May 24th, 2018
At Avaton Luxury Hotel & Villas Relais & Chateaux, 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 Avaton Luxury Hotel & Villas Relais & Chateaux.
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://avatonluxuryresort.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.
When this notice mentions “we,” “us,” or “our,”, “data controller,”, “controller,”, it refers to Avaton Luxury Hotel & Villas Relais & Chateaux.
Avaton Luxury Hotel & Villas Relais & Chateaux 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:
Avaton Luxury Hotel & Villas Relais & Chateaux “Θ ΧΑΝΤΖΗΣ ΚΑΙ ΣΙΑ ΟΕ” Komitsa Beach, Nea Roda, Athos Peninsula 630 75, Halkidiki GR
WebHotelier operates this booking system on behalf of Avaton Luxury Hotel & Villas Relais & Chateaux and is committed to protecting the privacy of the users of this system. WebHotelier is:
WebHotelier Technologies Limited Mnasiadou 9 (Demokritos Building, Office 16) 1065 Nicosia Cyprus
For the purposes of the GDPR, where WebHotelier processes your personal data on behalf of Avaton Luxury Hotel & Villas Relais & Chateaux, WebHotelier is the the Data Processor. When this notice mentions “data processor,” “processor,” “WebHotelier,” it refers to WebHotelier Technologies Limited.
The User may contact WebHotelier's Data Protection Officer:
Data Protection Officer email@example.com
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 Avaton Luxury Hotel & Villas Relais & Chateaux;
- to pass on your financial details to Avaton Luxury Hotel & Villas Relais & Chateaux 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).
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.
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.
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.
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.
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.
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.
Last updated: Saturday 12th may 2018
We recognize that privacy is an important issue. We have developed this Statement to explain our practices regarding the personal information we collect from you or about you on this site or via our apps, through written or verbal communications with us, when you visit one of our properties, or from other sources.
By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you agree to the collection and use of Personal Information as described in this Statement.
These terms may be amended, updated or otherwise modified, whether in whole or in part, at any time.The personal data, optional and compulsory, that you need to provide when you enter the web site or register forvarious applications related with services and products provided by AVATON LUXURY VILLAS RESORT and any additional personal data that will be requested in later stages are collected, processed, transferred, stored and used by AVATON LUXURY VILLAS RESORT , under its capacity as data controller, for the benefit of the company as well as by service providers, including the data processors and service providers as they are described below.
1. Information we collect about you and the method of collection
1.1 User Provided Information
AVATON LUXURY VILLAS RESORT obtains the information you provide when you proceed in general with actions for accommodations in our property, a stay, conduct business, opted in to receive news and offers and use Applications related to our services, through our web sites, reservation and call centers, social media, when you otherwise voluntarily provide it to us, including in connection with our loyalty program or other third parties. When you download and register to such an Application which is optional, please keep in mind that you may not be able to use some of the features offered by the Applications unless you register. When you register or use our web sites and / or an Application, you are required to provide certain personal data (such as your first and last name, email address, password etc.) by filling in the fields identified as mandatory in the registration form on the login page or document.
You will also be asked to provide personal information for special purposes when making a reservation or a reservation request through our Call Center, Resort, website or third parties websites (as mentioned below) or during your stay. Among others we collect:
contact information, such as your name, mailing address, e-mail address, and telephone number and ID photocopies, nationality, date of birth travel history;
credit card number or other payment account number, billing address, and other payment and billing information (“Payment Information”) and two sides photocopy of your card;
Receipts, invoices and amount of money you spent with us
Vouchers and travel partner program affiliation;
records and copies of your correspondence if you contact us;
information necessary to fulfil special requests (e.g., health conditions that require specific accommodation);
guest stay information, including date of arrival and departure, and goods and services purchased;
Resumes and CVs, wedding dates and wedding preferences
information collected through the use of closed circuit television systems, card key and other security systems; and
in limited cases, information relating to the credit of customers.
We may collect Personal Information from a variety of sources including:
through the website;
through reservation and call centers;
through social media and brand channels (e.g. Facebook, Twitter etc);
Through third party partners and suppliers;
from the resort facilities such as reception, restaurant, CCTV; or
when you otherwise voluntarily provide it to us, including in connection with our loyalty program.
We may also use the information you provided us to contact you from time to time to provide you with important information, required notices and marketing promotions, under the condition that you give us your consent with a direct opt in a relevant specific request of our, noting to you that you can opt out at any time of by sending us an email at firstname.lastname@example.org
Accepting our services and products and the use of our web sites and / or our related with AVATON LUXURY VILLAS RESORT Applications, you give us the explicit consent to collect, process, use and store your personal data according to the applicable laws and this contract.
1.2 Personal Information we collect from third parties
We may also collect information about you from third parties, including information from airlines, payment card, and other partners, including travel agencies, tour operators, Relais & Châteaux database; from your social media services consistent with your settings on such services; and from other third-party sources that are lawfully entitled to share your data with us. We use and share this information (and may append this information to the other information we have on file for you) for the purposes described in this Statement.
1.3 Personal Information from children
The use of the web site and / or our Applications is not intended for use by minors under the legal age requirement. No one under the legal age requirement (18 years old) may provide any personal information to or through our web site and / or our Applications. We do not knowingly collect personal information from minors. If you are under the legal age requirement, please do not visit our web sites, don't register to our Applications, don't make any use of the above or send any information about yourself to us, including your name, address, telephone number or email address. In the event that we find out that we have collected personal information from a minor without verification of parental consent, this information will be deleted, upon the minor’s parent or guardian notification. If you believe that we might have any information from or about a minor, please contact us at email@example.com
As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.
To the maximum extent permitted by applicable law and without limiting any other provision of this Policy, AVATON LUXURY VILLAS RESORT disclaims any liability for any personal data submitted in contravention of this clause.
1.4 Sensitive Information
The term "sensitive information" refers to information related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification. We do not generally collect sensitive information unless it is volunteered by you. We may use health data provided by you to serve you better and meet your particular needs (for example, the provision of disability access).
2.Purposes and use of processing and collection
We collect, process, use and store your personal data:
To authenticate you when log in to our web sites, our Application and wi-fi;
To fulfill the reservation or information requests and to remember your preferences and registration information;
To provide and personalize the services you request and expect from us and to offer you the expected level of hospitality;
For membership programs ;
To provide our services to you;
To measure and obtain data for administrative and other communication purposes in order to operate and improve the effectiveness of our services our facilities, our web sites and the Programs/ Applications related the operations of AVATON LUXURY VILLAS RESORT;
To comply with applicable law;
To support IT purposes;
To support operational procedures;
To fullfill requirements from banks (e.g in cases of disputed transaction);
To fullfill requirements police and other state organisations or goverment agencies;
For marerketing purposes such as newsletters, offers, etc as well as other marketing messages in accordance with any communications preferences you have expressed. For marerketing purposes We use your information to provide in-stay messaging, account alerts, and reservation confirmations; to send you marketing messages; and to conduct surveys, sweepstakes, prize draws, and other contests. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means (including on-property messaging, such as your in-room television). With your consent, we also use user-generated content (such as photos) from social media services to deliver display advertising or on our website and apps.
3. Data sharing and transfers
Your personal data are gathered, filed and processed by AVATON LUXURY VILLAS RESORT exclusively for the purposes of providing our services to you according to the applicable laws. By accepting the terms of this document, you give your explicit consent to AVATON LUXURY VILLAS RESORT to transfer your personal data to AVATON LUXURY VILLAS RESORT’s Partners, that is to third natural or legal entities who provide you with services in combination or in addition to its services (specifically for transport services, internal or external activities, visits to places, reservations procedure, marketing purposes etc) and for reasons connected with the better provision of services of AVATON LUXURY VILLAS RESORT to you.
it is required or authorized by law;
it is required to provide you with services that you have requested, in which case you will be considered to have given your consent (i.e. car rental, restaurant reservation, reward programs, tours or visits arrangements, ticket purchases, transfers, yacht or helicopter rentals, massage and beauty services and any other services provided by AVATON LUXURY VILLAS RESORT);
if your stay has been paid for by a third party we will provide billing information to the paying party;
if you have failed to pay owed amounts or you dispute payments;
If it is required to protect the rights, privacy, safety of AVATON LUXURY VILLAS RESORT property, site visitors, guests, employees or the public.
In addition, AVATON LUXURY VILLAS RESORT may disclose personal information in order to: permit us to pursue available remedies or limit the damages that we may sustain, enforce our websites' terms and conditions, and respond to an emergency.
3.1.2. We may disclose User Provided and Automatically Collected Information:
With government or law enforcement authorities, where required by applicable law in order to comply with any court order or other legal obligation, or respond to a government request;
When we consider in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others or to investigate theft or fraud;
With Service Providers and data controllers, which we use in order to execute and improve our services and support our business;
For the purposes of special programs, according to the more specific terms and conditions if/when you choose to participate.
3.2.1. Business Partners: We may partner with other people or companies jointly or separately to provide you with products, services, or offers based upon your experiences at our properties and may share your information with our business partners accordingly. For example, we may help, after having been asked from you and informed you about, to arrange among others rental cars or other means of transport, external activities, visits to places or other services from our business partners, and share personal information with our business partners in order to provide those services.
These Suppliers independently provide their services. It is clearly stated that their services do not concern us and may include other hotels, airlines, car rental companies, service providers, companies that organize package tours or bookings. All services provided by third parties are characterized in this way and are not related to our own services. Therefore, we encourage you to read their privacy policies and rules of providing their products and services. Keep in mind that these third parties may also contact you if they need to ask additional information about you to provide their services or to respond to a request you have submitted. We are not responsible for any communication of yours that takes place directly with these suppliers. AVATON LUXURY VILLAS RESORT expressly disclaim any liability and the potential or not potential guest hereby waives any claims which may be brought up against any kind of loss, injury or any kind of damages resulting from the services provided by the supplier.
3.2.2. Service Providers: We rely on third parties to provide services and products on our behalf and potentially share your personal information with them, as the case may be. In general, our service providers are required by law to protect your personal information and may not use or share your personal information unless required by law.
4. Location-based services (website and mobile)
We provide mobile apps that can be downloaded to your smartphone or mobile device and location based services in our website. These apps/website have a variety of functionalities that enhance the customer experience. If you allow our mobile apps/ website to access your location information on your device, our mobile apps may use your mobile device’s Global Positioning System (GPS) technology and other technology (such as wireless transmitters known as beacons) to provide you with information and offers based on the location of your device. Beacons allow us to collect information about your location by communicating with mobile devices that are in range. We may use this location information to enhance your on-property experience by delivering push notifications and other content to your mobile device, providing navigation assistance as you move around our locations, change language according to where you are located and sending you information and offers about products, services, or activities we believe may be of interest to you. We may share this information with third parties, including business partners and service providers, to provide information, offers, and services that may be of interest to you. You may prevent or limit collection of location information by changing the settings in the or by changing your device’s settings. All the location based information collected are processed and secured according to this Privacy Statement.
5. Data Retention Period
We will retain User Provided data for as long as you use our web sites and / or our Application and for a reasonable time thereafter so as to fulfill the afore mentioned purposes or to respect any applicable laws or statutes of limitation or terms of this Policy. We will retain Automatically Collected information for up to 20 years and thereafter may store it in an aggregate form.
6. Security and Protection of Presonal Data
AVATON LUXURY VILLAS RESORT recognizes the importance of information security, and is constantly reviewing and enhancing our technical, physical, and logical security rules and procedures. We implement appropriate technical and organizational measures to reasonably protect your personal data against unauthorized and unlawful access and processing or accidental loss, destruction, damage, theft, use or disclosure.
The safety and security of your information also depends on you. Where we have given you or where you have chosen a password for access to services through our web sites and/ or our Applications, you are responsible for keeping this password confidential. We request you not to share your password with anyone else.
Although "guaranteed security" does not exist either on or off the Internet, we safeguard your information using appropriate administrative, procedural and technical safeguards, including password controls and "firewalls".
We make every effort to ensure as fully as possibly the secure use of our web sites and our Applications. (It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail.
8.Your Rights- changing and accessing your personal information
According to applicable laws, you have the right to information, access, rectification, blocking, and/or requesting deletion and objection to processing, to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal, to lodge a complaint with the supervisory authority (Hellenic Personal Data Protection Authority) and to data portability, in relation to the processing of your personal data.
If you have any questions regarding your privacy while using our websites and / or services and / or Applications, or in case you want to exercise your rights, please contact us via email at firstname.lastname@example.org .
9. Your Consents
10. Other Information
When you visit and interact with Hilton websites and apps, we collect other information that does not directly identify you about your use of the site, such as a catalog of the site pages you visit, and the number of visits to our sites (“Other Information”). We use Other Information, as well as data received from third parties, to deliver you email, online (on our sites and other sites) and mobile advertisements.
Because Other Information does not personally identify you, such information may be disclosed for any purpose where permitted by law. In some instances, we may combine Other Information with personal information. If we do combine any Other Information with personal information, the combined information will be treated by us as personal information in accordance with this Statement.
11. Contact Us
If you have any questions about this Statement or how AVATON LUXURY VILLAS RESORT processes your personal information, please contact us by email at email@example.com
You can tell when this Statement was last updated by looking at the link and at the date at the top of the Statement. Any changes to our Statement will become effective upon posting of the revised Statement on the site.
13. Privacy statement revisions
As stated above, we may modify this Statement from time to time. To help you track the most significant changes, we will include a history of changes, below, so that you are aware of modifications to our Statement.
Last Update: Saturday 12th May 2018
Saturday 12th May 2018 Changes: