Privacy Policy - SyraSuites

Privacy Policy

Last Updated: September 10th, 2018

At Syra Suites Syros, we are committed to protecting and respecting your privacy. Please read this policy as it contains important information about how we use personal data that we collect from you or that you provide to us.

Information

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information about you (hereinafter, the “User”), in conjunction with your access to and use of www.syrasuites.gr (hereinafter “Website” or “Syra Suites Syros“) and our booking system.

You must carefully read this Privacy Policy, which has been written clearly and simply, to facilitate its understanding, and to freely and voluntarily determine whether you wish to provide their personal data, or those of third parties, to Syra Suites Syros.

When this policy mentions “booking system,” “booking engine,” “website,” “services,” it refers to all pages and functions under the website of Syra Suites Syros: https://syrasuites.reserve-online.net/ unless specified otherwise.

By accessing the booking form of the Website or providing information, either through our contact form or in the process of making a reservation, you agree to our privacy practices as set out in this privacy statement. We may change this policy from time to time. If these changes affect your data, you will be informed accordingly and the new privacy policy will be published to the Website.

Identity

When this policy mentions “we”, “us”, or “our”, “data controller”, it refers to “Ergozed Development SA”, which is the owner, operator and administrator of Syra Suites Syros, a company with registered offices at Solonos 54 str., Athens, Greece (hereinafter also referred as “Company”).

Data Controller

The Company operates this booking system through a data processor, as explained below. For the purposes of the General Data Protection Regulation (“GDPR”) (EU) 2016/679, we are the Data Controller. There is a strict contractual framework between the data controller and the data processor for the protection of your personal information and our processor is not permitted to process your data in any other way or for any other purpose. We are:

ERGOZED DEVELOPMENT SA,

Solonos 54 str.,

Athens, 10672

Greece

Data Processors

Your data may be provided to our partners and 3d parties who provide us with certain services (“data processors” or “processors“). Our processors are third party companies, which provide us with IT services (webhosting, email services, digital marketing services) and booking systems. We ensure you that we have explicitly asked for the maximum safeness and confidentiality for your data from our partners and third parties and that our data processors may only collect and process your personal data in accordance with our instructions. Further transfer from them to others is strictly prohibited.

 

Obligatory nature of providing the data

The data requested from the booking engine of the Website are, in general, mandatory (unless specified otherwise in the required field) to complete a booking. Accordingly, if they are not provided or are not provided correctly, we will be unable to process the booking. When you contact us via the Contact Form of the Website we also process any data provided by you, e.g. your email address and your message. If you do not to provide us with these data, you will not be able to send the Contact Form to us.

 

Personal data we collect and process

This will include:

• Personal information about you when you complete our contact form (your name, telephone, e-mail and your message);
• personal information about you which we ask you for (e.g. your name, address, and email address) when you make a booking from our booking engine;
• financial details in order to process your reservation when we require pre-payment;
• details of transactions you carry out through our booking engine and details of the fulfilment of your orders.

We grant permission to our data processors:

• to use your personal information for reserving rooms and/or other services for you at Syra Suites Syros;
• to pass on your financial details to the Company and/or appropriate third party (for example, credit card company) for the purpose of confirming or paying for a reservation;
• to use your information for marketing purposes (if you have booked for our services); and
• to pre-complete forms and other details on our Website to make your next visit to our booking engine easier (e.g. when amending or cancelling a booking).

Third-party data (e.g. book for a friend)

In the event that the User provides third-party data, they declare that they have the third party’s consent and undertake to provide the interested party -the data holder- with the information contained in this Privacy Policy, duly exonerating us and our data processor from any liability in this regard. However, we may carry out the necessary verifications to verify this fact, adopting the corresponding due diligence measures, in accordance with the data protection regulations.

Sensitive 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., 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).

Use of Services by Minors

The Services are not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Data through the Services. In case we find out that a User is a minor, we reserve the right to delete all related Personal Data and to not provide our Services to such User.

Purpose of processing personal data

Depending on the User’s requests, the personal data collected will be processed in accordance with the following purposes:

• To manage the bookings made, including payment management (where applicable) and the management of the user’s requests and preferences.
• To manage registration in loyalty or membership programs, as well as obtaining and redeeming points.
• To manage the User’s contact requests with us.
• To manage the sending of personalised commercial communications from us, by electronic and/or conventional means, in cases in which the User expressly consents or has booked for our services.
• To manage the provision of the contracted accommodation service, as well as additional services.
• To manage surveys and/or evaluations regarding the quality of the services provided by us and/or the perception of its image as a company.

Legal basis for the processing of your Personal Data is the performance of your contract with us, compliance with the our legal obligations and our legitimate interest to promote our services to our clients. In case you complete our contact form, your personal data will be processed only for the purpose of your communication with us and legal basis for this processing is your consent, which you provide by accepting this Privacy Policy.

Data Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law or if the User requests their withdrawal from us, opposes or revokes their consent.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you keep using the Services or if you have a booking or any request through our contact form, that has not yet been fulfilled)
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

Withdrawal of consent

When you communicate with us via the contact form of Syra Suites Syros, the fulfilment of the requested communication cannot be undertaken without your consent to the present Privacy Policy.

Likewise, in the event that you withdraw your consent, this will not affect the legality of the processing carried out previously.

To revoke such consent, the User may contact us at info@syrasuites.gr  or using our contact form.

Data Disclosure

We will use and disclose Personal Data as we believe to be necessary or appropriate:

• to comply with applicable law, including laws outside your country of residence;
• to comply with legal process;
• 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;
• to enforce our terms and conditions;
• to protect our operations;
• to protect the rights, privacy, safety or property of our own, you or others; and
• to allow us to pursue available remedies or limit the damages that we may sustain.

In any case, we disclose Personal Data only to our partners and suppliers, who need to have access to such data in order to provide us with their services and who are bound by appropriate confidentiality clauses.

International transfers of personal data

We do not transfer Personal Data to any country outside the European Union.

Cookies

Cookies are little text files which are sent to your browser and are saved on the hard drive of your device when you visit our Website. Cookies do not contain in any case personal information or information that could allow anyone to contact the Website visitor per e-mail, telephone etc. Using cookies makes it easier for the Website to memorize information about your visit by collecting useful information about your search preferences. In this way your experience will be improved the next time you visit our Website. Moreover, cookies help the Company to check the Website’s performance and traffic and to improve its content and presentation, according to visitors’ preferences. Some or all of the cookies described below may be stored on your browser. You can view and manage cookies in your browser (athough some mobile browsers may not offer this option).

Of the different types of cookies, the Website uses the following:

1. a) Absolutely necessary:

The technically necessary cookies are essential for the proper operation of the Website, allow you to browse and use its functions. These cookies do not recognize your individual identity. Without these cookies, we cannot provide our Website with effective functionality.

1. b) Performance Cookies (Google Analytics):

We use google cookies  in order to categorize our visitors and to collect statistical information on the Website’s traffic. These cookies collect information about how you use the site, for example, which pages you visit most often. These cookies collect aggregate, anonymous information that does not identify a visitor. They are used exclusively to improve the performance of a Website. For more information on Universal Analytics and cookies please visit https://support.google.com/analytics/answer/2838718?hl=en

1. c) Preference Cookies

We use Google Cookies to store your preferences about the use of Google Maps, such as zoom preferences, language, font size etc. Loss of the information stored in a preference cookie may make the Website experience less functional but should not prevent it from working.

1. d) Security Cookies

We use security cookies to authenticate users and to avoid CSRF attacks. For more information on CSRF attacks please visit https://www.owasp.org/index.php/Cross-Site_Request_Forgery_(CSRF)

Disable Cookies

You can enable, disable, or even completely delete cookies through the setup options in your browser. If you choose to disable cookies, some parts of the Website may not work properly. You can also prevent Google from collecting and using data from Google's cookies either by setting up your browser or by installing the program available at https://tools.google.com/dlpage/gaoptout?hl=el. In case you disable cookies, some parts of the Website may not work properly or not at all.

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Exercise of Rights

The User may contact us at any time free of charge, to:

• To obtain confirmation about whether or not personal data concerning the User are being processed by us.
• To access their personal details.
• To rectify any inaccurate or incomplete data.
• To request the deletion of their personal data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
• To confirm revocation of consent.
• To obtain from us the limitation of data processing when any of the conditions provided in the data protection regulations are met.
• To request the portability of your data.

Likewise, the user is informed that at any time he/she may file a complaint regarding the protection of their personal data before the competent Greek Data Protection Authority.

Security Measures

We will process the User’s data at all times in an absolute confidential way and maintaining the mandatory duty to secrecy with regard to said data, in accordance with the provisions set out in applicable regulations, and to this end adopting the measures of a technical and organisational nature required to guarantee the security of their data and prevent them from being altered, lost, processed or accessed illegally, depending on the state of the technology, the nature of the stored data and the risks to which they are exposed.

 

In case you need any clarification about the processing of your Personal Data by the Company, please do not hesitate to contact us at info@syrasuites.gr.