What is my personal data and what do you mean by process?
When we refer to personal data, we mean any information which relates to an identified or identifiable individual. Where we refer to process or processing, we mean anything which we may do with your personal data including collecting, storing, using, disclosing to third parties and erasing it.
What personal information do we collect from the people that visit our blog, website or app?
When registering on our site, as appropriate, you may be asked to enter your name, email address, Company Name, Industry or other details to help you with your experience. We collect personal data from and about you whenever you use our services, or if you are in touch with us in any way, whether this is directly or indirectly. We also collect data from publicly available sources (such as the Land Registry) which we use to profile clients internally for marketing purposes.
Examples of personal data which we might collect include (but are not limited to):
- names of all persons travelling
- contact details (such as telephone number, postal and e-mail addresses) of the person making the booking
- information in respect of any medical condition, disability or reduced mobility which may affect any person travelling – this comes within special categories of personal data (see below)
- your group composition; the ages of people in your group, their dates of birth, gender, nationality and passport information
- dietary information
- notes about our interactions with you
- copies of documents such as passport or driver’s licence
- your feedback on our service, including from third parties
- CCTV footage used to keep our villas secure.
- for an enquiry, the personal data we will need to process is likely to include the name and contact details of the person making the enquiry
For a booking or booking enquiry, we will process your personal data (other than any data which comes within special categories of personal data – see below) on the basis that this is necessary for the performance of your contract with us or to enable us to take steps at your request prior to your entering into a contract with us. We may also need to do so to comply with a legal obligation to which we are subject or in order to protect your vital interests (for example, in an emergency situation).
If you wish to receive brochures or other promotional material from us, we will need your name and the contact details applicable to the form of communication you have consented to. For example, if you wish to receive information by e-mail, we will need your e-mail address.
When do we collect information?
We collect information from you when you register on our site, subscribe to a newsletter, respond to a survey, fill out a form, Use Live Chat or enter information on our site. Provide us with feedback on our products or services.
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested
- To improve our website in order to better serve you
- To allow us to better service you in responding to your customer service requests
- To administer a contest, promotion, survey or other site feature
- To ask for ratings and reviews of services or products
- To follow up with them after correspondence (live chat, email or phone inquiries)
What are special categories of personal data?
Personal data which concerns your health or which reveals your racial or ethnic origin or your sexual orientation are special categories of personal data. Other information also comes within special categories but this is unlikely to be relevant to the booking and provision of travel arrangements.
Generally speaking, the processing of special categories of personal data requires your explicit consent.
Accordingly, information concerning any disability, medical condition, restricted mobility or other health related issue which may affect your travel arrangements (and related requirements) as well as dietary restrictions which disclose your religious beliefs or a health issue are special categories of personal data. We will ask for your consent to our processing this information at the time you make your booking or your booking enquiry.
Who may we provide your personal data to?
Where you make a booking, appropriate personal data will be passed on to the relevant suppliers of your chosen arrangements (such as villa owners, caretakers, experience providers, cooks, car hire companies, restaurants and lidos) together with any other third party (such as banks and/or credit card companies) who need this information so that we can arrange for your holiday to be provided. The information may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law. Certain information may also be passed on to security or credit checking companies.
We may also make personal data available to other companies who provide services on our behalf, such as mailing brochures and marketing material.
We only provide third parties with the personal data they require in order to deliver their services. Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services.
Where will we process your personal data?
Your personal data may be processed within Greece and/or any other country(ies) of the European Economic Area (EEA).
We may also process personal data outside the EEA. Data protection laws may not be as strong outside the EEA as they are in the EEA. Personal data will not be transferred to a country outside the EEA unless (1) the country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection or (2) the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (3) we are obliged to provide the personal data to a government / public authority in order to provide your holiday.
How do we protect your personal data?
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.
Can we use your personal data to send you information about our holidays or other services in the future?
We will only retain and use your personal data for marketing purposes where you have specifically consented to our doing so or, in relation to e-mail marketing, where we comply with the Privacy and Electronic Communications Regulations 2003 (PECR). PECR permits us to send you e-mail marketing where you have previously provided us with your e-mail address in the course of entering into a contract with us for tour arrangements or negotiations for such arrangements and we wish to e-mail you marketing material about our similar services or products. You will of course be given the opportunity to opt out of receiving such e-mail marketing communications when you first provide us with your e-mail address and whenever we send you any e-mail marketing.
You may provide your consent by opting to receive marketing material either on-line or by telephone. You may also choose in what ways you are happy to receive communications from us. You may, for example, be happy to receive information and offers by post and e-mail but not by telephone.
Can you withdraw your consent to our processing your personal data?
Yes, you can withdraw your consent to receiving marketing material or other communications from us, either generally or in any particular way, at any time by e-mailing us at firstname.lastname@example.org or telephone us.
How can you find out what information we are holding about you?
You are entitled to ask us (by letter or e-mail) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information. We promise to respond to your request without delay and in any event within 1 month unless the request is complex or you have made numerous requests in which case we may be able to extend our response time by a further 2 months.
What should you do if the personal data we are holding is inaccurate, out of date or incomplete?
If you believe this is the case, please tell us by e-mail as soon as possible. We will rectify the problem within 1 month or within 3 months if the rectification request is complex.
How long can we retain and process your personal data?
We will not process your personal data in a form which enables you to be personally identified for any longer than is necessary in order to fulfil the purpose for which it was originally collected or for any other legitimate business purpose.
Where your personal data has been provided for the purpose of the holiday arrangements or other services you have contracted, we are entitled to retain this data for a period of at 6 years after those arrangements have been completed. In certain limited circumstances, we may be able to retain it for a longer period.
If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective.
Can you ask us to delete your personal data?
Yes, you can ask us to erase your personal data in certain circumstances, for example where you have withdrawn your consent to further marketing material where the data in question has only been processed for this purpose. However, this is not always the case. Please see the previous paragraph for further information on the period of time we may retain personal data.
Do we use ‘cookies’?
- Understand and save user’s preferences for future visits.
- Keep track of advertisements.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
- Enable and support our security features, and to help us detect malicious activity and violations of our User Agreement.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies. If you disable cookies off, some features will be disabled It won’t affect the user’s experience that make your site experience more efficient and some of our services will not function properly.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users.
We use Google AdSense Advertising on our website
We have implemented the following:
- Remarketing with Google AdSense
- Google Display Network Impression Reporting
- Demographics and Interests Reporting
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
What should I do if I have a complaint about the processing of my personal data?
If you have any complaint about the way in which your personal data has been dealt with, please let us know by e-mail to email@example.com. We will investigate and respond to you as soon as we reasonably can.
Does our site allow third-party behavioral tracking?
It’s also important to note that we allow third-party behavioral tracking.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under 13.
27 Pergamou Street,
Glyfada, Attica 16675, Greece