This Privacy Policy, along with the Privacy Notice attached to our Registration Forms and our Cookies Policy, provides information and explains how our group of companies operating under the name “KALEVROS P.C.” (hereinafter “KALEVROS P.C.” or “we” or “us”) processes the personal data of our customers (hereinafter “Customer/s,” “Guest/s,” or “you”) and the visitors of our website (hereinafter “you”). It outlines the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will handle them.
Definitions included in this Privacy Policy shall have the meanings assigned to them in the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, which, together with Greek Law and the regulatory framework applicable in Greece, shall constitute the Data Protection Legislation.
We are committed to preserving the privacy of all visitors to https://www.auroraspetses.com (our “Website”) and to protecting any personal information that you may provide to us.
We provide this Privacy Policy to help you understand what we may do with any personal information that we obtain from you or for you. Personal information may include information about an identifiable individual, as defined by Data Protection Legislation, such as name, e-mail address, and telephone number, as well as other related information. By providing your personal information to us, you signify your acceptance of this Privacy Policy and agree that we may collect, use, and disclose your personal information and data as described in this Privacy Policy. If you do not agree with this notice and/or this Privacy Policy, please do not provide your personal details and data to us. However, you may need to do so if you want to make use of our accommodation services.
1. INFORMATION & PERSONAL DATA WE COLLECT
1.1. We may collect personal information about you when you use our website or our accommodation services and in any other way you may otherwise interact with us. The information we collect falls into the following categories: (a) information you provide us either during the process of booking accommodation services and checking on our Aurora Spetses or through our website or other promotional and marketing methods; (b) information we collect through automated methods; and (c) information we collect from other sources.
1.2. We may combine the information you provide us with information collected through automated methods or with information we receive from other sources.
1.3. We collect information you provide us. You may provide the following information to us:
1.3.1. Personal data and details you provide us in the Registration Form during your check-in at one of our Aurora Spetses or any other type of personal data that you provide to us when you choose to communicate with us or use our services, such as personal details, your name, postal and email addresses, phone number, date of birth, and other contact information, identity card or passport number, VAT number, check-in and check-out information, payment methods, and any other relevant information;
1.3.2. Personal details, such as your name, postal and email addresses, phone number, date of birth, and other contact information, when you register with our Website, log in to Wi-Fi, enter one of our competitions, or contact us by phone or through our online services;
1.3.3. Transaction information, including details about the services you book, prices, method of payment, and payment details;
1.3.4. Account information, such as your username or password (or anything else that identifies you) used to access our online services or to purchase or use our products and services;
1.3.5. Email and other contact details following your consent;
1.3.6. Profile information and preferences, after your prior consent, including products and services you like, the time you prefer to visit us, room preferences, bathroom preferences, food and beverage preferences, newspaper and magazine preferences, or any other preferences arising from your conduct, comments, choices, and recommendations during your past stays in Aurora Spetses, as well as purchase histories and records, activity information, membership in loyalty or recognition programs, and any other source of information legally collected by third parties or according to your approval during your stay in Aurora Spetses; and
1.3.7. Other personal information you choose to provide us when you interact with us.
1.4. We collect information through automated methods. In this context, we may use automated technology to gather information from your computer system or mobile device when you use our online services. Automated technology may include cookies, local shared objects, and web beacons. More information about cookies and other technologies is provided below.
1.5. We may collect information about your:
(a) internet protocol (IP) address;
(b) computer or mobile device operating system and browser type;
(c) type of mobile device and its settings;
(d) unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device;
(e) device and component serial numbers;
(f) advertising identifiers (for example, IDFAs and IFAs) or similar identifiers;
(g) referring website (a site that has led you to ours) or application;
(h) online activity on other websites, applications, or social media;
(i) communications to us or regarding us on social media; and
(j) activity related to how you use our online services, such as the pages you visit on our site.
1.6. Our Website may collect information about the exact location of your mobile device or computer using geolocation and technology such as GPS, Wi-Fi, Bluetooth, or cell tower proximity. For most mobile devices and computer systems, you can withdraw your permission for us to collect this information by adjusting the device or web browser settings. If you have any questions about how to prevent us from collecting exact information about your location, we recommend contacting your mobile device service provider, the device manufacturer, or your web browser provider. Our Website may not function properly without information about your location. If you would like us to delete information we have collected that could identify your location, please contact us at the address, phone number, or email address provided below.
1.7. We may collect information about you from other companies and organizations, as well as partners or service suppliers, such as information transmitted from third parties, like tour operators and travel agents, whether online or operating in any other form, reservation systems, platforms, suppliers of services, and any other means. We may also collect publicly available information. For example, we may gather information about you when you interact with us through social media.
2. COOKIES
We may obtain information about your general internet usage by using a cookie file, which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us improve our site and deliver a better and more personalized service. Some of the cookies we use are essential for the operation of our website. Please note that our advertisers may also use cookies, over which we have no control. For more information on how we use cookies, please refer to our Cookies Policy.
3. PURPOSE & USE OF THE INFORMATION & PERSONAL DATA
3.1. We use information collected, stored, and processed about you in the following ways:
3.1.1. In order to provide our services to our Guests and for administration and business purposes.
To manage your reservation and accommodation request, KALEVROS P.C. will collect, use, share, transfer, process, and store the personal data you provide to us. This processing is necessary for the performance of our obligations towards our Customers, to provide you with information or services, and to communicate with you, either following your request or as otherwise required. Additionally, we will use your personal data to provide our services to you and receive payment for such services, for internal Customer administration, and for business purposes, in order to provide you with the information or services you have requested and to improve our services, products, or procedures or adapt them, as practicable, to your needs.
3.1.2. For Marketing Communications.
With your consent, we may collect, use, share, transfer, process, and store your personal data to communicate with you regarding newsletters, promotions, featured specials, and other marketing materials, messages, and dedicated offers. You can withdraw your consent at any time by following the opt-out instructions in the marketing communications we send you. You can also withdraw your consent by contacting us at our contact details (auroraspetses@gmail.com). If you opt out of receiving marketing communications from us, we may still send you communications about your transactions.
3.1.3. In order to operate our Website.
We will process your personal information to ensure that content from our website is presented in the most effective manner for you and your computer, as well as for marketing and promotion of our services and products or services of third parties. Additionally, we may process your personal information to allow you to participate in interactive features of our Website when you choose to do so or to notify you about changes to our Website.
3.1.4. Legislation Compliance and the protection of our interests.
We may use your information to comply with our legal obligations according to applicable legislation or to disclose your personal data as necessary to comply with applicable laws and regulations, such as our obligation to collect personal data of our Guests according to Police Directives, to process and store accounting documents and files, to respond to requests from governmental, judicial, or any other competent authority, to protect our business, to bring or defend legal claims, and to protect the rights, interests, safety, and security of our organization, our employees, guests, visitors, or any third party in connection with investigating fraud or other crimes or violations of applicable laws, as well as to respond to emergencies.
3.1.5. Handling consumer complaints.
We will use your personal data to respond to any customer complaints and to defend Aurora Spetses or KALEVROS P.C. and present our case in any court or administrative authority in relation to any such customer complaint.
3.1.6.Preferences & Profile.
With your consent, KALEVROS P.C. will collect, use, share, transfer, process, and store your personal data to provide you with unique experiences and improved personalized services when you visit our Aurora Spetses in the future, according to your preferences and profile, to customize our commercial offers and promotional messages, inform you of special offers and new services created to satisfy your personal needs, promote brands, gain a better understanding of your requirements and wishes, and adapt our products and services to better meet your needs and requirements. You can withdraw your consent at any time by contacting us at our contact details (auroraspetses@gmail.com).
3.1.7. Bad Behavior of Guests.
For our group management and administration purposes, we may collect and process personal information of Customers or Guests who behaved inappropriately during their stay in our Aurora Spetses or showed anti-social behavior or non-compliance with safety regulations, were accused of theft, damage to property, or any other type of vandalism, and any payment incidents. Such processing is necessary for the legitimate interests of our business, for the protection of our future Guests and our employees, as well as to prevent fraud and the abuse of our property or staff.
3.1.8. Securing Payments.
We may adopt systems to assess the risk of fraud. In this context, we may use risk prevention service providers or systems for analysis, and depending on their results and investigations, we may need to take security measures, such as recommending different booking channels or requiring alternative payment methods. Non-compliance could lead to the suspension of a booking or the cancellation of an order. In the case of fraudulent use of any means of payment or payment methods leading to payment default or fraud, and despite any other legal actions that may be available, KALEVROS P.C. may retain such incident data on file to block future fraud or avoidance of payments and carry out additional checks. Such processing is essential and necessary to protect our legitimate interests, operate our business properly, prevent fraud, and file appropriate legal actions.
3.1.9. Extreme circumstances & public health.
In the event of extreme or unprecedented circumstances, particularly due to public health incidents or issues and pandemics, we may need to collect, store, process, and disclose to third parties and competent administrative authorities personal information, especially medical and other sensitive data, to comply with applicable legislation and regulations or to protect individuals, such as other Guests and Customers of Aurora Spetses or our employees, from the spread of a pandemic or any other type of risk and threat to health. If such personal data is stored by competent public authorities, you may need to refer to their privacy policy for further information on the use and processing of your personal data by them.
3.2. We may also use your data or permit selected third parties to use your data to provide you with information about goods and services that may be of interest to you, and we or they may contact you about these. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregated information about our users. We may use the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisements to target audiences.
3.3. To meet your special requirements, such as dietary needs, we may have to collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health, medical information, or sexual orientation. In this case, we will only process this data if you provide your express prior consent.
4. WHERE WE STORE YOUR PERSONAL DATA
4.1. As a principle, data collected from you shall not be transferred to and stored at a destination outside the European Economic Area (“EEA”).
4.2. In certain cases, your personal data may be shared with our service providers, vendors, or partners, which may be based anywhere in the world, including countries that may not offer the same legal protection for personal data as your country of residence. KALEVROS P.C. complies with the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, as well as the Greek Data Protection Legislation, and has concluded respective Data Protection Agreements with such service providers, vendors, or partners to protect and safeguard your personal data and ensure, as technically and practically feasible, an adequate level of protection by such third parties for your personal data. In any case, KALEVROS P.C. will only share your Personal Data on a strict “need to know” basis and under appropriate contractual restrictions (such as EU Standard Contract Clauses).
4.3. All information provided to us is stored on our secure servers. Any payment transactions will be encrypted.
4.4. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with any third party.
5. INFORMATION SECURITY
KALEVROS P.C. has established a strict and elaborate security system, adopts security procedures and measures, and takes appropriate technical and organizational measures, in accordance with legal provisions and market standards, to protect your personal data, avoid, as technically feasible, any security or personal data breach or security incident, and prevent the illicit or accidental destruction, alteration, or loss, misuse, unauthorized access, modification, or disclosure of any personal data stored and processed in our systems.
6. RETENTION OF PERSONAL INFORMATION
We retain personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law or applicable regulations.
7. DISCLOSURE OF YOUR INFORMATION
7.1. We will only share your information as described in this Privacy Policy.
7.2. Furthermore, we rely on third parties to provide services and products to you and may share your personal information with them as appropriate and necessary for the provision of our services, such as food and beverages, transportation, IT, Wi-Fi and network services, bank details, credit card issuers, tour operators, and other partners or vendors. We will also share your personal data with such third-party vendors who provide services to us, such as fulfilling orders, providing data processing and other information technology services, managing promotions, contests, prize draws, and sweepstakes, carrying out research and analysis, and personalizing individual customer experiences. All such third parties are contractually obligated to protect your personal data and information in accordance with the Data Protection Legislation and may not otherwise use or share your personal data and information, except as may be required by law or our contracts and data protection agreements. We do not allow those service providers to use this information or to share it for any purpose other than to provide services to us or on our behalf.
7.3. We may, for strategic or other business reasons, decide to sell or transfer all or part of our business. As part of that sale or transfer, we may disclose information we have collected and stored, including customer information, to anyone involved in that sale or transfer.
7.4. There may be times when we share information that does not directly identify you. For example, we may share anonymous, aggregated statistics about your use of our Website. We may also combine information about you with other customers and share or process this information in a way that does not identify you.
7.5. We have the right to use or share information as necessary to comply with any law, regulation, or legal request, to protect our Website, to bring or defend legal claims, to protect the rights, interests, safety, and security of our organization, our Customers and Guests, and our employees or users of the Website, or in connection with investigating fraud or other crimes, or violations of our policies.
7.6. In certain cases where you order services from third parties, we may provide such third parties with your information or personal data needed for them to make a reservation, conclude an agreement with you, assess their fees and charges, and generally provide you with the services promised by them. Those third parties are obliged to inform you of such disclosure of your personal data and information to them and to receive your consent before we provide them with the relevant information and data.
8. YOUR RIGHTS
8.1. Under the Data Protection Legislation, you have the right to request access to the personal data we hold about you, such as to be informed, upon your request, whether your personal data are subject to processing and to receive further information on such processing, including information on any transfers of personal data outside the EU and the appropriate or suitable safeguards we have in place for such transfer. As long as the requirements under the Data Protection Legislation are met, you may also request the correction of any inaccurate information we hold about you or the deletion of the same or restriction of the processing concerning your personal data. If such a request places us or our affiliates in breach of our obligations under any applicable laws, regulations, or codes of practice, then we may not be able to comply with your request, but you may still request that we block the use of your personal information for further processing. You may also have a right to data portability to another data controller under certain circumstances, as long as this would be technically and economically feasible. You may withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal. You may also lodge a complaint with the competent Data Protection Supervisory Authority (www.dpa.gr) If you believe that the processing is in violation of the law.
8.2. If you would like to exercise your aforementioned rights or if you have any questions or concerns about our Privacy Policy, please contact us at: auroraspetses@gmail.com.
LINKS TO OTHER WEBSITES AND SOCIAL MEDIA
9.1. Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, or any third party. If you follow a link to any of these websites, please note that these websites have their own privacy policies, and we do not accept any responsibility or liability for these policies or any processing conducted by such third parties. Please review these policies before submitting any personal data to these websites.
9.2. We may also have providers of other applications, tools, widgets, and plug-ins on our online services, such as Facebook “Like” buttons, which may also use automated methods to collect information about how you use these features. These organizations may use your information in accordance with their own policies, which we recommend that you read carefully.
10. CHANGES TO OUR PRIVACY POLICY
10.1. This Privacy Policy is effective as of the date noted at the bottom of this document. We may change this Privacy Policy from time to time. If we do so, we will post the revised version here and update the “Last Updated Version” date (the date it applies from) at the end of this document. You should check this link regularly for the most up-to-date version of our Privacy Policy, particularly before making a reservation at Aurora Spetses.
10.2. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email.
11. HOW TO CONTACT US
In order to protect confidentiality and your personal data, we may request that you provide us with identification credentials before responding to your request. Specifically, if we have reasonable doubts about your true identity, we may ask you to provide us with a copy of your police identification or passport, or information relating to your stay at Aurora Spetses, such as registration number, booking confirmation, check-in and check-out dates, or other useful information. If such information is not provided, we may refuse to respond to your request.
If you want to contact us about this Privacy Policy as well as for the exercise of your rights, you can reach us at auroraspetses@gmail.com.
12. LAW & JURISDICTION
This Privacy Policy is governed by and construed in accordance with the Laws of Greece, without regard to their choice of law provisions. The courts of Thessaloniki, Greece, will have exclusive jurisdiction over any and all disputes arising out of, relating to, or concerning this Privacy Policy, its interpretation, effect, and application.
