Privacy Notice

Last Updated: May 24th, 2018

At ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε, we are committed to protecting and respecting your privacy. Please read this notice as it contains important information about how we use personal data that we collect from you or that you provide to us.

Information & Consent

This Privacy Notice 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 our booking system.

By reading this Privacy Notice, the user is hereby informed on how we collect, process and protect personal data furnished through the booking engine.

The User must carefully read this Privacy Notice, which has been written clearly and simply, to facilitate its understanding, and to freely and voluntarily determine whether they wish to provide their personal data, or those of third parties, to ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε.

When this notice mentions “booking system,” “booking engine,” “system,” “website,” “platform,” “app,” “webapp,” “services,” “online services,” it refers to all pages and functions under https://oramamilos.reserve-online.net/ unless specified otherwise.

By accessing the platform or providing information, you agree to our privacy practices as set out in this privacy statement. We may change this notice from time to time. You should check this notice frequently to ensure you are aware of the most recent version.

Identity

When this notice mentions “we,” “us,” or “our,”, “data controller,”, “controller,”, it refers to ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε.

Data Controller

ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε 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. We are:

Orama Milos “ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε”
Adamantas
84800, Milos
GR

The User may contact our Data Protection Officer:

Data Protection Officer
k.papadopoulos.milos@gmail.com

Data Processor

WebHotelier operates this booking system on behalf of ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε and is committed to protecting the privacy of the users of this system. WebHotelier is:

Revplus Hellas S.A.
5th Km Rhodou-Lindou Ave.
851 00, Rhodes
Greece

For the purposes of the GDPR, where WebHotelier processes your personal data on behalf of ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε, WebHotelier is the the Data Processor. When this notice mentions “data processor,” “processor,” “WebHotelier,” it refers to WebHotelier Technologies Ltd.

WebHotelier is a certified PCI-DSS Level 2 Service Provider audited quarterly by Sectigo Limited.

The User may contact WebHotelier's Data Protection Officer:

Data Protection Officer
dpo@webhotelier.net

Obligatory nature of providing the data

The data requested in the forms accessible from the booking engine are, in general, mandatory (unless specified otherwise in the required field) to meet the stated purposes. Accordingly, if they are not provided or are not provided correctly, we will be unable to process the request.

Personal data we collect and process

This will include:

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 booking when we require pre-payment;
details of transactions you carry out through our booking engine and details of the fulfilment of your orders.
our data processor may only collect and process personal data collected and/or processed on behalf of us in accordance with our instructions. WebHotelier cannot process it in any other way or for any other purpose.

We grant permission to our data processor:

to use your personal information for reserving rooms and/or other services for you at ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε;
to pass on your financial details to ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε and/or appropriate third party (for example, credit card company) for the purpose of confirming or paying for a booking;
to use your information for marketing purposes (where you explicitly agree to this); 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).

Social Login:

In the event of registration and/or access through a third-party account, we may collect and access certain information of the User’s profile from the corresponding social network, solely for internal administrative purposes and/or for the purposes indicated above.

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 Notice, 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., 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).

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.

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 through the channels provided to this end.
To manage the sending of personalised commercial communications from us, by electronic and/or conventional means, in cases in which the User expressly consents.
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.

Data Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice 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 have an account with us or keep using the Services or if you have a booking 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)

Legitimate interest for processing your data

The data processing required in fulfilment of the aforementioned purposes that require the User’s consent cannot be undertaken without said consent.

Likewise, in the event that the User withdraws their consent to any of the processing, this will not affect the legality of the processing carried out previously.

To revoke such consent, the User may contact us through the appropriate channels.

By the same token, in those cases in which it is necessary to process the User’s data for the fulfilment of a legal obligation or for the execution of the existing contractual relationship between us and the User, the processing would be legitimized as it is necessary for compliance with said purposes.

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.

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.

International transfers of personal data

We may transfer your personal information to our data processor(s) or/and sub-processor(s) based outside of the EEA for the purposes described in this notice. If we do this, your personal information will continue to be subject to one or more appropriate safeguards set out in the law. These might be the use of model contracts in a form approved by regulators, or having our suppliers sign up to an independent privacy scheme approved by regulators (like the US ‘ Privacy Shield’ scheme).

Our data is stored in the cloud using Amazon Web Services in N. Virginia, USA and in Frankfurt, Germany. If you are accessing any of our systems from outside the USA, you acknowledge that your personal information may be transferred to the USA, a jurisdiction which may have different privacy and data security protections from those of your own jurisdiction, to be processed and stored.

User's Responsibility

The User:

Guarantees that they are of legal age or legally emancipated, where applicable, fully capable, and that the information furnished to us is true, accurate, complete and up-to-date. For these purposes, the User is responsible for the truthfulness of all the data communicated and will keep the information updated, so that said data reflects their actual situation.

Guarantees that he/she has informed third parties on whose behalf he/she has provided data, where applicable, of the aspects contained in this document. Also guarantees that he/she has obtained the third party’s authorisation to provide their data to us for the purposes indicated.

Will be responsible for false or inaccurate information provided through the Website and for damages, whether direct or indirect, that this may cause to us or third parties.

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 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.

ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε. (hereinafter "we", "us", "our"), operates the website www.oramamilos.gr (hereinafter the "Website"), recognizes the importance of the privacy of all its visitors and users and is committed to protect your personal data in compliance with applicable data protection and privacy laws, including the General Data Protection Regulation 2016/679 (hereinafter the "GDPR").

To this end, the present Privacy Policy is intended to inform you about our privacy practices and in particular the ways we, in our capacity as Data Controller of your personal data, handle information collected about you when visiting our Website.

1. Contact Information

Data Controller according to the GDPR is ΠΑΠΑΔΟΠΟΥΛΟΣ Κ. ΑΓΓΕΛΗ Α. Ο.Ε..

Address: ΑΔΑΜΑΝΤΑΣ, ΜΗΛΟΣ, 84800, ΜΗΛΟΣ, GR

TRN: 802482909

GCN: 177199138000

Telephone Number: +30 2287021008

Data Protection Officer: Antonios Papadopoulos

Email: oramamilos@gmail.com

If you have any questions, comments or concerns about our privacy practices and/or would like to submit a privacy request, please contact us at the abovementioned contact details.

2. Contact Information

When you access and navigate through our Website and make use of specific sections of the Website, certain personal data are being collected and processed for the purposes mentioned below and always upon application of an appropriate legal ground. In particular:

Contact details (name, surname, ID or passport number, email address, phone number and home address), credit card details (card type, credit card number, card name, expiration date and security code) and visitor details (arrival and departure dates, any special requests, comments on service preferences) in order to complete and manage your online booking, on the basis of Article 6 para. 1 (b) GDPR;

Data automatically collected (such as such as language settings, IP address, location, device settings, device operating system, activity details, time of use, redirect URL, status report, user information, the browser), for purposes of operation of our Website as well as statistical and advertising purposes, on the basis of Article 6 1 (a) GDPR and Article 6 par. 1 (f) GDPR, as further described in our Cookies Policy.

3. Recipients of your Personal Data

We do not allow personal information collected about you to be sold, traded, disclosed to or viewed by any third party. Your personal data is mainly processed exclusively by us and our authorized personnel.

We may, however, disclose your personal data in limited circumstances to certain categories of recipients, always ensuring that they provide the appropriate level of security and confidentiality of your personal data in compliance with applicable data protection laws. In particular, depending on the case, we may disclose your personal data to:

Services providers, who may perform services on our behalf relating to the Website’s operation and functionalities, such as IT and booking services providers, only to the extent necessary for the execution of the required services;

Law enforcement authorities, government officials, regulatory agencies or other parties, when we are required to do so by applicable law, regulations or legal process in connection, for instance, with an investigation conducted by judicial authorities regarding suspected and/or actual illegal activity or with a court order served on us, or when such disclosure is necessary upon our legitimate interests.

4. Location of your Personal Data

The storage and processing of your personal data is taking place only within the EU/EEA, where an adequate level of personal data protection is ensured.

If we are required to transfer your personal data to a third country, we will promptly inform you thereof and implement appropriate safeguards in accordance with applicable data protection laws, in order to conduct such data transfer and ensure that your personal information remains protected and secure.

5. Retention Period of your Personal Data

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, as outlined in this Privacy Policy, and in any case as required or permitted under applicable law and the corresponding statute of limitation.

The criteria used to determine the retention period of your personal data include inter alia: (i) the time period we have an ongoing relationship with you; (ii) whether there is a legal retention obligation to which we are subject, such as legal, tax or accounting requirements; or (iii) whether retention is advisable in light of our legitimate interest to have an accurate record of your dealings with us in the event of any complaint or challenge, litigation or regulatory investigation.

6. Your Rights

You have the following rights in connection with the processing of your personal data, provided that the respective legal requirements are met:

Right of access: you can receive confirmation as to whether or not personal data of yours are processed and request access to, as well as a copy of the processed data.

Right to rectification: you can request the correction of inaccurate personal data or the completion of incomplete personal data.

Right to erasure of your personal data, where one of the grounds set out under Art. 17 of the GDPR applies.

Right to restriction of processing, where one of the grounds set out under Art. 18 of the GDPR applies.

Right to object to the processing of your personal data, when we rely on our own or someone else’s legitimate interest, including to the processing for direct marketing purposes.

Right to data portability: you can request to receive your personal data in a structured, commonly used and machine-readable format and to transmit them to another controller, provided that the conditions of Art. 20 of the GDPR are met.

Right to withdraw your consent: in cases where processing is based on your provided consent, you can withdraw your consent at any time, without however affecting the lawfulness of processing based on consent before its withdrawal.

The aforementioned rights may be exercised at any time by submitting your request in writing at the following e-mail address: oramamilos@gmail.com. We will respond to your request as soon as possible, taking into account the nature and type of the request.

Finally, if we fail to take action on your requests, you have the right to lodge a complaint with the competent data protection authority. For users resident in Greece the competent authority is the Hellenic Data Protection Authority (HDPA), located in Athens (1-3 Kifissias Avenue, PC 11523), www.dpa.gr.

7. Links to Other Websites

Our Website may provide links to other websites owned or operated by third parties. Please be aware that we do not control other websites, nor have any liability for their content, security safeguards or privacy practices and that, in any case, the present Privacy Policy does not apply to these websites. Therefore, we strongly encourage you to get informed on the privacy policy of any linked website you visit.

8. Updates to our Privacy Policy

We may from time to time amend and update the present Privacy Policy. Although material amendments will be posted on the website, we encourage you to consult this Privacy Policy regularly, so that you are aware of its latest version and any updates.