Privacy Policy

EOS TOURS (SPS EOS TOURS LTD) – PRIVACY POLICY

Effective Date: [22.01.2026]

This Privacy Policy explains how EOS TOURS collects, uses,
stores, and protects your personal data in compliance with
the General Data Protection Regulation (EU) 2016/679 (GDPR)
and applicable Cyprus data protection legislation.
 
By using our services, you acknowledge that you have read
and understood this Privacy Policy.

TABLE OF CONTENTS

1. INTRODUCTION

1.1 About This Policy

This Privacy Policy describes how SPS EOS TOURS LTD, operating under the trade name EOS TOUR (“EOS TOURS”, “Company”, “we”, “us”, “our”), collects, uses, stores, shares, and protects personal data of our customers, website visitors, and other individuals who interact with our services.

We are committed to protecting your privacy and handling your personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Cyprus Processing of Personal Data (Protection of the Individual) Law of 2018 (Law 125(I)/2018).

1.2 Data Controller

DATA CONTROLLER
 
SPS EOS TOURS LTD
15 Tombs of the Kings Avenue
Christofi Complex, Shop 5
8045 Paphos, Cyprus
 
Company Registration: HE317514
 
Data Protection Contact:
Email: [email protected]
Phone: +357 99 247 900

1.3 Scope

This Privacy Policy applies to personal data collected through:

• Our website: www.eos-tour.com

• Bookings made directly with us (email, phone, in person)

• Bookings made through Online Travel Agencies (OTAs) such as Viator and GetYourGuide

• Participation in our tours and excursions

• Communications with us

2. PERSONAL DATA WE COLLECT

2.1 Data You Provide Directly

When you make a booking or contact us, we collect:

Data CategoryExamplesPurpose
Identity DataFull nameBooking identification, passenger lists
Contact DataEmail address, phone numberBooking confirmation, tour information, pick-up coordination
Location DataAccommodation addressPick-up point assignment and coordination
Booking DataTour selected, date, number of participants, preferencesService delivery
Communication DataEmails, messages, call recordsCustomer service, complaint handling

2.2 Data We Do NOT Collect

EOS TOURS does NOT collect:

• Passport or ID document numbers

• Payment card details (processed securely by payment providers — see Section 5)

• Health data (unless voluntarily disclosed for accessibility needs)

• Biometric data

• Data revealing racial or ethnic origin, political opinions, religious beliefs, or sexual orientation

2.3 Data Received from Third Parties

When you book through an Online Travel Agency (OTA), we receive:

• Your name

• Phone number

• Booking details (tour, date, number of participants)

We do NOT receive your email address or payment details from OTAs.

2.4 Data Collected Automatically

When you visit our website, we automatically collect:

Data TypeDetails
Technical DataIP address, browser type and version, device type, operating system
Usage DataPages visited, time spent, click patterns, referring website
Location DataApproximate geographic location (from IP address)
Cookie DataSee our Cookie Policy for details

This data is collected using cookies and similar technologies. For detailed information, please see our Cookie Policy at: eos-tour.com/cookies

3. HOW WE USE YOUR PERSONAL DATA

Under GDPR, we must have a valid legal basis to process your personal data. The table below explains how we use your data and the legal basis for each use:

PurposeLegal Basis (GDPR Article 6)
Processing and managing your bookingContract performance (Art. 6(1)(b))
Providing tour servicesContract performance (Art. 6(1)(b))
Sending booking confirmations and tour informationContract performance (Art. 6(1)(b))
Coordinating pick-up logisticsContract performance (Art. 6(1)(b))
Communicating about changes, cancellations, or issuesContract performance (Art. 6(1)(b))
Handling complaints and disputesContract performance / Legitimate interest (Art. 6(1)(b)/(f))
Complying with legal obligations (tax, licensing)Legal obligation (Art. 6(1)(c))
Improving our services and websiteLegitimate interest (Art. 6(1)(f))
Website analytics and performanceConsent (Art. 6(1)(a)) / Legitimate interest (Art. 6(1)(f))
Marketing (if you opt in)Consent (Art. 6(1)(a))
Protecting against fraud or illegal activityLegitimate interest (Art. 6(1)(f))
Defending legal claimsLegitimate interest (Art. 6(1)(f))

3.2 Legitimate Interests

Where we rely on “legitimate interest” as the legal basis, we have assessed that our interests do not override your rights and freedoms. Our legitimate interests include:

• Operating and improving our business

• Understanding how customers use our services

• Protecting our business from fraud

• Maintaining security of our systems

You have the right to object to processing based on legitimate interest (see Section 8).

3.3 What We Do NOT Do

EOS TOURS does NOT:

• Sell your personal data to third parties

• Use your data for automated decision-making or profiling that produces legal effects

• Send unsolicited marketing communications (unless you have opted in)

• Share your data with third parties for their marketing purposes

4. WHO WE SHARE YOUR DATA WITH

4.1 Service Providers (Tour Operations)

To deliver our tours, we share limited data with operational partners:

RecipientData SharedPurpose
Bus/coach operatorsName, pick-up location, phone numberPassenger list for pick-up and transport
Boat/vessel operatorsName, pick-up location, phone numberPassenger list for boarding
Tour guidesName, pick-up location, phone numberPassenger list for tour management
Restaurants (where included)Number of passengers, dietary requirements (if provided)Meal arrangements

These partners receive only the minimum data necessary to provide their services. They are contractually obligated to use this data solely for the specified purpose and to maintain appropriate security.

4.2 Technology Service Providers

We use third-party services to operate our business:

Provider TypePurposeData Location
Booking system (Bokun)Booking widget, reservation managementEU/EEA
Server hosting (Contabo)Website and CRM hostingGermany (EU)
Payment processors (Stripe, PayPal)Secure payment processingSee Section 5
Analytics (Google Analytics)Website analyticsUSA (with safeguards)
Advertising (Meta/Facebook Pixel)Advertising performanceUSA (with safeguards)

4.3 Online Travel Agencies (OTAs)

If you book through Viator, GetYourGuide, or another OTA:

• The OTA is an independent data controller for data collected through their platform

• We receive limited data from them (name, phone, booking details)

• We may share booking status updates with them

• Please refer to the OTA’s own privacy policy for how they handle your data

We may disclose your data when required by law or to:

• Comply with legal obligations or court orders

• Respond to requests from law enforcement or regulatory authorities

• Protect our rights, property, or safety

• Defend against legal claims

4.5 Business Transfers

If EOS TOURS is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

5. PAYMENT DATA

5.1 How Payments Are Processed

EOS TOURS uses third-party services to handle bookings and payment transactions:

• Bokun (bokun.io) — Booking management platform that provides the booking widget on our website

• Stripe (stripe.com) — Payment processor integrated with Bokun to process card payments

• PayPal (paypal.com) — Alternative payment method

When you make a booking through our website, the Bokun widget collects your booking details and passes payment information directly to Stripe for secure processing. EOS TOURS does not have access to your full payment card details at any point.

5.2 What We Do NOT Store

IMPORTANT: PAYMENT CARD SECURITY
 
EOS TOURS does NOT store, process, or have access to your
full payment card details.
 
• Credit/debit card numbers
• Card expiry dates
• CVV/security codes
 
When you book through our website, payment data is collected
by the Bokun booking widget and passed directly to Stripe
for processing using secure, PCI-DSS compliant systems.
 
Your card details never touch our servers.

5.3 Payment Processor Privacy

When you make a booking, you provide your details to services that have their own privacy policies:

• Bokun Privacy Policy: bokun.io/privacy-policy

• Stripe Privacy Policy: stripe.com/privacy

• PayPal Privacy Policy: paypal.com/privacy

5.4 What We Receive

After a successful payment, we receive only:

• Confirmation that payment was successful

• Transaction reference number

• Last 4 digits of card (for reference only)

• Billing name and address (if provided)

6. INTERNATIONAL DATA TRANSFERS

6.1 Where Your Data Is Stored

Your personal data is primarily stored and processed within the European Economic Area (EEA):

• Our CRM system: Hosted in Germany (Contabo GmbH)

• Booking system (Bokun): EU-based

• Operational data: Cyprus

6.2 Transfers Outside the EEA

Some of our service providers are based outside the EEA, particularly in the United States:

• Google (Analytics) — USA

• Meta/Facebook (Pixel) — USA

• Stripe — USA

• PayPal — USA

6.3 Safeguards for International Transfers

When data is transferred outside the EEA, we ensure appropriate safeguards are in place:

SafeguardDescription
EU-US Data Privacy FrameworkFor US companies certified under the framework
Standard Contractual Clauses (SCCs)EU-approved contract terms ensuring adequate protection
Adequacy DecisionFor countries deemed by the EU Commission to provide adequate protection
Binding Corporate RulesFor transfers within corporate groups with approved rules

You may request information about the specific safeguards applied to your data by contacting us.

7. DATA RETENTION

7.1 Retention Periods

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

Data TypeRetention PeriodReason
Booking and customer data2 years after last tourService delivery, customer service, potential claims
Financial/tax records6 yearsCyprus tax law requirements
Complaints and disputes3 years after resolutionLegal limitation periods
Website analytics26 monthsGoogle Analytics default, anonymised after
Marketing consent recordsUntil withdrawal + 1 yearProof of consent
Cookie consent12 monthsThen re-consent required

7.2 After Retention Period

When the retention period expires, we will:

• Securely delete your personal data; or

• Anonymise it so you can no longer be identified

7.3 Extended Retention

We may retain data longer if:

• Required by law

• Needed for ongoing legal proceedings or disputes

• You have given consent for extended retention

8. YOUR RIGHTS UNDER GDPR

8.1 Summary of Rights

Under GDPR, you have the following rights regarding your personal data:

RightDescription
Right to AccessRequest a copy of the personal data we hold about you
Right to RectificationRequest correction of inaccurate or incomplete data
Right to Erasure (“Right to be Forgotten”)Request deletion of your data in certain circumstances
Right to Restrict ProcessingRequest limitation of how we use your data
Right to Data PortabilityReceive your data in a structured, machine-readable format
Right to ObjectObject to processing based on legitimate interest or for direct marketing
Right to Withdraw ConsentWithdraw consent at any time where processing is based on consent
Rights Related to Automated DecisionsNot be subject to decisions based solely on automated processing

8.2 Right to Access (Subject Access Request)

You can request a copy of all personal data we hold about you. We will provide:

• The categories of data we process

• The purposes of processing

• Recipients or categories of recipients

• Retention periods

• Your rights

• Source of data (if not collected from you)

We will respond within one month of your request.

8.3 Right to Erasure

You can request deletion of your data when:

• Data is no longer necessary for the original purpose

• You withdraw consent (and no other legal basis applies)

• You object to processing and there are no overriding legitimate grounds

• Data was unlawfully processed

• Data must be erased to comply with law

We may refuse erasure if data is needed for:

• Exercising the right of freedom of expression

• Compliance with legal obligations

• Establishment, exercise, or defence of legal claims

8.4 Right to Object

You have the right to object to:

• Processing based on legitimate interest — we will stop unless we can demonstrate compelling legitimate grounds

• Processing for direct marketing — we will stop immediately upon your objection

8.5 How to Exercise Your Rights

To exercise any of these rights, contact us:

• Email: [email protected]

• Subject line: “DATA PROTECTION REQUEST — [Your Name]”

• Include: Your full name, email address used for booking, specific request

We may request proof of identity before processing your request.

We will respond within one month. If your request is complex, we may extend this by up to two months (we will notify you).

There is no fee for most requests. We may charge a reasonable fee for manifestly unfounded or excessive requests.

9. COOKIES AND TRACKING TECHNOLOGIES

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They help websites function, improve user experience, and provide information to website owners.

9.2 Cookies We Use

Our website uses the following types of cookies:

Cookie TypePurposeConsent Required
Strictly NecessaryEssential for website operation (e.g., session management)No
FunctionalRemember your preferences (e.g., language)Yes
AnalyticsUnderstand how visitors use our site (Google Analytics)Yes
MarketingTrack advertising effectiveness (Meta/Facebook Pixel)Yes

9.3 Third-Party Analytics and Advertising

We use:

• Google Analytics — to analyse website traffic and usage patterns

• Meta (Facebook) Pixel — to measure advertising effectiveness

These services may set their own cookies and collect data about your online activity.

9.4 Managing Cookies

You can control cookies through:

• Our cookie consent banner (when you first visit our site)

• Your browser settings (to block or delete cookies)

• Specific opt-out tools provided by Google and Meta

Note: Blocking certain cookies may affect website functionality.

For detailed information about specific cookies we use, please see our Cookie Policy at: eos-tour.com/cookies

10. DATA SECURITY

10.1 Security Measures

We implement appropriate technical and organisational measures to protect your personal data against:

• Unauthorised access

• Accidental loss, destruction, or damage

• Unlawful processing

Our security measures include:

• SSL/TLS encryption for data in transit

• Secure server infrastructure within the EU

• Access controls (data accessible only to authorised personnel)

• Regular security updates and patches

• Secure payment processing through PCI-DSS compliant providers

10.2 Staff Training

Our staff who handle personal data are trained on data protection obligations and the importance of protecting customer data.

10.3 Data Breach Procedures

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms:

• We will notify the Commissioner for Personal Data Protection within 72 hours

• If the breach is likely to result in high risk, we will notify you directly

• We will document all breaches and the actions taken

10.4 Your Responsibilities

To help protect your data:

• Keep your booking reference confidential

• Use secure networks when accessing our services

• Contact us immediately if you suspect unauthorised access to your account

11. PHOTOGRAPHS AND IMAGES

11.1 Our Practice

EOS TOURS does not systematically photograph customers during tours. We do not employ photographers or require photos for operational purposes.

11.2 Occasional Photos

On occasion, tour guides or staff may take photographs of groups or scenery that may incidentally include customers. These photos may be used for:

• Social media posts

• Website content

• Marketing materials

11.3 Your Rights Regarding Photos

If you do not wish to be photographed or to have your image used:

• Inform your guide at the start of the tour

• If you see a photo of yourself on our website or social media that you would like removed, contact us at [email protected] and we will remove it promptly

11.4 Customer Photography

Customers are free to take photographs during tours for personal use. Please be respectful of other participants who may not wish to be photographed.

12. CHILDREN’S DATA

12.1 Services for Children

Our tours are open to families including children. When a booking includes children (under 18 years of age), the booking must be made by a parent or legal guardian.

12.2 Data Collected

For child participants, we collect only:

• Name (for passenger list)

• Age category (for pricing, where applicable)

• Special requirements (if provided by parent/guardian)

By booking on behalf of a child, the parent or legal guardian consents to the collection and processing of that child’s data as described in this Privacy Policy.

12.4 Children’s Rights

Parents/guardians may exercise data protection rights on behalf of their children by contacting us.

13. CHANGES TO THIS PRIVACY POLICY

13.1 Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

13.2 Notification of Changes

If we make significant changes, we will:

• Post the updated policy on our website

• Update the “Effective Date” at the top of this policy

• For material changes that affect how we use your data, we may notify you by email (if we have your email address)

13.3 Your Continued Use

Your continued use of our services after changes are posted constitutes your acceptance of the updated policy. We encourage you to review this policy periodically.

14. CONTACT US AND COMPLAINTS

14.1 Contact for Data Protection Matters

DATA PROTECTION CONTACT
 
SPS EOS TOURS LTD
Attn: Data Protection
 
Address:
15 Tombs of the Kings Avenue
Christofi Complex, Shop 5
8045 Paphos, Cyprus
 
Email: [email protected]
Phone: +357 99 247 900
 
Please include “DATA PROTECTION” in the subject line
of any email regarding privacy matters.

14.2 Complaints to Us

If you have concerns about how we handle your personal data, please contact us first. We take all privacy concerns seriously and will investigate and respond promptly.

14.3 Complaints to Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority. In Cyprus, this is:

COMMISSIONER FOR PERSONAL DATA PROTECTION
(Επίτροπος Προστασίας Δεδομένων Προσωπικού Χαρακτήρα)
 
Address:
1 Iasonos Street
1082 Nicosia, Cyprus
 
Phone: +357 22 818 456
Fax: +357 22 304 565
Email: [email protected]
Website: www.dataprotection.gov.cy

If you are resident in another EU Member State, you may also complain to the supervisory authority in your country of residence.

— End of Privacy Policy —

Last updated: [22.01.2026]

Version 1.1