Privacy Notice

Last Updated: May 24th, 2018

At A.H. WINVEST, 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 A.H. WINVEST.

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://thegemsocietyboutiquehotelspa.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 A.H. WINVEST.

Data Controller

A.H. WINVEST 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:

The Gem Society Boutique Hotel & Spa “A.H. WINVEST”
Aristeidou 3
10559, Athens
GR

Data Processor

WebHotelier operates this booking system on behalf of A.H. WINVEST 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 A.H. WINVEST, 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 A.H. WINVEST;
  • to pass on your financial details to A.H. WINVEST 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.

PERSONAL DATA PROTECTION POLICY

Thank you for visiting the Company’s website or contacting us via e-mail.

We in the Company “Winvest Greece LTD” (hereinafter referred to as “the Company”) consider it extremely important to protect the personal data of our hotel guests and the visitors of our website. For this reason, we have taken the necessary steps to comply with all rules for the protection of personal data. We handle personal data with special care, in accordance with the Company’s Personal Data Protection Policy, as well as European Law (EU Regulation 2016/679 – GDPR) and any other applicable national legislation (L. 4624/2019 currently in force) with regards to collection, storage, processing, access and transfer of personal data.

You may on all times access the Company’s updated Privacy Statement Personal Data Protection Policy (hereinafter referred to as “Privacy Policy”) at the current web page of our website www.thegemsocietyhotel.com.

The Privacy Policy applies to personal data collected by means of communication, such as our website, e-mail and other online tools, which contain a link to this Privacy Policy. This Privacy Policy does not apply to personal data gathered from sources and by means of communication outside the Internet, except in cases where such personal information is consolidated with personal data collected online. We only collect personal data in relation to you, if you choose to provide it to us. We do not share your personal data with third parties, unless you have expressly authorized us to do so.

Please read our Privacy Policy to learn more about how we collect, use, share and protect personal information online:

CRITERIA OF LEGALITY

Personal data may be processed, if at least one of the following applies:

-the subject of the personal data (you) has given his/ her consent;
-processing is necessary for the performance of a contract between the subject (you) and the Company (us);
-processing is necessary for the Company to comply with its legal obligations;
-for the establishment, exercise or defense of legal claims or proceedings.

PERSONAL INFORMATION COLLECTED

You can visit our website without giving us any personal information, by not entering this information in any field on our website and by not using any available personalized services. We collect your personal information, only if you choose to provide it to us.

The personal information that we process includes:

-Identity information – such as name, age, gender and passport information;
-Contact information – such as your home address, postal code, e-mail address and phone number;
-Financial information – such as your credit card details;
-Health information – where disclosed and relevant to the provision of services;
-Preference information – such as special requests, service issues and other preferences for your stay.

AUTOMATICALLY COLLECTED INFORMATION

A specific type of information is automatically collected whenever you contact our website, as well as through e-mails that we exchange. The automatic technologies we use include, for example, web servers, cookies and web beacons.

IP ADDRESSES

The IP address is a number given to your computer each time you connect to the Internet. All computers have IP addresses which allow computers and servers to be identified and communicate with each other. The Company collects IP addresses to analyse its website, control its profitability and pass on collective information to affiliated companies, business partners and/ or vendors.

COOKIES

Cookies are information that is automatically placed on a predefined folder on your computer every time you enter our website. Cookies help uniquely distinguish your computer from the server. They also allow us to collect information about the server in order to help you browse the web better, and to be able to analyse the website and control its operation.

WEB BEACONS

In our website or emails, the Company may use a common internet technology called web beacons (also known as “action tag” or “clear GIF technology”). Web beacons help analyse the effectiveness of our website by measuring, for example, how many visitors the website has received or how many visitors have chosen a particular piece of the website. Web beacons, cookies and other means of identification do not automatically collect identifiable information about you.

If you would like to maintain your anonymity when browsing our web page, you can set your browser to refuse cookies or to notify you whenever they are sent to you. Only if you voluntarily submit identifiable information, such as a registration request or an e-mail, automatic means will be used to provide further information about your use of our web page and/ or interactive e-mails, with the purpose to become more useful to you.

USES OF YOUR PERSONAL DATA

For each of the categories of personal data described above, we use your personal data for the following purposes:

-To enable you to use our website;
-To help us identify you and any accounts you hold with us;
-To provide superior customer service to you;
-To assist us in making your reservation and providing the services you request;
-To process transactions through our website;
-For billing purposes in relation to your stay with us;
-To contact you in relation to matters that arise from your stay with us;
-To conduct surveys to receive your views of our service delivery (if, where required, you separately provide your consent to this);
-To analyse customer trends and insights;
-To operate our business, including for internal purposes, such as auditing, data analysis, statistical and research purposes and troubleshooting, to help us improve our services.

In some cases, we may combine personal data with other information, to generate anonymized, aggregate statistical data (e.g. number of visitors, domain name of the Internet Service Provider) that helps us improve our products and services. When this occurs, we remove all identifiers from the personal data you have provided to us and keep it in aggregate form.

PRINCIPLES APPLIED DURING PROCESSING

The Company may process your personal data, in order to provide you with personalised services. Your personal data is not used for purposes other than those described in this Privacy Policy, unless we obtain your prior permission or unless this is required or permitted by law. Personal data should be processed in a way that is compatible with the purpose for which it was collected.

The principle of proportionality applies to the processing of personal data. Among other things, it creates the obligation not to collect personal data unnecessarily.

Personal data used should be accurate and up-to-date. Personal data that is no longer accurate and complete should be corrected or deleted.

The processing of personal data should be in accordance with the principles of good faith. This means that data subjects can rely on the processors to show proper care in all data processing issues.

Individuals whose personal data has been processed should be updated accordingly if they so request. In particular, they have the right to be informed of the purposes for which their data is processed, the type of data they concern and the identity of the recipients of the data. Where necessary, data subjects are also entitled to request the correction, non-transmission or deletion of their data. The above rights may be limited only if such limitation is provided for by law. This applies, in particular, to scientific research.

Personal data is protected against unauthorised disclosure and any unauthorised processing. The measures put in place should ensure a level of security commensurate with the nature of the data to be protected and the risks that may arise from its processing. The Company is responsible for implementing and complying with EU Regulation 2016/679 and the applicable National Law.

Employees of the Company dealing with the processing of personal data should be suitably informed. Any procedures for the processing of personal data by third parties by agreement should be set out in writing. The Company will ensure that the third party is properly processing the personal data and is in compliance with the principles set forth in this Privacy Policy. In the event that the third party decides that it cannot ensure an adequate level of security of personal data, the Company will terminate the cooperation.

SECURITY

Our Company applies technical and organisational security measures and other procedures to protect your personal data against unauthorized access, alteration, misuse, disclosure, loss or destruction. In order to ensure the confidentiality of your data, our Company also uses firewalls and password protection programs in line with international market standards.

Our partners who support us in the operation of this website also comply with these provisions.

However, it is your responsibility to ensure that the appliance you use (i.e. PC, phone, tablet, etc.) is sufficiently secure and protected against malicious software such as Trojan, virus, etc. You should be aware that, without sufficient security measures (e.g. secure browser setup, up-to-date virus software, effective firewall, no software from doubtful sources, etc.), there is a risk that the data and codes you use for protected access to your data, may be disclosed to unauthorized third parties.

The Company makes every reasonable effort to keep personal data collected only for the time it takes for the purpose for which it was collected or until its removal is requested (if that occurs earlier) unless the applicable legislation gives the right to preserve them.

ACCESS TO PERSONAL DATA & RIGHTS

You retain the following rights in detail, which can be exercised by sending an e-mail to the address  from your personal email address, enclosing a copy of your identity card:

Right to be informed about your personal data: Upon your request, we will provide you with information about the personal data we hold for you.

Right to correct and complete your personal data: If you notify us in this regard, we will correct any inaccurate personal data you may have. We will fill in incomplete data upon notification by you, provided that such data is necessary for the purpose of processing.

Right to delete your personal data: Upon your request, we will delete the personal data held by our Company. However, some data will only be deleted after a specified hold period, for example because in some cases it may be legally required to retain the data, or because the data is required to fulfil our contractual obligations vis-à-vis you.

Right to bind your personal data: In some cases provided by law, we will block your data upon your request. Further processing of blocked data occurs only to a very limited extent.

Right to withdraw your consent: You may -at any time- withdraw your consent to the processing of your personal data in the future. The lawfulness of your data processing remains unaffected by this action, up to the point at which where your consent is withdrawn.

Right to object to the processing against your data: You can always object to the processing of your personal data in the future, given that we process your data in the base of one of the legal justifications provided for in Article 6 (1e or 1f) of Regulation (EU) 2016/679.

NEWSLETTERS

The Company through its website uses your e-mail address, provided that you have given your consent through specific subscription fields, to advertise its products and services.

Newsletter is sent only to users and subscribers who have chosen to receive them and is fully technically compatible with mailing regulations. The Company provides Newsletter subscribers with the option of deleting them from the recipients list. When a subscriber chooses to be deleted from the recipients list then his email is permanently deleted. Newsletter subscribers’ emails are used exclusively for this purpose and for no other purposes.

The newsletters that the users receive by subscribing to the recipients list, are intellectual property of the Company and are therefore protected by the relevant provisions of Greek law and international conventions.

PERSONAL DATA OF MINORS

Our website is intended for adult audiences. We do not collect personal data from anyone we know is under the age of 18 without prior verifiable consent from their legal representative. The legal representative has the right to request access to any information provided by the minor and can also request its removal .

OTHER TERMS

This Privacy Policy is governed by the principles of EU Regulation 2016/679 and the applicable National Law.

If any of these terms are found to violate the applicable law, they shall automatically become void, without in any way affecting the validity of the remaining terms.

The Company may conclude an agreement for the assignment of its obligations to an appropriate third party.

All notifications must be made in writing by hand or by post.

The above terms constitute the complete agreement with the Company, which reserves the right to modify, update or delete any terms herein without any notice. Modification or updates will take effect once this text is revised accordingly.

REVISION OF THE PRIVACY POLICY

The Company reserves the right to modify or periodically revise the Privacy Policy at its sole discretion. If any changes are made, the Company will record the date of change or revision in the Privacy Policy and the updated Privacy Policy will take effect from that date. We encourage you to periodically review the Privacy Policy to stay informed about any changes to the way we manage your personal data. The continued use of our website will indicate your consent to the updated policy and the use of any new features.

LINKS TO OTHER WEBSITES

Our website may contain links to a number of other web pages that may include useful information for our visitors. This Privacy Policy does not apply to these websites, and we encourage you to visit them directly to learn their privacy policy.

HOW TO CONTACT THE COMPANY

For any questions or in case you wish the Company to change or modify your profile, please contact us in writing at the following address: contact@thegemsocietyhotel.com

Should you require more information on data protection or have any relevant complaints, you may contact the Greek Data Protection Authority at 1-3, Kifisias str., P.C. 115 23, Athens, dpa.gr.

JULY 2024