POLITIQUE DE CONFIDENTIALITÉ

Scope of This Privacy Policy

This Privacy Policy shall be applicable to all Sani Resort’s premises and/or digital environments owned by SANI or operated for SANI, related to our activities.

Where the terms “SANI Resort”, “Sani”, “we”, “us”, or “our” are mentioned in this Privacy Policy, they shall refer to “SANI DEVELOPMENT AND TOURISTIC S.A.” (Sani S.A).

Sani S.A is the Data Controller (except for specific cases mentioned in this Privacy Policy) and can be contacted at 55, Nik. Plastira Street, Thessaloniki.

At SANI Resort, we guarantee our commitment to respecting and protecting your privacy, as well as safeguarding your personal data. Our vision and goal is the provision of services that exceed your highest expectations. Therefore, SANI with respect to the applicable national and European legal framework about data protection, especially the new European General Data Protection Regulation 2016/679 (GDPR) provides you hereby a lawful, fair and transparent policy in order to inform you about the personal data we collect, how we use it, and how the use of this information can benefit your experience while visiting our premises and/or our online platforms (website’s and mobile application).

We are dedicated to achieving transparency of the collection and use to your personal data, therefore we wish to provide you via this Privacy Policy with information about:

- what personal data we collect and how we use them;

- the purposes we process your personal data and the relevant legal basis under which we process your personal data;

- your rights related to your personal data.

This Privacy Policy aims to transparently inform you on the processing of your personal data, however it may not include all our processing activities as these constantly evolve. In case that a new processing activity is added, we shall endeavor to update this Privacy Policy and, in any case, we will provide you with the necessary information before you provide us with your data.

You can always find out more by contacting our Data Protection Officer at the contact details, as further described below (Your Rights).

What Personal Data we collect and how we use them

Α.Guests

A.1. Data collected for booking purposes

Online booking engine through our website:

If you decide to make a booking reservation through our website, we will collect your name and surname, address, city, country, telephone, email, any special requests you may have, your credit card details (card type, card number, secure code, expiration date, card owner), arrival date and departure date as well as flight details in case of a transfer request.

Our mobile application:

If you decide to make a booking reservation through our mobile application (Sani App), we will collect your name and surname, address, city, country, telephone, email, any special request, your credit card details (card type, card number, secure code, expiration date, card owner). For more information please refer to our Mobile Application’s Privacy Policy.

Booking confirmation form:

If you contact us directly, to make a reservation, we will send you the booking confirmation form in order to provide us the necessary information, such as name and surname, address, telephone, email, your credit card details (i.e. card type, card number, expiration date, card owner).

Third parties’ online booking engines and/or travel agents:

In this case, we receive an email confirming your booking, including information such as your name and surname,  country, arrival date and departure date, flight details in case of transfer, any (family) members that will accompany you, any special requests (i.e. requirement for transportation, declaration of special preferences and/or allergies that we should be aware of).

A.1.1. Purposes of processing – legal basis

We collect your booking data in order to:

  • Process and complete your booking reservation:
  • Process the payment of the relevant services, fees and charges. Our legal basis is that processing is necessary for the performance of a contract with you.
  • Collect and recover money owed to us. Our legal basis is our legitimate interest.
  • Process your details in case of disputes. Our legal basis is our legitimate interest.
  • Facilitate your booking and organize airport transfer, if you make a request for that. Our legal basis is that processing is necessary for the performance of a contract with you.

A.2. Registration Data – Check-in procedure

When you arrive at Sani Resort – Check-in procedure:

During your arrival at Sani Resort, you will provide us with the necessary information for the check-in procedure. More specifically, we collect your title, your first and last name, your language, your address (street, postcode, city, country), your nationality, your telephone number, your email address, names of any (family) members that will accompany you and their date of  birth, your date of birth, passport/ID number, car plate, your credit card details, arrival date and departure date as well room number.

Allergies/Special Preferences Declaration:

Allergies and special preferences may constitute in some cases sensitive personal data. We may collect such data only if you voluntarily provide us, or when we ask you to do so and you provide us your explicit consent.

If you wish to share with us your allergies or other preferences, in order to register this information in our systems and inform the relevant departments during your stay at our premises, we will ask you to provide us your consent to keep this data and subsequently inform adequately our a la carte restaurants and/or housekeeping department for your safety, convenience and esteemed personalized services. In such case, we will collect your name, surname, date of birth, arrival and departure date and room number, as well as any allergy or any preference request. 

A.2.1. Purposes of processing – legal basis

We collect your registration data for:

  • Completion of the registration procedure. Identification data is necessary in order to comply with our legal obligations
  • Serving your stay. Our legal basis is our legitimate interest. In case you wish to record your allergies/preferences information, we will proceed to relevant processing if you provide us your consent.
  • Facilitating administration. Our legal basis is our legitimate interest.
  • Facilitating payment procedure. Payment information is necessary in order to issue your invoice and comply with fiscal obligations
  • Improving our services to offer you memorable stays. Our legal basis is our legitimate interest.
  • Offering you personalized services (regarding preferences etc.). Our legal basis is your prior consent, if provided.
  • For communication and marketing purposes including analyzing your travel and accommodation preferences in order to offer you tailor-made services. Our legal basis is your prior consent, if provided.
  • Promoting our special offers and goods, services or forthcoming events or promotions which may interest you. Our legal basis is your prior consent, if provided.

A.3. Room Service

In case you wish to submit an “In room Dinning” request, then your order (including food preferences and any allergies, if reported) along with your name and your room number will be collected. This information will be properly destroyed upon your departure.

A.3.1. Purposes of processing – legal basis

We collect data you provide us via room service for:

  • Serving your stay. Our legal basis is our legitimate interest. In case you wish to record your allergies/preferences information, we will proceed to relevant processing if you provide us your consent.

A.4. Membership Data

If you have been provided with a Sani Resort Membership Card as a returning guest/repeater, we collect your name, surname and membership number and we process this information when you make use of the relevant privileges. 

A.4.1. Purposes of processing – legal basis

We collect your Sani Resort Membership data to:

  • Provide you with special offers and rewards and better serve your stay. Our legal basis is our legitimate interest.

A.5. Restaurants’ Reservations Data

Reservation via our call center:

In case you wish to make a restaurant reservation through the reservations’ call center, we collect your name, surname, room number and any other special request you may have.

Reservation via Sani’s App:

In case you wish to make a restaurant reservation via our Sani App, we collect your name, surname, room number and relevant booking details.

A.5.1. Purposes of processing – legal basis

We collect the data you provide us for Restaurant Reservations for:

  • The management of your reservations through the call center or our Sani’s App. Our legal basis is our legitimate interest.

A.6. Personal Data when you visit our Spa/Gym Facilities

When you visit our Spa/ Gym facilities, we collect personal information which is necessary for the provision of our services.

  • During your registration we collect your name, surname, email address, signature and room number.
  • If you wish to enjoy our Spa treatments, then you need to provide us with all the above-mentioned data and necessary health information, through the completion of the treatment questionnaire (such as medication, allergies, possible pregnancies etc.), as it is included in our Consultation Form.
  • Moreover, if you buy products from us, we will process your retail sales data.

A.6.1. Purposes of processing – legal basis

We collect the data you provide us when you visit our Spa/Gym facilities for:

  • Completion of the registration procedure. Identification data is necessary for our legitimate interest to keep safe our guests and premises.
  • The provision of our services, via the completion of the treatment questionnaire in our Consultation Form. These data are necessary in order to maintain all safety and security measures during the provision of our services, for the protection of your, as well as our staff’s health. Such processing is based on your consent, if provided.  
  • The completion of a transaction and invoicing. Our legal basis is that processing is necessary for the performance of a contract with you.
  • In order to send you newsletters, e-mails and news on our latest spa products and related offers. We will proceed to relevant processing if you provide us your consent.
  • Transferring your email address to our business cosmetics partners to receive communication about their news, latest product launches and offers. We will transfer your data, if you provide us your consent.

A.7. Personal data you provide in the course of Children/Sport Activities.

We collect and process minors’ (i.e. under the age of 18) personal data for their participation in different Children or Sport Activities as they are occasionally organized and held at Sani Resort. We do not collect these data directly from the minors, but from their legal guardians. In the context of Children/Sport Activities, personal data are being collected, indicatively, in the following cases:

World Wide Kids Activities:

World Wide Kids is a childcare expert for the hospitality and leisure industry. Worldwide Kids’ goal is to aid our guests in providing the highest standards of childcare for children of all ages. Therefore, we have assigned World Wide Kids to handle our Kids’ Clubs. They are responsible for the whole operation of the kids’ club including the processing of personal data, therefore they act as the Data Controllers. We only receive personal information for specific processing activities for which we act as Data Processors on their behalf. You can learn more about World Wide Kid’s Privacy Policy at the following link: https://www.worldwide-kids.com/privacy-policy/.

In any case, if you wish to express a request regarding relevant personal data, you can always address to our DPO (contact details below) and we will forward your request to World Wide Kids.

Chelsea Football Academy:

The personal data we collect in case your child participates in our Chelsea Football Academy are the parents’ name and surname, the child’s name, age, parent’s telephone number etc.

A.7.1. Purposes of processing – legal basis

We collect the data you provide us when your child is registered in our football academy for:

  • The completion of a transaction and invoicing purposes. Our legal basis is that processing is necessary for the performance of a contract with you.
  • Ensuring security. Our legal basis is the legitimate interest.

A.8. Children Consultancy services

We always endeavor to work with the best professionals to meet even the most difficult demands. In this respect, we work with “Carol Mae Consulting” to offer our guests baby and toddler advice program. If you wish to use this service, which helps families adjust their children’s sleep and behavioral routines to the holiday setting, we will not receive any personal information about you and your child. All personal data are shared directly to the Consultant by you. However, data that is absolutely necessary for invoicing purposes (i.e. your name, surname, room number and costs of the Consulting Services) shall be transferred by the Consultant to us. In any case, if you wish to express a request regarding relevant personal data, you can always address to our DPO contact details below and we will forward your request to Carol Mae Consulting.

A.8.1. Purposes of processing – legal basis

We collect data you provide via Kid’s Consultancy services for:

  • The completion of a transaction and invoicing purposes. Our legal basis is that processing is necessary for the performance of a contract with you.

A.9. Personal Data collected via Guests’ Questionnaires

For us, your feedback is valuable, as it helps us improve our services to you. You may at any point provide us with your feedback, by completing our Guest Questionnaire. If you wish to complete it, the provision of personal information (i.e. your name, surname, room number email, address, country, profession, arrival data, length of stay, data of birth) is optional.

A.9.1. Purposes of processing – legal basis

We collect the data you provide us through our Guests Questionnaires for:

Evaluating your experience, improving our services, as well as to further contact you to discuss your experiences during your stay at our premises, and evaluate services rendered to you in the future. Our legal basis is our legitimate interest.

A.10. Personal Data Collected for the use of SANI Marina

When you submit an “application form – statement for the mooring of the boat” for the use of our Marina, we collect all the voucher issue details, boat owners or legal representatives’ details, captain’s details (i.e. name, surname, address, country, contact details, tax registration number, tax office).

A.10.1. Purposes of processing – legal basis

We collect the data you provide for the use of SANI Marina for:

  • The completion of a transaction and invoicing purposes. Our legal basis is that processing is necessary for the performance of a contract with you.

A.11. Personal Data collected for Security reasons

Images/video

We collect, process and store images through our video- surveillance systems (“CCTV systems”), where installed, for security reasons, pursuant to the requirements and standards set by the national and union law for the retention of data, sound and images.  

Security Reports

Reports including personal data are being prepared by our Security department for security reasons (i.e. incident reports, object lost reports, open safe list etc.). Such reports may include personal information, such as name, surname room number and will be recorded only for security purposes. 

Accident form

In case that an accident occurs in our premises, you will be requested to provide information such as your name, surname, date of birth, room number, duration of stay, as well as some additional information about the accident, such as the location of the incident, date and time of incident, it’s nature and any further relevant details.

A.11.1. Purposes of processing – legal basis

Our Security department collects data for:

  • The operation of the CCTV system in order to guarantee the security of our employees, establishments and equipment. Our legal basis is the legitimate interest.
  • The creation of security reports. Our legal basis is the legitimate interest.
  • To assess and investigate an accident/incident according to relevant internal procedures, for the proper handling of any legal issues arising onwards:
  • Transferring data to our insurance company. Our legal basis is your explicit consent, if provided.
  • Handling of the incident. Our legal basis is that processing is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity.

A.12. Profiling

We may use your information in order to evaluate certain personal aspects relating to you as a client. However, we do not proceed to any decision on you, based solely on automated processing, including profiling, which may produce legal effects concerning you or which may similarly significantly affect you.

When we use profiling for the provision of tailor made offers and services (not wholly automated decision making), you always have the right to object to such processing (including profiling) that is related to direct marketing at any time by submitting your request to our DPO contact details, as further described below (Your Rights).

A.12.1. Purposes of processing – legal basis

We may use your personal data to:

  • Analyze aspects concerning your personal travelling preferences and interests. Our legal basis is the legitimate interest.
  • Customize tailor made services ahead of, during or after your stay with us. Our legal basis is the legitimate interest.
  • Provide you with direct marketing services. We will proceed to relevant processing if you provide us your consent.

B. Data collected through our website or online platforms

B.1. Personal Data Collected via your registration to our Newsletter

When you register for receiving our newsletter, we collect and store your email address and if you wish you can submit your name, surname and country.

B.1.1. Purposes of processing – legal basis

We use data you provide us when you register to our Newsletter for:

  • Communication with you and sending you newsletters about our services, products and offers. We will proceed to relevant processing if you provide us with your consent.

B.2. Agents’ Data

Agents’ Registration System:

if you register as an agent via website: https://saniresort.swapsystems.com/createagent.aspx kindly note that, by providing your information via this form, you are registered as an agent to Swap Systems. For more information on the protection of your personal data from Swap Systems please visit their website: https://www.swapsystems.com/.

Sani will be informed of your request and you will receive a notification email once your account has been activated. Data selected via this form are Company’s data and Company’s contact person, and not considered as personal data or information. We will use the email address that you provide us via this form, to inform your company about our business news as part of our cooperation. However, you can always choose to unsubscribe from this business communication by clicking the unsubscribe button which is available in our communications.

B.2.1. Purposes of processing – legal basis

We use data you provide us via our Agents’ Registration System for:

  • Completion of the registration procedure. However, these data are only processed for our business relationship. These data do not constitute personal data, in any case if personal data are being processed, our legal basis is our legitimate interest.
  • Informing your company about our business news in the context of our cooperation. Our legal basis is our legitimate interest.

B.3. Personal Data Collected via Sani’s App

The Application obtains the information you provide when you download and register the Application. The Application is created and developed by M-HOSPITALITY (H+S Technology Solutions S.A.) on behalf of SANI S.A.  Signing up to the Mobile Application is optional, but when you choose to do so and use the Mobile Application, you provide indicatively, your first name, last name, email address, password and other registration information, mobile, hotel or resort, prefix, gender, country of origin and any other information you may provide us when you contact us for assistance, as well as credit card information for reservations via the Mobile Application. We may also collect information on bookings or requests you submit via the Mobile Application. For more information on the use and protection of your personal data collected through the Mobile Application, please refer to the Mobile Application’s Terms of Use and Privacy Policy.

B.3.1. Purposes of processing – legal basis

We collect your data in order to:

  • Provide you with the application and facilitate navigation through our app. Our legal basis is our legitimate interest.
  • Provide you with location alerts and notifications, if you have provided your consent.
  • Create your account. We will proceed to relevant processing if you provide us your consent.
  • Process and complete your booking, if effectuated via the app:
  • Facilitate your booking and respond to your request. Our legal basis is that processing is necessary for the performance of a contract with you.
  • Complete the payment of the relevant services, fees and charges. Our legal basis is that processing is necessary for the performance of a contract with you.
  • Collect and recover money owed to us. Our legal basis is our legitimate interest.
  • Process your details in case of dispute notifications. Our legal basis is our legitimate interest.

B.4. Online Technologies

At SANI’ s website and Mobile Application, we may use cookies, invisible pixels, and web beacons to obtain information about you while visiting our websites. For more information on our use of cookies, please read our Website’s Cookies Policy as well as our Cookies Policy for the mobile application.

C. Job Applicants & Employees

C.1. Job Applicants

If you wish to apply for a job vacancy, we will collect and further process only the personal information which is necessary for the assessment of your suitability to the job position (e.g. name, surname, contact details, education, working experience etc.). We collect these data when you submit an application by any means (e.g. by sending an email to the Company’s email address, using recruitment platforms, accessing through the Company’s website), as well as through the documents you enclose with your application (e.g. CV, certifications, certificates etc.). Moreover, during the assessment of your application, we may use further questionnaires or personality tests which reveal information about you, in order to further evaluate your suitability for a particular job position, ensuring having obtained your prior consent. When you include into your application the contact details of your previous employers, we may contact them, so as to provide us with information about your position, collaboration with them and their evaluation for you.

For more specific information about the relevant processing of your personal data you can read the Job Applicants’ Privacy Notice available at: https://www.sani-resort.com/uploads/assets/45208dd2b3.pdf

C.1.1. Purposes of processing – legal basis

We collect your data in order to:

  • Assess your application. Our legal basis is our legitimate interest.
  • Maintain your CV and assess its suitability for relevant vacancies in SANI-IKOS group. Our legal basis is our legitimate interest.
  • Learn more about your personality. We will proceed to relevant processing if you provide us your consent.
  • Contact with your previous employers, so as to provide us with information about your position, collaboration with them and their evaluation for you. Our legal basis is our legitimate interest.
  • Send you communication on SANI-IKOS group educational seminars, programs and actions. We will proceed to relevant processing if you provide us your consent.

C.2. Employees

We collect and process personal information related to the employment relationship, as defined in the relevant agreement. Indicatively, such data may include the name, surname, forenames, date of birth, place of birth, gender, nationality, home address, e-mail address, contact telephone numbers, ID number, Tax Identification Number, Social Security Number and other insurance registry numbers, health booklet, criminal record (if required by the relevant position), work permit, bank account number (IBAN), CV, education diploma, health, marital status and data of depending members of the family, data on your education and training, on your working experience, as applicable for the exercise of our statutory obligations. We always provide you with a relevant privacy notice as an Annex to our Agreement, respecting your privacy and your respective rights.

C.2.1. Purposes of processing – legal basis

We collect your data in order to:

  • Handle our contractual agreements. Our legal basis is the need to process your data in the context of our contractual obligation or during the pre-contractual stage.
  • Fulfill our legal obligations as employers. Our legal basis is the need to process your data in compliance with a legal obligation.
  • Use your photos to upload them to the website. We will proceed to relevant processing if you provide us your consent.

D.1. Personal Data of our business partners

If you are cooperating with us, we may process only the necessary data to fulfill our contractual agreement and serve our business relationship.  We shall only collect Company’s data and/or Company’s contact persons’ data which are not considered as personal data or information. We may use the email address that you voluntarily provide us to inform your company about our business news as part of our cooperation. However, you can always choose to unsubscribe from this business communication by clicking the unsubscribe button which is available in our communications.

D.1.1. Purposes of processing – legal basis

We use data you provide us as our business partners for:

  • Serving our business relationship. These data do not constitute personal data, in any case if personal data are being processed, our legal basis is our legitimate interest.

Informing you and your company about our business news in the context of our cooperation. Our legal basis is our legitimate interest.

Special Categories of Personal Data – Sensitive Personal Data

When referring to the notions of “special categories of personal data” or “sensitive personal data”, they reflect the kind of personal information that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and genetic data, biometric data which allows to uniquely identify a natural person, health data and/or data regarding sexual orientation. We may collect such data only if you voluntarily provide us, or when we ask you to do so and you provide us your explicit consent.

Minors Data

We do not seek or obtain personal data directly from minors (i.e. under the age of 18), instead we endeavor to collect such data from their legal guardian and when necessary we obtain relevant consent. However, as it is impossible to always determine the age of persons who access and use our websites, we encourage parents or guardians to contact us if they notice any case of unauthorized data provision by minors in order to exercise accordingly their rights such as deletion of their data.

Transfer of Personal Data

The personal information you provide us is being kept secured and safeguarded. We may share your information within our group – companies and public services for the above described purposes.

Furthermore, we may disclose your personal data to third parties (legal entities or individuals) which process your personal data under our written order and clarifications (Data Processors). We always guarantee that these third parties imply the same measures for the protection of your personal data and act only under our written orders with respect to your personal data.

More specifically, in the context of pursuance of the processing purposes, personal data may be transferred to:

-          Third companies which provide us relevant services (e.g. hosting services, finance, legal or technical support, payroll, etc). In any case, all these companies are contractually bound with us in order to ensure the observance of confidentiality, as well as commitment to the data protection legislation.

-          Companies in our Group, to the extent that this transfer is necessary for the pursuance of our purposes.

-          Public authorities (Police, prosecuting authorities, tax authorities etc.) in the context of issuance of fines, or upon relevant request.

When information is transferred as afore-mentioned, we limit the extend of information that is being disclosed, to the strictly necessary for the performance of the specific purpose. In addition, given that some of our activities are processed by third-parties, we endeavor to ensure by contractual assurances that personal data processing is secure and fully compatible with this privacy policy.

When the transfer of data concerns a country outside the European Union (EU) or the European Economic Area (EEA), we always check whether:

• The Commission has issued an adequacy decision on the third country to which the transfer is addressed to.

• Appropriate safeguards are in place in accordance with the Regulation for the transfer of such data.

In any other case, the transfer to a third country is not allowed and we may not transfer personal data unless any of the specific derogations provided for in the Regulation apply (e.g. explicit consent of the data subject, upon informing him/her on the risks of the transfer, the transfer is necessary for the performance of a contract at the request of the subject, there are reasons of public interest, it is necessary to support the legal claims and the vital interests of the subject etc.).

Third-Party Websites’ Disclaimer

We may provide hyperlinks to third-party websites as a convenience to our users; SANI S.A. does not control third-party websites and is not responsible for the content of any linked-to third-party websites or any hyperlink in a linked-to website. We are not responsible for the privacy practices or the content of third-party websites.

Your Rights

At SANI S.A., we endeavor to protect and respect your rights, as set forth by General Data Protection Regulation, including more specifically:

 (i) your right to be informed on the processing of your personal information (i.e. right of access) and to request and obtain further information on the processing applied;

(ii) your right to request for correction of their inaccurate personal data;

(iii) your right to request for deletion of personal information provided, unless prohibited by legitimate reasons;

(iv) your right to request for limitation of processing;

(v) your right to request for portability of your personal information; and

(vi) your right to objection/opposition to further processing thereof.

In these cases, SANI will respond in writing within 30 days upon receipt and identification of the request.

In addition, in the event of exercising one or more of the above-mentioned rights of correction, deletion and restriction of your data, these requests shall also be forwarded to any third-party recipient to whom the personal information may have been disclosed in the scope of pursuance of the aforementioned processing purposes.

Data Protection Officer

In order to ensure that your personal information is being efficiently protected, SANI S.A. has appointed a Data Protection Officer to whom data subjects may address their requests and questions in relation to this privacy policy, as follows:

SANI RESORT,

Halkidiki, Greece, 630 77 Kassandra,

tel: +30 2374099789,

email: privacy@saniresort.gr

In case you consider that we have not properly responded to your request, you can always contact the relevant Greek Data Protection Authority (www.dpa.gr).

Information Security

Although, no method of transmission over the Internet or method of electronic storage is 100 percent secure, at SANI we have taken all commercially reasonable measures and precautions in order to maintain your data accuracy and to ensure the appropriate use of information we collect about you, as well as to secure and protect your personal information from unauthorized access, while you enjoy products and services we provide you during your physical presence in our premises or your digital visits in our online environment, respectively.

Retention Period of Personal Data

Your personal data is retained for a predetermined and limited period depending on the purpose of processing, after the end of which, these personal data is being deleted from our files unless another retention period is required or permitted by applicable law.

Updates to the Privacy Policy

SANI may amend this Privacy Policy from time to time in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our guests, properties, strategic marketing partners, and service providers. Updated versions will be uploaded to our website and date stamped so that you are always aware of when our Privacy Policy was last updated.

Revised: April 2019

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