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Aposperia Apartments Privacy Notice

We know that you care about your personal data and how it is used, and we want you to trust that Aposperia Apartments uses your personal data carefully. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it.

You have the right to object to certain uses of your personal data including the use of your personal data for direct marketing. See what your rights are and how you can exercise them here.

Who is collecting data?

Any personal data provided to or collected by Aposperia Apartments is controlled by Aposperia Apartments (hereinafter referred as “Aposperia Apartments”, “We”, “Us”. This Privacy Notice applies to personal data collected by Aposperia Apartments in connection with the services and products we offer.

This Privacy Notice also applies to Aposperia Apartments marketing content, including offers and advertisements for Aposperia Apartments products and services, which we (or a service provider acting on our behalf) send to you on third-party websites, platforms and applications based on your site usage information. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.

What personal data is being collected?

Personal data means any information that can be used to identify directly or indirectly a specific individual.

We may collect personal data from a variety of sources. This includes:

Personal data you give us directly,

Personal data we collect automatically, and

Personal data we collect from other sources.

You may be asked to provide your personal data when you are in contact with us. Aposperia Apartments may share this personal data with each other and use it in a manner consistent with this Privacy Notice. We may also combine it with other information to improve our products, services, content, and advertising.

You are not required to provide Aposperia Apartments the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.

Ways in which we collect your personal data

We may collect personal data from a variety of sources. This includes:

Personal data you give us directly. We collect data about how you use our services and products, such as the types of content you view or engage with, or the frequency and duration of your activities. We also collect personal data you provide us when you sign up for a marketing newsletter, complete a survey or register for an account to buy our services. In so doing, we may ask for personal data, such as your name, gender, date of birth, address, email address, telephone number or credit card details.

Personal data we collect automatically. We also receive and store certain types of personal data whenever you interact with us online. For example, we use cookies and tracking technologies (to find out more, see our  Cookies Policy) to obtain personal data when your web browser accesses our websites or advertisements and other content served by or on behalf of Aposperia Apartments on other websites. Your personal data is also collected when you search, buy, post, participate in a contest or questionnaire or communicate with our customer service teams. Examples of the types of personal data we collect include; IP address, device ID, location data, computer and connection information such as browser type and version, time zone setting, browser plug-in types and versions, operating system, and purchase history – which Aposperia Apartments sometimes aggregates with similar information from other consumers. During some of your internet browsing on Aposperia Apartments website we may also use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.

Personal data we collect from other sources. We collect personal data from other sources including our trusted partnerships with third-parties and where we operate Aposperia Apartments accounts on third-party platforms: Additionally, we receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful. We also collect information about you and your activities from a third-party when we jointly offer services or products, or from third-party data enrichment providers who may deliver insights to Aposperia Apartments about the personal data we hold.

When and why we collect “special categories of personal data”

Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” and benefit from additional protection under the European data protection legislation.

We limit the circumstances where we collect and process these special categories of data.

Aposperia Apartments sometimes collects data related to your health such as allergies to provide you tailored services and products. Aposperia Apartments only collects and uses this personal data where you have provided us with your consent for us to do so.

How do we protect children’s privacy?

We understand the importance of taking extra precautions to protect the privacy and safety of children using Aposperia Apartments premises and services.

Aposperia’ s Apartments website is designed and intended for use by adults.

If you are a child under the age where parental consent is required in your Country and Greece also, you should review the terms of this Privacy Notice with your parent or guardian to make sure you understand and accept them. If we discover that we have collected personal data from a child without consent from a parent or guardian where such consent should have been obtained, we will delete that personal data  in the soonest possible time.

We sometimes use your personal data to carry out age verification checks and enforce any such age restrictions.

What purposes do we use your data for?

We collect, process and disclose your personal data for the following purposes:-To process your payments, if you purchase our services, to provide you with your order status, deal with your enquiries and requests, and assess and handle any complaints;

-To process and answer your inquiries or to contact you to answer your questions and/or requests;

-To develop and improve our products, services, communication methods and the functionality of our websites;

-To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;

-To understand and assess the interests, wants, and changing needs of consumers, to improve our website, our current products and services, and/or developing new products and services; and

-To provide personalized products, communications and targeted advertising as well as product recommendations to you.

Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.

What are the legal grounds for the processing of your personal data?

In some cases, we rely on legitimate interest for processing your personal data. A legitimate interest could exist for example, when you sign up for a loyalty scheme with one of our companies and we use the personal data collected to conduct data analytics to improve our products or services. This ground will only be used where it is necessary to achieve a legitimate interest, for example to optimize a service, and does not outweigh your rights as an individual. This legal basis will only be relied upon where there is no less intrusive way to process your personal data. We can assure you that if legitimate interest is used as a ground for processing your personal data, we will keep a record of this and you have the right to ask for this information.

We also process your personal data when we have a legal obligation (e.g., tax obligations) to perform such processing. For example, a court order or a subpoena may require us to process personal data for a particular purpose, or we may be compelled to process personal data to report suspicious transactions under the local anti-money laundering rules.

ProfilingProvided you have given us your consent (for example, accepting the setting of cookies on your browser online or signing up for email newsletters from one of our brands), Aposperia Apartments shall use your personal data to build profiles. We create profiles by analysing the information about your online surfing, searching and buying behaviour and by placing your personal data in one or more segments. These segments are used by Aposperia Apartments to personalise the website and our communications to you (such as showing relevant content to you when you visit our site or in a newsletter to you), and to display relevant offers and advertisements, and via third-party websites. The segments can also be used for third-party campaigns on the Aposperia Apartments.

You can withdraw your consent to prevent your personal data being used this way at any time by for example using the manage cookies section of our Cookie Notice or unsubscribing to the use of your email address if you have logged into one of our websites or signed up to any marketing newsletters.

By way of example, Aposperia Apartments collects data, with your consent, from:

-Our websites about what you view and the way you interact with our content;

-Our digital display advertising that we serve to you on social platforms and other publisher’s websites; and

-Forms you fill in online and send to us about what your interests are.

If you have asked to receive emails or SMS communications from us, we track whether you open, read or click on the content to see what you are interested in so that we can give you more content that we think you are more likely to enjoy.

Based on this profile information, we may also give you advertising that we think you will like and want to see as you view content from us or from our network of publishers that we advertise with. Sometimes, with your consent, we may use your current location to serve advertising to you that is to do with promotions or events that are happening nearby that we think you might be interested in.

Who will it be shared with?

Aposperia Apartments shares your personal data internally and with selected authorized third-parties. For example, we share your personal data with third-party service providers, other third-parties, as well as in case of business transfers or legal disclosure.

Aposperia Apartments shares your personal data internally and with selected authorized third-parties in the following circumstances:

Authorized Third-party service providers. In order to carry out your requests, respond to your inquiries, fulfil your orders or make other features, services and products available to you through our websites we share your personal data with third-party service providers that perform functions on our behalf, such as companies that: host or operate Aposperia Apartments website, process payments, analyse data, provide customer service, or other third-parties that participate in or administer our promotions. They have access to personal data needed to perform their functions but may not use it for other purposes. Further, they must process this personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws and regulations  applied to Processors.

Other third-parties. Your personal data will also be used by us or shared with our advertisers, advertising networks, advertising servers, social media networks, providers of postal or delivery services, sponsors, and analytics companies or other third-parties in connection with marketing, promotional, data enrichment and other offers, as well as product information.

Business transfers. Your personal data will be used by us for internal reasons, primarily for business and operational purposes. If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to Aposperia Apartments website, your personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such personal data will be considered an asset of ours and as such it is possible they will be sold or transferred to third-parties.

Legal disclosure. We may transfer and disclose your personal data to third-parties:

To comply with a legal obligation;

When we believe in good faith that an applicable law requires it;

At the request of governmental authorities conducting an investigation;

To verify or enforce our “Terms of Use” or other applicable policies;

To detect and protect against fraud, or any technical or security vulnerabilities;

To respond to an emergency; or otherwise

To protect the rights, property, safety, or security of third-parties, visitors to Aposperia Apartments websites.

International data transfers

When sharing personal data with third parties to assist us in providing you with products or services, Aposperia Apartments may transfer data outside the EEA. The transfer of your personal data to countries outside the EEA will be in accordance with the provisions of current legislation and in this case our service providers are expected to commit to high standards of data protection through recognized EU standards or specific contractual obligations to ensure the protection of your rights under GDPR relevant provisions on international transfers.

How do we protect your personal data?

Aposperia Apartments takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure.

Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise personal data wherever possible.

Access to your personal data is only permitted among our authorized employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations by signing data processing agreements, when processed by third-parties acting as Processors.

How long do we keep your personal data for?

We will keep your personal data for as long as we need it for the purpose it is being processed for. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.

What are your rights?

We ensure your rights with respect to processing of personal data and ensure that you may exercise them. You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights by sending an email or submitting a request through the “Contact Us” form on our websites.

The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights.

The right to access and rectification. You have the right to access, correct or update your personal data at any time.

The right to data portability. The personal data you have provided us with is portable. This means it can be moved, copied or transmitted electronically under certain circumstances.

The right to be forgotten. Under certain circumstances, you have right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.

The right to restrict processing. Under certain circumstances, you have the right to restrict the processing of your personal data.

The right to object. Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).

The right to lodge a complaint with a Supervisory Authority. You have the right to complaint directly with Hellenic Data Protection Authority about how we process your personal data

The right to withdraw consent. If you have given your consent for processing your personal data., you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal data at any time by contacting us with the details provided below.

How do you contact Aposperia Apartments?

Aposperia Apartments nominated Data Protection Officer who can be contacted at Aposperia Apartments address …………………………………. and email [email protected]

If you have any questions or concerns about Aposperia Apartments Privacy Notice or data processing or if you would like to make a complaint about a possible breach of privacy laws, please do so by sending an email or submitting a request through the “Contact Us” form on our websites.

When a privacy question or access request is received we have a dedicated team which reviews the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the Supervisory Authority in Greece which is the Hellenic Data Protection Authority (www.dpa.gr)

How do we keep this notice up to date?

We will update this Privacy Notice when necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top of this Notice. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes). We will also keep prior versions of this Privacy Notice in an archive for your review.

Additional Privacy Terms or Notices

In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.

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