Privacy Notice
For the processing of Personal Data of Hotel Customers and Website Visitors
Version 1.0
10.05.2019

Introduction
This Privacy Policy applies to the processing of your personal data (hereinafter referred to as "Personal Data") as a hotel customer or visitor to our Website (hereinafter referred to as the "Customer" or "Guest" or "you"), made by the company TNEE POLLIAS SA (hereafter "Hotel" or " Delfinia Resort Hotel" or "we"). As a hotel customer or visitor to our Website you are entitled to the protection of your Personal Data. The Hotel respects your privacy and your personal data and always complies with the Personal Data Protection Legislation. The hotel also undertakes to act transparently as to how to collect and use the data in the course of fulfilling its obligations. The term "Personal Data Protection Legislation" (hereinafter referred to as "Legislation") means all laws, regulations, directives, etc., Greek or European that deal with the processing of Personal Data, privacy and security. Basic, but not exclusively, legal acts are the General Data Protection Regulation (GDPR), the ePrivacy Directive on Privacy in Electronic Communications and any other Opinion or Guideline issued by the Hellenic Data Protection Authority. It is important to read carefully and keep this policy explaining explicitly how and why we collect your Personal Data, what we do with them, how long we maintain them, with whom we share them, how we protect them, and the choices you can have about them. In this way you will always be fully aware of the ways and reasons for which we use this data and your rights in accordance with the Legislation. 

Data Controller 
The Hotel in accordance with the General Data Protection Regulation acts as "Data Controller". This means that the Hotel is responsible for deciding on the ways and purposes for which it collects and uses ("processing") your personal data. Our contact details are:
TNEE POLLIAS SA
Delfinia Resort Hotel Main Street, Kolymbia
Rhodes, 85103, Greece
Tel: +30 22410 56601
E-mail: reservations@delfiniaresort.com
https://www.delfiniaresortkolymbia.com

Principles of Processing
In the context of complying with the Data protection Legislation, we make every effort and in particular: 
• We process your personal data in a legal, fair, clear, objective and transparent manner. 
• We collect your data only for specified, explicit and legitimate purposes that we deem appropriate and have been adequately explained to you. We also assure you that they will not be used in any other way except for those purposes. 
• We collect and maintain the least possible data which is appropriate, relevant and absolutely necessary for processing purposes. 
• We confirm that the data is correct and kept up-to-date and accurate. 
• We will retain your data only for as long as we need it to fulfill any purpose of processing. 
• We will make sure that we store them with the appropriate security. 
• We process it in a way that ensures that it will not be used unlawfully or against to your will. 

Legal basis for the processing of personal data 
We process your Personal Data according to at least one of the legal bases mentioned in particular below: 
• Processing of your Personal Data is necessary for the execution of the contract between us. 
• Processing is based on your consent, given for one or more specific purposes. 
• Processing is necessary to comply with the legal framework that obliges the Hotel to maintain and process specific categories of personal data. 
• Processing is necessary to safeguard your vital interest or any other person. 
• Processing is necessary for the purposes of the legitimate interests pursued by the Hotel or a third party unless these interests override your own interests, fundamental rights and freedoms with regard to the protection of Your Personal Data. 
• Processing is necessary for the performance of a duty performed in the public interest or in the exercise of public authority assigned to the Hotel. 

Personal Data we Collect and Process 
Personal Information is any information that relates to you as an identifiable person. In detail, the Personal Data we collect and process are described below: 
• Identity information (name, surname, gender, date of birth, marital status, identity card or passport, nationality, country of residence, occupation, etc.) 
• Contact details (home address, telephone or fax numbers, email address, etc.) 
• Information related to your stay (room preferences, arrival and departure dates, names, birth dates and ID or passport numbers of people staying in the room). 
• Information about the consumption of products (food, beverages), provision of services (travel, spa, recreation, etc.), participation in actions on site and possible related charges and bills. 
• Financial information such as details of your payment method, your credit card details, tax ID number, detailed costs and transaction history.
• Special requests and other preferences regarding your stay to satisfy particular circumstances (professional, health, social, entertainment, religious, etc.) 
• Health related information, allergies, nutritional preferences, etc. 
• Information you provide about your preferences regarding the hotel's ability to communicate with you, for example, for sending mail. 
• Data collected from hotel and customer security control systems such as closed CCTV. 
• Health data, physician call, symptoms, medical history, personal medical data collected by you or your relatives or friends in the event of illness, injury, accident, or emergency during your stay at the hotel. 
• Data about complaints, complaints or objections that you may have submitted. 
• Details regarding your level of satisfaction with our products, services and more generally your experience during your stay. 

When you use our Website, we also collect information automatically, some of which may be personal data. These include items like language settings, IP address, location, device settings, device operating system, usage time, redirect URL, etc. We can also collect data through cookies. Cookies are small files that store a website on a visitor's computer and to which the Site has access to analyze the user's behaviour. In detail, both the types of cookies that are present and the type of processing that is made are described in a separate policy (Cookies Policy) 

We also use Google Analytics to analyze the use of our Website. Google Analytics generates statistics and other site usage information that is used to generate reports. In detail, the types of edits processed through Google Analytics are described in a separate policy (Cookies Policy)

In case of registration and / or access through a Social Login account, we can collect and access specific information about the user's profile from the corresponding social network only for internal administrative purposes and / or for the purposes mentioned above.

We do not process minors' data without the consent of the parent or guardian. 

Edit special categories of personal data 
The General Privacy Policy defines specific categories of data that need to be processed according to stricter procedures such as health data. The processing of such data is only possible when it is given after your request given (eg dietary allergies) or if required by applicable laws or regulations. 

How we collect and source Personal Data Data 
The collection of personal data is usually from yourself but we may also collect your Personal Data from other sources as below: 
• From travel agents, business associates, and third-party systems (e.g., reservations). 
• Information generated for you when you use our products and services. 
• From family members, partners, or beneficiaries of products and services. 
• From our Website
• Business partners (for example, financial institutions, insurers), account holders or others who are part of our products and services.

Purpose of Collection and Processing of Your Personal Data
We process and use your personal data for one or more of the following purposes:
• For the performance of the contract between us and in order to fulfill our contractual obligations such as the provision and completion of a reservation, including payment management, the provision and completion of the contractual accommodation service, and additional services you have requested.
• To manage requests you have submitted.
• To respond more effectively to special requests, and other preferences regarding your stay to satisfy particular circumstances (professional, health, social, entertainment, religious, etc.)
• To protect your vital interests.
• To protect the public interest.
• To protect the legitimate interests of the Hotel (or third party) provided that the interests or fundamental rights and freedoms of the Visitors do not override these interests.
• To manage your communication requests through the channels provided for this purpose.
• To comply with the legislative framework that obliges the Hotel to maintain and process specific categories of personal data such as compliance with legitimate requests from law enforcement authorities such as the police or tax authorities.
• To handle complaints, comments, incidents, illness, accidents, injuries or emergencies during your stay at the hotel.
• To be able to contact you or any other relevant contact in an emergency.
• To provide personalized information, offers and services during your stay.
• For direct marketing actions such as newsletters and promotional communications for new products and services or other offers that we believe may be of interest to you through physical mail, email, mobile devices or social networks (with your consent).
• For direct marketing actions by publishing photos and videos in electronic or printed media (with your consent).
• To evaluate the effectiveness of promotional campaigns and advertising.
• To identify, investigate and prevent fraud and other illegal activities. For these purposes, personal data may be shared with third parties, such as law enforcement authorities, and external consultants.
• To improve visitor experience, our business operations and our business partners, develop new products and services and review and improve current products and services and promotional activities through information provided by your reviews and ratings .
• For your safety, protection and in order to avoid unlawful actions against you.

Some of these processing instances overlap to a certain extent and, in total, constitute legitimate bases and legitimate purposes within which we process your personal data.

Your personal data will be used solely for the purposes for which it has been collected. If we are required to use your personal data for any other purpose, you will be informed and notified of the legal basis on which the processing will be based or your consent may be requested.

In any case, your personal data is processed in accordance with the principles hereof and the rules of the Personal Data Protection Regulation.

Automated decision making, including profiling
We do not make decisions that can have a significant impact on you, including profiling, in an automated way (decision-making exclusively with the use of a computerized system) 

When and how we share or disclose Personal Data we receive with others 
In order to fulfill its contractual and legal obligations for the purposes contained in this Privacy Policy, the Hotel may transfer certain personal data to third parties including credit institutions, tax authorities, accountancy agencies, travel agents, suppliers , co-operating private insurance companies, doctors, lawyers, health care providers, maintenance providers, various service providers, etc. and more generally by any third party required to meet the regulatory and legal obligations. 

Data transmission will be made by ensuring (where feasible) that these third parties process your data with absolute confidentiality, taking appropriate security measures to protect them in accordance with our policies and not using your personal data for our own purposes or any purpose other than those agreed upon. 

Specific data may be passed on to your relatives only with your prior consent or in an emergency. 

In addition to the above, the Hotel will not transfer personal data to any third party unless it is legally obliged to do so or when it has to comply with its contractual and legal duties (the tax authorities or the police performing our audit duties) 

The Hotel will not sell your personal data to third parties under any circumstances and will not allow third parties to sell the data they have forwarded to them. 

We work with third parties to offer you online reservation services such as booking.com or Web Hotelier and Channel Managers. Although we provide the content on these websites and you make a reservation directly to us, the processing of the reservations is made by third parties. The data you give to these third parties is stored in one or more databases hosted by them. These third-party companies do not use or access your personal information for purposes other than managing reservations. 

Protection of your personal data
Data is stored in a variety of resources, including the physical file, the Site, the Property Management System, and other IT systems (including email). The data are stored in the whole and the format they are submitted to, without any interference with their content.
Amendments to this policy
The Hotel reserves the right to modify this Privacy Policy and its associated practices at any time to respond to changes in the regulatory environment, business needs, or to meet the needs of the subjects, properties, strategic partners and service providers without notice. Such changes, modifications, additions or deletions to the Privacy Policy will replace previous disclosures and will take effect immediately upon publication.
Updates will be posted on the Hotel's website and will be marked with a publication date so that you always know when the policy was last updated.


Na koji način dijelimo vaše osobne podatke s trećim stranama?

  • Booking.com: U partnerstvu smo s tvrtkom Booking.com B.V. sa sjedištem na adresi Herengracht 597, 1017 CE Amsterdam, Nizozemska (www.booking.com) (u daljnjem tekstu Booking.com) kako bismo vam pružili uslugu online rezervacije smještaja. Iako smo mi odgovorni za sadržaj na ovoj stranici i rezervaciju vršite izravno putem naše stranice, sam postupak rezervacije odvija se putem Booking.com-a. Podaci koje unesete na toj stranici također će biti dostupni Booking.com-u i njegovim partnerima. To može uključivati osobne podatke kao što su vaše ime, kontaktni podaci, podaci o plaćanju, imena gostiju koji putuju s vama i bilo koje druge podatke koje ste naveli prilikom rezervacije. Za više informacija o grupaciji kojoj pripada Booking.com, molimo, posjetite stranicu O Booking.com-u.
  • Booking.com će vam poslati potvrdu rezervacije, poruku e-pošte prije dolaska i pružiti vam informacije o objektu i njegovoj okolici. Booking.com će vam također osigurati Službu za korisnike dostupnu 0-24 iz svojih lokalnih ureda na više od 20 jezika. Pružanje informacija Službi za korisnike Booking.com-a omogućuje brzu reakciju ukoliko vam zatreba pomoć. Booking.com može koristiti vaše osobne podatke u tehničke, analitičke i marketinške svrhe, kako je utvrđeno u Pravilima privatnosti Booking.com-a. To može značiti da će pristup vašim osobnim podacima imati i ostale tvrtke grupacije Booking Holdings Inc. u svrhu analize te kako bi mogli pripremiti ponude vezane uz putovanja samo za vas te vam ponuditi potpuno personaliziranu uslugu. Ako to zahtijeva primjenjivi zakon, Booking.com će vas prvo tražiti pristanak. Ako se vaši podaci prosljeđuju u zemlju koja ne pripada Europskom gospodarskom prostoru (EEA), Booking.com će sklopiti ugovore kojima će se pobrinuti da su vaši osobni podaci i dalje zaštićeni u skladu s europskim standardima. U slučaju pitanja vezanih uz Booking.com-ovu obradu vaših osobnih podataka, molimo kontaktirajte: dataprotectionoffice@booking.com.
  • BookingSuite: Vaši se osobni podaci mogu dijeliti s tvrtkom BookingSuite B.V. sa sjedištem na adresi Herengracht 597, 1017 CE Amsterdam, u Nizozemskoj, tvrtkom koja upravlja ovom internetskom stranicom i internetskom stranicom suite.booking.com.