Privacy Policy

Welcome to the Privacy Policy of iSPACE ΙΔΙΩΤΙΚΗ ΚΕΦΑΛΑΙΟΥΧΙΚΗ ΕΤΑΙΡΙΑ (iSPACE I.K.E.). We respect your privacy and are deeply committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website, use our AI Assistant, or access our 3D Virtual Tours, and tell you about your privacy rights and how the law protects you.

Our core philosophy is "Privacy by Design". We only collect data that is absolutely necessary for the functioning of our services. If we don't need it, we don't collect it.

Under the General Data Protection Regulation (GDPR), the legal responsibilities vary depending on whose data is being processed:

• When you are our B2B Client: When a business (e.g., a hotel owner) signs up for our services, iSPACE acts as the Data Controller for their billing details, contact names, and emails.
• When an End-User uses our AI Widget: When a guest visits a hotel's website and interacts with the iSPACE AI Assistant, the hotel is the Data Controller, and iSPACE acts solely as the Data Processor. We process the chat inputs strictly on behalf of our Client.

3.1 End-User Anonymity: By default, our AI Assistant does not collect Personally Identifiable Information (PII). When an end-user chats with the AI, the chat logs are completely anonymous. We do not collect, track, or store IP addresses, geographic addresses, or names of the end-users.

3.2 Legal Basis for Processing: We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract: Processing billing and contact data to provide the agreed SaaS services.
• Legitimate Interests: Using anonymized analytics (Google Analytics 4, MS Clarity) to study user behavior and improve our platform.
• Legal Obligation: Retaining financial and invoicing data to comply with Greek tax authorities.

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

• Billing & Tax Records: Retained for ten (10) years in accordance with Greek tax and corporate legislation.
• AI Chat Logs: Retained for a maximum period of ninety (90) days to allow Clients to monitor AI performance and update their knowledge base. After 90 days, these logs are automatically and permanently deleted from our servers.

To provide intelligent responses, iSPACE utilizes third-party Enterprise Application Programming Interfaces (APIs), including OpenAI, Google APIs, and various Weather APIs.

Strict Zero-Training Policy: We have established strict enterprise agreements with these providers. It is explicitly guaranteed that the chat logs, user queries, and any internal business documents you upload to the iSPACE Panel are NOT used to train the public foundation models of OpenAI, Google, or any other provider. Your proprietary data remains completely segregated and secure.

iSPACE does not sell, rent, or trade personal data to data brokers or marketing agencies. Data is only shared with our strictly vetted Sub-processors (such as AWS for hosting and OpenAI for text generation) exclusively for delivering the functionality of our platform.

International Transfers: Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: We use specific contracts approved by the European Commission known as Standard Contractual Clauses (SCCs), or we ensure the provider is certified under the EU-US Data Privacy Framework.

In accordance with Article 22 of the GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you.

iSPACE confirms that our AI Assistant operates strictly as an informational and customer support tool. It does not perform automated decision-making or profiling that produces legal effects or similarly significantly affects the end-user (e.g., it does not automatically decline service or perform credit scoring).

Our platform and B2B services are not intended for children. Furthermore, the AI widget deployed on our Clients' websites is directed at adult consumers.

In accordance with Article 21 of the Greek Law 4624/2019, the processing of personal data of a minor, when offering information society services directly to them, is lawful only if the minor has reached the age of 15 years. We do not knowingly collect data relating to children under this age limit.

We have put in place appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. All data is encrypted in transit using industry-standard TLS/SSL protocols.

Our primary infrastructure is hosted securely on Amazon Web Services (AWS) within the European Union (EU), ensuring robust compliance with European data localization standards.

Under the GDPR and Greek Law 4624/2019, you have several rights regarding your personal data. You have the right to:

• Request access to your personal data (data subject access request).
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data ("Right to be forgotten").
• Object to processing of your personal data where we are relying on a legitimate interest.
• Request restriction of processing of your personal data.

We would appreciate the chance to deal with your concerns before you approach the authorities. However, you have the right to make a complaint at any time to the Hellenic Data Protection Authority (ΑΠΔΠΧ), the Greek supervisory authority for data protection issues.

Hellenic Data Protection Authority details:
Website: www.dpa.gr
Address: Kifissias 1-3, PC 115 23, Athens, Greece
Telephone: +30 210 6475600

If you wish to exercise any of your GDPR rights, request data deletion, or have any questions regarding this Privacy Policy, please contact us directly.

Email: info@i-space.gr
Phone: +30 210 3008099
Data Controller: iSPACE I.K.E. (Mavromichali 95-97, Athens 11472, Greece)