This Privacy Statement describes the privacy practices of Theofilos Chalkiadakis S.A., Stalis, 70 007, Crete, Greece and is compliant with the General Data Protection Regulation EU 2016/679 as well as with the National Data Protection legislation.
It explains what information we collect about you when you visit our site and/or when you make a reservation with us and how we handle your information to ensure that your rights are always respected, for data that we collect:
Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, together with offline channels, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Statement.
Collection of Personal Data
“Personal Data” are data that identify you as an individual or relate to an identifiable individual.
We collect Personal Data in accordance with law, such as:
In more limited circumstances, we also may collect:
If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.
How We Collect Personal Data
We collect Personal Data in a variety of ways:
Collection of Other Data
“Other Data” are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:
How We Collect Other Data
We collect Other Data in a variety of ways:
We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical data about the use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions.
If you do not want data collected with cookies, you can learn more about controlling cookies at http://www.allaboutcookies.org/manage-cookies/
You can choose whether to accept cookies by changing the settings on your browser or by managing your tracking preferences by clicking on “Cookie Settings” located at the bottom of our homepage. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs.
Use of Personal Data and Other Data
We use Personal Data and Other Data to provide you with Services, to develop new offerings and to protect the Theofilos Chalkiadakis S.A. and our guests as detailed below. In some instances, we will request that you provide Personal Data or Other Data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.
We use Personal Data and Other Data for our legitimate business interests, including the following:
We will use Personal Data and Other Data to manage our contractual relationship with you, because we have a legitimate interest to do so and/or to comply with a legal obligation.
We will use Personal Data and Other Data to provide personalized Services according to your Personal Preferences either with your consent or because we have a legitimate interest to do so.
We will use Personal Data and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.
We use Personal Data and Other Data in this way to manage our contractual relationship with you, comply with a legal obligation and/or because we have a legitimate interest to do so.
Disclosure of Personal Data and Other Data
Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Data and Other Data with the following:
Other Uses and Disclosures
We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of the Theofilos Chalkiadakis S.A., you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.
Non- Theofilos Chalkiadakis S.A. Entities
This Privacy Statement does not address, and we are not responsible for the privacy, data or other practices of any entities outside of the Theofilos Chalkiadakis S.A., including Franchisees, Owners, Authorized Licensees, Strategic Business Partners or any third party operating any site or service to which the Services link, payment service, loyalty program, or website that is the landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data.
In addition, we are not responsible for the data collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or the Apps or our Social Media Pages.
Third Party Advertisers
We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Online Services, other websites or online services. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through the use of pixel tags).
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section, below.
LINKS TO OTHER WEB SITES
In order to anticipate your needs, our website provides links to other web sites and third parties for your convenience and information. We are not responsible for the collection, use, maintenance, sharing or disclosure of data (including personal data) by such third parties. We encourage you to contact these third parties to ask questions about their privacy practices, policies and security measures before disclosing any personal data. We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.
Choices, Access and Retention
You have choices when it comes to how we use your data and we want to ensure you have the information to make the choices that are right for you.
If you no longer want to receive marketing-related emails, you may opt out by following the instructions in any such email you receive from us
We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out.
Special Notice for California Residents: Customers who reside in California and have provided their Personal Data to us can request, once per calendar year, information about our sharing of certain categories of Personal Data to third parties and within the Theofilos Chalkiadakis S.A., for their direct marketing purposes. Such requests should be submitted to us firstname.lastname@example.org or:
Theofilos Chalkiadakis S.A. (Cactus Bay), Stalis, 70 007, Crete, Greece
We will provide a list of the categories of Personal Data disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
How You Can Access, Change or Suppress Your Personal Data
If you would like to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by law), you can contact us at email@example.com or by mail:
Theofilos Chalkiadakis S.A. (Cactus Bay), Stalis, 70 007, Crete, Greece
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or other limitations you would like to put on our use of your Personal Data. For your protection, we only fulfill requests for the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation, or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase, reservation, or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.
YOUR DATA PROTECTION RIGHTS
You have the following rights in terms of your personal data:
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:
We will delete your data:
Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).
The Theofilos Chalkiadakis S.A. is a global organization and provides a global service. Sharing data cross-border is essential to the Services so that you receive the same high-quality service wherever you are in the world. As a result, we will, subject to law, transfer Personal Data and Other Data collected in connection with the Services, to entities in countries where data protection standards may differ from those in the country where you reside. By making a reservation, visiting or staying at a Theofilos Chalkiadakis S.A. branded property or using any Theofilos Chalkiadakis S.A. branded service, you understand that we transfer your Personal Data globally.
Processors in third countries are obligated to comply with the European data protection regulations and to provide appropriate safeguards in relation to the transfer of your data in accordance with GDPR Article 46.
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your Personal Data.
Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA
AUTOMATED DECISION AND PROFILING
In executing our business activities, we do not use any automated decision-making. We may from time to time process some aspects of your data automatically, in order to enter into a business relationship with you.
Updates to This Privacy Statement
The “LAST UPDATED” legend at the top of this page indicates when this Privacy Statement was last revised. Any changes will become effective when we post the revised Privacy Statement on the Online Services. Your use of the Services following these changes means that you accept the revised Privacy Statement. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, please contact us at (email)
At Theofilos Chalkiadakis S.A., we respect your privacy and want to provide you with information and choices. The options provided below allow you to express your preferences: what and how much you share with us and when and how you hear from us.
We want to learn what is relevant to you and ensure you have a personalized experience. As described earlier, we use digital tools like cookies and tags on our web pages. Cookies also help us provide, protect and improve our services.
To adjust your preferences, please visit our Cookie Settings page.
We want to engage with you in a way that is meaningful to you. We recognize that you may only want to hear from us in a limited way.
You may choose to unsubscribe from our newsletters by clicking the link at the bottom of one of our communications
*Please note that even if you choose to opt-out of communications with us, we will continue to send you transactional messages about your specific reservation or stay with us, such as pre-arrival, confirmation and guest satisfaction surveys.
Use of Personal Data
If we intend to use your Personal Data for a purpose that is materially different from these purposes or if we intend to disclose it to a third party not previously identified, we will notify you and offer you the opportunity to opt-out of such uses and/or disclosures where it involves Personal Data or opt-in where Sensitive Personal Data is involved.
Disclosures to Service Providers
We sometimes contract with other companies and individuals to perform functions or services on our behalf such as spas and restaurants within our hotels, website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. They may have access to Personal Data needed to perform their functions but are restricted from using the Personal Data for purposes other than providing services for us or to us. Theofilos Chalkiadakis S.A. requires that its Service Providers that have access to Personal Data received from the EEA and Switzerland provide the same level of protection as required by the Privacy Shield Principles. We are responsible for ensuring that our Service Providers process the Personal Data in a manner consistent with our obligations under the Principles.
We use reasonable physical, electronic, and administrative safeguards to protect your Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data and the risks involved in processing that information.
Data Integrity and Purpose Limitation
We limit the collection and use of Personal Data to the information that is relevant for the purposes of processing and will not process Personal Data in a way that is incompatible with the purposes for which the information has been collected or subsequently authorized by you. We take reasonable steps to ensure the Personal Data is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Data.
Access to Personal Data
You can ask to review, correct, or delete Personal Data that we maintain about you by sending a written request to firstname.lastname@example.org
Theofilos Chalkiadakis S.A., Stalis, 70 007, Crete, Greece
GR 70007 Stalis, Crete island – Greece
Tel: +30 28970 35001
Fax: +30 28970 35080
This Policy may be changed from time to time, consistent with the requirements of the Privacy Shield. You can determine when this Policy was last revised by referring to the "LAST UPDATED" legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site.
Data Protection Officer (DPO)
Mr. Kalantzakis Giannis