This Privacy Policy provide information and explain the way our group of companies using the trade name “Mitsis” (hereinafter “Mitsis”) and our partner TripAround, Inc. (“we” or “us” or “our”) process the personal data of our customers (hereinafter “Customer/s”, “Guest/s” or “you”) and the visitors of our website (hereinafter “you”), when ordering, booking or requesting an experience through this platform powered and operated by TripAround, Inc., such as a travel activity, spa treatments, tours, sporting activities, restaurant reservations, and other similar travel or tourist activities. It sets out the basis on which any personal data collected from you through this platform or that you provide to us therein, will be processed by us and TripAround, Inc.. Please read the following carefully, in order to understand our views and practices regarding your personal data and how we will treat them.
We would like to underline at this early stage that services provided through TripAround, Inc.’s platform are considered third party services, according to article 13 of our General Terms and Conditions (found in https://www.mitsishotels.com/terms/). As a consequence, you may order, book, request such third party services at your own free will, choice and responsibility. Mitsis and the Hotel shall not be held liable for any damage, injury or accident any Guest may incur by using such third party Services. Our Customers use such third party services at their own risk and responsibility.
Definitions included in this Privacy Policy shall have the meaning assigned to them in the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, which together with Greek Law and the regulatory framework applicable in Greece shall constitute the Data Protection Legislation.
Controllers are all the hotel companies of Mitsis , which are:
1) XENODOXEIA ELLADOS - MITSIS COMPANY SA, Kiotari, 85109, Genadi, Rhodes, Greece;
2) Κ. MITSIS X.Τ.Ε. S.A., 12, Filotheis Street, Galatsi, 11147, Athens, Greece;
3) FALIRAKI Α.X.Ε., Faliraki, 85100, Rhodes, Dodecanese, Greece;
4) THOLARI S.A., 12, Filotheis Street, Galatsi, 11147, Athens, Greece;
5) DIAGORAS Α.X.Ε., Faliraki, 85100, Rhodes, Greece;
6) PANEVROPA Α.X.Ε., Panagia Anissaras, 70014, Anissaras Chersonisou, Heraklion, Crete, Greece;
7) XENODOCHIAKES & TOURISTIKES EPICHIRISEIS KORALI S.A., 28, G Papanikolaou Street, 85100, Rhodes, Dodecanese Greece;
8) GRAND HOTEL SUMMER PALACE S.A., 1, Akti Miaouli Street & Papanikolaou Street, 85100, Rhodes, Dodecanese, Greece
9) GALINI X.T.E.E. S.A., 5, G. Vasiliadi Street, 35008, Kamena Vourla Fthiotidas, Greece; and
10) K.MITSIS FILOXENIA S.A., 12, Filotheis Street, Galatsi, 11147, Athens, Greece, which, also, acts as the primary Processor for Mitsis .
Processor: For the services of this platform the basic and main processor is the company with trade name TripAround, Inc. a California Corporation with offices located at 300 Hamilton Avenue, Palo Alto, CA 94301, USA (hereinafter referred to as “TripAround”).
We are committed in preserving the privacy of all visitors to https://www.mitsishotels.com/privacy-policy-table-res/ and in protecting any personal information that you may provide to us.
We provide this Privacy Policy to help you understand what we may do with any personal information that we obtain from you or for you. Personal information may include information about an identifiable individual, as defined by Data Protection Legislation, such as name, addresess, e-mail address, telephone numbers, passport numbers, national ID card numbers, drivers’ licenses numbers, travel interests, travel activities as well as other related information.
By providing your personal information to us, you signify your acceptance of this Privacy Policy and agree that we may collect, use, and disclose your personal information and data as described in this Privacy Policy. If you do not agree with this notice and / or this Privacy Policy, please do not provide your personal details and data to us. However, you may need to do so, if you want to make use of the services provided therein.
1. INFORMATION & PERSONAL DATA WE COLLECT
1.1. We may collect personal information about you when you use this website – TripAround’s platform or the services provided therein and in any other way you may otherwise interact with us. The information we collect falls into the following categories: (a) information you provide us either during the process of booking or ordering services and checking in our hotels or through the website of TripAround’s platform or other promotion and marketing methods; (b) information we collect through automated methods; and (c) information we collect from other sources.
1.2. We may combine the information you provide us with information collected through automated methods or with information we receive from other sources.
1.3. We collect information you provide us. You may provide the following information to us:
1.3.1. Personal data and details you provide us in your order through TripAround’s platform or the Registration Form during your check in at one of our hotels or any other type of personal data, which you provide to us, when you choose to communicate with us or use the services of TripAround’s platform;
1.3.2. Personal details, when you register with TripAround’s platform and/or our a Mobile Application, log-in to Wi-Fi, enter one of our competitions or contact us by phone or through our online services;
1.3.3. Transaction, information, including information about the services you book, prices, method of payment and payment details;
1.3.4. Account information, such as your username or password (or anything else that identifies you) used to access our online services or to buy or use our products and services;
1.3.5. Email and other contact details following your consent;
1.3.6. Profile information and preferences, after your prior consent, including products and services you like, the time you prefer to visit us, experiences information relating to the services ordered or provided through TripAround’s platform, activities and other related information, as well as food and beverages preferences or any other preferences provided through the use of such services and any other source of information legally collected by third parties or according to your approval and during your stay in any of our hotels or your use of TripAround’s platform; and
1.3.7. Other personal information you choose to give us when you interact with us.
1.4. We collect information through automated methods. In this context, we may use automated technology to collect information from your computer system or mobile device when you visit our restaurants, use our online services or in-restaurant technology. Automated technology may include cookies, local shared objects, and web beacons. There is more information below about cookies and other technologies.
1.5. We may collect information about your:
(a) internet protocol (IP) address;
(b) computer or mobile-device operating system and browser type;
(c) type of mobile device and its settings;
(d) unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device;
(e) device and component serial numbers;
(f) advertising identifiers (for example, IDFAs and IFAs) or similar identifiers;
(g) referring website (a site that has led you to ours) or application;
(h) online activity on other websites, applications, or social media;
(i) communications to us or regarding us on social media; and
(j) activity related to how you use our online services, such as the pages you visit in TripAround’s platform or in our mobile apps.
1.6. TripAround’s platform may collect information about the exact location of your mobile device or computer using geolocation and technology such as GPS, Wi-Fi, Bluetooth or cell tower proximity. For most mobile devices and computer systems, you are able to withdraw your permission for us to collect this information by using the device or web-browser settings. If you have any questions about how to prevent us from collecting exact information about your location, we recommend you contact your mobile-device service provider, the device manufacturer or your web-browser provider. Our Website may not work properly without information about your location. If you would like us to delete information we have collected, which could identify your location, please contact us at the address, phone number or email address below.
1.7. We may collect information about you from other companies and organizations as well as partners or suppliers of services, such as information transmitted from third parties, like the third parties that provide services through TripAround’s platform. We may also collect information that is publicly available. For example, we may collect information about you when you interact with us through social media.
2. COOKIES
We may obtain information about your general internet usage by using a cookie file, which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and our platform and to deliver a better and more personalised service. Some of the cookies we use are essential, in order to be able to operate our website and the platform. Please note that our advertisers may also use cookies, over which we have no control. For more information on the way we use cookies, please refer to our Cookies Policy.
3. PURPOSE & USE OF THE INFORMATION & PERSONAL DATA
3.1. We use information collected, stored and processed about you in the following ways:
3.1.1. In order to provide our services to our Customers and for administration & business purposes.
In order to manage your order, booking, request or any other services provided through TripAround’s platform, we will collect, use, share, transfer, process and store the personal data you provide to us. This processing is necessary for the performance of our obligations towards our Customers, to provide you with information or services and in order to communicate with you, either following your request or otherwise required to do so. In addition, we will use your personal data, in order to provide our services to you and receive payment for such services, for internal Customer administration as well as business purposes, in order to provide you with the information or services you have requested and to improve our services, products or procedures.
3.1.2. For Marketing Communications.
With your consent, we may collect, use, share, transfer, process and store your personal data in order to communicate with you with regard to newsletters, promotions and featured specials, as well as other marketing material, messages and dedicated offers. You can withdraw your consent at any time by following the opt-out instructions in the marketing communications we send you. You can also withdraw your consent by contacting us at the contact details of our DPO ([email protected]). If you do opt out of receiving marketing communications from us, we may still send communications to you about your transactions.
3.1.3. In order to operate our website or the platform.
We will process your personal information in order to ensure that content from our website or TripAround’s platform is presented in the most effective manner for you and for your computer as well as for marketing and promotion of our services and products or services of third parties. Additionally, we may process your personal information, so as to allow you to participate in interactive features of the website or TripAround’s platform, when you choose to do so or to notify you about changes to the website or TripAround’s platform.
3.1.4. Legislation Compliance and the protection of our interests.
We may use your information, in order to comply with our legal obligations, according to applicable legislation or to disclose your personal data as necessary to comply with the applicable laws and regulations, such as our obligation to collect personal data of our Customers, to process and store accounting documents and files, to respond to requests from governmental, judicial or any other competent authority, to protect our business, to bring or defend legal claims, to protect the rights, interests, safety and security of our organization, our employees, guests, visitors or any third party, in connection with investigating fraud or other crime or violations of applicable laws, as well as to respond to an emergency.
3.1.5. Handling consumer complaints.
We will use your personal data in order to reply to any customer complaint as well as to defend any hotel or Mitsis and present our case in any Court or administrative authority in relation to any such customer complaint.
3.1.6. Preferences & Profile.
With your consent, we will collect, use, share, transfer, process and store your personal data, in order to provide you with unique experiences, improved and personalized services, experiences, such as travel activities, spa treatments, tours, sporting activities, restaurant reservations and other similar travel and tourist activities, to enable Customers to enhance such Guests’ travel experience by suggesting new activities similar to what a Guest may have enjoyed previously, to customize our commercial offers and promotional messages, inform you on special offers and new services created to satisfy your personal nees, promote brands, gain a better understanding of your requirements and wishes and adapt our products and services to better meet your needs and requiremenets. You can withdraw your consent at any time by contacting us at the contact details of our DPO ([email protected]).
3.2. We may, also, use your data or permit selected third parties to use your data, so as to provide you with information about goods and services, which may be of interest to you and we or they may contact you about these as well as in order for them to be able to provide you with the services ordered through TripAround’s platform. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregated information about our users. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to targeted audience.
3.3. In order to meet your special requirements, such as dietary requirements, we may have to collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health, medical information or sexual orientation. In this case, we will only process this data, if you provide your express prior consent.
4. WHERE WE STORE YOUR PERSONAL DATA
4.1. As a principle, data collected from you shall not be transferred to and stored at a destination outside the European Economic Area (“EEA”).
4.2. Υour personal data will be processed by TripAround within the European Union.
Mitsis complies with the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 as well as the Greek Data Protection Legislation and has concluded a Data Protection Agreement and an EU Standard Contract Clauses Agreement with TripAround, in order to protect and safeguard your personal data and ensure, as technically and practically feasible, adequate level of protection by TripAround for your personal data. TripAround is, also, required to bound by such obligations and provisions its respective subcontractors. In any case, Mitsis will only share your Personal Data under a strict ”need to know” basis and under appropriate contractual restrictions.
4.3. All information provided to us is stored on our secure servers. Any payment transactions will be encrypted.
4.4. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with any third party.
5. INFORMATION SECURITY
We have established a strict and very elaborate security system, adopt security procedures and measures and take appropriate technical and organizational measures, in accordance to legal provisions and market standards, so as to protect your personal data, avoid, as technically feasible, any security or personal data breach or security incident and prevent the illicit or accidental destruction, alteration or loss, misuse, unauthorized access, modification or disclosure of any personal data stored and processed in our systems. However, the transmission of information through the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or TripAround’s platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access and use, indicatively physical security, technical measures, firewalls, organizational measures, password systems and any other reasonably protective measure.
6. RETENTION OF PERSONAL INFORMATION
We retain personal information for the period of time necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law or applicable regulations.
7. DISCLOSURE OF YOUR INFORMATION
7.1. We will only share your information as described in this Privacy Policy.
7.2. We may share your information within the companies, members of Mitsis , which include all our hotels, our affiliates and our subsidiaries. All members of Mitsis that receive information are not authorized to use or share the information, except as set out in this Privacy Policy.
7.3. In addition, K.MITSIS FILOXENIA S.A., a member of Mitsis , is, also, our primary Processor, providing direct sales, marketing and other administrative, support and consulting services to all members of Mitsis . In this context, your personal data will be disclosed and processed by K.MITSIS FILOXENIA S.A. on behalf of any member of Mitsis .
7.4. In addition, TripAround, Inc acts as the primary Processor for the services provided by TripAround’s platform as well as the services provided on behalf of Mitsis under this Privacy Policy. In this context, your personal data will be disclosed and processed by TripAround Inc. and its subcontractors on behalf of any member of Mitsis . We rely on TripAround or third parties to provide services and products to you and may share your personal information with them as appropriate and necessary for the provision of our services, such as indicatively food and beverages, transportation, IT, wifi and network services, bank details, credit card issuers, experiences, travel activities, spa treatments, tours, sporting activities, restaurant reservations and other similar travel and tourist activities. We will, also, share your personal data with TripAround, in order to provide services to us, such as fulfilling orders, providing data processing and other information technology services, managing promotions, contests, carrying out research and analysis and personalizing individual customer experiences. TripAround and its subcontractors are contractually obligated to protect your personal data and information, in accordance to the Data Protection Legislation and may not otherwise use or share your personal data and information, except as may be required by law or our contracts and data protection agreements. We do not allow TripAround and its subcontractors to use this information or to share it for any purpose other than to provide services to us or on our behalf.
7.5. There may be times where we may share information when it does not directly identify you. For example, we may share anonymous, aggregated statistics about your use of the website or TripAround’s platform and services. We may, also, combine information about you with other customers and share the information in a way that does not identify you.
7.6. We have the right to use or share information as necessary to comply with any law, regulation or legal request, to protect our Website, to bring or defend legal claims, to protect the rights, interests, safety and security of our organization, our Customers and Guests and our employees or users of the website and TripAround’s platform or in connection with investigating fraud or other crime, or violations of our policies.
8. YOUR RIGHTS
8.1. Under the Data Protection Legislation you have the right to request access to the personal data we hold about you, such as to be informed, upon your request, whether your personal data are subject to processing and to receive further information on such processing, including information on eventual transfers of personal data outside the EU and the appropriate or suitable safeguards we have in place for such transfer. As long as the requirements under the Data Protection Legislation are met, you may also request the correction of any inaccurate information we hold about you or the deletion of the same or restriction of the processing concerning your personal data. If such a request places us or our affiliates in breach of our obligations under any applicable laws, regulations or codes of practice, then we may not be able to comply with your request but you may still be able to request that we block the use of your personal information for further processing. You may also have a right to data portability to another data controller under certain circumstances and as long as this would be technically and economically feasible. You may withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal. You may also launch a complaint with the competent Data Protection Supervisory Authority (www.dpa.gr), if you feel that the processing contravenes the law.
8.2. If you would like to exercise your above mentioned rights or if you have any questions or concerns about our Privacy Policy please contact our Data Protection Officer in: [email protected].
9. LINKS TO OTHER WEBSITES AND SOCIAL MEDIA
9.1. Our website and TripAround’s platform may, from time to time, contain links to and from the websites of our partner networks, and advertisers or any third party. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or any processing taking place by such third parties. Please check these policies, before you submit any personal data to these websites.
9.2. We may, also, have providers of other applications, tools, widgets and plug-ins on our online services, such as Facebook “Like” buttons, which may also use automated methods to collect information about how you use these features. These organizations may use your information in line with their own policies, which we recommend that you read carefully.
10. CHANGES TO OUR PRIVACY POLICY
10.1. This Privacy Policy is in effect as of the date noted at the bottom of this document. We may change this Privacy Policy from time to time. If we do, we will post the revised version here and change the “Last Updated Version” date (the date it applies from) at the end of this document. You should check this link regularly for the most up-to-date version of our Privacy Policy, particularly before making an order or booking services through TripAround’s platform.
10.2. Any changes we may make to our Privacy Policy in the future will be posted on this page and where appropriate, notified to you by e-mail.
11. HOW TO CONTACT US
In order to protect confidentiality and your personal data we may request that you provide us with identification credentials, before responding to your request. Particularly, if we have reasonable doubts about your true identity, we may ask to provide us with a copy of your police identification or passport or information relating to your stay in our hotels, such as registration number, booking confirmation, check in and check out dates or other useful information. If such information is not provided, we may refuse to provide an answer to your request.
If you want to contact us about this Privacy Policy as well as for the exercise of your rights, you can reach us at [email protected].
