Protection of personal data of our clients is a priority for us. For this reason, FRESH HOTEL strives to comply with applicable laws and regulations related to Personal Data protection. This Policy sets forth the basic principles by which the FRESH HOTEL processes the personal data it collects
2. Basic Principles Regarding Personal Data Processing
Fresh Hotel as the controller strictly adheres to the data protection principles set out in Article 5 of the General Data Protection Regulation
2.1. Lawfulness, Fairness and Transparency
Fresh Hotel is processing Personal data lawfully, fairly and in a transparent manner in relation to the data subject.
2.2. Purpose Limitation
Personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
2.3. Data Minimization
Fresh Hotel holds the accurate personal data of the subjects and ensures that their observance is limited to what is necessary in relation to the processing purposes. At the same time, it applies the appropriate technical measures to achieve the above objectives.
Personal data that Fresh Hotel holds are accurate and, where necessary, up to date; All the required steps are taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified in a timely manner.
3. Collection of personal data
“Personal Data” is any information relating to an identified or identifiable natural person.
Fresh Hotel collects the following personal data:
- Name, Surname, email address, telephone number and home address
- Credit or debit card data, or other payment data
- ID or passport data (date and place of birth, nationality)
- Visitors’ data as dates or arrival and departure, special needs, comments in relation to services’ preferences, provision of services or other services used).
4. Purpose of processing
We process your personal data especially for the following purposes:
- Reservations: we process your personal data for making and completing your reservation
- Customer service: we process your personal data for your optimum service
- Marketing actions: We may also use your data for marketing purposes provided we have firstly secured your consent. In cases we use your personal data for direct marketing purposes as newsletters and promotional communications for new products and services or other offers that we believe may be of interest to you, we include an Unsubscribe link which you can use if you do not wish such messages from us in the future.
- Communication: There may be times when we may contact you by email, mail, phone or text message, depending on the contact information you have shared with us. This may take place for a variety of reasons:
- We may need to respond to and handle requests you have submitted to us.
- When you are using our services we may send you a questionnaire so as to to share with us your experience of your stay at Fresh Hotel. We believe that this additional service is useful for both you and us, since on the basis of your feedback we will be able to improve our services.
- Legal procedures and compliance: in some cases, we need to use the information provided, which may include personal data, for managing and resolving legal disputes or complaints, for regulatory inquiries and compliance, or for the implementation of the agreement(s), or for complying with legitimate requests from law enforcement authorities to the extent required by law.
5. Legal basis
Fresh Hotel processes legally your personal data provided the process:
- processing is necessary for the performance of our contract
- is necessary for Fresh Hotel’s compliance with a legal obligation or for the purposes of its legitimate interests arising from your contractual relations with the Company its other rights deriving from the Law.
- It is based on your consent. When personal data collection has as a legal basis your consent, Fresh Hotel has the obligation to guarantee that you, as data subjects give your consent freely, by affirmative action, expressly and by unambiguous indication of the content of the text you are consenting about. Fresh Hotel gives you the possibility to withdraw your consent anytime. Where collection of personal data of children under 16 years old, Fresh Hotel guarantees that before the collection the consent of the parents has been given. The processing of personal data must take place only for the purpose for which the data were initially collected. In case Fresh Hotel wishes to process collected personal data for another purpose, it must seek your consent with express and determined written format. Any such application must contain the initial purpose for which the data were collected, in addition for the new or additional purpose(s).
Fresh Hotel applies reasonable procedures to prevent access to and misuse of information, including personal data. We use appropriate business systems and procedures to protect information that includes personal data. We also apply security procedures and technical and physical limitations of access and use of personal data on our servers. Only authorized personnel have access to personal data in their work.
7. Relation of Fresh Hotel with Third Parties
Whenever Fresh Hotel uses a third-party supplier or business partner to process personal data on its behalf, it ensures that this processor will provide security measures to safeguard personal data that are appropriate to the associated risks.
Fresh Hotel strives to ensure that the supplier or business partner is processing personal data to carry out its contractual obligations towards Fresh Hotel or upon its instructions and not for any other purposes.
8. Data Retention
We keep your personal data, for as long as we deem necessary and reasonable to provide you with our services, to comply with applicable law, for the management of legal disputes, for the purposes of our business, including the detection and prevention of fraud or other illegal activities. All of the above personal data are subject to the present Personal Data Protection Policy. If you have questions about a particular period of retention of certain types of personal data, please contact us using the contact details below.
9. Rights of Access by Data Subjects
Fresh Hotel as a data controller, the company is responsible to provide data subjects with a reasonable access mechanism to enable them to access their personal data, and must allow them to update, rectify, erase, or transmit them.
9.1. Right of access
You have the right to be aware and verify the legitimacy of the processing. So, you have the right to access the data and get additional information about its processing.
9.2. Right of rectification
You have the right to study, correct, update or modify your personal data.
9.3. Right to restriction of processing
You have the right to request restriction of processing of your personal data in the following cases: (a) when you contest the accuracy of your personal data and until it has been verified, (b) when you object to the deletion of personal data, and you request instead of deletion, their limited use c) when personal data are not needed for processing purposes, however, they are indispensable to you for the foundation, exercise, support of legal claims, and (d) when you object to the processing and until it is verified that there are legitimate reasons that concern us and override the reasons why you are opposing to processing.
9.4. Right to object
You have the right to object at any time to the processing of your personal data where, as described above, it is necessary for the purposes of legitimate interests we pursue as data controllers.
9.5. Right to data portability
The Data Subjects have the right to receive, on request, a copy of the digital data they have provided to Fresh Hotel in a structured form and transfer these data to another controller. Fresh Hotel is responsible for ensuring that these requests are handled within one month, provided these claims are not manifestly unfounded. When exercising the right to data portability, the data subject has the right to request the direct transmission of personal data from one controller to another where technically feasible.
9.6. Right to be Forgotten
Upon request, the Data subjects have the right to request from Fresh Hotel the deletion of their personal data. Fresh Hotel will immediately take the required actions (including technical actions) to satisfy the request and will also secure it from any third parties using or processing personal data on its behalf. In cases of mandatory data processing required by law, this right is subject to specific restrictions or does not exist, as the case may be.
If you believe that any of your personal data that we hold is incorrect or inaccurate, you may request that you view this information, request it to be corrected or deleted. Please contact us through the Data Subject Access Form here.
10.Response to Personal Data Breach Incidents
When Fresh Hotel learns of a suspected or actual personal data breach, it shall immediately perform internal investigation and take appropriate remedial measures in a timely manner, according to the Personal Data Breach Policy. Where there is any risk to the rights and freedoms of data subjects, the Company notifies the Hellenic Data Protection Authority without undue delay and, when possible, within 72 hours.
If you have any questions or need clarification regarding the processing of your personal data by Fresh Hotel, please send your message to the email address email@example.com and will be happy to serve you directly.