This website is not intended for children and we do not knowingly collect data relating to children.
Personal data, or personal information, means any information about an individual, which can be used to identify that person. It does not include data where the identity has been removed (anonymous data).
We collect a variety of personal information about our guests, customers and visitors to our website.
This personal data falls into these categories:
We do not ordinarily collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) nor do we collect any information about criminal convictions and offences. The only exceptions to this are: (i) if you provide health data to us as part of a spa booking, we will use this to perform our contract with you, and we need your explicit consent to use your health data as part of that or (ii) you have made the special category data obviously public.
How we collect data
We may collect or receive data in lots of different ways.
You may give us data in person when you are a guest at one of our hotels, for example when you:
You may give us data remotely when you interact with us via this website, by post, phone or email, or through chat or social media, for example, when you:
We may get some data automatically, for example, we could collect data about your equipment, browsing or the way you use this website. We may also collect data when you click on one of our adverts (including the ones you see on third party websites or social media). The systems we use for guest management may also collect data automatically to help create a guest profile, which in turn gives us a better understanding of how we can improve your experience with us.
We may get some data from third parties as part of the booking process for our accommodation, hospitality, spa treatments or services at our hotels. For example, when you:
We may receive data about you from various other types of third parties, including:
How and why we use your personal data
We use your personal information in a number of ways, including providing and personalizing the services you request and expect from us, to offer you a high level of hospitality, conduct direct marketing and sales promotions and as set forth below in more detail. We will collect your consent prior to processing your data where required by applicable law.
We are obligated to collect certain data, including your name, address, payment information, and, in certain countries, travel document information, in order to process your reservation. Failure to provide this information will result in our inability to process your reservation. We may use your personal information to provide you with information about meeting and event planning. We may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages in accordance with any communications preferences you have expressed. We use your information to provide in-stay messaging, account alerts, and reservation confirmations and to send you marketing messages. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. We may also collect information from your payment card, which can be appended to personal information and used by us to recognize what type of card you have, the bank or network of the card, and present and/or send you targeted marketing messages based on your payment method and in accordance with your communication preferences. We may use your personal information to improve our services and to ensure that our site, products, and services are of interest to you. We may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better, more personalized service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Statement.
We may process your personal data for more than one legal basis depending on how we are using it. Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regards and take account of these rights.
If you choose not to give us your personal data
When you make a booking with us for accommodation, hospitality, spa treatments or other services, we may need to collect some of your personal data by law, or under the terms of a contract we have with you. This means that if you decide not to give us your data, we might not be able to provide the service, and may have to cancel your booking or gift shop purchase. We will let you know if this is the case at the time, so you can decide what you’d like to do.
Explaining the legal bases for using personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
When we are considering legitimate interests, we make sure we think about and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Unless it is necessary for a reason allowable in the GDPR, we will always obtain explicit consent from a data subject to collect and process their data. Where consent is given, a record will be kept documenting how and when consent was given. If the personal data is not obtained directly from the data subject, then this information will be provided to the data subject within a reasonable period after the data are obtained. Where the personal data collected and processed is required to fulfill a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a dining or room reservation cannot be made without a name, email address and credit card details.
If the personal data is required to be collected and processed to comply with the law, then explicit consent is not required.
Sharing your personal data
We may share personal data with the following categories of third parties:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not share your personal data outside Europe.
Cookies help us to provide you with a good experience when you use our website and also allow us to improve our website and services. We use the following categories of cookies:
The data received from our website cookies is anonymized data, therefore individuals cannot be identified.
We can use strictly necessary and functional cookies without consent. We gain your consent for other cookies via the banner that you see the first time you visit our website. You can choose not to consent. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
However, if you do not consent, or use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.
Please be aware that if you delete your cookies we will no longer know that you’ve opted out of online behavioral advertising, so our adverts can still appear to you on other websites.
If you do not wish to receive such cookies from us, please adjust your browser’s settings accordingly
Adjusting your browser’s cookie settings
If you are using Internet Explorer 11, 10, 9, 8, 7, 6
Choose Tools then
Select the Privacy tab,
Under settings, select Advanced
Check Override automatic cookie handling
Check and choose if you want to allow, block or be prompted for first and third-party cookies.
If you are using Internet Explorer 5.0 or 5.5:
Choose Tools, then
Click the Security tab
Click on Custom Level
Scroll down to the sixth option to see how cookies are handled by IE5 and change to Accept, Disable, or Prompt for action as appropriate.
If you are using Internet Explorer 4.0
Choose View, then
Click the Advanced tab
In Internet Explorer 3.0: You can View, Options, Advanced, then click on the button that says Warn before Accepting Cookies.
If you are using Chrome
At the top right, click More and then Settings
At the bottom, click Advanced
Under “Privacy and security,” click Content settings
From here, you can,
Turn on cookies: Next to “Blocked,” turn on the switch
Turn off cookies: Turn off Allow sites to save and read cookie data
If you are using Safari
Click Privacy, then do any of the following:
Always block cookies: Select ‘Block all cookies’
If you are using Firefox
Select Options from the right side of the drop-down menu.
Click Privacy & Security tab
In History, select the use custom settings for history option in the drop-down menu of the panel’s History section.
There will you will have the option to tick or untick, always use private browsing mode, remember my browsing and download history, remember search and from history, accept cookies from web sites or clear history when Firefox closes.
Advertising and marketing
You could see our adverts in lots of different places. If you see one of our adverts on a website and in social media, it may not be directed specifically at you and may simply be there because we’ve bid for the space.
You may choose to opt in to receive our newsletter on our website. We may also be able to send you relevant direct marketing about our hotel, services and events unless you choose to opt out when making a booking with us, visiting our hotel.
Here are some examples of our direct marketing activities which may be directed specifically at you:
We also work with partners to try and promote the reach of our adverts, using analytics and retargeting. To make sure the adverts you see on websites and social media are relevant, we use Tracking Data to see what you’ve looked at. Tracking Data, and in particular cookies, help us to do this by telling us which adverts will be most relevant to you and potential new guests on website and social media. The cookies used for this purpose are often placed on our website by specialist organizations – and this is also why when you’ve been on our website, you might see content from our website again. This includes retargeting.
Cookies can also tell us if you’ve seen a specific advert, and how long it’s been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you won’t find interesting.
Almost all the cookies that relate to advertising are part of third party online advertising networks. We do not control cookies which are set by advertising networks.
Any personal data in hard copy format will be kept in a locked filing cabinet, drawer or safe, with restricted access. Confidential paper records will not be left unattended or in clear view anywhere with general access. All electronic devices are password-protected to protect the information on the device in case of theft. Digital data is coded, encrypted or password-protected, on a network drive that is regularly backed up on and off-site. All members of staff are provided with their own secure login and password, and every computer regularly prompts users to change their password. Emails containing sensitive or confidential information are password-protected if there are unsecure servers between the sender and the recipient. The security of our computer and storage systems, and access to them, is continuously monitored.
How long we keep your personal data for
We will only keep your personal data for as long as we need to fulfill the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements.
To decide how long we should keep your personal data for, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or sharing 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.
By law we have to keep basic information about our guests and customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we may remove your identity from your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data: This enables you to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to withdraw consent: Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not shared with anyone who doesn’t have the right to receive it. We may also contact you to ask you for more information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you’ve made a number of requests. In this case, we will let you know and keep you updated.
How to contact us
Please be advised that the following terms and conditions apply when we receive and use your CV and your recruitment application to our Company. In particular, the Processing Manager is the company named Cronwell Hotels & Resorts (COMPANY), which has its registered office in Halkis 8A, 55535, Pilea, Greece, website: https://cronwellconsulting.com/.
By sending your CV and by this mean voluntary submission of personal data and information that includes your contact details and CV data, you consent to the storage, use, processing and transmission of such data for the purposes detailed below by COMPANY. This processing is necessary in order to manage your recruitment request and if you do not provide this data, we will not be able to manage it.
The purpose of the processing is the initial assessment of the candidate’s application, the examination of the application, the examination of the recruitment possibility, as well as the reassessment of the application at a later date for the recruitment of the same or another job position within the COMPANY, based on the evaluation of the candidate's curriculum vitae within the specified below foregoing time of the data holding.
No transmission of your personal data takes place by the COMPANY and its kept confidential.
By applying, you consent to the transmission and processing of your data by COMPANY for the above-described purpose. COMPANY takes the necessary measures to maintain your personal information secure both during transmission and processing procedures. The right to access and process the above personal data, which are in candidates’ database, maintained by the COMPANY, has only its appointed employees.
The personal data of candidates, who are not recruited, shall be retained for a period of twenty-four (24) months after applying for the purpose of any reassessment of the application for the same or similar job position that may occur within the COMPANY. After this period, the data is permanently erased/deleted.
You may at any time exercise the rights set forth in the REGULATION including the right to information and access, amend, erase (right to be forgotten), limitation of processing, portability and the right to object to the processing.
These rights are exercised by sending a letter to 22 Laertou street, 55535 Pilaia, Thessaloniki, Greece or via email to firstname.lastname@example.org.
If you exercise any of your rights, we will take all reasonable measures to satisfy your request within thirty (30) days of receipt of the request, after we have informed you either of your request satisfaction or of the reasons that prevent from this satisfaction.
Right to appeal to the Authority
You have the right to appeal to the Personal Data Protection Authority for issues concerning the processing of your personal data. For the Authority's responsibility and the way of complaint submission, you can visit its website (www.dpa.gr My Rights Submit a Complaint) where detailed information is available.