Valid from: 21/05/2018

OUR COMMITMENT

GRECOTEL SA and its affiliates holds as its highest priority the protection of your personal data. We make every effort to carefully store and process the information you share with us.

Because we appreciate your trust, we have created this Privacy Policy to inform you about how we collect, use, and share your information. The collection, use, and disclosure of your information is based on your consent and the provisions of applicable law.

GRECOTEL SA and our affiliates protect your personal data through technical data security measures, internal management procedures, and physical data protection measures. We continually strive to improve our systems and procedures so that they stand out above all others.

Thanks for your continued interest and support.

PRIVACY POLICY

1. Consent

"Personal data" means any information that is collected or recorded in a way that may allow direct (e.g. surname) or indirect (e.g. phone number) identification of a natural person.

We recommend that you read this text, which describes the privacy policy, before providing us with personal data.

This "Collaborator Personal Data Protection Charter" is a part of the terms and conditions that govern our hotel services. By accepting these terms and conditions, you explicitly accept the provisions of this Charter.

2. Scope

At GRECOTEL SA (hereinafter referred to as "GRECOTEL" or "we", "us"), we know how important it is to protect the privacy of our collaborators; we try to be as clear as possible about the way in which we collect, use, share, transfer, and store your information. This Privacy Policy summarizes the practices we follow regarding your data.

This Privacy Policy applies to all hotels operated by GRECOTEL SA and our affiliate companies. This Privacy Policy also applies to this website, all websites, online applications, and online and offline promotional actions by GRECOTEL SA as well as any Service or function provided by us that refers to this Privacy Policy or provides a link hereto (collectively referred to as our "Services").

Please note that the Privacy Policy applies to your use of our Services, regardless of whether you use a computer, mobile phone, tablet, TV, or any other device to access our Services. Additionally, this privacy policy applies to Services that are provided without the use of electronic means.

It is important that you carefully read this Privacy Policy because with every use of our Services you agree to the practices described herein. If you do not agree with the practices described in this Privacy Policy, you should not use our Services.

3. For what purposes do we collect data?

We collect and use personal data to manage your relation with GRECOTEL SA and to offer our Services to you. Certain personal data is collected to provide you with personalised and improved services.

We collect personal data with the following purposes:

a) To manage reservations and other hospitality services

• Create and store legal documents in accordance with applicable law.

• Collect data to meet requests relating to your stay (e.g. room preferences).

b) To manage of your hotel stay

• Manage the access to your room.

• Monitor the use of services (room telephone, mini bar, online room service, Wi-Fi access, etc.).

• Manage lists with customers’ personal data for operational purposes, e.g. daily customer arrival and departure lists and a list of special category customers (e.g. VIP, privilege members, Counter Club members, etc.).

c) To improve our hotel services

• Tailor products and Services to better meet your requirements.

• Process your personal data using marketing programmes for marketing and promotional purposes.

• Provide you with useful information for offers or other promotional messages.

• Inform you about special offers and new Services.

• Provide customised content and recommendations based on your previous activities.

d) To manage our relations with you before, during, and after your stay

• Manage loyalty programmes.

• Manage customer databases.

• Evaluate and analyse the market, our customers, our products, and Services.

• Create statistical data and reports.

• Gain knowledge and manage the preferences of new and recurring customers.

• Send newsletters, promotion products and offers, or to contact you by telephone.

• Manage requests for deletion from update lists.

• Create and manage questionnaires and statistics.

• Organise lotteries, contests and offers.

e) To improve our services

• Conduct market research/analysis of questionnaires and customer comments.

• Manage customers’ claims and complaints.

• Offer loyalty programme privileges

f) To improve system security

• Record data to ensure security and to prevent fraud.

g) To comply with Greek and European law

h) To conduct market research/analysis of questionnaires and customer comments.

i) To conduct focused marketing campaigns, direct marketing and sales promotion activities.

4. What personal data do we collect?

Information provided directly by you

We are obliged to request the following details about you and/or your family members:

• Contact details (e.g. surname, given name, father’s name, passport number, ID-card details, telephone, home address, email)

• Personal data (e.g. date of birth, nationality, place of birth)

• Information regarding your children (e.g. given name, date of birth, passport number)

• Billing details (e.g. credit card number, VAT number)

• Loyalty program member number (member number for loyalty program of GRECOTEL SA or other parties, such as airline operators)

• Date of arrival and departure, flight number, and room number

• Preferences and interests (e.g. non-smoking room, preferred floor, type of bed, sports, cultural interests)

• Health Data, such as medical reports and certificates, medical test results, data on pathological diseases, etc.

• Questions and comments submitted during or after your stay in one of our Hotels.

Information from third parties

We may receive information about you from available public and commercial sources. This, we may combine with other information that we receive directly from you or in relation to you. We may also receive information about you from third party social networking services when you choose to connect to such services.

You may choose not to provide certain types of information, but this may limit your access to certain Services.

5. When do we collect personal data?

We collect personal data in various cases, such as:

a) Hotel activities

• Room reservation

• Check-in and payment

• Reservation of seat and/or use of hotel services, such as catering, spa, and recreational services

• Various requests, complaints, and/or disputes

b) Participation in marketing programmes or events

• Registration in loyalty programmes (e.g. Privilege)

• Participation in online and offline surveys (for example, customer satisfaction survey)

• Participation in contests and games

• Subscription to mailing lists in order to receive offers and other promotions by email

c) Transmission of information from third parties

• Tourist agencies, tourist offices, GDS reservation systems, online reservation systems (e.g. booking.com, expedia.com, etc.), and other reservation systems

d) Actions through electronic devices

• Login on our websites

• Connection to our WiFi network of our hotels

• Completion of online forms (e.g. reservation forms, precheck-in forms, satisfaction survey forms, etc.)

• Through social media promotional activities

• Through e-mail upon contact

e) Actions through interpersonal communication

• Face to face contact during business meeting or in the framework of communication during presentations or exhibitions

6. Third party access terms to your personal data

GRECOTEL SA and its affiliates do not disclose your information to third parties for their own business or marketing purposes without prior your consent.

However, we may disclose your information to the following entities:

• Affiliates. Your information may be shared between affiliates of GRECOTEL SA.

• Business associates. We may also share your information with trusted business partners. These entities may use your information to provide you with services you have requested, make provisions relating to your interests, and offer you promotions, advertisements, and other material.

• Service providers and/or any third parties that may process information on our behalf. We may also share your information with companies that provide services on our account or behalf, such as IT contractors, bulk mailers, banks, credit card institutions, law firms, mail service companies, printing services companies, etc.

Credit approval: Upon submission of a credit approval claim, personal data are utilized and disclosed to designated third parties according to applicable legislation in order to decide on the credit approval and its subsequent level.

Credit approval: Upon submission of a credit approval claim, personal data are utilized and disclosed to designated third parties according to applicable legislation in order to decide on the credit approval and its subsequent level.

• Other third parties, if so required by law or in order to protect our Services. Situations may arise in which we share your information with other third parties:

o To comply with the law or mandatory legal procedure (such as search warrants or other court orders)
o To confirm or implement our compliance with the policies governing our Services
o To protect the rights, ownership or security of GRECOTEL SA or any of our affiliates, business partners, or customers

• Other third parties in relation to corporate transactions. We may share your information with third parties within the context of a merger or transfer, or in the event of bankruptcy.

• Other third parties with your consent or at your command. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties if you give your consent or if you request us to do so.

To provide you the best possible service, we allow access to your personal data or to certain categories to competent, authorised members of our personnel. This includes:

• Reservations departments

• IT department

• Marketing/Guest Relations department

• Legal Services department, if and when required

7. Protection of personal data during international transfers

For the purposes set out in Article 3 of this Charter, we may transfer your personal data to internal or external recipients who may be located in countries that offer different levels of protection for personal data.

Please note that data protection and other laws in the countries to which your information may be transferred may not be as protective as those in your country. To protect your privacy, the transfer will take place according to the legislation governing the processing of personal data.

GRECOTEL SA takes all reasonable measures to safeguard the transfer of personal data to an external recipient in a country that offers a different level of privacy than the country where the personal data is collected.

8. What we do to keep your information safe?

We have taken organizational and technical measures to protect the information that we collect in relation to our Services, especially sensitive personal data. Our IT department implements international standards and practices to ensure the safety of networks and the encryption of data.

However, please bear in mind that despite the reasonable measures that we take to protect your information, no website, internet transmission, computer system or wireless connection is ever completely safe.

9. Data storage

We take reasonable measures to ensure that your personal information will be stored no longer than needed for the purpose which it has been collected and no longer than required by the contract or the applicable legislation.

10. Cookies, beacons and similar technologies

We and certain third parties who provide content, advertisements, or other features for our Services may use cookies, beacons, and other technologies in certain parts of our Services.

Cookies

Cookies are small files that store information on your computer, mobile phone, or other device. They allow the entity who places these files on your device to identify you across different websites, services, devices, and/or browsing times. Cookies serve a range of useful purposes. For example:

• Cookies can remember your login credentials so you do not have to enter them again each time you connect to a service.

• Cookies help us and third parties to understand the most popular parts of our Services; they help us see which pages and features are visited by the users and how much time is spent on each. By studying this kind of information, we can customise our Services and provide you with a better experience.

• Cookies help us and third parties to understand which advertisements you have viewed so you do not receive the same advertisement each time you access the Service.

• Cookies help us and third parties provide you with relevant content and advertisements by collecting information about your use of our Services and other websites and applications.

When you use a website to access our Services, you can make settings in your browser to accept all cookies, reject all cookies or notify you when cookies are sent. Each browser is different. Refer to the “Help” menu of your browser to find out how you can change your cookie preferences. The operating system of your device may offer more control settings for cookies.

However, please note that certain Services may have been designed to work with cookies and that deactivating cookies may affect your ability to use those Services or part of those Services.

Other local storage

We and certain third parties may use other kinds of local storage technologies, such as Local Shared Objects (commonly called “Flash cookies”) and local HTML5 storage (HTML5 Web Storage) in conjunction with our Services. These technologies are similar to the cookies mentioned above as they employ storage on your device and can be used to store information concerning your activities and preferences. However, these technologies may use different parts of your device than typical cookies, and therefore may not be controlled with the standard tools and browser settings.

Beacons

We and certain third parties may also use technologies called “beacons” (or “pixels”) that send information from your device to a server. Beacons can be embedded in internet content, videos, and emails to allow a server to read certain types of information from your device. Beacons can also be embedded to determine when you have viewed specific content or a specific email message, the time and date on which the beacon was viewed, and the IP direction of your device. We and certain third parties use beacons for a variety of purposes, such as to analyse the use of our Services and (in combination with cookies) to offer you more relevant content and advertisements.

By accessing and using our Services, you agree to the storage of cookies, other local storage technologies, beacons, and other information on your devices. You also allow us and the aforementioned third parties to access these cookies, local storage technologies, beacons, and information.

11. Access and correction of your data – right to erasure (‘right to be forgotten’)

In addition to existing lawful user rights, according to the legislation in certain jurisdictions, you may also be entitled to request details on the information that we collect and to correct any inaccuracies that may be contained in such information. If permitted by law, we may charge you a small fee for the provision of this possibility. We may refuse to handle requests that are repeated to an unreasonable degree, require disproportional technical effort, jeopardise the privacy protection of others, are extremely impractical, or involve access that is not otherwise required by domestic law. If you wish to submit a request for access to your data, please contact the Data Privacy department (see section “13 .Questions and contact”).

Υοu have the right to obtain the erasure of your personal data from the controller.

12. Updates

This policy may be amended from time to time. To ensure that you are aware of any changes, please check this policy on a regular basis, especially before submitting a reservation request with one of our hotels. By accessing or using our Services after we have posted an updated version of the Privacy Policy, you agree with the new practices contained in the update. The most recent version of the privacy policy will always be available here: grecotel.com/data-protection. You can check the “valid from” date at the top to find out when the Privacy Policy was last changed.

A printed version of this Privacy Policy can be found at the reception desk at all our hotels. You may also request a copy by contacting the Data Privacy department (see section “Questions and contact”).

13. Questions and contact

If you have any questions regarding this policy or the protection of data at Grecotel SA and our affiliates, please contact the Data Private Department at the following address:

L & L Managing Partner
Email: [email protected]

• The term “affiliates” refers to companies of the N. Daskalantonaki Group. Affiliates may also include companies with which we relate though co-ownership or participation.