With this Privacy Notice (effective as of April 2024), HOMILY wishes to inform its guests about the processing of their personal data during their stay. HOMILY, acting as a Data Controller, has taken the required technical and organizational measures in order to be fully compliant with the General Data Protection Regulation 2016/679 (GDPR), Law 4624/2019, the Decisions, Instructions and Opinions of the Hellenic Data Protection Authority and in general the national/EU legislation and jurisprudence regarding data protection, in order to guarantee the security, integrity and confidentiality of your personal data.
1. What personal data we collect, for which purposes and which are the legal bases
1 Name, surname, email, phone number, address, number of guests, date and number of reservations, booking path (e.g. website, by phone, travel agent, via a booking platform, etc.) date of arrival and departure, type or residence, cost per night, payment details, comments –> Purpose: Management of room reservations (Legal Basis: GDPR article 6 para.1΄b & GDPR article 6 para.1΄c)
2 First name, last name, phone number, email, address, zip code, city, country, passport/ID number, number of guests, date of reservation, reservation method, arrival and departure date, type of residence, cost per night–> Purpose: Provision of accommodation services ( GDPR article 6 para.1΄b & GDPR article 6 para.1΄c )
3 Name, surname, date, content of request/complaint, phone number, email –> Purpose: Management of requests/complaints ( GDPR article 6 para.1΄b , GDPR article 6 para.1΄c & GDPR article 6 para.1΄f )
4 Reservation and accommodation data such as first and last name, duration of stay, type of residence, number of guests, additional charges, discounts, payable costs, payment method data in issued receipt/invoice,–> Purpose: Invoicing (GDPR article 6 para.1΄b, GDPR article 6 para.1΄c & GDPR article 6 para.1΄f )
5 Image data collected through the closed-circuit surveillance system, data included in security (e.g. theft) or accident reports such as name and surname, duration and room of stay, description of event/ accident etc. –> Purpose: Safety of people and goods ( GDPR article 6 para.1΄c & GDPR article 6 para.1΄f)
6 Email –> Purpose: Sending Newsletter emails ( GDPR article 6 para.1΄a)
7 Name, surname, email address, telephone, personal data included in a message –> Purpose: Communication with the website users ( GDPR article 6 para.1΄b)
2. How long your personal data is retained for
Personal data shall be retained for as long as necessary for data collection purposes, unless otherwise specified by law. It is HOMILY’s responsibility, once the retention period expires, to ensure that your data will be safely deleted or destroyed in accordance to explicitly described standards and specifications.
3. To whom your personal data are disclosed and/or transferred
HOMILY may disclose your personal data to its authorized employees and/or transfer data collected through this website to:
a) External Partners entrusted with the provision of services or the execution of specific tasks such as, but not limited to, credit card issuers, financial institutions, external auditors, lawyers, external contractors, product suppliers, IT service providers, support service providers of all kinds of computer-based information systems or electronic systems and networks. Those entities offer adequate assurance for the implementation of necessary technical and organizational measures, so that data processing is conducted in accordance to GDPR and other relevant legislation for data protection.
b) Supervisory, independent, judicial, prosecuting, public and/or other authorities, bodies or parties assigned to control/monitor our activities within the scope of their responsibilities.
4. Cross-Border Data Transfers
The Personal Data and other information collected from you will probably not be transferred to or stored at any destination outside the European Economic Area (“EEA”). In case such a need arises, in order to comply with applicable data protection law, HOMILY will implement international data transfer agreements based on EU Standard Contractual Clauses in order to
provide appropriate and suitable safeguards for Personal Data transferred to countries outside the EEA where an adequate level of protection is not already guaranteed.
5. Rights of the data subject
The General Data Protection Regulation provides you with rights that HOMILY is committed to satisfy. Thus, your rights are:
• the right to access; You have the right to receive a copy of the personal data HOMILY holds on you as well as information about how it is used.
• the right to rectification; You have the right to ask to correct personal data HOMILY holds on you where it is incorrect, inaccurate or incomplete.
• the right to erasure; This right entitles you to require the erasure of your personal data from HOMILY’s systems and records. However, this right applies only in certain circumstances (e.g. where HOMILY no longer needs the personal data for the purpose for which it was collected or where you withdraw consent to the use of your personal data and where there is no other legal basis for continuing to use it).
• the right to restrict processing; This right entitles you to restrict the processing of your personal data by HOMILY. Where this right is exercised, HOMILY is still permitted to store your personal data, but other use of the data is prohibited, save in certain limited circumstances.
• the right to object to processing; You have the right to object to the use of your personal data in certain circumstances. However, HOMILY may continue to use your personal data, despite your objection, where there are compelling legitimate grounds to do so or HOMILY needs to use your personal data in connection with any legal claims.
• the right to data portability; This right allows you to obtain your personal data in a format that enables you to transfer that personal data to another organisation. You may have the right to have your personal data transferred by HOMILY directly to the other organisation, if this is technically feasible.
• the right to complain to a supervisory authority; You have the right to lodge a complaint with the Data Protection Commissioner if you think that HOMILY has not processed your personal data in accordance with data protection legislation.
• the right to withdraw consent; You have the right to withdraw your consent to the processing of your personal data by HOMILY at any time. This will not affect the lawfulness of our processing before the withdrawal.
If you wish to exercise any of the rights set out above, please contact HOMILY via email at [email protected] so we provide you with the necessary information.
You may also address your requests via email and HOMILY shall answer all your requests within one (1) month. In the extremely rare cases that such a fulfillment is proven unfeasible, HOMILY shall immediately inform you explaining the reasons in detail.
If you believe that our processing of your personal information trespasses data protection laws, you have a legal right to report a complaint to the Hellenic Data Protection Authority (DPA).
6. Contact Information
DATA PROTECTION OFFICER
Email: [email protected]
Telephone: +30 6941643141