
  • Transport Data (History): The total number of Transfers You have made through Us in
    cases You have an Account with Us.
  • Technical / Device Data: The type of software used when entering the Platform, when
    using it, etc, IP address, login information, browser type and version, operating system
    and platform and other technology on the devices You use to access our Platform, etc.
  • Login Data, when You log in Your account in the Platform which is Your email and
  • Profile Data created from the information You provide to us when You make a booking,
    from data regarding Your preferences and provided to Us optionally, from Your
    interaction with the Newsletters (e.g., how many and what newsletters You open and
    when), from Your purchase habits deriving from products You may buy from Us, from
    information derived from Your browsing (kind, time, cost), from Your feedback on the
    market research that our Company may conduct from time to time, from Your feedback
    and Your questions to us or any complaints from Your interaction with Social Media, or
    directly from Our Customer care, from the information You voluntarily upload to Social
    Media, from information collected from cookies we use, from data that You grant us You
    when You complete questionnaire that we send to You following the payment etc (such
    as nationality, consumer preferences etc).
  • Demographic data : age, city, Postal Code etc.
  • Cookie data: number of visits to the Platform, visitor interaction with the Platform (see
    analytically Cookies Policy ).
  • Customer service data: when You call Customer Support Team, we collect Your full
    name, voice data etc.

Platform and its services are provided exclusively to people who are at least 18 years of
age or older. If You are under 18, please do not use or provide us with any personal
data, and do not use the Platform and the Service.

We collect directly from You the following personal data:- When You open an Account with Us and also book a Transfer, You provide us with
identity data, contact data, payment data etc- When You communicate with us, we collect identity data and communication data, and
customer service data if You contact Customer Support Team etc.We collect the following data and information for You automatically.

  • By using cookies and other related technologies, we collect and / or create data
    about Your preferences, the type of newsletter You open or not, its content and your
    interaction with us after each newsletter, the type of Transfer You booking, the search
    terms You’ve entered or the links You clicked on the Platform etc,
  • From Your bookings, we create data about Your bookings, and booking history, Your
    preferences etc.
  • Data about the devices through which You visit our Platform, such as IP address,
    login information, browser type and version, operating system and platform, and other
    technology on the devices You use to access our Platform, etc.
  • Data about the page from which You log in and the page You visit when You leave the
    Platform (i.e. your Browsing history)

We collect from third parties the following data and information about You:

– from Drivers when they are ask to rate a ride

– from Hotels when a transfer is booked through Your Hotels Platform.

2. HOW and WHY do we use Your personal data.

We use Your data for the legal purposes referred below. However, where the European laws
restrict or prohibit certain activities described in this notice, we will not use information about
You for those purposes.

Subject to the above, We may use information about You for the following purposes :

  • To subscribe You to the Platform and open your Account.
  • To identify You every time You log in.
  • To provide you with the Service.
  • To arrange for Your Pick Up and delivery to a booked place.
  • To communicate with You about Your Transfer.
  • To communicate with You about the Platform.
  • To communicate with You in order to address any of the inquiries or problems You have.
  • To receive Your payments for the Services.
  • To help You as a Traveller for the Transfer.
  • To handle / process Your requests, such as change of a Transfer that You have booked,
    change Your personal details, exercise Your rights.
  • To transmit documents and information necessary for the use of the Platform and the
  • For marketing purposes.
  • For security reasons for the transactions.
  • for business analysis and enhancements, such as making our Services available and
    optimized, optimizing Your experience and service within the Platform, and customizing
    Your experience in Platform
  • For statistical analysis.
  • To comply with regulatory obligations.
  • For other purposes that we will notify You, or identify to You on a case-by-case basis, at
    the point where Your information is originally collected.

The legal basis for our use of information about You is one of the following (which we explain in
more detail in the “find out more” section):

  • compliance with a legal obligation to which we are subject;
  • the performance of a contract to which You are a party;
  • a legitimate business interest that is not overridden interests You have to protect the
  • where none of the above applies, Your consent (which we will ask for before we
    process the information).

find out more…

Purpose of processing Data that we process for the purpose Legal basis For Your Subscription to the
Platform and opening of Your Account.
We process Your data
– for Your identification
– to recognize You as a Platform user.
– To give You access to the features and service of the Platform.
– to use the Platform Service/ Features- Identity data- Communication Data- Log in Data Legal basis is:a) your consent upon Your subscription to the Platform.
b) our legitimate interest to identify You if necessary, for the avoidance of any fraud or security incident.
c) fulfilling of our contractual obligationsa) to give You access to the features and service of the Platform in order to use it b) for creation/administration of
Your account in the Platform.
For booking a transfer & for the provision of our Service We process Your data:
– for booking a transfer
– filing of a transfer order
– To send a request to Driver for Your pick Up.
– for identification
– to contact You for any case regarding Your Transfer
– to contact You for any case regarding the Platform and the Service.
– to process any payment and generally to proceed to any transaction with You regarding the Trans
– to activate mechanisms to prevent fraud against You or against us
– Identity data
– Communication data
– Payment data

Legal basis is:
a) contractual obligation to fulfill Your transfer booking.
b) legal obligation of our Company to comply with tax law,
c) legitimate interest to collect payments, detect any fraud.
d) consent in specific processing such us storage of data for future purposes etc. Support, handling of Your requests-
Communication regarding Transfer & the Platform.

We process Your data for:
– Contacting You regarding Transport Services
– Your support in general on issues related to the Company, its services, Your account in the Platform
– Complaints or clarifications
– Generally management and optimization of user experience in the Platform.
– Customer care for issues related to the Company, Platform, transfers, services, bookings etc.
– Complaints or clarifications
– Exercise of Your rights
– Identity data
– Communication Data
– Information that You provide us related to Your request
– And data that we create for You. In case a call is recorded, You will be notified beforehand by a relevant audio message.

Legal basis is :
a) legal obligation of our Company to have means for customer care before and after booking, to reply to Your inquiries
about exercising of Your rights.
b) legitimate interest of our Company to reply to Your requests, to optimize customer care services and communication with
Travellers, and also to handle any case in the best way to the benefit of data subject and that is reasonably expected by data subjects.
c) contractual obligation if You contact us about Your Transfer Αdvertising & Marketing
– to send newsletters generic and personalized.
– to send marketing communication via email, or multimedia, push notifications etc.
– to run promotions, loyalty programmes, etc.
– Customer’s satisfaction with Company’s services.
– Personalized marketing communication via personalized messages based on Traveller’s preferences.
– Identity data
– Communication data,
– Profiling data,
– Demographic data,
– Cookies data
– or combination of all the above data.

a) the legitimate interest of our Company to process Traveller’s data provided to us:

i) for the Transfer or other transaction

ii) for the purpose of direct commercial communication for related services or purposes.

In these cases, you may request to opt-out with a click on the unsubscribe button in the email or by contacting with us. In addition,
the Company has the legitimate interest to make Your profile based on all information that we have for You (e.g. transfer history,
Your preferences) and also based on Your purchases and Your interaction with newsletters, Your place of residence, in order to
enhance your experience. b) Your consent you provide us voluntarily to send you newsletters and personalized information via
email, and other multimedia and in case you agree to send you push notifications. Business analysis and improvements for :
– Unceasing Platform operation
– technical excellence and security of transactions
– optimization of technical systems
– addressing technical issues
– compiling reports and keeping data
– Log in data
– Identity data
a) the legal obligation to secure information and confidentiality
b) the legitimate interest for security of networks, avoidance of any fraud and unauthorized access to data, for our business
continuity, upgrading our systems and our partners’ system, for our business development, optimization of our technical
systems and processes, any data process that prevails rights and freedoms of data subjects that data subjects reasonably
expect to be processed for this purpose. You have the right to oppose the above processing per data processing case. It
should be noted, however, that the Company is entitled to demonstrate legal reasons for the processing to prevail interests,
rights and freedoms of data subjects. Statistical analysis to rate and improve Platform services and procedures that includes :
– Rating and improvement of business processes
– Responsiveness and management of Your requests
– Responsiveness and management of the Platform
– Research and / or analysis to understand needs of users
– Adoption of new business and business models,programs and partnerships.
– Improvement of Your experience
– Delivery of related content
– Quality surveys
– Statistical analysis
– Financial data
– Transfer history data
– Profile data

a) the legitimate interest of the Company for the further processing of aggregated data for the purpose of statistical analysis
to improve its products and services while complying with all the necessary safeguards to collect and process data that do not
identify a particular data subject and do not affect the rights and freedoms of data subjects.
b) the legitimate interest to, analyze usability and functionality of the Platform, to improve our business performance for our
users, to improve our partnerships, always respecting Your rights, freedoms and interests for Your personal data. Provision
of personalized services, personalized Traveler experience:
– transfer data to Your personal Driver in order to welcome You and provide You a personalized experience during Your transfer
– Share data with the partner hotel in case You have booked a transfer with our Company though hotel’s page in order to provide
You a personalized experience during Your accomodation at the hotel .
– Identity data
– Profile data
Your consent to provide us voluntarily personal data in order for Us or Our partners to provide You with personalized

3. WHO do we share Your information with and for what purposes?
For the operation of the Platform, fulfillment of contractual obligations and for Your best support as user, our Company reserves the right to cooperate with third-party service providers that provide us with their services and access only those data that are absolutely necessary for the service they offer us (e.g. subscribing to the Platform and managing Your account, execute our contract between us, optimization of our services, etc.). These third service providers are bound by contract not to use Your information for any other purposes.
More specifically, our Company cooperates with:
(a) a third company acting as processor and hosts data that You provide us through the Platform
(b) Data analysis companies
(c) Research companies
(d) third-party email marketing companies acting in the name and on our behalf to send You the newsletter.
(e) advertising and marketing companies
(f) Data analysis companies
(g) Research companies
(h) Fraud Detection and Prevention Organizations,
(i) 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. In addition, in the event of a merge or redemption or other change in our business, the new owners, etc. have the right to use Your personal data in the same way according to this Privacy Policy. Your data may be communicated to competent judicial, police and other administrative authorities upon their request and in accordance with the applicable laws. Moreover, in case of a statutory provision, a service order or a formal preliminary examination, our Company has the right to place the relevant information at the disposal of the respective authority.


1. SECURITY of Your personal data

We take appropriate technical and organizational measures to protect Your personal data from unauthorized disclosure, use, conversion or destruction. Where appropriate, we use encryption and other technologies that can help to secure any information You provide us. We also ask our service providers to comply with privacy and data protection requirements.

find out more…

More specifically, Your personal data are managed exclusively by specially authorized personnel of the Company under our control. In order to conduct the processing, the Company selects individuals or third parties with corresponding professional qualifications that provide sufficient guarantees in terms of technical knowledge and personal integrity to maintain confidentiality.
The Company, through its respective contractual commitments and its partners, takes all necessary security measures to protect and secure confidentiality and integrity of personal data. In any case, the security is subject to reasons beyond Company’s influence, as well as to reasons resulting from technical problems of the network that are not controlled by the Company or reasons of force majeure
events. You should not disclose the data / passwords You have for Your account, which are personal and non-transferable. For personalized communication, our Company also uses appropriate mathematical and / or statistical processes to compile the profile and performs regular quality and security checks on the systems and algorithms it uses to correct the factors that lead to inaccuracies in the data.


2. HOW LONG will information about You be kept

We will retain information about You for the period necessary to fulfill the purposes for which the information was collected. After that, Your account will be deleted. Such period will vary depending on the purposes for which the information was collected. Please note that in some circumstances, You have the right to request a deletion of the information. Furthermore, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes. We may also keep it until You request its deletion, or in case of data based on Your consent, until You withdraw Your consent, or until You opt out for the processing for which we have legitimate interest. To determine data retention time of Your personal data, we take into account the nature of Your data, the quantity, purpose, security, etc. You have the right to request from us to delete Your data. 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 of time. In any case, Your data is stored with safety.

find out more…

Management of Your account in the Platform Until Your account is deleted or after 2 years of the last action. Transfer Orders We will process Your data for the time required to manage a Transfer and/or products or services You have ordered, including any necessary time to refund, handling complaints or claims relating to the Transfer or service. We may retain some of Your information that You may provide us for more time, until You ask us to stop storing it. Transfers If You book a Transfer, we will retain details of this for so long as required to complete the Transfer and to comply with any legal obligations (for example, for tax and accounting record-keeping purposes). We may only store aggregated data for the Transfer for business analytic purposes. Customer care If You contact the Customer Support team of the Company, we will make a record of the matter (including details of Your enquiry and our
response) and retain it while it remains relevant to our relationship. Temporary records may be relevant only until more permanent records are made, and will be retained only temporarily. Usability and quality analysis We will process Your data during the period we will perform an action or a specific quality survey or until we have anonymized Your browsing data Marketing Until You unsubscribe from our newsletter recipients list, or until You withdraw Your consent, or until You oppose (opt out) processing,
otherwise we will retain Your data for five (5) years maximum. However, some elements of Your profile, such as files about how we interact with You, may stop to be in force after a period of time, so we automatically delete them after a specified period (usually 3 years) depending on the purpose for which we have collected them. if we do not have communication with You for a long time (usually
3 years), we will stop sending You promotional messages and we will delete history of Your responses. This will happen, for example, if You never click on our Newsletter, if You never log in to a digital contact point or if You never contact us or do not book a transfer, or contact customer service. The reason is that, in these cases, we assume that You prefer not to receive any message from us. Business analytics Business analytics data is typically collected automatically when You use Company’s touchpoints and becomes anonymised/ aggregated shortly afterwards.

3. TRANSFER of Your personal data to third countries

The Company generally keeps Your personal data within the European Economic Area. When Your data is to be transmitted to third countries outside the European Economic Area or International Organizations for which no European Commission decision is available, all the appropriate safeguards provided for in the applicable data protection legislation on the transfers to third countries.


You may have some or all of the following rights in respect of information that we hold about you:

    •  request us to give You access to it;
    •  request us to rectify it, update it, or erase it;
    •  request us to restrict our use of it, in certain circumstances;
    •  object to our using it, in certain circumstances;
    •  withdraw Your consent to our using it;
    •  data portability, in certain circumstances;
    •  opt out from our using it for direct marketing; and
    •  lodge a complaint with the supervisory authority in Your country (if there is one).

We offer You easy ways to exercise these rights, by calling at Customer Support Team by sending email at [email protected]
Some mobile applications we offer might also send You push messages, for instance about new products or services. You can disable these
messages through the settings in Your phone or the Platform. It may be necessary, for the security of Your information, to ask for some
information about You for the purposes of Your identification. Your right is exercised free of charge, however, when your right is abusively
used, we may ask You a fee in accordance with the conditions set by law. In any case, we respond to Your requests within one month,
except in exceptional cases where our response time to a request may be longer.

find out more…

Right in respect of the information about You that we hold Further detail (note: certain legal limits to all these rights apply)
· to request us to give You access to it (article 15)
This is confirmation of:
· whether or not we process information about You;
· our name and contact details;
· the purpose of the processing;
· the categories of information concerned;
· the categories of persons with whom we share the information
· (if we have it) the source of the information, if we did not collect it from You;
· (to the extent we do any, which will have been brought to Your attention) the existence of automated decision-making, including
profiling, that produces legal effects concerning You, or significantly affects You in a similar way, and information about the logic
involved, as well as the significance and the envisaged consequences of such processing for You; and
· the criteria for determining the period for which we will store the information.
On Your request we will provide You with a copy of the information about You that we use (provided this does not affect the rights
and freedoms of others).
· to request us to rectify or update it (article 16) This applies if the information we hold is inaccurate or incomplete.
· to request us to erase it (article 17)This applies if:
· the information we hold is no longer necessary in relation to the purposes for which we use it;
· we use the information on the basis of Your consent and You withdraw Your consent (in this case, we will remember not to contact
You again, unless You tell us You want us to delete all information about You in which case we will respect Your wishes);
· we use the information on the basis of legitimate interest and we find that, following Your objection, we do not have an overriding
interest in continuing to use it;
· the information was unlawfully obtained or used; or
· to comply with a legal obligation.
· to request us to restrict our processing of it (article 18) This right applies, temporarily while we look into Your case, if
· contest the accuracy of the information we use; or
· have objected to our using the information on the basis of legitimate interest (if You make use of Your right in these cases, we
will notify You before we use the information again).
This right applies also if:
· our use is unlawful and You oppose the erasure of the data; or
· we no longer need the data, but You require it to establish a legal case.
· to object to our processing it (article 21) You may at any time object to any processing of Your personal data, which are processed
under the legitimate interest of the Company or the fulfillment of a duty performed in the public interest.
· to withdraw Your consent to our using it (opt- out) This applies if the legal basis on which we use the information about
You is consent. These cases will be clear from the context.
· to data portability (article 20)
(i) You have provided data to us; and
(ii) we use that data, by automated means, and on the basis either of Your consent, or on the basis of discharging our contractual
obligations to You, then You have the right to receive the data back from us in a commonly used format, and the right to require
us to transmit the data to someone else if it is technically feasible for us to do so.
· to lodge a complaint with the supervisory authority You can lodge a complaint with the supervisory competent authority in Your country.
· Identity card We take into account the confidentiality of all files that contain personal data and we reserve the right to ask
You for proof of Your identity if You make a claim about those files.
· Costs We will not charge You for the exercise of Your rights in relation to Your personal data unless, as required by law, Your request
for access to information is unreasonable or excessive, so we may charge a reasonable fee under these conditions. We will notify You
of any charges before fulfilling Your request.
· Timelines We aim to respond to any valid requests within one (1) month of receipt, unless it is very complex or You have made a
number of requests, so we aim to respond within three months. We’ll let You know if we’ll need more than one (1)
month for the reasons outlined above. We may ask You if You can tell us exactly what You want to receive or what exactly is
Your concern. This will help us to act faster for Your request. In any case, You should provide us with specific and truthful
facts and / or facts in order to be able to answer and / or satisfy Your request, otherwise we reserve the right to make
any errors that are out of our control. In addition, our Company may refuse requests that are unjustified or
excessive or abusive or inaccurate or generally illegal according the provisions of the law.


1. Copyright

1.1 The Company is the proprietary and lawful owner of all Intellectual Property Rights in the
Platform and the Service and grants Travellers the right to access the Platform and use
the Service under the present Terms of Use (“License”). Limitations of the License are
referred to the ACCEPTABLE USE OF THE PLATFORM POLICY of the Platform .
1.2 The Company is the owner and retains in its possession and ownership all rights, titles
and interests regarding the Platform and the Service, its functions and features
(indicatively but not restrictively: its Software, its programs, philosophy, look and feel,
methodology and technique by which it has been designed, its model, algorithms,
information and materials, know-how regarding the Platform, the Service and Software,
as well as any modifications, notifications, improvements,parameterizations, derivative
functions, manuals and other documents related to the Implementation and operation of
the Platform.
1.3 All the content of the Platform /Service, such as texts, graphics, logos, icons, images,
etc, is the property of the Company and are protected by the Legislation of England and
Wales, European Law and International Conventions and therefore the Traveller has no
right to the Platform/Service other than those granted to him under the License under the
present Terms of Use.
1.4 The names, images, logos and distinctive features representing Our Company and its
products / services, such as the brand name “SeaBlue”, “SeaBlue Tours” and
the products / services provided under this brand name and/or any of its derivative, or
composite, homonymous or similar names, and/or any other logos, trademarks and
distinctions, trade secrets, patents and any other intellectual property rights in respect of
the Platform/ Service and the functions that become known to the Traveller through the
Service, are the exclusive trademarks and distinctive features of the Company and are
protected by UK, European and international trademark laws, and industrial and
intellectual property and competition law. In any case, their exposure to the Platform
shall in no way grant You and/or any third party a license or right to use them.
1.5 With these General Terms of Use, We grant You a limited and non transferable license to
access and use the Platform and Service, but not permission to download the Content
and the Code of the Platform in its entirety or in part, unless We give You our express
written permission. This license does not allow any resale or commercial use of the
Platform/ Service or its content, collection and use of our catalogs, our products, our
commercial policy, data mining, etc. You are entitled to use the above only for Your
personal use.
1.6 You may not use any “post-tags” or any other “hidden text” based on our Company’s
brand names or trademarks without our express written consent. In the event of an
unauthorized use, the License granted shall cease to be valid. The same applies to any
use of our Company’s logos and trademarks. Any copying, analog / digital recording and
mechanical reproduction, distribution, transmission, downloading, processing, resale, of
part or of all the Platform Content for any purpose other than strictly personal use is
forbidden, unless we give You our writing consent.

2. Technical Support – Enhancements of Platform

The Company has no obligation and is not currently bound to provide technical support,
improvements, customizations and/or renewals to the Platform and/or the Service. Only
occasionally and at its sole discretion it may upgrade the Platform and the Platform. You
may also need to make software updates, otherwise the Company has no responsibility
for any incompatible features of the version of the Platform You are using. In any case,
You acknowledge and agree that these General Terms govern any current version of the
Platform and the Service.

3. External Links

The Platform may contain links to third party websites whose information and data
protection practices are different to those of the Company. The Company is not liable for
the information or data protection practices used by third parties on their websites. It is
recommended, before using other websites, to read and understand the terms of use and
their privacy policy. The Company does not check the availability, content, privacy policy,
quality and completeness of other web sites that the Platform may refer to through “links”,
hyperlinks, or banners. The Company shall in no case be deemed to embrace or accept
the content or services of the websites and pages to which it refers to or that it is in any
way affiliated to them.

4. Contact

By using the Platform/ Service, You agree to receive electronic communications from us
and You unreservedly accept that they meet all legitimate written communication
requirements as to the reason they are created. For any complaints, comments,
suggestions, etc. You want to submit to us, please contact Our Customer Service at
[email protected]

5. Final Terms

The present General Terms are the definite and unique terms in force, regarding the
provision of the Service by the Company to the User and any prior terms, prior
agreements and arrangements, written or oral between the Company and the User
regarding the use of the Service, are hereby repealed.

6. Waiver

Any delay, negligence or tolerance by the Company in enforcing the User’s adherence to
any of the present terms shall not constitute a waiver or a detriment to any of the
Company’s rights. In case any term of the present document is held as void by any
competent Court or Authority and therefore inapplicable, then the said term will not
invalidate the remaining terms herein, which all of them will remain in full force and effect.

7. Invalidity of Terms

In the event that any part of the present document is held invalid or void by a court decision,
such invalidity shall not affect the validity of the remaining part of these General Terms,
which shall remain valid as if the invalid part were deleted. The Company will seek to
replace any invalid term with a new valid one, the effect of which will be the as similar as
possible to the one of the one canceled.

8. Assignment

This Agreement may not be assigned by You without the prior written approval of the
Company but may be assigned without Your consent by the Company to (i) a parent or
subsidiary, (ii) a purchaser of assets, or (iii) a successor to a merger . Any attempted
assignment of the Agreement, in violation of this article, is void.

9. Applicable Law – Jurisdiction

Any dispute between the parties concerning the Platform, interpretation, nullity of the terms
of the contract, the existence or non-existence of rights and obligations of the contracting
parties under contract or even tort, shall be interpreted in accordance with laws of
England and Wales and shall be subject to the exclusive jurisdiction of the competent
courts of the city of London, under the jurisdiction of which the parties are voluntarily

10. Cookies


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