1. Pre–ample

This Master Privacy Policy ("Privacy Policy") explains the collection, use, and disclosure of "personal information" by ELSSI Ltd ("ELSSI"), a Greece Corporation, with its principal place of business at 37 Mavrokordatou Str., 18538 Piraeus, Greece, through the websites that ELSSI operates at www.elssi.gr (the "ELSSI Website"), www.elssi.eu, www.elssi.net, (collectively, together with all sub–domains thereof). This Privacy Policy does not apply to any of the websites operated by affiliates of ELSSI. In addition, additional or supplemental Privacy Policy terms ("Supplemental Privacy Policy Terms") may apply to a particular Website or service provided thereon. All such Supplemental Privacy Policy Terms will be accessible for you to read either within, or through your use of, that Website or service. This Privacy Policy also explains our commitment to you with respect to our use and disclosure of non personal browsing and site usage data that ELSSI collects as the provider of the Websites. That commitment is contained in a "Data Usage Policy," below. As used in this policy, "personal information" means information that would allow a party to identify you such as, for example, your name, address or location, telephone number or email address. By accessing the Websites you are accepting and agreeing to the practices described in this Privacy Policy.

2. Our Principles

ELSSI is committed to handling responsibly the information and data we collect about you through our Websites, whether personal information or non personal browsing and site usage data. We have designed our Privacy Policy and our Data Usage Policy consistent with the following principles (the "Principles"):

1. Privacy policies and data collection and use policies should be human readable, comprehensive, and easy to locate;
2. Only the minimum amount of information reasonably necessary to provide you with services should be collected and maintained, and only for so long as reasonably needed or required;
3. Information you provide through our Websites, or that we gather as a result of your use of our Websites or services, should not be used for marketing or advertising purposes, nor should it be provided voluntarily (without your permission) to anyone else unless required; and
4. Unless restricted or prohibited by law, and provided your email address has been collected and retained, you should be notified when circumstances require ELSSI to provide a third party with your personal information.

3. Personal Information ELSSI Collects

We may collect personal information at several places on the Websites, including without limitation:

• in connection with your purchasing any of our services;
• when you provide us with your personal information such as by sending an email to us or signing up to receive a newsletter or our events listing;

4. What ELSSI does with Personal Information

Emails and Newsletters. We use the personal information you provide to us when you send us emails or sign up to receive our newsletter or events listing in order to respond to your request – for example, to reply to your email or to send you communications about news and events related to ELSSI. When you subscribe to our newsletter, events list or one of our email discussion lists, your name and email address is stored in our corporate database. Any other personal information that we may collect which is not described specifically in this Privacy Policy will only be collected and used in accordance with the Principles.

5. Disclosures of Personal Information

In general, it is not ELSSI practice to disclose personal information to third parties. We may share personal information in two instances: First, ELSSI may share personal information with our contractors and service providers in order to maintain, enhance, or add to the functionality of the Websites or our service provisioning. Second, we may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Master Terms of Use and Privacy Policy; (c) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (d) protect our rights, reputation, and property, or that of our users, affiliates, or the public. If ELSSI is required to provide a third party with your personal information (whether by subpoena or otherwise), then provided we have collected and retained an email address for you, ELSSI will use reasonable means to notify you promptly of that event, unless prohibited by law or ELSSI is otherwise advised not to notify you on the advice of legal counsel.

6. Data Usage Policy: Non Personal Browsing and Site Usage Information

Our Data Usage Policy covers how we maintain and use information about you that is collected by our Websites and server logs. Non Personal Browsing Information We Collect. When you use the Websites, our servers (which may be hosted by a third party service provider) may collect information indirectly and automatically (through, for example, the use of your "IP address") about your activities while visiting the Websites and information about the browser you are using. No Linking. We do not intentionally link browsing information to the personal information you submit to us. We use this information for internal purposes only, such as to help understand how the Websites are being used, to improve our Websites and the features we provide, and for systems administration purposes. No Selling or Sharing. Except in the unique situations identified in this Privacy Policy, ELSSI does not sell or otherwise voluntarily provide the non personal browsing information we collect about you or your website usage to third parties. Notice. If ELSSI is required to provide a third party with your non personal browsing information (whether by subpoena or otherwise), then ELSSI will use reasonable means to notify you promptly of that event, unless ELSSI is prohibited by law from doing so or is otherwise advised not to notify you on the advice of legal counsel. Any other non–personal information that we collect which is not described specifically in this Privacy Policy will only be collected and used in accordance with the Principles.

7. Reorganization or Spin–Offs

ELSSI may transfer some or all of your personal and/or non personal browsing information to a third party as a result of a reorganization, spin–off or similar transaction. Upon such transfer, the acquirer’s privacy policy will apply. In such event, ELSSI will use reasonable efforts to notify you and to ensure that at the time of the transaction the acquirer’s privacy policy complies with the Principles.

8. Children

The Websites are not directed at children under the age of 13. We will never knowingly request personal information from anyone under the age of 13 without requiring parental consent. Our Master Terms of Use specifically prohibit anyone using our Websites from submitting any personally identifiable information about persons under 13 years of age. Any person who provides their personal information to ELSSI through the Websites represents that they are 13 years of age or older.

9. Third–Party Sites

The Websites may include links to other websites. You should consult the respective privacy policies of these third–party sites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.

10. Special Note to International Users

The Websites are hosted in Greece. If you are accessing the Websites from USA, European Union, Asia, or any other region with laws or regulations governing personal data collection, use and disclosure that differ from our local laws, please note that you are transferring your personal data to Greece which may not have the same data protection laws as other regions. By providing your personal data you consent to:

• the use of your personal data for the uses identified above in accordance with the Privacy Policy; and
• the transfer of your personal data to Greece as indicated above.

11. Changes and Updates to this Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will also revise the Effective Date below. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of the Websites constitutes your agreement to this Privacy Policy and any updates.

12. Using this Privacy Policy for Your Own Purposes

The ELSSI Privacy Policy is adhering to the Creative Commons Attribution 3.0 License. You are free to use and adapt this Privacy Policy for your own purposes. However, please keep in mind that this policy, as written, may not be completely suitable for your situation. It is strongly recommended to seek the advice of your own attorney or counsel before using this Privacy Policy.

Questions ?

If you have questions about this Privacy Policy, please contact us by email at info@elssi.gr.

Effective Date: September 29, 2011