Privacy Policy

PRIVACY POLICY-VILLA FRYDI

 

Effective date: 20 February 2020

 

INTRODUCTION

 

Villa Frydi (“Villa Frydi”, “Us” or “We”) operates the www.villafrydi.gr website (“Website” or “Service”). We respect the privacy of any person visiting the Website (“User”). We are thus committed to ensuring that your privacy is protected.

This Privacy Policy lays out the main framework regarding how we collect, process and store your personal data when you visit or make a booking from www.villafrydi.gr (the “Site”), in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR), as well as any applicable national laws and regulations in effect regarding data protection. By using the Website, you agree to be bound by this Privacy Policy, you agree to the collection, use and disclosure of information in accordance with this policy and hereby accept the procedures and practices stated in this herein.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from the Website.

 

SCOPE

This Privacy Policy applies only within the Website and other pages where this policy appears. This would describe and explain how we take care and handle your personal information you shared to us. By accepting the Privacy Policy and the Terms & Conditions, you expressly consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

 

PERSONAL DATA THAT WE PROCESS

 

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

 

We collect Device Information using the following technologies:

 

– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

 

– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

– “Data Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

 

  • “Data Processors” (or Service Providers) “Data Processor” (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
  • -“Data Subject” (or User) is any living individual who is using the Website and is the subject of Personal Data.

 

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, payment information (including credit card numbers, paypal codes), email address, and phone number. We refer to this information as “Reservation Information.”

 

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Reservation Information.

 

 

PURPOSE OF DATA PROCESSING

We process the Order Information that we collect in order to fulfill any orders placed through the Site (including processing your payment information, arranging for your reservation, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

 

  • Screen our reservations for potential risk or fraud; and
  • Communicate with you for advertising purposes relating to our products or services, provided that you have clearly and explicitly consented for such communication. (For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.)

 

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, to assess the success of our marketing and advertising campaigns) and for marketing/retargeting purposes.

 

 

INFORMATION COLLECTION AND USE

 

We collect several different types of information for various purposes to provide and improve our Service to you.

 

Types of Data Collected Personal Data

If you attempt to use the services and applications of our website and/or choose to provide information to us, this website shall collect Personal Identification Information from you (“Personal Data”). Once collected, we will safely store your information for a reasonable period of time. The information collected includes, but is not limited to:

 

  • Email address, personal or business
  • Email address, personal or business
  • Full name
  • Telephone number(s) residential or/and business, including mobile phone number(s), fax number(s) etc.
  • Skype name, ICQ number, Viber number etc.
  • Full Address (es), residential or/and business, including State, Province, ZIP/Postal code, City, Country
  • Usage Data
  • Cookies
  • Information relating to any transactions carried out between you and the Website or in relation to the Website, including information relating to any purchases you make of our goods or services
  • Information that you provide to us for the purpose of registering with the Website
  • Information that you provide to us for the purpose of subscribing to Website services, email or SMS notifications and/or newsletters
  • Any other information that you choose to send to us

 

Use of Data

 

Information gathered from any web pages of the Website may be used for:

 

  • Website provision, maintenance and administration
  • Internal record keeping purposes
  • To gather analysis or valuable information so that we can improve our products and services
  • Website customization according to your needs and interests
  • Enabling your use of the services available on the Website
  • Sending to you goods or providing you services purchased via the Website
  • Sending statements and invoices or collecting payments from you
  • Sending you email notifications or newsletters which you have specifically requested
  • Contacting you with newsletters, general commercial communications, promotional material, marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
  • Sending you service updates
  • Providing third parties with statistical information about our users (this information will not be used to identify any individual user)
  • To detect, prevent and address technical issues
  • To provide customer support, to deal with enquiries and complaints made by or about you relating to the website
  • Marketing research purposes Personally Identification Information are never released, sold or leased to any unaffiliated third parties (individuals, companies or organizations) for any reason without the approval of the User at the time of collection, except if required by law.

The administration and protection of personal data are subdued to Greek and international laws.

 

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are from the European Economic Area (EEA), Villa Frydi legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. Villa Frydi may process your Personal Data because:

 

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it’s not overridden by your rights
  • For payment processing purposes
  • To comply with the law

 

RETENTION OF DATA

Villa Frydi will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Villa Frydi will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

 

TRANSFER OF DATA

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Greece and choose to provide information to us, please note that we transfer the data, including Personal Data, to Greece and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Villa Frydi will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

DISCLOSURE OF DATA

We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy policy. In addition, we may disclose your personal information:

 

  • To governmental agencies to the extent that we are required to do so by law
  • In connection with any legal proceedings or prospective legal proceedings
  • To the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this privacy policy, we will not provide your information to third parties.

 

DISCLOSURE FOR LAW ENFORCEMENT

Under certain circumstances, Villa Frydi may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

LEGAL REQUIREMENTS

Villa Frydi may disclose your Personal Data in the good faith belief that such action is necessary to:

 

  • To comply with a legal obligation
  • To protect and defend the rights or property of Villa Frydi
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

 

USAGE DATA

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information about your computer and about your visits to and use of this website such as your computer’s Internet Protocol address (e.g. IP address), geographical location, browser type and version, operating system, referral source, the pages of the Website that you visit, website navigation, length of visit, the time and date of your visit unique device identifiers and other diagnostic data).

 

YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Villa Frydi aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

 

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Villa Frydi relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

NEWSLETTER

 

If you wish to receive a newsletter we need to save and use your e-mail address. We will then send electronic messages at appropriate intervals to the e-mail address you gave us, which may also contain specific advertisements along with information on our products. However, you can unsubscribe at any time by e-mail you request to info@villafrydi.gr.

 

 

DURATION OF DATA RETENTION

The Company will only keep your personal data for as long as necessary to fulfill the purposes for which they were collected. 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.

 

SHARING YOUR PERSONAL INFORMATION

 

We share your Personal Information with authorized third parties to help us use your Personal Information, as described above. We use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

 

Additionally, please note that your information might be transferred outside of Europe, including Canada and the United States, as long as these jurisdictions provide an adequate level of data protection.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

 

ACCESSING AND UPDATING PERSONAL INFORMATION

When you use our services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services have different procedures to access, correct or delete users’ personal information. We do retain personal information from closed accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our policies and take other actions otherwise permitted by law. You may request details of personal information which we hold about you at any time by writing to info@villafrydi.gr. Provision of such information will be subject to:

 

  • Payment of a fee
  • The supply of appropriate evidence of your identity

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

 

 

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

ANALYTICS

We may use third-party Service Providers to monitor and analyze the use of our Service.

 

GOOGLE ANALYTICS

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

 

BEHAVIORAL REMARKETING

Villa Frydi uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

 

GOOGLE ADWORDS

Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

 

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

 

BING ADS REMARKETING

Bing Ads remarketing service is provided by Microsoft Inc. You can opt-out of Bing Ads remarketing by visiting:

 

https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

 

FACEBOOK

Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

 

To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

 

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

 

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

 

PAYMENTS

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

 

The payment processors we work with are:

 

PayPal or Braintree

 

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full .

 

EXTERNAL WEBSITES

The Website may contain links to external websites of affiliates and/or websites of interest that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. Villa Frydi has no control and is not responsible for the content of any external sites the Website is linking to or linked from. External sites or services that may be accessible through the Website have separate, independent data and privacy practices, and therefore we disclaim any responsibility or liability for their content, policies, practices or actions. You are strongly advised to examine the privacy policy as well as the terms and conditions of any external sites before visiting and disclosing any personal information. Please contact those vendors and others directly if you have any questions about their privacy policies.

MINORS

The Website does not address and is not intended for visitors that are minors or under eighteen (18) years of age. Villa Frydi does not knowingly solicit or collect information from individuals under the age of eighteen (18). If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us If we determine that we have inadvertently collected personal information from someone under eighteen (18) years of age, without verification of parental consent we will take reasonable steps to purge this information from our systems. We encourage parents and guardians to spend time online with their children and to participate and monitor the Internet activities of their children.

 

POLICY AMENDMENTS – NOTIFICATION OF CHANGES

Villa Frydi reserves the right to change or update this Privacy Policy by posting the policy in this page at any time without further notice. All Privacy Policy changes will take effect immediately upon their posting on the Website. We will update the “effective date” at the top of this Privacy Policy. Please check the Website periodically for any changes to this Privacy Policy. We may also notify you of changes to our privacy policy by email. Please ensure that you have added info@villafrydi.gr to your email client safe list to assure that you receive any privacy policy updates. Your continued use of the Website and/or acceptance of our e-mail communications following the posting of changes to this Privacy Policy will constitute your acceptance of any and all changes.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

 

RIGHTS OF DATA SUBJECTS

Υou have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. You have the right to request to see a copy of the data records we hold about you and to request corrections or deletions.

 

AMENDMENTS

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

 

SECURITY

 

We employ technical and organizational security measures to guarantee that your data is protected from loss, incorrect modifications and unauthorized third-party access. To the greatest extent possible, we ensure that only authorized persons have access to your personal data and only insofar as it is necessary in the scope of the above-mentioned purposes.

 

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to file a complaint, please contact us by e-mail at info@villafrydi.gr or by visiting the Contact page on our website.