Privacy Policy San Antonio Corfu Resort

Scope of This Policy

 

This Privacy Policy describes how the San Antonio Corfu Resort collects, uses, consults or otherwise processes an individual’s Personal Data.

For the purposes of EU Privacy Law, depending on the type of Personal Data processing described in this Privacy Policy, San Antonio Corfu Resort operating as a sole Controller.

The hotel will be solely responsible for the processing activities for which it is the sole Controller.

We are committed to protecting the privacy of our users and customers.

San Antonio Corfu Resort will not lease or sell your personal information to others and it will not share (except from the reasons stated at the present notice) your personal data to third parties.

This Privacy Policy is intended to inform you how we gather, define, and use Personal Data that you provide to us when using our websites and mobile applications or when relying on our hospitality services. Please take a moment to read this Privacy Policy carefully. Please note that if you plan to submit someone else’s Personal Data to us, for instance when making a booking on their behalf, you may only provide us with that person’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.

This policy includes a description of your data protection rights, including a right to object to some of the processing activities we carry out. Please note that your rights as a data subject may vary depending upon where you live.

EU Privacy Law requires us to be specific about our reasons and legal grounds for using your Personal Data. Accordingly, for the purposes of EU Privacy Law only, the information below describes the types of data we process, where we get your data from, the grounds we rely on to carry out the processing, and who we may share your data with. Except for the “Processed Data Categories” sections set out in the information below, nothing is intended to bind us in respect of our non-EU users.

Definitions

Controller: 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.

EU Privacy Law: Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (the “GDPR”), as well as any legislation and/or regulation implementing or created pursuant to the GDPR and the e-Privacy legislation, or which amends, replaces, re-enacts or consolidates any of them, and all other national applicable laws relating to the processing of Personal Data and privacy.

Processor: A natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller.

Recipient: A natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a Third Party or not.

Third Party: A natural or legal person, public authority, agency or body other than the data subject, controller, Processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.

Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the GDPR.

Personal Data: 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, in particular 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.

Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Privacy Shield: The EU-U.S. and Swiss-U.S. Privacy Shield legal framework, designed by the U.S. Department of Commerce and the European Commission and Swiss Administration to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring Personal Data from the European Union and Switzerland to the United States in support of transatlantic commerce.

Standard Contractual Clauses: Sets of standard contractual clauses for transfers as adopted by the European Commission for the international transfer of Personal Data.

Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

Hotel Booking Process

Hotel booking process

In the context of the hotel booking process – whether this takes place online on our brand website, through an online booking channel, via a travel agent, through our call center or directly at the hotel – we process your Personal Data for the purpose of (i) enabling you to reserve a room in the hotel of your choice; (ii) verifying the availability of the hotel and to administer the booking; (iii) sending you a booking confirmation; and (iv) sending you non-commercial pre-arrival emails. You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you.

Processed data categories

Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Telephone number, Title

Source of data

Depending on the booking mechanism used:

  • Directly from you through the online booking form
  • Through the online booking channel, you used to make the booking
  • From your Travel agent
  • From our reservations department
  • From the hotel you made a direct booking with

Ground for processing

Processing is necessary to take steps to enter into and perform a contract.

 

Interrupted or incomplete online booking process (abandoned cart)

When you are booking online but for some reason are not able to finalize the booking process, we process your Personal Data for enabling you to easily continue the online booking process by sending you an email with a link to the online booking form, which is pre-filled on the basis of the data you had already provided in the form.

Processed data categories

Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, number, Title

 

Source of data

Directly from you through the online booking form

Ground for processing

It is in San Antonio’s Corfu Resort legitimate interest as a business to re-market an interrupted or incomplete booking process. In this context, San Antonio’s Corfu Resort business interests prevail over yours.

 

Recipients of Data

  • Email communications service provider
  • Provider of targeted advertisements

 

Guest Satisfaction surveys

We may send you guest satisfaction surveys by email during or after your stay to enable us to measure the performance of our hotels. You may unsubscribe from our guest satisfaction survey emails at any time by clicking on the unsubscribe link in the emails sent to you.

Processed data categories

Country of residence, Date of arrival and departure, Email address, First name / Last name, Nationality, Stay details

Source of data

Depending on the booking mechanism used:

  • Directly from you through the booking form
  • Through the online booking channel, you used to make the booking
  • From your Travel agent
  • From our reservations department
  • From the hotel you made a direct booking with

Ground for processing

Processing is necessary to ensure and follow up on the reliable performance of the contract you have with us.

 

Service emails analytics

In the context of service emails, which includes guest satisfaction survey emails and any non-commercial pre-arrival emails concerning your booking, we may process and collect your Personal Data, and notably whether you have opened and actioned a service email, for analytical purposes in order to measure the click-through rate and improve the content of our service emails. You may unsubscribe from our service emails at any time by clicking on the unsubscribe link in the service emails sent to you.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories

Email address, Email clicking behavior, Email opening behavior, First name / Last name,

Source of data

From our email analytics service provider

Ground for processing

It is in San Antonio’s legitimate interest as a business to understand the email clicking behavior of its guests to determine whether improvements are needed. In this context, San Antonio’s business interests prevail over yours.

Recipients of Data

  • IT service provider
  • Email analytics service provider

 

Hotel Guest

Hotel check-in and check-out

When staying at the hotel of your choice, we will collect and process your Personal Data for the purposes of (i) registering your arrival and departure at the hotel; (ii) assigning you a key/ key card to your room; (iii) obtaining a credit card guarantee or hotel deposit to ensure payment of your stay; (iv) managing (and archiving) your hotel registration card; (v) creating or updating your profile in our hotel management system; (vi) assessing your eligibility for a room upgrade and managing this if applicable; (vii) managing payment of your stay; (viii) establishing, printing or sending an invoice for your stay; and (ix) paying a commission to your travel agent (if applicable).

In the event you have booked a room in our hotel but do not show up – without cancelling – on the date of arrival communicated, we will process your Personal Data for the purposes of (i) cancelling your stay and any other reservation you may have made; and (ii) managing, processing and settling any outstanding payment that may be due.

Processed data categories

Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Telephone number, Title

Source of data

Depending on the booking mechanism used:

  • Directly from you through the booking form
  • Through the online booking channel, you used to make the booking
  • From your Travel agent
  • From our reservation department
  • From the hotel you made a direct booking with
  • Directly from you through the hotel registration card

Ground for processing

Processing is necessary to perform the contract you have with us.

Recipients of Data

  • IT service providers
  • Your Travel agent, if applicable

 

Credit limit reports

To ensure payment for all guests staying in a hotel room, each hotel guest is asked for a credit card or deposit upon arrival. In order to ensure that you do not exceed your credit limit during your stay, we produce a credit limit report multiple times a day for the purposes of verifying whether your credit limit has been exceeded. These credit limit reports may contain your Personal Data. Please note that in limited circumstances these credit limit reports may be subject to one of our internal financial audits, and may therefore be accessed by members of our internal audit department, in order to ensure that our hotel follow the hotel’s internal guidelines and policies.

Processed data categories

Date of arrival and departure, First name / Last name, Payment card type, number and expiration date

Source of data

Depending on the booking mechanism used:

  • Directly from you through the booking form
  • Through the online booking channel, you used to make the booking
  • From your Travel agent
  • From our reservation department
  • From the hotel you made a direct booking with
  • Directly from you through the hotel registration card

 

 

 

Ground for processing

Processing is necessary to ensure the performance of the contract you have with us.

Recipients of Data

  • IT service providers

 

Hotel stay

When you stay in our hotel, we endeavor to make your stay as pleasant as possible. This requires processing your Personal Data for the purposes of providing specific services during your hotel stay. These services include (i) housekeeping and maintenance; (ii) returning lost or forgotten items to you; and/or (iii) managing your and your co-guests’ preferences, such as dietary requirements and pillow preferences, to provide you with a better service during your stay with us.

Processed data categories

Address, Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Other preferences, Telephone number

Source of data

Depending on the booking mechanism used:

  • Directly from you through the booking form
  • Through the online booking channel, you used to make the booking
  • From your Travel agent
  • From our reservations department
  • From the hotel you made a direct booking with
  • Directly from you during your stay at the hotel

Ground for processing

It is in San Antonio’s legitimate interest as a business to organize its day-to-day hotel maintenance activities, to personalize the services it provides, and/or to be able to identify the owner of a lost or forgotten item. Taking into account the limited Personal Data processed and shared for such purpose(s), San Antonio’s business interests prevail over yours.

Recipients of Data

  • Hotel personnel, including housekeeping, maintenance, front desk, and/or other hotel personnel concerned
  • IT service providers

 

Hotel guest additional services and facilities

In our hotel you can benefit from additional services and facilities, such as breakfast, room service, minibar, pool, restaurants and bars, spa treatments, laundry services, parking, taxi requests, free Wi-Fi, etc. In the event you make use of additional services or facilities at our hotel, your Personal Data may be processed to (i) manage the booking and use of such additional hotel services and/or facilities; (ii) administer any advance bookings of additional services and/or facilities to your file; (iii) personalize returning guests’ arrival to the hotel and the choice of room amenities and room features; and (iv) manage the expenses incurred for such additional services and/or facilities.

Processed data categories

Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, number and expiration date, Title

Source of Data

  • Directly from you through the online booking form
  • Through the online booking channel, you used to make the booking
  • From your Travel agent
  • From our reservations department
  • Directly from you through the hotel registration card
  • Directly from you when making your additional service/facility request with the hotel front desk or the concierge

Ground for processing

Processing is necessary to take steps with a view to entering into a contract and/or to perform the contract.

Recipients of Data

  • Hotel personnel, including front desk, room service, and/or other hotel personnel concerned
  • IT service providers

 

Subscription to Our Newsletters

  • Newsletters and marketing communications

If you have explicitly consented to receive our newsletters or marketing communications, including in relation to the San Antonio Corfu Resort, we may, from time to time, contact you with information about our services and latest offers and process your Personal Data for this purpose.

If you no longer want to receive our newsletters or marketing communications, please let us know by sending us an email at info@sanantoniocorfuresort.com. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails sent to you.

Processed data categories

Address, Date of birth, Email address, First name / Last name, Gender, Hobbies and interests, Telephone number, Hotel stay history, Country of residence

Source of data

Directly from you when subscribing to our newsletter or later when completing your account

Ground for processing

Ad hoc consent obtained during the subscription to our newsletter

Recipients of Data

  • IT service providers
  • Email communications service provider

 

  • Newsletters and marketing communications analytics

In the context of our newsletters and marketing communications, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our newsletters and marketing communications.

Processed data categories

Email address, Email clicking behavior, Email opening behavior, First name / Last name,

Source of data

From our email analytics service provider

Ground for processing

It is in San Antonio’s legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, San Antonio’s business interests prevail over yours.

Recipients of Data

  • IT service providers
  • Email analytics service provider

 

Mobile Applications

To assist our guests in booking, planning and enjoying their stay, we offer mobile applications for our hotel.

Depending on how you use our mobile applications, your Personal Data may be processed for the purposes of (i) enabling you to reserve a room in the hotel of your choice (ii) addressing the requests you have made through the mobile app.

To avoid having us receive or use your real-time location, do not opt in to location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the application. Equally, if you would like to no longer receive push notifications via one of our mobile applications, you can revoke push notification permission for the mobile application(s) in your device’s operating system settings.

The information below describes the types of data we process in the context of our mobile applications, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with

Processed data categories

Email address, First name / Last name, Location data, Stay details, Telephone number

Source of data

Directly from you when downloading our application(s) or when interacting with the application(s)

Ground for processing

Ad hoc consent obtained during the installation of the application or in the context of your use of the application

 

Recipients of Data

  • Mobile applications provider
  • Cloud and hosting service providers

 

Website Forms

Should you have a particular query or feedback, including the exercise of one of your rights under the GDPR, you may contact us through the contact forms available on our website(s). In such context, we may process your Personal Data for the purposes of handling and providing an answer to your query or request or to follow up on your feedback.

The information below describes the types of data we process for these purposes, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories

Address, Email address, First name / Last name, Stay details, Telephone number, and any other data you may decide to share with us in open comment boxes.

Source of data

Directly from you through the form

Ground for processing

Ad hoc consent obtained through the contact form

Recipients of Data

  • IT service providers

 

Analytics

We may use any data you provide to us for analytical purposes to optimize your experience, enhance our marketing, business and operational efficiency, create segments of our customers based on their Personal Data and tailor our offers and promotions to your preferences and consumption habits. In the context of such analytics, we analyze and may combine different data we hold about our guests, including (i) responses to guest satisfaction surveys; (ii) communications guests have with us; (iii) click-through rates for our marketing communications; (iv) our guests’ behavior on our websites; and (v) bookings; Processed data categories

Hotel stay details, Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Title, First name / Last name, First name / Last name of adult co-guest(s), Email address, Telephone number, Payment card type, number and expiration date,

Source of Data

  • Directly from you through the online booking form
  • Through the online booking channel, you used to make the booking
  • From your Travel agent
  • From our reservations department
  • From our email analytics provider
  • Directly from you when making your additional service/facility request with the hotel front desk or the concierge

 

Ground for processing

  • IT service providers
  • Analytics service provider

 

Social Media and Online Reviews

Our website includes social media functions. These functions may collect your IP address and the page you currently visit in our website and you may have to activate cookies to properly activate this function. The social media functions and widgets are hosted by third parties or are hosted directly in our website. Your interactions with these functions are regulated from the Privacy Policy of each provider organization.

We may process your Personal Data obtained through social media platforms (including Facebook, Instagram, LinkedIn, Weibo and Twitter) or online reviews (including on TripAdvisor) concerning our hotel for the purposes of (i) addressing your questions or complaints; (ii) monitoring our online reputation; and (iii) improving our services and identifying opportunities on which we can focus.

Some of our social media pages allow users to submit their own content. Please remember that any content submitted to one of our social media pages can be viewed by the public, and you should be cautious about providing certain personal information (e.g., financial information or address details) via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms (e.g., Facebook or Instagram). Please also refer to the respective privacy and cookie policies of the social media platforms you are using.

Processed data categories

Any Personal Data you may decide to share with us or published on social media or in other online reviews about us

Source of Data

  • Directly from you through publicly accessible social media pages, online booking channels or other (review) websites
  • From our online reputation monitoring service provider

Ground for processing

  • Online reputation monitoring service provider

 

Social media contests

From time to time, we may organize a contest on one of our social media pages. If you choose to participate in such contest, we will process your Personal Data for the purpose of organizing and managing the social media contest and picking the winner(s).

Processed data categories

This depends on the data fields in the contest concerned, but almost always includes the following categories of data:

Address, Email address, First name / Last name, Telephone number

Source of data

Directly from you through our social media pages

Ground for processing

Processing is necessary to take steps to enter into and perform a contract as you accept the terms and conditions of the contest.

Recipients of data

  • IT service provider

 

Your Rights – Under EU Privacy Law

If you are in the EU, EU Privacy Law grants specific rights, summarized below, which you can in principle exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request via email at info@sanantoniocorfuresort.com.

Should you have unresolved concerns, you have the right to lodge a complaint with a Supervisory Authority where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Supervisory Authority.

Right to withdraw consent
Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging in to your account on our website or by contacting us at info@sanantoniocorfuresort.com. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy.

Right to access and rectify your data
You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, passwords and/or any other preferences, you can easily do so by logging in to your account on our website (if you have one) or by contacting us at info@sanantoniocorfuresort.com or You may also request a copy of the Personal Data processed as described in this Privacy Policy.

Right to erasure
In accordance with EU Privacy Law, you have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via email at info@sanantoniocorfuresort.com.

Right to restriction of processing
Under certain circumstances described in EU Privacy Law, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data.

Right to object to processing
Under certain circumstances described in EU Privacy Law, you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes.

Right to data portability
Where you have provided your data directly to us and where the processing is carried out by automated means and based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about you in a structured, commonly used and machine-readable format, and to transmit this data to another service provider.

 

Your Rights – Non-EU Users

Depending on where you are located you will have different rights in respect of your Personal Data and we will comply with the relevant requirements of applicable laws and this Privacy Policy.

California Privacy Rights

If you reside in California, you have the right to ask us one time each year if we have shared Personal Data with third parties for their direct marketing purposes. To make a request, please send us an email at info@sanantoniocorfuresort.com or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

 

Russian Citizens

In accordance with Russian Federal Law “On Personal Data” No. 152-FZ we collect, record, systematize, accumulate, store, update (renew and modify), and extract Personal Data about Russian citizens using databases located in the territory of the Russian Federation. If you indicate that you are a Russian citizen of the Russian Federation, we will process your Personal Data in compliance with this requirement and your profile will be maintained on databases in the Russian Federation. If you do not indicate that you are a citizen of the Russian Federation, we are not able to process and maintain your Personal Data under these requirements and will not be liable for that. You are solely responsible for indicating the country of your citizenship. Information containing Personal Data of Russian citizens may be transmitted from the Russian Federation to countries that ensure an adequate level of protection for Personal Data, including member states of the European Union and other countries which Russian law recognizes as ensuring adequate to protection, and also to other countries that may not ensure adequate level of protection for Personal Data. By submitting information to us on our sites and apps, submitting forms to us, or registering on our sites, programs and apps, or making reservations, you grant us consent to process your Personal Data.

 

Security Measures

Appropriate technical and organizational measures are implemented in order to ensure an appropriate level of security of your Personal Data, including but not limited to encryption techniques, physical and IT system access controls, obligations of confidentiality, etc.

In the event Personal Data is compromised because of a Personal Data Breach we will make the necessary notifications, as required under applicable laws.

 

How Is Your Personal Data Shared with Third Parties?

We only share or disclose information as described herein, including with Third Parties.

Your Personal Data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of the Controller(s) legitimate interests in compliance with applicable laws. In addition, we may share your Personal Data and other information with a successor to all or part of our business, where this is in our legitimate interests in facilitating a business sale and in this context our business interests prevail over yours. For example, if parts of our business or assets are sold, we may disclose user information as part of that transaction, subject to applicable law.

 

 

How Long Will We Keep Your Personal Data?

We retain your Personal Data for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law. For example, we may retain your Personal Data if it is reasonably necessary to comply with any legal obligations, meet any regulatory requirements, resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy and prevent fraud and abuse.

To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

Does This Privacy Policy Apply to Third Party Websites?

If you click on a link to a Third-Party website, you will be taken to a website we do not control and our Privacy Policy will no longer be in effect. Your browsing and interaction on any other website is subject to the terms of use and privacy and other policies of such Third-Party website. Read the privacy policies of other websites carefully. We are not responsible or liable for the information or content on such Third-Party websites.

 

What Happens If We Make Modifications to This Policy?

We reserve the right to modify and update this Privacy Policy from time to time. We will bring these changes to your attention should they be indicative of a fundamental change to the processing or be relevant to the nature of the processing or be relevant to you and impact your data protection rights.

 

How to Contact Us

Questions, comments, remarks, requests or complaints regarding this Privacy Policy are welcome and should be addressed to info@sanantoniocorfuresort.com. If you have questions about our hotel’s practices or the information it has, please contact the hotel directly.