Privacy Policy and Information Notice on Processing of Personal Data

LAST UPDATED May 2018

Grecian Hotel Enterprises Ltd, together with our holding company(ies), affiliates, and the hotels, or other properties we own, operate or manage (“Properties”) (together, “Grecian Hotels”, “Grecian Group”, “Grecian”, “we” or “our”), respect the privacy of every individual who visits our Properties and/or uses any of our websites.

This Privacy Policy applies to information that (i) you provide to us when you stay with us (or make enquiries to stay with us); and (ii) we collect from you when you visit any of Grecian Hotel’s websites. The following sections of this Privacy Policy describe the types of information we collect, how and for what purposes we use that information, with whom we share it, and the choices and rights available to you regarding our use of your information. We also describe the measures we take to protect the security of the information we hold and how to contact us about our privacy practices, and to exercise your rights.

  1. Information we collect
  2. Use of information
  3. Sharing Information
  4. Your rights
  5. Data Transfers
  6. How we protect your information
  7. How long we keep information for
  8. Links to other websites
  9. Cookies
  10. Updates to privacy Policy
  11. How to contact us

 

 

1. Information we collect 
Information you provide on a voluntary basis

We will collect, store and process information about you if you voluntarily provide us with such information in connection with the following:

  • filling in a form on any of our websites;
  • filling in a physical registration card;
  • contacting us by telephone or face to face (e.g., in the context of making a reservation);
  • sending us a letter, e-mail or social media message;
  • subscribing to receive a service from us (e.g., a newsletter, blog or by following us on social media);
  • requesting promotional information from us (e.g., information about any of our good or services including gift cards);
  • participating in a survey, competition or prize draw; or
  • contributing content to us (e.g., for display on a Grecian blog).

The types of information we may obtain include:

  • your name, gender, home and work contact details, business title, e-mail address, telephone number, date and place of birth, nationality;
  • details of food allergies/dietary requirements and special requests made (for example, relating to a disability) you provide to us;
  • passport and visa information, payment information, travel history and details of joint travellers;
  • dates of your stay and associated charges;
  • purchase or delivery of products or services;
  • reviews and opinions about our brands, products and services;
  • information we receive about you from any third parties through whom you have booked your arrangements; or
  • information we receive about you from other members of the Grecian Group (which may include information relating to travel dates, food allergies, special requests and room preferences, and details of payments made to us).

We do not collect “sensitive information” (e.g., information on racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) unless it is volunteered by you.

We may use medical or other sensitive data provided by you to better serve and meet your needs (but under no circumstances will we process any sensitive data for marketing and/or profiling purposes). Such sensitive information is only shared with other members of the Grecian Group or our third party service providers (acting as data processors) for the purpose of providing the services you request. By making such special requests or notifying us of such preferences, you agree to us sharing your information in this way.

Personal information we collect automatically

When you visit a Grecian website, we may also collect certain information through the use of “cookies” and other automated means. Cookies are small pieces of information that are stored by your browser on your computer's hard drive. Such information may comprise the following information:

  • Date and time;
  • Originating IP address;
  • Domain name;
  • Type of browser and operating system used (if provided by the browser);
  • URL of the referring page (if provided by the browser);
  • Object requested;
  • Completion status of the request;
  • Geographic location; or
  • Language preferences.

2. Use of information 
Typically, we will use and process your information to:

  • help us create content that is relevant to our visitors;
  • make improvements to our websites and social media pages and ensure that content on these is presented in the most effective manner for you;
  • provide you with information, products or services that you request from us or which we feel may interest you;
  • assess and help us understand general trends and patterns relating to our business;
  • provide for the safety and security of our guests and visitors;
  • manage general record keeping;
  • enable us to compile anonymous, aggregated statistics that allow us to understand how users use our websites and to help us improve the structure of our websites;
  • enable you to make reservations, buy Grecian gift cards and payments;
  • meet any legal and/or regulatory requirements;
  • provide the products or services you request from us; and
  • improve our products and services and to ensure our products and services are of interest to you.

The processing of your personal information for:

  • marketing and profiling purposes is managed solely by Grecian Hotel Enterprises Limited as data controller. Your decision to provide your information for such purposes is optional and will have no consequence on your ability to stay with us or benefit from the requested services;
  • all purposes concerning your booking, your stay and to provide you with the services you have requested, is managed by Grecian Hotels International Limited and the Grecian property(ies) you visit as joint controllers. Your decision to provide information to us is voluntary however, if you do not provide such information you may no longer be able to benefit from our services.

We may process your personal information by both automated and manual means. We may use your information in other ways for which we provide specific notice at the time of collection.

3. Sharing information

We do not sell, otherwise disclose, or share information we collect and hold about you, except as described in this Privacy Policy.

We may share your information within the Grecian Group, which may use this information to offer products and services to you consistent with the purposes identified in this Privacy Policy. We may also share information with service providers who perform functions and services on our behalf. Such third parties will be appointed as data processors and will be provided only with information necessary to perform the services on our behalf but are not authorised to use such information for any other purposes.

We may disclose information about you if we are required to do so by law or pursuant to legal process, or in response to a request from law enforcement authorities or other government officials.

We reserve the right to transfer information about you in the event that we sell or transfer all or a portion of our business or assets, in accordance with applicable law. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use information you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your information with any inquiries concerning the processing of that information.

4. Your rights

You have certain rights to the information we process about you as expressly provided for by applicable law. You may request access to the information we hold about you, update, amend or correct the information, and in some circumstances you may object to our use of your information.

You also have the right to request that we cease sending marketing communications, whether by email or otherwise, to you. You can do this by (i) checking the applicable box(es) on any form used to collect information from individuals, or (ii) clicking the unsubscribe link displayed in any of the marketing e-mails you receive, or (iii) otherwise requesting that we do not process your information for marketing purposes.

California's "Shine the Light Act", California residents are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use

To exercise these rights or to make a complaint or submit an inquiry about our privacy practices, please contact us at social@grecianhotels.com. You can also write to us at:

General Manager 
Grecian Hotel Enterprises Limited 
Kryou Nerou 32
5340 Ayia Napa 
CYPRUS

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. Please note that if you opt out as described above, we will not be able to remove your information from the databases of third parties with whom we have already shared your information, with your consent. You should contact such third parties to opt out directly.

 

5. Data transfers

We may transfer to and store the information we collect about you in countries other than the country in which the information was originally collected, including the United States, Canada or other destinations outside the European Economic Area (“EEA”). Those countries may not have the same data protection laws as the country in which you provided the information. When we transfer your information to other countries, we will protect the information as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of information to countries outside the EEA.

By submitting your information to us, you agree to this transfer, storing and processing.

6. How we protect your information

We maintain administrative, technical and physical safeguards designed to protect the information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Services providers and contractors who might have access to your information in order to provide services on our behalf will be contractually obliged to keep such information in confidence, provide adequate data security measures, and may not use that data for any other purpose.

For your own protection, we encourage you not to include sensitive personal information, credit card or similar data in any e-mails you send us or our staff.

 

7. How long we keep information for

Grecian only retains your information for as long as needed to fulfil the purposes for which it is collected, unless otherwise provided by law.

8. Links to other websites

Our websites may provide links to other websites for your convenience and information. These websites operate independently from us. Linked websites may have their own privacy policies, which we strongly suggest you review. To the extent that any linked websites you visit are not owned or controlled by us, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.

9. Cookies

A “cookie” is an element of data that a website can send to your browser which may then be stored on your system. We use cookies to gather information about the visitors to our websites (as they enable us to improve our websites and deliver a better and more personalised service). We do not associate the information in a website visitor’s cookie with any other information about that visitor.

We do not control the use of such third party technology and we are not responsible for any actions or policies of such third parties. When you access our websites you will receive a clear notice advising you that the website you are visiting intends to use cookies and that:

i. by continuing to use the website you consent to their use; or 
ii. you must click an “I accept” box in order for cookies to be placed.

Unless you have adjusted your browser setting so that it will refuse cookies from our websites, our system will issue cookies. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking "help" on your browser's menu or by visiting www.allaboutcookies.org. Please note, however, that without cookies you may not be able to take full advantage of all our websites features.

10. Updates to our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our processing of your information and privacy practices. We will post a prominent notice on each of Grecian’s websites to notify you of any significant changes to our Privacy Policy and indicate at the top of the Privacy Policy when it was most recently updated.

 

11. How to contact us

If you have any questions or comments about this Privacy Policy, the use of cookies, if you would like us to update information we have about you or your preferences, or to exercise your rights of access, rectification, blocking, or deletion, or to object to the processing of your information, please contact us by email at social@grecianhotels.com  or write to us at:

General Manager 
Grecian Hotel Enterprises Limited 
Kryou Nerou 32
5340 Ayia Napa 
CYPRUS