TERMS OF USE
Last updated: 25 October 2026 · Version: 1.0
1. Scope and Acceptance
These Terms of Use govern access to and use of the website https://www.tourtlee.com (the “Website”), owned and operated by HALF PRICE TOURS I.K.E. under the brand Tourtlee (“we”, “us”, the “Business”). By accessing or using the Website, the visitor/user (the “User”) confirms that they have read, understood and unconditionally accepted these Terms. If you do not agree, please do not use the Website.
2. Changes to the Terms
We reserve the right to amend these Terms at any time, without prior notice. Amendments take effect upon publication on the Website. Continued use after any amendment constitutes acceptance of the revised Terms. We recommend reviewing this page periodically.
3. Availability
We make reasonable efforts to keep the Website continuously available, without however guaranteeing uninterrupted or error-free operation. The Website may be unavailable due to maintenance, technical issues, upgrades or causes beyond our control. We reserve the right to modify, suspend or discontinue the Website, in whole or in part, at any time.
4. Permitted Use and User Obligations
The User must use the Website in accordance with the law, good faith and these Terms. Indicatively and without limitation, the following are prohibited:
- any unlawful, abusive or improper use;
- transmitting malicious software (malware, viruses, trojans) or carrying out attacks (DDoS, brute-force, SQL injection);
- unauthorised automated data collection (scraping, crawling, harvesting) without written permission;
- sending false, misleading, offensive or unsolicited (spam) messages through the available contact channels;
- circumventing, disabling or interfering with security measures or access restrictions;
- infringing the rights of third parties or of the Business (intellectual property, personal data, etc.).
5. Contacting Us through the Website
When contacting us through the available channels (indicatively email or phone), the User must provide accurate, truthful details and must not submit content that is unlawful, offensive or infringes third-party rights. Sending a message does not create a contractual or professional relationship unless this is expressly confirmed. Please do not send us sensitive data (e.g. health data or medical history) or other special categories of personal data, and send identity details only when the chat asks for them for a booking. For how contact data is processed, see the Privacy Policy.
5A. Bookings through the Chat
The Website does not sell tours through a shopping cart. Bookings are made in a chat, on the Website or on WhatsApp. We take bookings for tours only. Each tour is run by a local operator. Before you pay, the chat shows you the tour, the date, the price, the pick-up details where offered, and its cancellation policy; those booking terms apply to your booking. Tips and treats from other local businesses (for example restaurants or car rentals) are their own offers: you deal with them directly. Payment is made by card on a secure page of our payment provider (Stripe); we do not see or store your full card number. After payment you receive a voucher. For sea trips, the law requires us to collect certain details of every passenger for the Port Authority (Hellenic Coast Guard); we ask for them in the chat before the trip.
6. Content Disclaimer
The content of the Website is provided for general information purposes only. We endeavour to keep it accurate and up to date, without however guaranteeing its completeness, correctness, suitability or timeliness. Use of the content is at the User's sole responsibility.
7. No Professional Advice
The content of the Website does not constitute legal, financial, medical, dietary or other specialised professional advice and must not be treated as such. For any individual matter the User should consult a qualified professional. No information on the Website substitutes an individual professional assessment.
8. Intellectual and Industrial Property
8.1 Rights & Branding. All content of the Website (texts, graphics, logos, images, design, distinctive signs, code, layout) is the intellectual/industrial property of the Business or its licensors and is protected by applicable law. Reproduction, copying, modification, distribution or commercial exploitation without prior written permission is prohibited.
8.2 Infringement Notice Procedure. If you believe content on the Website infringes your rights, please send a request to info@tourtlee.com including: (a) a description of the work/right, (b) the exact location (URL) of the content at issue, (c) your contact details and (d) a good-faith statement. We will review the request and take appropriate action.
9. Third-Party Links
The Website may contain links to third-party websites. These links are provided for the User's convenience and do not imply endorsement or control on our part. We bear no responsibility for the content, policies or practices of third-party websites; access to them is at the User's sole responsibility.
10. Third-Party Services / APIs / Integrations
The Website may rely on third-party services, APIs or integrations (e.g. hosting/CDN, messaging services, analytics). Their operation is governed by the terms and policies of the respective providers. We do not guarantee the availability or uninterrupted operation of third-party services and bear no responsibility for their acts or omissions.
11. Cookies
The Website uses cookies and/or equivalent technologies. For detailed information on their type, purpose and management, see the Cookie Policy.
12. Limitation of Liability
The Website and its content are provided “as is” and “as available”, without warranties of any kind, express or implied. To the maximum extent permitted by law, we are not liable for any direct, indirect, incidental, consequential or special damage arising from the use of, or inability to use, the Website, even if we had been informed of the possibility of such damage. Nothing in these Terms excludes or limits liability that cannot be excluded or limited under mandatory law (including liability for wilful misconduct/gross negligence or consumer-protection law).
13. Indemnification
The User agrees to indemnify and hold the Business harmless from any claim, damage, loss or expense (including reasonable legal fees) arising from their breach of these Terms or unlawful use of the Website.
14. Security
We take reasonable technical and organisational measures for the security of the Website. However, no transmission of data over the internet is completely secure; we do not guarantee absolute security and the User acknowledges the inherent risks of the internet.
15. Force Majeure
We are not liable for failure to perform obligations due to events of force majeure beyond our reasonable control (indicatively: natural disasters, pandemics, strikes, network/power outages, cyber-attacks, acts of government).
16. Suspension / Revocation of Access
We reserve the right to suspend or revoke, without notice, the access of any User who violates these Terms or the law, or where this is deemed necessary for the security or protection of the Website and third parties.
17. Governing Law and Jurisdiction
These Terms are governed by Greek law and the law of the European Union. Any dispute that may arise falls under the jurisdiction of the courts of Rhodes, without prejudice to any mandatory consumer-protection provisions.
18. Severability
If any provision of these Terms is held invalid or unenforceable, the remaining provisions remain in full force.
19. No Waiver
Any failure or delay on our part to exercise any right does not constitute a waiver of that right.
20. Entire Agreement
These Terms, together with the Privacy Policy and the Cookie Policy, constitute the entire agreement between the User and the Business regarding the use of the Website.
21. Contact
For any question about these Terms you may contact us at info@tourtlee.com.
This document is a compliance baseline and not legal advice; for special categories of data (e.g. health), e-commerce/payments, concierge/travel/identity data or minors, specialised legal review is recommended.
PRIVACY POLICY
Last updated: 25 October 2026 · Version: 1.0
This Privacy Policy describes how we collect, use and protect your personal data when you visit and use the website https://www.tourtlee.com, in accordance with the General Data Protection Regulation (EU 2016/679, the “GDPR”), Greek Law 4624/2019 and Law 3471/2006.
1. Data Controller
The controller of your data is:
- Company: HALF PRICE TOURS I.K.E., Rhodes 85100, Greece, VAT EL800827484
- Brand: Tourtlee
- Contact email / exercise of rights: info@tourtlee.com
2. Data We Collect
- Contact data: details you provide when contacting us: full name, email address, phone number (if you state it) and the content of your message.
- Partner requests: the details a business gives us in the Partners form: type, name and VAT number of the business, contact person, email, phone, area and message.
- Chat and booking data: what you write to us in the chat on the Website or on WhatsApp, and the details needed for a booking: names, email and/or phone, number of travellers, date, hotel or pick-up point, and payment status (never your full card number).
- Passenger details for sea trips: the details of every passenger that the Port Authority (Hellenic Coast Guard) requires for sea trips.
- Technical data: IP address, browser/device type, operating-system details and basic security/operational data of the website.
3. Minors
The Website is not directed at persons under 15. We do not knowingly collect minors' data; if such collection comes to our attention, the data is deleted.
4. Purposes, Legal Bases, Data and Retention
We process your data only for specific, explicit and lawful purposes, on the corresponding legal basis (Article 6 GDPR):
| Purpose | Legal basis | Data | Retention |
|---|---|---|---|
| Handling & replying to your message/request | Legitimate interest (Art. 6.1.f) and/or pre-contractual steps (Art. 6.1.b) | name, email, phone, message content | 24 months from last contact |
| Booking, paying for and providing your booking (with the local business) | Performance of a contract (Art. 6.1.b) | chat and booking data | as long as needed for the booking, then as tax and accounting law requires |
| Passenger lists for sea trips | Legal obligation (Art. 6.1.c) | passenger details | as the Port Authority rules require |
| Partner requests | Pre-contractual steps (Art. 6.1.b) / legitimate interest (Art. 6.1.f) | partner request details | 24 months from last contact |
| Keeping correspondence/contact history | Legitimate interest (Art. 6.1.f) | as above | 24 months |
| Security, stability & abuse prevention | Legitimate interest (Art. 6.1.f) | technical data, IP, logs | as long as required for security |
| Visitor statistics (cookieless) | Legitimate interest (Art. 6.1.f). No consent needed for cookieless/non-identifying analytics | aggregated, anonymised | aggregated |
| Compliance with legal obligations (e.g. tax, if a transaction arises) | Legal obligation (Art. 6.1.c) | relevant records | as provided by law |
Where the legal basis is consent, you may withdraw it at any time, without affecting the lawfulness of processing before withdrawal. Providing data when contacting us is optional; without the minimum required details we may not be able to respond to your request.
5. Recipients / Processors / Third Parties
We do not sell your personal data. We may share it with carefully selected providers acting as processors on our behalf, under the relevant agreements (Article 28 GDPR):
- The local business that provides your booking (only the details needed to provide it, e.g. names, number of travellers, pick-up point).
- Chat platform provider (the chat on the Website) and WhatsApp (Meta) when you message us there.
- Payment provider (Stripe).
- Booking database hosting provider.
- Hosting, content-delivery network and attack-protection provider.
- Provider that relays and delivers contact-form messages.
- The Business's email provider (receiving and replying to messages).
- Cookieless analytics tool.
- Public authorities/bodies: where required by law.
The above are listed by category of recipient, as Article 13 GDPR permits. If you would like the specific details of the providers we use, you may request them at the contact address given in this Policy and we will respond.
6. International Transfers (Articles 44-49 GDPR)
Certain of the above providers may process data outside the European Economic Area (e.g. USA). In such cases an adequate level of protection is ensured through the provided safeguards: Standard Contractual Clauses (SCCs) and/or the EU-US Data Privacy Framework, where applicable.
7. Your Rights as a Data Subject
Under the GDPR you have the following rights:
- Right of access (Art. 15): to be informed whether we process your data and to receive a copy.
- Right to rectification (Art. 16): to request correction of inaccurate or completion of incomplete data.
- Right to erasure / “right to be forgotten” (Art. 17): to request deletion of your data, under the conditions of the law.
- Right to restriction of processing (Art. 18): to request that processing be restricted in certain cases.
- Right to data portability (Art. 20): to receive your data in a structured, commonly used, machine-readable format and transmit it to another controller.
- Right to object (Art. 21): to object to processing based on legitimate interest, and, at any time and unconditionally, to processing for direct-marketing purposes.
- Right to withdraw consent (Art. 7(3)): where processing is based on consent, to withdraw it at any time, without retroactive effect.
- Automated decision-making / profiling (Art. 22): No automated decision-making or profiling with legal or similarly significant effects is carried out.
Exercising your rights: You may exercise your rights by sending a request to info@tourtlee.com. We will reply within one (1) month of receiving the request (extendable by two months in complex cases, per Article 12 GDPR). Exercising your rights is in principle free of charge.
Right to lodge a complaint (Art. 77 GDPR): If you consider that the processing of your data violates the law, you have the right to lodge a complaint with the supervisory authority:
- Hellenic Data Protection Authority (HDPA)
- Address: 1-3 Kifissias Ave., 115 23 Athens, Greece
- Tel.: +30 210 6475600 · Email: contact@dpa.gr · Web: www.dpa.gr
8. Data Security
We apply appropriate technical and organisational measures to protect your data from unauthorised access, loss, alteration or leakage (indicatively: HTTPS/TLS transport encryption, access controls, provider security measures). No method of transmission or storage is completely secure; we are however committed to continuously improving our measures.
9. Source of the Data
Data is as a rule collected directly from you (e.g. when you contact us) or automatically while browsing (technical/statistical data). We do not obtain your data from third-party sources, except the payment status that our payment provider sends us.
10. Updates to this Policy
We may update this Policy. Each new version carries an updated date/version number and applies from its publication on the Website.
11. Contact
For any matter relating to data protection or the exercise of your rights: info@tourtlee.com.
This document is a compliance baseline and not legal advice; for special categories of data (e.g. health), e-commerce/payments, concierge/travel/identity data or minors, specialised legal review is recommended.
COOKIE POLICY
Last updated: 25 October 2026 · Version: 1.0
1. What Cookies Are
Cookies are small text files stored on your device (computer, phone, tablet) when you visit a website. They are used for basic operation, security and, where permitted, for measuring traffic or for marketing purposes. Equivalent technologies (e.g. local storage, pixels) fall under the same rules.
2. Cookies We Use
The Website follows a cookieless approach: it uses only strictly necessary elements and analytics without cookies and without identifying users.
A. Strictly Necessary / Functional These are essential for the operation and security of the Website and do not require consent. Strictly necessary elements also include preferences the user actively sets (e.g. the user's own language choice), where needed to deliver the explicitly requested service. Indicative table:
| Name / Element | Provider | Purpose | Duration |
|---|---|---|---|
| Anti-DDoS / load balancing (e.g. __cf_bm, cf_clearance) | Content-delivery & security provider | website security & stability | session up to ~30 minutes / per provider |
| Feature protection (session / CSRF token) | Website | abuse prevention | session |
| Chat greeting shown (session storage) | Website | show the chat greeting once per visit | session |
| tt_packages | Website | keep partners signed in to the partner packages page after they enter the password | 8 hours |
B. Analytics without Identification (Cookieless) We use a privacy-friendly analytics tool: no cookies, no cross-site tracking, no persistent unique identifiers. The data is aggregated and non-identifying. Under the Hellenic DPA's guidelines, this processing rests on legitimate interest and does not require prior consent.
3. Third-Party Cookies
We do not use third-party cookies for advertising or tracking (e.g. cookie-based Google Analytics, Meta/Facebook Pixel, advertising/remarketing tags). No such technology is loaded.
4. Managing Cookies
Because only strictly necessary elements and cookieless analytics are used, no consent banner is shown: this page is informational. You can always manage or delete cookies from your browser settings. Disabling strictly necessary elements may affect the operation of the Website.
5. Contact
For any question about this Policy: info@tourtlee.com.
This Website was technically built by Polarzee (www.polarzee.com), acting solely as its technical developer. All content, statements, services and data-processing practices are the full and sole responsibility of Tourtlee, as the Website's owner and data controller. Polarzee does not act as controller or processor of visitors' personal data, provides no warranty as to the accuracy or lawfulness of the content, and bears no liability for any direct or indirect damage connected with the use of the Website.