Privacy Notice
This is the Privacy Notice of Elias Beach Hotel (hereinafter ¨Hotel¨
or ¨we¨) which is under the management of Sunnyseeker Hotels Ltd
(hereinafter ¨Management Company¨). It refers to the processing of your
personal data, as guests of the Hotel or visitors of our website
www.eliasbeach.com (hereinafter ¨ Guests¨, ¨Visitors¨ or ¨you¨).
We respect your personal data and commit to being transparent during the
data collection and processing. The Hotel also commits to operating in
compliance with the Cypriot or European Legislation in the areas of
Personal Data Processing, Privacy and Data Security. The legislation
includes, inter alia, the General Data Protection Regulation (GDPR) and
the ePrivacy Directive for the protection of private life in electronic
communications. We also consider the Guidelines issued by the Office of
the Commissioner for Personal Data Protection in Cyprus.
It is important that you read this privacy notice together with any
other privacy notice we may provide on certain occasions when we are
collecting or processing your personal data so that you are fully aware
of how and why we are using your data. This privacy notice supplements
any other notices and is not intended to override them.
1. Important Information
Data Controllers
The Hotel and Management Company, acting as joint Data Controllers,
determine the purposes and means of personal data processing jointly.
You can exercise your rights against either of the joint Controllers.
Elias Beach Hotel belongs to E.O.E Tourist Enterprises Ltd,
a Company with its registered office: Makariou & Agias Elenis, 36,
Galaxias Commercial Center, floor 4, office 404, 1061, Nicosia, Cyprus.
Hotel Contact Details
:
Elias Beach Hotel
Address: Ancient Amathus Avenue 125, Pareklisia 4533, Limassol, Cyprus
Tel.: +357-25636000
E-mail: info@eliasbeach.com
If you have any questions about this privacy notice, including any
requests to exercise your legal rights, please contact our DPO using the
details set out below.
DPO Contact Details
:
E-mail: dpo@eliasbeach.com
Address: Ancient Amathus Avenue 125, Pareklisia 4533, Limassol, Cyprus
Tel.: +357 25636000
Changes to the Privacy Notice
We may amend this Privacy Notice at any time. Any change will be valid
from the publication of the updated Privacy Notice on our website, and the publication date will be mentioned.
Your duty to inform us about changes in your personal details
It is important that the personal data we hold about you is accurate and
current. Please keep us updated about your personal data changes during
your relationship with us.
Links to Third–Party Websites
Our website may include links to third-party websites. Clicking on those
links may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for
their privacy statements. When you leave our website, we encourage you
to read the privacy notice of every website you visit.
2. What personal data do we collect about you?
Personal data is any information relating to an identified or
identifiable person. We may collect, use, store and transfer different
kinds of your personal data which we have grouped together as follows:
Identity Data: name, surname, title, ID or Passport number, date of birth, gender, domicile and nationality.
Contact Details: physical address, email address and telephone or fax number.
Data on your stay in the Hotel: room preferences,
arrival and departure times, full name, date of birth and ID or passport
number of the guests that will stay at room.
Data on the products consumption (food, drinks) and the use of services (e.g. spa, transports or leisure).
Data on your preferences on special occasions: social, professional or religious occasions, leisure and health (e.g. allergies and food preferences).
Data collected from the security systems: records from the cameras through the Closed-circuit television (CCTV).
Data collected in the event of an incident: doctor details, medical history, injury or accident details, contact details in case of emergency.
Data on your complaints or comments.
Data on your reviews of your stay in the Hotel or/and the use of services or products.
Marketing Data: your preferences in relation to receiving information about us, our services and events.
Financial Data: payment method details, bank account details, credit card details, detailed expenses and transaction history.
Technical data: information collected when you visit our website. For more information about the use of cookies, please read our Cookie Notice available on our website.
3. How do we collect your personal data?
We use different methods and sources to collect your personal data including, inter alia, the following:
From you directly during your visit in the Hotel, or electronically,
by phone, post or any other means. This includes, inter alia, personal
data that you provide when you:
– contact us or make a reservation via our website.
– want to receive information about the Hotel, our services and products.
– fill out the registration cards during the check-in.
From your family members, colleagues and beneficiaries of products or services.
From travel agents, third parties booking platforms and business partners (e.g. insurance agents).
From data collected when you use our products and services.
From the automated technologies. As you interact with our website,
we may automatically collect technical data by using cookies. For more
information about the use of cookies, please read our Cookie Notice available on our website.
4. Why do we collect and process your personal data?
We use your personal data only for the following purposes:
when it is necessary for performing a contract. This includes:
– providing services, such as accommodation and restaurant, or organizing events
– processing payments
– fulfilling your special requests for your preferences on special occasions (professional, social, religious etc.)
when processing is necessary for the purposes of the Hotel’s
legitimate interests on the condition that the Guests’ fundamental
rights and freedoms do not override these interests, particularly:
– for analyzing and improving our current services and products as well
as creating new services and products through your comments and reviews
– analysing the information about you for statistical purposes
– contacting you in order to inform you about offers and services during your stay at the Hotel
– managing your contact requests through the means provided for that purpose
– managing your complaints and comments
– collecting information about your preferences to personalise and improve the quality of our communications with you
– preventing and detecting security threats, frauds or other criminal or malicious activities
– for insurance purposes
– for exercising or defending our legal rights or for complying with court decision or orders
– for controlling the access on our premises for security purposes
Closed-circuit television (CCTV) is used for purposes of the Hotel’s legitimate interests, particularly:
– for crime prevention and detection
– for the security and protection of our premises
– for the security of Guests, Employees and Contractors
– for assuring the Guests, Employees and Contractors of the security
measures that have been taken so that the fear of crime will be reduced
– for assisting the local law enforcement authorities with the crime
detection and prevention, including the fight against terrorism
– For discouraging antisocial behavior, particularly crimes related to alcohol and drugs on our premises
when processing is necessary for the protection of your vital interests. This includes, inter alia,
– managing incidents, sicknesses, accidents, injuries or cases of emergency during your stay at the hotel
– contacting you or other relevant contact person in case of emergency
when processing is necessary for compliance with a legal obligation,
including maintaining records, compliance checks or screening and
recording (e.g. for tax purposes, for fraud and crime prevention and
detection etc.). This can include sharing your personal data with third
parties, such as the competent law enforcement authorities.
when you give us your consent to process your personal data, such as:
For Marketing:
– to communicate with you to keep you up to date on new products and
services or other offers that may interest you or our events by post,
email, phone or/and by using the social media
We will only provide you with marketing related information after you
have, where legally required to do so, opted to receive those
communications and having provided the opportunity for you to opt out at
any time. You can ask us to stop sending you information about us, our
services, products or events at any time by contacting us at info@eliasbeach.com.
Where you opt out of receiving information about us, our services or
events, your opt out will not apply to personal data provided to us for
any other purpose.
For Cookies:
– to collect information about your preferences to personalize and
improve the quality of our communications with you. You can set your
browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies, please
note that some parts of our website may become inaccessible or not
function properly. For more information about our use of cookies, please
read our Cookie Notice available on our website
Automated decision making
We will not use your personal data for taking any automated decisions
affecting or creating profiles, i.e. decision making by electronic means
without any human involvement.
Change of purpose of possessing
We will only use your personal data for the purposes for which we
collected it, unless we reasonably consider that we need to use it for
another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will
notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your
knowledge or consent, where this is required or permitted by law.
5. Who do we share your data with?
We may have to share your personal data for the purposes mentioned in
this Privacy Notice with the following categories of recipients:
the Management Company of the Hotel
third parties including banks, travel agencies, suppliers, ITs,
insurance companies, lawyers, doctors, medical carriers, service
providers
regulatory bodies, law enforcement authorities, or pursuant to an order of a court or a legal obligation
your relatives in case of emergency or following your prior consent
Third companies providing electronic reservation services (e.g.
booking.com) store your personal information for managing the
reservations. In this case, the reservation is directly made in the
Hotel, but these companies process the reservation.
We require all third parties to respect the security of your personal
data and to treat it in accordance with the law. We do not allow our
third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions. In no case
we will not sell your personal data as well as we do not allow third
parties to sell the data we transfer to them.
6. How do we transfer your personal data outside European Economic Area (EEA)?
We do not transfer any personal data to countries outside the EEA.
Nonetheless, it might be necessary to do so for the purposes mentioned
in this Privacy Notice and we will take steps to ensure that your
personal data receives an adequate level of protection. In case where
your personal data is transferred to a service provider for processing
in any country outside the EEA that is not recognized by the EU
Commission as providing an adequate level of protection for personal
data, we will ensure that appropriate safeguards as per the EU
Commission’s standard contractual clauses or by any other appropriate
safeguard as foreseen under the applicable data protection law are
provided.
7. What security measures do we take?
The Hotel data is stored in different places, such as physical file,
website, electronic management system of the Hotel (Theova) and other
electronic systems (e.g. email). We have put in place appropriate
security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorized way, altered or disclosed.
Site Access Control: unauthorized persons are not
allowed to have access to areas within our Hotel whereby personal data
are processed and in case that the provision of access to such persons
is necessary, they do not remain unattended.
System Access Control: only authorized persons have access to data processing systems.
Data Access Control: authorized persons with access
to data processing system have access only to the data they are
authorized to access and are bound by confidentiality.
Transfer Control: personal data are only transferred in prescribed manner and under certain circumstances.
Disclosure Control: we always ascertain and check where and to whom data can be transferred by means of data transmission facilities.
Order Control: personal data of a data subject is
processed in strict accordance with the data subject’s instructions and
the appropriate law.
Availability Control: personal data is protected against accidental destruction or loss as all data is backed up.
Breach Control: procedures to deal with any
suspected personal data breach and for the notification of any
applicable regulator or an affected data subject of a breach have been
laid down.
As for the closed–circuit television (CCTV), the measures taken include, inter alia, the following:
The CCTV records and the relevant equipment are placed in a locked
server room where only authorized persons have access, and other people
are allowed entry only in the presence of an authorized person.
The authorized persons and the contracting security company have
access to the CCTV system. The access to the hard disk where the CCTV
records are saved, is strictly limited and protected with strong
passwords and encrypted archives.
Our security measures are audited regularly by external security
experts in order to maintain our security level to international
standards and to ensure that personal data is handled in a secure way.
8. How long do we keep your personal data?
We will only retain your personal data for the period necessary to
fulfil the purposes described in this Privacy Notice. In the case where a
guest relationship existed, we will retain your personal data for a
period of at least twelve (12) months from your departure from the
Hotel, except for the following cases where the data is required to be
kept for a longer period:
statistical purposes
managing issues regarding payment and invoicing
sending direct marketing messages to guests that have given their consent
till the lost objects are returned to the Guests
managing accidents or incidents that occurred during the stay in the Hotel
keeping comments and preferences for frequent guests on the condition that they have given their consent
complying with legal or regulatory obligations (e.g. for accounting purposes)
till the period that claims against the Hotel can be issued before
courts or other prosecution authorities so that the Hotel will be able
to defend its legal rights
in case of litigation, till the court proceedings or enforcement measures are carried out
As for the CCTV records, they are retained for a period of
twenty-five (25) days from the recording date. However, we may have to
retain this data for a longer period, such as for defending our legal
rights before courts or other enforcement authorities.
In general, to determine the appropriate retention period for personal
data, we consider the amount, nature, and sensitivity of the personal
data, the potential risk of harm from unauthorized use or disclosure of
your personal data, the purposes for which we process your personal data
and whether we can achieve those purposes through other means, and the
applicable legal requirements.
In some circumstances you can ask us to delete your data. See below to read more about your right to erasure.
9. What are your rights?
You have the following rights regarding your personal data:
Right of Access: You have the right to access to
your personal data. You can ask for a copy of the personal data we hold
about you. There are situations where we may deny your request, for
example, if making the information available to you would reveal
personal data about another person, or if we are legally prevented from
disclosing such information.
Right to Rectification: It is our objective to keep
your personal data accurate, current and complete. You have the right to
request the correction of any incomplete or inaccurate data we hold
about you, though we may need to verify the accuracy of the new data you
provide to us.
Right to Erasure: You have the right to ask us to delete or remove your personal data in case that
there is no good reason for us continuing to process it
you have successfully exercised your right to object to processing (see below)
we may have processed your information unlawfully
we are required to erase your personal data to comply with local law
You should note, though, that we may not always be able to comply
with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
Right to Object: You have the right to object to the
processing of your personal data when we are relying on a legitimate
interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on
this ground as you feel it impacts on your fundamental rights and
freedoms. In some cases, we may demonstrate that we have compelling
legitimate grounds which override your rights and freedoms. You also
have the right to object when we are processing your personal data for
direct marketing purposes.
Right to Restrict Processing: This enables you to ask us to suspend the processing of your personal data in the following cases:
if you want us to establish the data’s accuracy
when our use of the data is unlawful but you do not want us to erase it
when you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
Right to Data Portability:
You have the right to request the transfer of your personal data to you
or to a third party. We will provide to you, or a third party you have
chosen, your personal data in a structured, commonly used,
machine-readable format.
Right to Withdraw Your Consent: You have the right
to withdraw your consent at any time where we are relying on consent to
process your personal data. However, this will not affect the lawfulness
of any processing carried out before the withdrawal of consent. If you
withdraw your consent, we may not be able to provide certain services to
you. We will advise you if this is the case at the time you withdraw
your consent.
If you wish to exercise any of the above mentioned rights, please contact us at dpo@eliasbeach.com.
Right to file a complaint
You have the right to lodge a complaint with the Office of Cyprus Commissioner for Personal Data Protection.
No fee usually required
You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a reasonable
fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these
circumstances.
What do we need from you?
We may need to request specific information from you to help us confirm
your identity and ensure your right to access your personal data (or to
exercise any of your other rights). This is a security measure to ensure
that your personal data is not disclosed to any other person. We may
also contact you to ask for further information in relation to your
request.
Time limit to respond
We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is
particularly complicated or you have made more requests. In this case,
we will notify you.
We recommend that you visit our website often in order to keep updated
with the changes in our Privacy Notice. For previous versions of our
Privacy Notice, please contact us at dpo@eliasbeach.com.
Updated 14.04.2022