MENU CLOSE
BUY A
PROPERTY
OWNERS
AREA
BOOK NOW BOOK
CLOSE
RESIDENCES
HOTEL

Privacy Policy

1       Introduction

This Policy applies to the following companies: Aphrodite Hills Resort LTD, Property Management LTD, Services LTD, Tennis and SPA LTD hereinafter collectively referred to as “Aphrodite Hills” or “AH” as data controller of the personal data collected from this website.

Aphrodite Hills is committed to protecting the personal information collected when you use our website and other services. This Website Privacy Policy pertains to Aphrodite Hills website and sets out Aphrodite Hills commitment in protecting Personal Data and how that commitment is implemented regarding the collection, use, transfer and retention of Personal Data. This Policy is valid only for cases that we define the purposes and means of the processing, therefore acting as data controller.

2       Personal Data Collection and Use

Aphrodite Hills has designed a standard website contact form to initiate communication with any interested individual. This form is used for any inquiries or requests and it directs them to the appropriate division or staff member. Additionally, we provide Aphrodite Hills phone numbers for a more direct contact if required. Our landline phone calls are recorded for training and monitoring purposes, and our recordings are usually held for six months. In order to handle and address your inquiries and requests we might collect and store your name, email, telephone number and any other information you might choose to share with us. That information is strictly used to adequately respond to your inquiries or requests and will not be disclosed to third parties others than those mentioned in this policy or where disclosure is required or permitted by law.

Aphrodite Hills has implemented a customer’s account feature for the ability to book residences, to add golf reservations, other activities (fitness, spa, horse riding, etc.) and services (housekeeping, babysitting, baby care, etc.). The personal data needed in order to manage your account is your full name, email, password, country, communication preference and any other information you might choose to share with us. These data are processed only for the purpose they are received and not for any other purposes that are not mentioned in this policy. In case you wish to proceed with the payment for any of the aforementioned services, we will ask for your credit card details. These details are not stored by us but transmitted securely, through our trusted partner JCC Payment Systems Ltd, to the bank. For details of the transaction please refer to JCC Privacy Policy.

Aphrodite Hills has designed other services through the website such as requesting information on buying or renting properties in Aphrodite Hills resort area, to check the availability of residences, using golf, tennis, spa activities, wedding planning, book a table at the restaurant and dining services. For these purposes, Aphrodite Hills needs to receive your name, email address, phone number, country, the special offer you prefer and anything else you choose to share with us.

Aphrodite Hills also offers the ability to book a room in the “The Aphrodite Hills Hotel” through the website of Atlantica Hotel Management Limited (hereinafter referred to as “Atlantica”). If you choose to proceed with a booking reservation then you will be automatically redirected to the website of Atlantica who will be the controller of your personal data and therefore will be responsible to inform you respectively.

In case Aphrodite Hills and all the affiliates decide to use your personal data for different purposes than those described in this policy, e.g. marketing purposes (news, events, activities, new products and services offered by them, advertising campaigns and/or promotional activities) you will be informed and asked for your consent. In any case that a user of the service may wish to withdraw consent, we offer the ability through the emails that we send or by contacting our DPO. In such cases we also permanently delete the email address from our database.

For processing to be lawful under the General Data Protection Regulation (GDPR), we identify a lawful basis before we can process your personal data. In case you were directed to agree with this policy, the legal basis for the data processing effected by us is the granting of your explicit consent to the processing, by submitting the consent form only in case you agree with this policy.

3       Transfer of Personal Data

Aphrodite Hills may disclose Personal Data collected to our suppliers or subcontractors insofar as reasonably necessary for dealing with your inquiries or requests. Such transfers will be protected by appropriate safeguards (e.g. appropriate contractual clauses, data processing contracts, intra-group disclosures of personal data, etc.). In addition, we may disclose Personal Data where such disclosure is necessary for compliance with a legal obligation to which we are subject. In any case that we might need to transfer personal data at third parties, Aphrodite Hills is committed to ask for your consent if we will not recognize any other legal basis.

4      Children

Our website is not intended for children and we do not intentionally solicit or collect personal data from individuals under the age of 18. If we are notified or otherwise discover that a minor’s personal information has been improperly collected, we will take all commercially reasonable steps to delete that information.

In limited instances, we may have a campaign or program targeted towards children. In these instances, details on the information practices will be presented within the terms and conditions of the program or campaign.

5       Personal Data Retention and Deletion

Aphrodite Hills is committed not to retain personal data for a longer period than it is necessary regarding the reasons that the personal data was obtained and we will make sure we will delete it securely. For additional information on retention and deletion periods, please refer to Our Details section.

6       Rights of Data Subjects

In this section Aphrodite Hills addresses the rights deriving from Regulation (EU) 2016/679 and how these rights can be accessed from the Data Subjects. For any further clarifications please refer to Our Details section

7      Individual’s Right of Access or Rectification

Aphrodite Hills assumes that Personal Data collected directly from the individual will be accurate and complete. Individuals can access and update their own Personal Data using the Data Subject Request Form.

8      Individual’s Right to Erasure

The data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies. The Right to Erasure can be requested using the Data Subject Request Form.

Aphrodite Hills is obligated to erase personal data where one of the following applies:

  • personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • the data subject withdraws consent and no other legal basis for processing exists;
  • the data subject objects to the processing carried out on the grounds of the Data Controller’s legitimate interests and there are no other overriding legitimate grounds for the processing;
  • the personal data has been unlawfully processed.

If the request to erase Personal Data has been received, identity has been confirmed, the request meets one of the above requirements and there is no legal contrary reason for processing, Aphrodite Hills must delete the relevant data in its entirety. The request shall be recorded in the Data Subject Request Log.

If Aphrodite Hills cannot actually delete personal data, Aphrodite Hills will ensure that:

  • is not able, or will not attempt, to use the personal data to inform any decision in respect of any individual or in a manner that affects the individual in any way;
  • does not give any other organization access to the personal data;
  • protects the personal data with appropriate technical and organizational security; and commits to permanent deletion of the information if, or when, this becomes possible.

9      Individual’s Right to Restrict Processing

The data subject has the right to obtain from the controller restriction of processing using the Data Subject Request Form.

10    Individual’s Right to Object

Individuals have the right to object at any time to processing of their personal data using the Data Subject Request Form.

11     Individual’s Right to Data Portability

Upon request and provided that the relevant requirements stipulated in Article 20 of GDPR are met, a data subject should have the right to receive a copy of their Personal Data in a structured format using the Data Subject Request Form.

These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.

If Aphrodite Hills cannot respond fully to the request within 30 days, the DPO shall nevertheless provide the following information to the Data Subject, or their authorized legal representative within the specified time:

  • An acknowledgement of receipt of the request.
  • Any information located to date.
  • Details of any requested information or modifications which will not be provided to the Data Subject, the reason(s) for the refusal, and any procedures available for appealing the decision.
  • An estimated date by which any remaining responses will be provided.
  • An estimate of any costs to be paid by the Data Subject (e.g. where the request is excessive in nature).
  • The name and contact information of the contact person.

12       Amendments

Should Aphrodite Hills elect to change this Privacy Policy, in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our guests, properties, strategic marketing partners, and service providers, we will post the changes here. Updated versions will be posted to our web site and date stamped so that you are always aware of when the Privacy Policy was last updated. Where the changes are significant, we may also choose to email concerned users with the new details. Where required by law, will we obtain your consent to make these changes.

13       Our Details

If you have any concerns, questions or complaints about this policy, then please contact us at: info@aphroditehills.com

In case you have any concerns regarding the processing of your data by us such us violation of the applicable laws, you may file a complaint to the corresponding supervising authority. You can find the contact details for all EU Supervisory Authorities at:

http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

“By clicking the check box, you are confirming that you have read the Privacy Policy and that you are consenting to Aphrodite Hills holding and processing your personal data for purposes as described in this Policy.”