Villa Sophie takes your privacy extremely seriously. We are committed to protecting and respecting your privacy. Please read this policy as it contains important information about how we use personal data that we collect from you or that you provide to us.
When this policy mentions “booking system,” “booking engine,” “system,” “website,” “platform,” “app,” “services,” “online services,” it refers to all pages and functions under https://villasophie.gr/ unless specified otherwise. When this policy mentions “we,” “us,” or “our,”, “data controller,”, “controller,”, it refers to Villa Sophie.
For the purposes of the General Data Protection Regulation, Villa Sophie is the Data Controller and therefore we are responsible for your personal data. Villa Sophie is a company registered in Greece whose registered address is: Villa Sophie, Kalamaki, 29100, Zakynthos, Greece. The User may contact Villa Sophie at email@example.com. The User may also contact Villa Sophie’s Data Protection Officer at firstname.lastname@example.org. The Data Processor of Villa Sophie’s website is Set 2 Web (18 Kalvou street, 29100, Zakynthos, Greece). The User may contact Set 2 Web at email@example.com.
By accessing the website or providing information, you agree to our privacy practices as set out in this privacy statement. We may change this policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version.
2. Obligatory nature of providing the data
The data requested in the forms accessible from the website and the booking system of Villa Sophie 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.
3. Personal data we collect and process
Personal information we may collect from you and process includes:
• personal information about you which we ask you for (e.g. your name, phone and email address) when you make a booking through our website’s booking system or send a message through our website’s contact forms;
• financial details in order to process your booking when we require pre-payment / deposit;
• details of transactions you carry out through our booking system and details of the fulfilment of your orders.
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).
Our Services are not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Data through the Services.
4. 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.
• For marketing purposes in order to inform you of news, updates and any new services.
5. Data retention
Your Personal Data will be retained in accordance with our data retention policy which categorises all of the data assets held by us and specifies the appropriate retention period for each data asset. These periods are based on the requirements to keep the data for as long as necessary to fulfil the purpose for which it was collected, to meet any legal requirements or to satisfy any reporting, accounting or contractual needs.
6. 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.
7. Data disclosure
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.
8. Third parties
We may need to share your information with third parties in order to provide you with our services or to market to you, these third parties include:
• cloud services providers who host our website and systems
• third-party development teams who help develop and maintain the service
• payment card providers who handle transactions on our behalf
• third-party marketing organisations we work with
• information security providers who monitor the security of our website
Where we do share your information with third parties, Villa Sophie ensures that the highest levels of data protection are in place in accordance with the law. Third parties with whom we share data are only permitted to process this data for the specified purposes we stipulate with them.
We do not sell your information onto third parties.
9. International transfers
Where possible, we ensure that your data is stored within the European Economic Area (EEA), however some of our storage locations and service providers may be hosted outside of the EEA. When we do need to transfer your personal data out of the EEA, we ensure one of the following safeguards are in place to provide a similar level of security of your data:
• Your personal data has been transferred to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission; or
• The hosting environment we use has specific contracts, codes of conduct or certification mechanisms in-place which have been approved by the European Commission; or
• Where we transfer data to the United States, we ensure our providers are certified as part of the EU-US Privacy Shield programme.
If none of these safeguards are available, we will only transfer your data with your explicit consent – which can be removed at any time by contacting us.
10. User’s responsibility and rights
• 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.
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 data.
• 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 the 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 kindly ask that before any complaints are lodged, that you contact us first to try and resolve any issues you may have.
You may exercise any of these rights by raising a subject access request with us. We will not charge you for making a request and we will make all reasonable efforts to respond to you within 30 days. Sometimes it may take longer than 30 days to gather all the information we may hold on you, in this situation we will keep you updated at all times.
You can instruct us at any time to stop processing your personal data for the purposes of marketing.
We may refuse your request or withhold any personal information that you request if there is an overriding legal reason for us to do so.
11. Security Measures
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.
The cookies we use are Forms Related Cookies (When you submit data to us through a form cookies may be set to remember your user details for future correspondence) and Site Preferences Cookies (In order to provide you with a great experience on our website, we may provide the functionality to set your preferences for how this website runs when you use it. In order to remember your preferences, we may need to set cookies so that this information can be recalled whenever you interact with a page to meet your preferences).
Most browsers allow you to refuse to accept cookies and to delete cookies. The method for doing so differs with each browser, the following guides for the most common internet browsers detail the processes for doing this:
• https://support.google.com/chrome/answer/95647?hl=en (Google Chrome)
• https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Mozilla Firefox)
• https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)
• https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari)
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Microsoft Edge)
Blocking cookies may impact your experience on our website as you may not be able to make full use of the features on it.
We keep this policy under regular review. This policy was last reviewed on 2/6/2019.