Privacy Notice

Last Updated: May 24th, 2018

At PRIMA HOTELS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ, 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 PRIMA HOTELS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ.

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://delphiarthotel.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 PRIMA HOTELS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ.

Data Controller

PRIMA HOTELS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ 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:

Delphi Art Hotel “PRIMA HOTELS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ”
Agiou Konstantinou 27
10437, Athens
GR

Data Processor

WebHotelier operates this booking system on behalf of PRIMA HOTELS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ 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 PRIMA HOTELS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ, 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 PRIMA HOTELS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ;
to pass on your financial details to PRIMA HOTELS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ 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
At Prima Hotels we prioritize your privacy and are committed to ensuring the security, integrity, and confidentiality of the personal data you share with us. To this end, we are updating our personal data protection policy to comply with the requirements of the current legal framework.
With this personal data protection policy, we would like to inform you of the characteristics of the progressing of the personal data you provide to us through the website www.primahotels.gr.

Data Controller
The company with the name “Prima Hotels Private Capital Company” and the distinctive title “Prima Hotels”, which has its registered office at 62, Kifisias Avenue, Athens, Attica, is the controller of the processing of the personal data of visitors to the website www.primahotels.gr, which it manages.
The communication with Prima Hotels is achieved by sending e-mail to the address info@primahotels.gr.

Data Protection Officer
The company named 'TOTAL HOSPITALITY LP' with the distinctive title 'TOTAL HOSPITALITY,' registered at 11 Gyzi Nikolaou Street, Athens, Attica, acts as the Data Protection Officer (DPO) for the processing of personal data of visitors to the website www.primahotels.gr, which is managed by Prima Hotels.
The communication with Total Hospitalityis achieved by sending e-mail to the address dpo@primahotels.gr.

Categories of personal data
Prima Hotels maycollect through this website the following categories of personal data of its visitors:
🗸 When making accommodation reservations in one of the hotels hosted on this website, Prima Hotels may collect the customers’ personal information (first name, surname, identity card or passport number, date of birth, nationality), contact details (telephone number, e-mail address), payment details (credit or debit card or prepaid card details), information about the stay (arrival date and departure date, information about preferences in goods and services, information about the customer's preferences and preferences in the hotel).
🗸 When browsingthis website, Prima Hotels may collect the visitors’ technical information (IP address, information about the type of program and technology used to access the website).
🗸 Prima Hotels may process the contact information (phone number, email address) of the visitors who subscribe to the newsletter of this website. Furthermore, Prima Hotels ction may process any other information that visitors to this website may wish to share with us, in order to better inform them about the accommodation services provided.

Purposes and legal basis for the processing
Prima Hotels processes the above categories of personal data in order to fulfil the following processing purposes, based on the following legal basis for processing:
🗸 Prima Hotels processes the personal data that visitors enter in the reservations field, in order to make a reservation in their name for accommodation in one of hotels hosted on this website and, ultimately, to provide them with tourist and hotel services. The legal basis for the above processing is the execution of the hotel contract between the customer who makes the reservation through this website and the hotel business in question.
🗸 Prima Hotels processes the visitors' personal data related to their visit to this website, in order to better understand their preferences and improve the services provided through this website. The legal basis for the above processing is the consent of the website visitors, which concerns the activation of cookies and is provided by their positive action.
🗸 Prima Hotels processes the personal data of visitors who subscribe to the website's newsletter in order to send informative, advertising and promotional material in relation to the hotels hosted on this website and the tourism and hotel services provided by them, as well as for research purposes. The legal basis for the above processing is the consent of the visitors, which is provided through the completion of the data necessary to subscribe to the newsletter. With regard to research purposes, we may contact you to invite you to participate in a survey or to fill in a questionnaire on the quality of the services of the hotels hosted on this website and your level of satisfaction with your stay in one of them.
🗸 Prima Hotels may process personal data of website visitors in order to comply with its obligations imposed by law or by a court order or decision of an administrative authority.

Recipients of the personal data
Prima Hotels guarantees that your personal data will under no circumstances be processed without one of the legal basis for processing. All staff members are committed, by signing a confidentiality agreement, to comply with the obligations under Regulation (EU) 2016/679 and relevant national legislation, as applicable. Prima Hotels may disclose or transfer your personal data to the following categories of recipients, under the conditions set out below:
To judicial or administrative authorities, in compliance with an obligation imposed by law or by a judicial decision or a decision of an administrative authority.
🗸 To its partners, in the context of our contractual relationships and for the fulfilment of specific purposes set out in the relevant contractual documents, in particular to the hotel businesses hosted on this website. In any case, Prima Hotels ensures that all its partners comply with the legislation on the protection of personal data and take all appropriate and suitable measures to ensure the confidentiality, integrity and availability of your data.
🗸 To judicial or administrative authorities, in compliance with an obligation arising from the law or from a judicial decision or from a decision of an administrative authority.

Prima Hotels is share, over this Website, content on social media channels, including, but not limited to, Facebook, Twitter, Instagram and LinkedIn. We guarantee that all the data displayed on the abovementioned channels and pages have been anonymized.

Transfer of the personal data to a third country
Prima Hotels does not transfer or intend to transfer personal data of visitors to this website to third countries or international organizations.

Retention period for the personal data
Prima Hotels ction stores your personal data for the period of time strictly necessary to achieve the processing purposes for which the data were collected in the first place. Prima Hotels may store your personal data for longer than it is strictly necessary, solely for statistical purposes.

Rights
Prima Hotels guarantees the full exercise of the rights provided for in Regulation (EU) 2016/679 and the relevant national legislation, as applicable from time to time. You have the right to:
🗸 To withdraw your consent for processing operations based on it. In this regard, you are entitled to withdraw your consent at any time to the processing of the data you have entered in order to receive informative and promotional messages via the newsletter of this website.
🗸 To obtain information as to whether personal data that concern you are being processed and, where that is the case, access to your personal data and the relevant information set out in Article 15 (1) of (EU) Regulation 2016/679. 🗸 To request the update of incomplete or inaccurate personal data that concern you.
🗸 To request the complete and permanent erasure of your personal data from our records.
🗸 To request the restriction of processing of your personal data, given that the requirements set out in Article 18 of (EU) Regulation 2016/679 are met.
🗸 To receive your personal data in a structured, commonly used and machine – readable format.
🗸 To request the transmit of your personal data to another Data Controller.
🗸 To lodge a complaint with the Hellenic Data Protection Authority (https://www.dpa.gr/en).
Prima Hotels guarantees to satisfy your requests, free of charge, without any undue delay and, in any event, within one (1) month of receipt of the request. We shall extend this period by two (2) further months, where necessary, taking into account the complexity and the number of the requests.

Links to other Websites
Prima Hotels shall not be liable in relation to any damage or loss caused when visitors to this website are transferred to other websites through links that may be contained in it. This policy does not include information about the personal data protection and cookies policies of these websites.

Contact
In order to exercise the aforementioned rights, to express any question or complaint and to evaluate this policy, please contact our Data Protection Officer at the email address dpo@primahotels.gr.

Modification of the Policy
This Personal Data Protection Policy may be modified in the future. Any change or addition will be displayed in this website, in order to always keep you up to date on how we process and protect your personal data. No change to this policy shall be applied before being notified to you.