This Privacy Notice will inform you as to how “POMERA ESTATES LTD” operating Margadina Lounge Hotel in Ayia Napa (hereinafter referred to as the “Company”, “we”, “us”, “our” and similar) collects and processes information about you and in particular your personal data and is respecting your privacy. We hereby assure you that this Policy fully respects and complies with EU Regulation 679/2016 and the relevant Law 125 / I / 2018 of the Republic of Cyprus.
Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, indicatively by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Regarding the personal data processing in cases we as a company determine the purposes and means of the processing, i.e. in cases we are the Controller is the legal personPOMERA ESTATES LTD, address 24, Kryou Nerou str. 5340 Ayia Napa, Cyprus, tel: +357 23815000, email: firstname.lastname@example.org.
Principles we adhere to
At Margadina Lounge Hotel, we are committed to and adhering to the following principles of processing personal data in accordance with Article 5 of the Regulation. The personal data are:
processed lawfully, fairly and in a transparent manner in relation to the data subject (principle of ‘lawfulness, fairness and transparency’);
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (principle of ‘purpose limitation’);
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (principle of ‘data minimisation’);
accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are rectified without delay (principle of ‘accuracy’);
kept in a form which permits identification of data subjects for no longer than it is necessary or as required by relevant Laws (principle of ‘storage limitation’);
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures (principle of ‘integrity and confidentiality’).
Finally, we are able to demonstrate compliance with the aforementioned principles (principle of ‘accountability’).
Collection of Personal Data
We as the Controller collect your Personal Data in the following cases:
When you contact us directly or indirectly through our collaborators, or through our webpage and Social Media accounts, in order to be informed regarding our services or ask relevant information, or to request an offer regarding our services;
If you receive our services, if you cooperate with us, or if you are involved in events related to the offer of our services;
If you fill in any of our documents or you lodge a grievance with us;
When your personal data is disclosed to us by third parties – partners under contracts or agreements;
When you are connected to our Wi-Fi or webpage or when vising our premises where a CCTV system is operating for security reasons;
When you are an employment candidate;
When you are one of our employees.
In addition, it is noted that we process personal data, which third parties, usually legal persons, disclose to us if we have the role of Processor on their behalf. In such case these Legal Persons hold the responsibility to properly inform you.
Minors’ Personal Data
We do not collect and process minors’ personal data without verifiable parental consent in cases when we are able to control it. For example, it is not possible to control information that is communicated to us online. In any event, if we find that we have collected any personal information from a minor without verifiable parental consent (in accordance with Article 8 of the Regulation), we will immediately delete the information from our records. If you believe we may have collected information from a minor, please contact our company.
Categories of Data Subjects
The categories of data subjects include:
Natural persons or legal persons’ executives interested in our services;
Natural persons receiving services from us or are related to the delivery of our services, or natural persons and employees of our suppliers and other legal persons cooperating with us;
Candidates for employment;
Kind of Personal Data we may collect about you
Data from the following categories of personal information about you may be collected and processed per case in order to serve the purpose of the data collection and in accordance with the relevant legal basis as described in this Policy:
Your contact details or of a natural person you may indicate instead of you (name, surname, address, telephone or fax number, email);
Occupational information (occupation, position);
Information necessary upon your arrival usually indicated in the Registration Card you have to fill in, such as contact details of you and persons accompanying you, nationality, date of birth, passport or ID number, dates of arrival and departure, and terms of stay.
Information related to terms of agreements (yours and persons involved) such us necessary part of the aforementioned information, terms, information in relation to preferences or requests and amounts;
Payment and transaction details (IBAN, account number, credit or debit card details, tax number, desired payment method, terms of payment etc.);
Incident investigation data, such as incident details, data of persons involved or witnesses, and related information during investigation;
Client history (satisfaction, transaction details, claims, problems, terms) and information related to assessing persons and situations;
Apps / websites / social media related data (cookies, full name or nickname, information you publicly disclose and comments on social media, or email attachments);
During your connection to our Wi-Fi we temporary receive your device IP or MAC address that is not stored after disconnection;
In case of events organised by third parties details of organisers, contact persons, names of participants, telephone numbers, e-mail, address, type of event, amount, preferences / special requirements, comments;
Your photo and only with your consent when attending our own events, or your image when you enter our premises where a CCTV system is operating due to security reasons;
Employment data and/or data referred in your Curriculum Vitae and data related to studies, competencies or previous working experience and any other related data if you disclose this information to us.
It is noted that we collect some more kind of personal data about our employees; they are informed throughout documents, manuals, policies and procedures and information internally provided.
Purposes of Processing & the Legal Bases of Data Processing
The processing of personal data is based on one of the “legal bases” as referred to in Article 6 of the Regulation (or Article 9 in case of special categories of personal data).
The legal bases on which the collection and processing of personal data is based (in most of the cases) are, the compliance in performing our contractual obligations, the compliance with our legal and statutory obligations, your consent, and the safeguarding our legitimate interests. For special categories of personal data, the explicit consent, the performance of obligations and the exercise of specific rights of the controller or data subject in the field of labour law and social security / social protection law and for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment. The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:
Consent: when you communicate with us in any way directly or indirectly as interested in our services, when you are interested in working to or cooperate with us, when you fill in some of our documents besides those necessary by the institutional framework, when informing you about our services in the context of our promotions, when you make a complaint, when you visit our social media accounts, when you are permitting us taking a photo of you, when you give us your business card.
Commitment to perform our contractual obligations: when you have agreed to receive our services, when you are our employee or collaborator, during the payment of our liabilities or when we are contacting you in the framework of a contract.
Compliance with our legal obligations: to comply with our legal obligations to all sorts of authorities such as labour law, regulatory authorities, tax, accounting, auditing, judicial authorities and agencies or in connection with our contractual obligations or during payment of our liabilities.
Safeguarding our legitimate interests: to improve our services, or when investigating and managing any potential incident, to receive our payment, for the assessment of persons and situations, and when your image is recorded in our legal CCTV system.
Our employees are informed about the processing purposes and the legal bases with specific documents internally provided.
Retention of Data Period
We store personal data for as long as it is required by the respective processing purpose and any other permitted linked purpose.
Data collected on the basis of contractual and legal obligations shall be retained after the expiry of the contractual and legal obligations as provided by the relevant institutional framework.
Personal Data included in offers that does not lead to a cooperation agreement is kept for 3 months.
Personal data related to our CCTV System are retained no more than 20 days.
Cookies are stored depending on their categories as you may be informed in our cookies policy linked to the present policy (please see below).
Personal data you disclose to us as candidates are stored for 12 months.
Our Wi-Fi does not store information after disconnection.
Data that may be needed for our legitimate interests as a Controller shall be kept until the reason for storing such data ceases.
Specifically, for the data we process based on your consent, these are kept from obtaining the consent until it is revoked or there is no longer need to store it.
Information that is no longer necessary is safely destroyed or anonymised. We limit access to your personal data to those employees who need to use it for the specific purpose.
How we ensure the security of Personal Data
We have received reasonable organizational and technical measures to protect the personal data we collect, and in particular any specific categories of personal data. We follow international standards and practices to ensure the security of our networks. We ensure you that your personal data is processed securely and legally, by adhering to policies and developing and implementing procedures in accordance with the purposes and legal bases of processing. For example, the following security measures are used to protect personal data against unauthorised use or any other form of unauthorised processing:
Access to personal data is restricted to a limited number of authorised employees under a need to know basis, and the necessary data transfer is done by secure procedures.
Our employees are bound to confidentiality clauses and agreements, with limited classified access to the necessary data only.
We select trusted collaborators who are bound in writing, in accordance with Article 28 of the Regulation, with the same obligations regarding the protection of personal data. We reserve the right to audit them in accordance with Article 28 (3) (h).
In our Information and Communication Technology systems used for the processing of personal data, all reasonable technical measures are taken to prevent loss, unauthorised access or other illegal processing.
In addition, access to these ICT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet or a web site cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.
Some of the security measures we take are not announced for obvious reasons.
To whom the Data may be disclosed
We take measures to ensure that the recipients of personal data are kept to a minimum. The personal data we process as Controller are disclosed to third parties, provided that the legality of such disclosure is fully justified. Specific personal data from those we lawfully process as the Controller, may be accessed by (or disclosed to) on a case-by-case basis by:
Any relating supervisory authority within its role;
Any public or judicial authority where required by law or judicial decision.
Systems’ administrator bound to strike confidentiality clauses.
The accountant and the auditor of the company, and only in relation to necessary financial data.
The advocate, for whatever data is required in legal cases, under confidentiality.
The cooperating Insurance company and only for the relevant part of the information.
Partner banks (of the company, the staff or affiliates and suppliers), only for payment related data.
The GDPR and Information Security System consultant in relation to minimum but necessary parts of information and data.
The personal data we collect is processed within the European Economic Area (EEA). We do not transfer as the Controller personal data to third countries or International Organisations.
Your rights as a Data Subject and how you can exercise them
You have the right to be informed, the right of consent if it is the legal basis for the processing, the right of access to your personal data, the rights of rectification and erasure (in cases it is permitted), the right to restriction of processing, the right to data portability, the right to object. If processing is based on your consent you may withdraw it at any time.
The right to be informed is exercised through this privacy and personal data protection notification. In some cases it is also mentioned on documents and forms we are using. You may ask a hard copy of our policy by communicating with us.
The right of consent is been provided to you by design when necessary (when there is no other legal basis related to the collection of information).
We inform you that we are not using software of decision making solely based on automated processing, including profiling.
More specifically, you have the following rights as applicable per case, provided that you will exercise them in writing and after the verification that you are the data subject.
Right of access: you have the right to obtain from us confirmation as to whether or not your personal data are being processed as well as other relevant information, and, where that is the case, access to your personal data.
Right of rectification: you have the right of rectification of your inaccurate personal data as well as to have incomplete personal data completed by providing a supplementary statement.
Note: Since it is not possible for us to be aware of any changes to your personal data if you do not inform us, please help us keep your information accurate by informing us of any changes to your personal information we do process.
Right to erasure (‘right to be forgotten’); we have to positively answer such right when:
your personal data are no longer necessary in relation to the purposes for which we collected it;
you withdraw your consent on which the processing is based and where there is no other legal basis for the processing;
your personal data have been unlawfully processed;
your personal data have to be erased for compliance with a legal obligation we are subject to;
your personal data have been collected in relation to the offer of information society services.
We reserve the right to refuse this right if the processing is necessary for compliance with any legal obligation we are subject to, or for reasons of public interest, or for the foundation and exercise or support of our legal claims (according Article 17 § 3, GDPR).
Right to restriction of processing; you have the right to restriction of processing when:
you contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
we no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
you objected to processing pending the verification whether our legitimate grounds override those of yours.
Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and under an explicit request such data to be transferred to both you and another natural or legal person who will process it.
Right to object: you have the right to object to the processing of your data at any time when the reason for the processing relates to direct marketing.
In the event that you make such request in a written or electronic form regarding any of the above rights, we will assess your request and respond within one month of its receipt, either for its satisfaction or to provide you with objective reasons preventing it from being satisfied, or, given the complexity of the request and the number of requests at the given time, request from you an extension of response for a further two months period (according Article 12.3 of the Regulation).
The exercise of your rights is free of charge. Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to answer or charge you an administrative fee.
If you are dissatisfied with the use of your data by us, or our response after exercising your rights, you have the right to lodge a complaint with a supervisory authority.
Personal Data Breach
In the event of a breach of the security and integrity of the personal data processed, we will take the following measures in accordance with Article 33 and 34 of the Regulation in case we are the Controller and we will:
Assess it in order to implement the appropriate procedures needed to limit the breach;Examine the extent of the breach and the sensitivity of the data included;
Evaluate the risk and its impact on your rights and freedoms;
Endeavour to reduce as much as possible the damage that is or may be caused;
Notify within a time limit of 72 hours of becoming aware of the breach, the National Personal Data Protection Authority, if required;
Assess the impact on your privacy and take appropriate measures to prevent the repeating of the incident.
In the event we are the processor, we will inform the Controller as soon as possible.
Links to other Websites
Cookies are simple text files downloaded to your computer or mobile device when you visit a website. There are many different categories and types of cookies.
We only use session cookies that are essential for uniqueness. We do not use any other type of cookies. These cookies however are not identifying you and are not storing any information after disconnection.
Most browsers allow you to change your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful; otherwise you should use the “Help” option in your browser for more details.
Cookie settings in Internet Explorer
Cookie settings in Firefox
Cookie settings in Chrome
Cookie settings in Safari web
Contact details with the National Data Protection Authority
Cyprus Personal Data Protection Authority, 1 Iasonos Street, 1082 Nicosia, telephone +357.22818456, e-mail: email@example.com.
Additional information and terminology for the Regulation can be found at https://eur-lex.europa.eu/legal-content/EL/TXT/?uri=celex%3A32016R0679.
Contact with us
If at any time you want to contact with us or to make a request regarding your rights or any other matter relating to the protection of personal data you may contact with our Personal Data Coordinator: address 24, Kryou Nerou str. 5340 Ayia Napa, Cyprus, tel: +357 23815000, email: firstname.lastname@example.org.
This policy was updated and is effective from October30, 2020, and will be reviewed when there is a significant change. This review will be available on our website, with a note of the effective date. You may find a hard copy of this policy at our premises or may be dispatched at your request.