PRIVACY NOTICE

Privacy Notice
This is the Privacy Notice of Mikes Kanarium City Hotel (hereinafter ¨Hotel¨ or ¨we¨) which is under the management of Sunnyseeker Hotels Ltd (hereinafter ¨Management Company¨). It refers to the processing of your personal data, as guests of the Hotel or visitors of our website mikeskanariumhotel.com (hereinafter ¨ Guests¨, ¨Visitors¨ or ¨you¨).
We respect your personal data and commit to being transparent during the data collection and processing. The Hotel also commits to operating in compliance with the Cypriot or European Legislation in the areas of Personal Data Processing, Privacy and Data Security. The legislation includes, inter alia, the General Data Protection Regulation (GDPR) and the ePrivacy Directive for the protection of private life in electronic communications. We also consider the Guidelines issued by the Office of the Commissioner for Personal Data Protection in Cyprus.
It is important that you read this privacy notice together with any other privacy notice we may provide on certain occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.

1. Important Information
Data Controllers
The Hotel and Management Company, acting as joint Data Controllers, determine the purposes and means of personal data processing jointly. You can exercise your rights against either of the joint Controllers.
The Mikes Kanarium City Hotel belongs to Camy Hotel Services Ltd, a Company with its registered office at 71 Faneromenis, 6031 Larnaca, Cyprus.
Hotel Contact Details:
Mikes Kanarium City Hotel
Address:      71 Faneromenis, 6025 Larnaca, Cyprus
Tel.:              +357-24624500
E-mail:           info@mikeskanariumhotel.com  

The Management Company ¨Sunnyseeker Hotels Ltd¨, a Company with its registered office at 41 Themistokli Dervi, Hawaii Tower, offices 301-303, 1066 Nicosia, Cyprus.
Contact Details:
Sunnyseeker Hotels Ltd
Address:        23 Artemidos Avenue, 6025 Larnaca, Cyprus                                    
Tel.:                +357 24663333
Fax:                 +357 24651787
E-mail:             info@sunnyseekerhotels.com

Data Protection Officer (DPO)
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO using the details set out below.
DPO Contact Details:
E-mail:                 dpo@sunnyseekerhotels.com
Address:           23 Artemidos Avenue, 6025 Larnaca, Cyprus                                    
Tel.:                   +357 24663333

Changes to the Privacy Notice
We may amend this Privacy Notice at any time. Any change will be valid from the publication of the updated Privacy Notice on our website, and the publication date will be mentioned.
Your duty to inform us about changes in your personal details
It is important that the personal data we hold about you is accurate and current. Please keep us updated about your personal data changes during your relationship with us.
Links to Third-Party Websites
Our website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. What personal data do we collect about you?
Personal data is any information relating to an identified or identifiable person. We may collect, use, store and transfer different kinds of your personal data which we have grouped together as follows:

• Identity Data: name, surname, title, ID or Passport number, date of birth, gender, domicile and nationality.
• Contact Details: physical address, email address and telephone or fax number.
• Data on your stay in the Hotel: room preferences, arrival and departure times, full name, date of birth and ID or passport number of the guests that will stay at room.
• Data on the products consumption (food, drinks) and the use of services (e.g. transports or leisure).
• Data on your preferences on special occasions: social, professional or religious occasions, leisure and health (e.g. allergies and food preferences).
• Data collected from the security systems: records from the cameras through the Closed-circuit television (CCTV).
• Data collected in the event of an incident: doctor details, medical history, injury or accident details, contact details in case of emergency.
• Data on your complaints or comments.
• Data on your reviews of your stay in the Hotel or/and the use of services or products.
• Marketing Data: your preferences in relation to receiving information about us, our services and events.
• Financial Data: payment method details, bank account details, credit card details, detailed expenses and transaction history.
• Technical data: information collected when you visit our website. For more information about the use of cookies, please read our Cookie Notice available on our website.

3. How do we collect your personal data?
We use different methods and sources to collect your personal data including, inter alia, the following:

• From you directly during your visit in the Hotel, or electronically, by phone, post or any other means. This includes, inter alia, personal data that you provide when you:
• contact us or make a reservation via our website.
• want to receive information about the Hotel, our services and products.
• fill out the registration cards during the check-in.
• From your family members, colleagues and beneficiaries of products or services.
• From travel agents, third parties booking platforms and business partners (e.g. insurance agents).
• From data collected when you use our products and services.
• From the automated technologies. As you interact with our website, we may automatically collect technical data by using cookies. For more information about the use of cookies, please read our Cookie Notice available on our website.

4. Why do we collect and process your personal data?
We use your personal data only for the following purposes:

• when it is necessary for performing a contract. This includes:
• providing services, such as accommodation and restaurant, or organizing events
• processing payments
• fulfilling your special requests for your preferences on special occasions (professional, social, religious etc.)
• when processing is necessary for the purposes of the Hotel’s legitimate interests on the condition that the Guests' fundamental rights and freedoms do not override these interests, particularly:    

• for analyzing and improving our current services and products as well as creating new services and products through your comments and reviews
• analysing the information about you for statistical purposes
• contacting you in order to inform you about offers and services during your stay at the Hotel
• managing your contact requests through the means provided for that purpose
• managing your complaints and comments
• collecting information about your preferences to personalise and improve the quality of our communications with you
• preventing and detecting security threats, frauds or other criminal or malicious activities
• for insurance purposes
• for exercising or defending our legal rights or for complying with court decision or orders
• for controlling the access on our premises for security purposes

Closed-circuit television (CCTV) is used for purposes of the Hotel’s legitimate interests, particularly:

• for crime prevention and detection
• for the security and protection of our premises
• for the security of Guests, Employees and Contractors
• for assuring the Guests, Employees and Contractors of the security measures that have been taken so that the fear of crime will be reduced
• for assisting the local law enforcement authorities with the crime detection and prevention, including the fight against terrorism.
• For discouraging antisocial behavior, particularly crimes related to alcohol and drugs on our premises

• when processing is necessary for the protection of your vital interests. This includes, inter alia,
• managing incidents, sicknesses, accidents, injuries or cases of emergency during your stay at the hotel
• contacting you or other relevant contact person in case of emergency
• when processing is necessary for compliance with a legal obligation, including maintaining records, compliance checks or screening and recording (e.g. for tax purposes, for fraud and crime prevention and detection etc.). This can include sharing your personal data with third parties, such as the competent law enforcement authorities.
• When you give us your consent to process your personal data, such as:

                      For Marketing:

• to communicate with you to keep you up to date on new products and services or other offers that may interest you or our events by post, email, phone or/and by using the social media

We will only provide you with marketing related information after you have, where legally required to do so, opted to receive those communications and having provided the opportunity for you to opt out at any time. You can ask us to stop sending you information about us, our services, products or events at any time by contacting us at info@mikeskanariumhotel.com  .
Where you opt out of receiving information about us, our services or events, your opt out will not apply to personal data provided to us for any other purpose.
For Cookies:

• to collect information about your preferences to personalize and improve the quality of our communications with you. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about our use of cookies, please read our Cookie Notice available on our website.

Automated decision making
We will not use your personal data for taking any automated decisions affecting or creating profiles, i.e. decision making by electronic means without any human involvement.
Change of purpose of possessing  
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

5. Who do we share your data with?
We may have to share your personal data for the purposes mentioned in this Privacy Notice with the following categories of recipients:

• the management company of the Hotel
• third parties including banks, travel agencies, suppliers, ITs, insurance companies, lawyers, doctors, medical carriers, service providers
• regulatory bodies, law enforcement authorities, or pursuant to an order of a court or a legal obligation
• your relatives in case of emergency or following your prior consent

Third companies providing electronic reservation services (e.g. booking.com) store your personal information for managing the reservations. In this case, the reservation is directly made in the Hotel, but these companies process the reservation.
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. In no case we will not sell your personal data as well as we do not allow third parties to sell the data we transfer to them.

6. How do we transfer your personal data outside European Economic Area (EEA)?
We do not transfer any personal data to countries outside the EEA.
Nonetheless, it might be necessary to do so for the purposes mentioned in this Privacy Notice and we will take steps to ensure that your personal data receives an adequate level of protection. In case where your personal data is transferred to a service provider for processing in any country outside the EEA that is not recognized by the EU Commission as providing an adequate level of protection for personal data, we will ensure that appropriate safeguards as per the EU Commission’s standard contractual clauses or by any other appropriate safeguard as foreseen under the applicable data protection law are provided.

7. What security measures do we take?
The Hotel data is stored in different places, such as physical file, website, electronic management system of the Hotel (Theova) and other electronic systems (e.g. email). We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

• Site Access Control: unauthorized persons are not allowed to have access to areas within our Hotel whereby personal data are processed and in case that the provision of access to such persons is necessary, they do not remain unattended.
• System Access Control: only authorized persons have access to data processing systems.
• Data Access Control: authorized persons with access to data processing system have access only to the data they are authorized to access and are bound by confidentiality.
• Transfer Control: personal data are only transferred in prescribed manner and under certain circumstances.
• Disclosure Control: we always ascertain and check where and to whom data can be transferred by means of data transmission facilities.
• Order Control: personal data of a data subject is processed in strict accordance with the data subject’s instructions and the appropriate law.
• Availability Control: personal data is protected against accidental destruction or loss as all data is backed up.
• Breach Control: procedures to deal with any suspected personal data breach and for the notification of any applicable regulator or an affected data subject of a breach have been laid down.

As for the closed-circuit television (CCTV), the measures taken include, inter alia, the following:

• The CCTV records and the relevant equipment are placed in a locked server room where only authorized persons have access, and other people are allowed entry only in the presence of an authorized person.
• The authorized persons and the contracting security company have access to the CCTV system. The access to the hard disk where the CCTV records are saved, is strictly limited and protected with strong passwords and encrypted archives.

Our security measures are audited regularly by external security experts in order to maintain our security level to international standards and to ensure that personal data is handled in a secure way.

8. How long do we keep your personal data?
We will only retain your personal data for the period necessary to fulfil the purposes described in this Privacy Notice. In the case where a guest relationship existed, we will retain your personal data for a period of at least twelve (12) months from your departure from the Hotel, except for the following cases where the data is required to be kept for a longer period:

• statistical purposes
• managing issues regarding payment and invoicing
• sending direct marketing messages to guests that have given their consent
• till the lost objects are returned to the Guests
• managing accidents or incidents that occurred during the stay in the Hotel
• keeping comments and preferences for frequent guests on the condition that they have given their consent
• complying with legal or regulatory obligations (e.g. for accounting purposes)
• till the period that claims against the Hotel can be issued before courts or other prosecution authorities so that the Hotel will be able to defend its legal rights
• in case of litigation, till the court proceedings or enforcement measures are carried out.

As for the CCTV records, they are retained for a period of one (1) month from the recording date. However, we may have to retain this data for a longer period, such as for defending our legal rights before courts or other enforcement authorities.
In general, to determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure 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.
In some circumstances you can ask us to delete your data. See below to read more about your right to erasure.

9. What are your rights?
You have the following rights regarding your personal data:
Right of Access: You have the right to access to your personal data. You can ask for a copy of the personal data we hold about you. There are situations where we may deny your request, for example, if making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information.
Right to Rectification:  It is our objective to keep your personal data accurate, current and complete. You have the right to request the correction of any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
Right to Erasure:  You have the right to ask us to delete or remove your personal data in case that

• there is no good reason for us continuing to process it
• you have successfully exercised your right to object to processing (see below)
• we may have processed your information unlawfully
• we are required to erase your personal data to comply with local law

You should take into account, though, 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.
Right to Object: You have the right to object to the processing of your personal data when 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. In some cases, we may demonstrate that we have compelling legitimate grounds which override your rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes.
Right to Restrict Processing:  This enables you to ask us to suspend the processing of your personal data in the following cases:

• if you want us to establish the data’s accuracy
• when our use of the data is unlawful but you do not want us to erase it
• when 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
• if 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 Data Portability: You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Right to Withdraw Your Consent: You have the right to withdraw your 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 the withdrawal of consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the abovementioned rights, please contact us at dpo@sunnyseekerhotels.com.

Right to file a complaint
You have the right to lodge a complaint with the Office of Cyprus Commissioner for Personal Data Protection.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What do we need from you?
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 your personal data is not disclosed to any other person. We may also contact you to ask for further information in relation to your request.

Time limit to respond
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 complicated or you have made more requests. In this case, we will notify you.
We recommend that you visit our website often in order to keep updated with the changes in our Privacy Notice. For previous versions of our Privacy Notice, please contact us at dpo@sunnyseekerhotels.com.

Updated 30.07.2019