COSTA NAVARINO Privacy Notice - Last Updated February 2023
Contents
Information We collect
about you
Why do We process your
personal data?
With whom do We share
your personal data?
How to Exercise Your
Rights/DPO details
Complain to the Hellenic
Data Protection Authority
TEMES S.A. (hereinafter ‘’We’’ ‘’Our’’ ‘’Us’’) is the operator of Costa Navarino and is a leading investor, and developer in the high-end tourism and real estate sector in Greece. We are the data controller of your personal data collected through this Application, unless an explicit reference to another data controller is made. Please find below Our contact details:
Head office
5, Pentelis Street
17564 PALEO FALIRO, ATTIKI, GREECE
Tel.: +30 211 0160200, 210 9490200
Email: info@temes.gr
A. Information we collect directly from you while using the Application:
While you are using this Application, the following types of personal data are being collected directly from you:
Full name
Room number
Date and time of booking
Nationality
+and any other information provided for a specific booking activity (for example your dietary restrictions).
In addition, We create and retain authentication and activity logs and traffic data (type of device, date and hour of connection to the Application, your mobile operating system, IP address etc.) generated automatically through your use of the Application.
B. Information We process from other platforms
We also process personal data you directly provide in other Costa Navarino-related platforms (like the platforms of our processors that allow you to book golf or spa activities) and data you directly provide to affiliated third parties who provide you the services you have booked via Our Application. We do this to ensure We will inform you about events or activities that you are actually interested in and to enhance your stay.
We process your personal data:
ü to allow you to subscribe to the Application as user
ü to authenticate you when you log in the Application
ü to ensure the secure use of the Application
ü to remember your preferences and registration information
ü to book one of the available activities/services via the Application
ü to provide you with the history of your bookings
ü to inform you about our services and offers (only if you consent)
ü to analyze data in order to improve Our Application and enhance your digital experience.
We rely mainly on the necessity of the above processing activities for the performance of Our contract with you to offer you the available services within the Application. For direct marketing purposes We rely on your consent, while in the context of conducting data analysis, We rely on Our legitimate interests to provide you with a seamless digital experience.
1) We share your personal data with entities that act on Our behalf (hereinafter ‘’ Processors’’) only to the extend this is necessary for the provision of Our services. Specifically:
-We make use of expert third-party service providers (namely m-hospitality IKE) to develop and improve the Application.
-To allow you to book activities via Our Application, We collaborate with Triparound, INNOPOLIUM I.K.E. (for restaurant reservations), Golf Manager (for golf reservations) and EUROTEL (for spa reservations), each of which acts as Our Processor. The contact details of these Processors are provided in the table below:
|
Name of Processor |
Contact Address |
Email |
Telephone number |
|
Triparound Inc. |
555 Bryant Street #558, Palo Alto, CA 94301, US |
hello@triparound.com |
US Phone: +1 (650) 30 40 501; GR Phone: +30 (210) 700 6315 |
|
INNOPOLIUM I.K.E. (i-host) |
28 Octovriou 2, Chalandri,Athens, 15238 |
contact@i-host.gr |
+30 211 212 84 25 |
|
EUROTEL HOSPITALITY S.A (Aphrodite) |
Velestinou 11, Neo Irakleio, Athens, 14122 |
info@eurotel.gr |
+30 2106595000 |
|
Golf Manager S.L |
P.º de la Castellana, 153,
28046 Madrid |
info@golfmanager.com |
+34 636 23 60 52 |
-To allow you to book golf-related activities, you will be redirected to the Golf Manager platform, in which you will be asked to subscribe separately from Our Application. Please note that this Privacy Notice addresses only the use and disclosure of information We collect through your interaction with Our Application. We encourage you to familiarize yourself with the privacy notice provided by Golf Manager prior to providing it with your information.
2) We do not provide all available activities/experiences by ourselves. In some cases, We use affiliated third parties to provide you with the requested service. In such cases We also share your personal data with the relevant third parties. For instance, if you have booked a scuba diving class, We will share your data with the provider of scuba diving to provide you with the booked activity. Please note that the affiliated third parties act as independent controllers, and We have no control over their processing activities.
3)We also may disclose your personal data to government or law enforcement authorities, where required by applicable law in order to comply with any court order or other legal obligation.
The Application is not intended for use by minors (as defined by applicable law) under the legal age of 15. If a minor provides us with its data without parental or guardian consent, this information will be deleted, unless the parent or guardian instruct us to do otherwise. If you believe that We might process information directly received by a minor, please contact us at dpo@costanavarino.com .
We do not transfer your personal data outside the EEA.
The length of time We retain your personal data varies depending on the type of information and its use. We will only keep your personal data for as long as it is necessary to provide the services and/or activities you have requested, or until you withdraw your consent, in cases We rely on it. When your personal data is no longer necessary, it will be securely deleted or anonymised.
According to applicable legislation, you have the following rights:
a) right of access: you have the right to be informed about the processing of your data and if this is the case to receive a copy of your data.
b) right of rectification: you have the right to ask us to correct any information We process about you that you think is inaccurate (i.e., wrong email address). You also have the right to complete information you think is incomplete.
c) right to restriction of the processing of your personal data: you have the right to request the restriction of processing in certain circumstances. For example, you have the right to request from the Company not to delete data that you consider necessary for the establishment, exercise or defense of legal claims.
d) right to erasure: you have the right to request the deletion of your data in certain circumstances.
e) right to object: you have the right to object to the processing of your data in certain circumstances
f) your right to withdraw consent: If We process your personal data based on your consent, you have the right to withdraw consent at any time.
You may exercise the aforementioned rights by submitting a request to Our appointed Data Protection Officer (‘DPO’). We will reply within one (1) month upon receipt of the request. This deadline might be extended for two (2) additional months, in case your requests are excessive or complicated. Please find below Our DPO’s contact details:
Data Protection Office
TEMES S.A.,
5 Pentelis str.,
P. Faliro, 17564
E-mail: dpo@costanavarino.com
Tel: +30 210 9490249
In case you deem that We have not duly satisfied your request
and the protection of your personal data is somehow affected, you may lodge a
complaint through the dedicated online portal of the Hellenic Data Protection
Authority (Athens, 1-3 Kifissias Avenue, 11523 Athens, Greece | +30 210
6475600). You may find detailed guidelines on how to lodge a complaint on the DPA’s website.