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PRIVACY*POLICY

1. NEWEL’S COMMITMENT TO PROTECTING PRIVACY

Because we consider you an important guest, our first priority is to offer you exceptional times and stays throughout our group of apartments.

Your complete satisfaction and confidence in NEWEL are absolutely essential to us.

That’s why, as part of our commitment to meeting your expectations, we have set up a customer privacy protection policy. This Charter formalizes our commitments to you and describes how NEWEL uses your personal data.

The main rules are founded on seven principles.

2. CONSENT

“Personal data” means any information collected and logged in a format that allows you to be identified personally, either directly (e.g. name) or indirectly (e.g. telephone number) as a natural person. Before providing us with this information, we recommend that you read this document describing our customer privacy protection policy.

This Personal Data Protection Charter forms part of the terms and conditions that govern our hotel services. By accepting these terms and conditions, you expressly accept the provisions of this Charter.

3. NEWEL’S SEVEN PRINCIPLES FOR PROTECTING YOUR PERSONAL DATA

The seven principles below are applicable throughout our group of aparthotels.

Transparency: When collecting and processing your personal data, we will communicate all information to you and inform you of the purpose and recipients of the data.

Legitimacy: We will collect and process your personal data only for the purposes described in this Charter.

Relevance and accuracy: We will only collect personal data that is necessary for data processing. We will take all reasonable steps to ensure that the personal data we hold is accurate and up to date.

Storage: We will hold your personal data for the period necessary for processing the same in compliance with the provisions of the law.

Access, rectification, opposition: You may access, modify, correct or delete your personal data. You may also oppose the use of your personal data, particularly to avoid receiving sales and marketing information. The details of the department to contact in this respect are via gdpr@the-newel.com

Confidentiality and security: We will ensure reasonable technical and organizational measures are in place to protect your personal data against alteration or accidental or unlawful loss, or unauthorized use, disclosure or access.

Sharing and international transfer: We may share your personal data within THE NEWEL or with third parties (such as commercial partners and/or service providers) for the purposes set out in this Charter. We will take appropriate measures to guarantee security when sharing or transferring such data.

For any questions concerning the seven principles of THE NEWEL GDPR, please contact us by our mail address gdpr@the-newel.com

4. SCOPE OF APPLICATION

This Charter applies:

To all data processing implemented in our subsidiary and managed hotels, i.e. those operating under Newel(Newel Acropolis,Newel Metaxourgeio,Newel Psychiko ) This list is regularly updated.

To all NEWEL reservation websites, including www.the-newel.com

5. WHAT PERSONAL DATA IS COLLECTED?

At various times, we will be obliged to ask you, as an NEWEL customer, for information about you and/or members of your family, such as:

Contact details (for example, last name, first name, telephone number, email)

Personal information (for example, date of birth, nationality)

Information relating to your children (for example, first name, date of birth, age)

Your credit card number (for transaction and reservation purposes)

Your arrival and departure dates

Your preferences and interests (for example preferred floor, type of bedding, etc.)

Your questions/comments, during or following a stay in one of our establishments.

The information collected in relation to persons under 18 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, you can contact the Data Privacy department to arrange for this information to be deleted.

We do not deliberately collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation.

Moreover, depending on applicable local laws, other information could be considered sensitive, such as your credit card number, your leisure activities, personal activities and hobbies, and whether or not you are a smoker. We may be obliged to collect such information in order to meet your requirements or provide you with an appropriate service, such as a specific diet.

In this case, depending on the laws in force in certain countries, your prior consent may be required with regard to the collection of sensitive information.

6. WHEN IS YOUR PERSONAL DATA COLLECTED?

Personal data may be collected on a variety of occasions, including:

Apartment activities:

Booking an apartment

Checking-in and paying

Eating/drinking from the vendor machines during your stay

Requests, complaints and/or disputes.

Participation in marketing programs or events:

Signing up for loyalty programs

Participation in customer surveys (for example, the Guest Satisfaction Survey)

Online games or competitions

Subscription to newsletters, in order to receive offers and promotions via email.

Transmission of information from third parties:

Tour operators, travel agencies, GDS reservation systems,online travel agencies,destination management companies,event organizers and others.

CCTV is in operation throughout the accommodation for the purposes of, including but not limited to:

Security of property, employees and guests; Health & Safety, and; Public Liability.

Internet activities:

Connection to NEWEL websites (IP address, cookies)

Online forms (online reservation, questionnaires, NEWEL pages on social networks, network login devices such as Facebook login etc.).

7. FOR WHAT PURPOSES?

We collect your personal data for the purposes of:

Meeting our obligations to our customers.

Managing the reservation of rooms and accommodation requests:

Creation and storage of legal documents in compliance with accounting standards.

Managing your stay at the apartments:

Monitoring your use of services

Managing access to rooms

Internal management of lists of customers having behaved inappropriately during their stay at the apartments (aggressive and anti-social behavior, non-compliance with the accommodation contract, non-compliance with safety regulations, theft, damage and vandalism, or payment incidents).

Improving our accommodation service, especially:

Processing your personal data in our customer marketing program in order to carry out marketing operations, promote brands and gain a better understanding of your requirements and wishes

Adapting our products and services to better meet your requirements

Customizing commercial offers and the promotional messages we send to you

Informing you of special offers and any new services created by NEWEL or one of its subsidiaries.

Managing our relationship with customers before, during and after your stay:

Managing the loyalty program

Providing details for the customer database

Segmentation operations based on reservation history and customer travel preferences with a view to sending targeted communications

Predicting and anticipating future behaviors

Developing statistics and commercial scores, and carrying out reporting

Providing context data for the offer push tool when a customer visits a Group website or makes a reservation

Knowing and managing the preferences of new or repeat customers

Sending you newsletters, promotions and tourist, accommodation or service offers, or offers from NEWEL partners, or contacting you by telephone

Managing requests to unsubscribe from newsletters, promotions, tourist offers and satisfaction surveys

Taking into account the right to object

Using a dedicated telephone service to search for persons staying in NEWEL aparthotels in the event of serious events affecting the accommodation in question (natural disasters, terrorist attacks etc.).

Use a trusted third party to cross-check, analyze and apply certain devices to your collected data at the time of booking or at the time of your stay, in order to determine your interests and your customer profile, and to allow us to send you personalized offers.

Improving NEWEL services, especially:

Carrying out surveys and analyses of questionnaires and customer comments

Managing claims/complaints

Offering you the benefits of our loyalty program.

Securing and enhancing your use of NEWEL websites, especially:

Improving navigation

Implementing security and fraud prevention.

Conforming to local legislation (for example, storing of accounting documents).

8. CONDITIONS OF THIRD-PARTY ACCESS TO YOUR PERSONAL DATA

a. In order to offer you the best service, we can share your personal data and give access to authorized personnel and external service providers from NEWEL, including:

Accommodation staff

Reservation staff using NEWEL reservation tools

IT departments

Commercial partners and marketing services

Medical services if applicable

Legal services if applicable

Generally, any appropriate person within NEWEL entities for certain specific categories of personal data.

b. With service providers and partners: your personal data may be sent to a third party for the purposes of supplying you with services and improving your stay, for example:

External service providers: IT sub-contractors, international call centers, banks, credit card issuers, external lawyers, dispatchers, printers.

Commercial partners: NEWEL may, unless you specify otherwise to the Data Privacy department, enhance your profile by sharing certain personal information with its preferred commercial partners. In this case, a trusted third party may cross-check, analyze and apply certain devices to your data. This data processing will allow NEWEL and its privileged contractual partners to determine your interests and your customer profile, and will allow us to send you personalized offers.

Social networking sites: In order to allow you to be identified on the website without the need to fill out a registration form, NEWEL has put the Facebook & Google login system in place. If you log in using the Facebook or Google login system, you explicitly authorize NEWEL to access and store the public data on your Facebook and Google account, as well as the other data mentioned during use of the Facebook and Google login system.NEWEL may also communicate your email address to Facebook or Google in order to identify whether you are already a Facebook or/and Google user, in order to post personalized and relevant ads on your Facebook and Google account if appropriate.

c. Local authorities: We may also be obliged to send your information to local authorities if this is required by law or as part of an inquiry and in accordance with local regulations.

9. PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS

For the purposes set out in Clause 7 of this Charter, we may transfer your personal data to internal or external recipients who may be in countries offering different levels of personal data protection.

Consequently, in addition to implementation of this Charter, NEWEL employs appropriate measures to ensure secure transfer of your personal data to an NEWEL entity or to an external recipient located in a country offering a different level of privacy from that proposed in the country where the personal data is collected.

Other than those that are required to carry out your reservation, dataflows to countries having different levels of personal data protection are regulated by standard contractual manager-to-subcontractor clauses defined by the European Commission. Dataflows to the United States are made to entities that belong to Safe Harbor.

10. DATA SECURITY

NEWEL takes appropriate technical and organizational measures, in accordance with applicable legal provisions, to protect your personal data against illicit or accidental destruction, accidental alteration or loss, and unauthorized access or disclosure. To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection etc.).

When you submit credit card data when making a reservation, SSL (Secure Socket Layer) encryption technology is used to guarantee a secure transaction.

11. STORAGE OF DATA

We retain your personal data only for the period necessary for the purposes set out in this Charter or in accordance with the provisions of applicable law.

12. ACCESS AND MODIFICATION

You have the right to access your personal data collected by NEWEL and to modify it subject to applicable legal provisions.

You may also exercise your right to object by writing to the address below.

In the event of difficulty exercising your rights, we have designated responsibility for data protection compliance to a suitable individual within the organization. Mr. Michael Vardaros has been appointed as Data Protection Officer (DPO). If you have any questions about our preparation for the GDPR, please contact gdpr@the-newel.com

Or mail at the following address:

NEWEL

Vouliagmenis Avenue 3

Athens 11636

For the purposes of confidentiality and personal data protection, we will need to identify you in order to respond to your request. NEWEL may request a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If NEWEL is dissatisfied with the quality, further information may be sought before personal data can be released.

If your personal data is inaccurate, incomplete or not up to date, please send the appropriate amendments to the Data Privacy representative as indicated above.

You can request the following information:

– Contact details of the data protection officer, where applicable.

– The purpose of the processing as well as the legal basis for processing.

– If the processing is based on the legitimate interests of NEWEL or a third party such as one of its clients, information about those interests.

– The categories of personal data collected, stored and processed.

– Recipient(s) or categories of recipients that the data is/will be disclosed to.

– How long the data will be stored.

– Details of your rights to correct, erase, restrict or object to such processing.

– Information about your right to withdraw consent at any time.

– How to lodge a complaint with the supervisory authority (Data Protection Regulator).

– Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

– The source of personal data if it wasn’t collected directly from you.

– Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

All requests will receive a response as swiftly as possible and in accordance with applicable law.

Under GDPR you have ‘The Right to be Forgotten’ where you as a customer can, at any time, request that we remove all your personal information from our system. However it is important to remember that any Right to be Forgotten request does not override requirement to hold information under any other legislation, for example, you cannot request for financial records to be destroyed that you undertook in the last 7 years within NEWEL accommodation.

At any point whilst NEWEL is in possession of or processing your personal data, all data subjects have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.

Right of portability – you have the right to have the data we hold about you transferred to another organisation.

Right to object – you have the right to object to certain types of processing such as direct marketing.

Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

You may also exercise your rights in respect of your personal data that is stored and processed by a hotel following a stay. To do this, you must contact the hotel directly.

13. UPDATES

We may modify this Charter from time to time. Consequently, we recommend that you consult it regularly, particularly when making a reservation at one of our hotels.

14. QUESTIONS AND CONTACTS

For any questions concerning the NEWEL’s personal data protection policy, please contact gdpr@the-newel.com .