Customer Personal Data Protection Charter
Valid from: 21/5/2018
At MONOGRAM HOTELS, we prioritise the protection of your personal data as part of our general philosophy to aim for the highest possible customer satisfaction and to build strong relations of trust.
We understand the importance of your personal data and make every possible effort to store and process the information you share with us with utmost care.
At MONOGRAM HOTELS, we enhance the protection of your personal data by implementing technical data security measures and internal management procedures, as well as physical data protection measures. We continuously evolve our systems and procedures in order to stand out in relation to others. We thank you for your continued interest and support.
"Personal data" means any information that is collected or recorded in a form that may allow direct (e.g. surname) or indirect (e.g. phone number) your identification as a natural person.
This "Customer Personal Data Protection Charter" is a part of the terms and conditions that govern our hotel services. By accepting these terms and conditions, you explicitly accept the provisions of this Charter.
3. For what purposes do we collect data?
We collect and use personal data in order to manage your relation with MONOGRAM HOTELS and in order to offer our Services to you. Certain personal data are collected to provide you with personalised and improved services.
We collect personal data with the following purposes:
a) Management of reservations and other hospitality services
- Creation and storage of legal documents in accordance with applicable law
- We collect data in order to prepare and meet requests relating to your stay (e.g. room preferences)
b) Management of your stay at the Hotel
- We manage the access to your room
- We monitor the use of services (room telephone, mini bar, online room service, WiFi access etc.)
- We manage lists with customers’ personal data for operational purposes such as, e.g., daily customer arrival and departure lists and a list with special category customers.
c) Improvement of our hotel services
- In order to tailor our products and Services to better meet your requirements
- We process your personal data using marketing programmes for marketing and promotional purposes, but also to better understand your requirements and wishes
- We provide you with useful information for offers or other promotional messages
- We inform you about special offers and new Services
- We provide customised content and suggestions based on previous activities with our Services
d) Management of our relations with you before, during, and after your stay
- Management of customer databases
- We evaluate and analyse the market, our customers, our products and Services
- We create statistical data and reports
- We acquire knowledge and manage the preferences of new and recurring customers
- In order to send newsletters, promotion products and offers, or to contact you by telephone
- We manage requests for deletion from update lists
- We create and manage questionnaires and statistics
- We organise lotteries, contests and offers, to the extent allowed by law
e) Improvement of our Services
- We conduct market research and analysis of questionnaires and customer comments
- We manage customers’ claims and complaints
f) System security
- We record data to ensure security and to avoid fraud
g) Compliance with Greek and European law
h) Conducting market research, customer satisfaction and quality assurance, direct marketing and sales promotions
i) Conducting targeted advertising campaigns on the Internet through third-party websites
4. What personal data do we collect?
Information provided directly by you
A number of our Services provide the possibility to provide information directly to us. For example:
- Several of our Services allow users to create accounts or user profiles. In conjunction with these Services, we may ask you to provide certain details about yourself in order to set up your account or profile.
- When ordering a paid product or service from us, we may ask certain details for the processing of your order, such as your name, room details and billing data.
- When participating in an online or offline contest or promotional action organised by us, we may ask you for your name, contact details, email address, age and gender, personal and occupational interests, other personal characteristics, and your opinion of our products and/or services.
- Some of our Services allow you to communicate with other people. This communication will be transmitted through, and stored on our systems.
We are obliged to request the following details about you and/or your family members:
- Contact details (e.g. surname, given name, father’s name, passport number, ID-card details, telephone, home address, email)
- Personal data (e.g. date of birth, nationality, place of birth)
- Information on your children (e.g. given name, date of birth, passport number)
- Billing details (e.g. credit card number, VAT number)
- Date of arrival and departure, flight number and room number
- Preferences and interests (e.g. non-smoking room, preferred floor, type of bed, sports, cultural
- Medicine data about your health, such as medicine reports and certifications, medical test results, data on pathological diseases, etc.
- Questions and comments submitted during or after your stay in one of our Hotels.
The data we collect on persons under the age of 16 are restricted to given name, surname, nationality, and date of birth, and can be provided only by an adult / guardian. We thank you for your efforts to ensure that children do not send us personal data without your consent (especially through the internet). Should any information of this type be sent to us, you can communicate with us to schedule the deletion of such information.
Moreover, information such as your passport number, your recreational activities, your hobbies, any health issues that you may have, or whether you are a smoker or not, can be described as sensitive. We retain such information only if we are obliged to do so by applicable law or if you have explicitly given us your consent (e.g. in order to provide you with an appropriate Service, such as a special diet)
Information on your use of our Services
Apart from the information provided directly by you, we may also collect information on your use of our Services through the software of your device, or by other means. For example, we may collect:
- Device information - such as hardware model, International Mobile Equipment Identity (IMEI) and other unique device identity data, MAC address, IP address, operating system issue, and setting of the appliance you use to access our Services.
- Connection information - such as the time and duration of use of the Service, search commands entered in the Services, and information that may be stored in cookies we have placed on your device.
- Location information - such as GPS signal of your appliance, or information on WiFi access points that may be transmitted to us when you use our Services (e.g. WiFi, Guestportal, Mobile Apps).
- Audio/visual information - such as recordings we make of your voice (and which may be stored on our servers) when you use voice commands to use a Service, or audiovisual information collected through closed circuit tv circuits (CCTV) for security reasons.
- Other information that relates to your use of our Services, such as the applications that you use, the websites that you visit, and the way in which you interact with content offered through a Service.
Information from third parties
We may receive information about you from available public and commercial sources (to the extent permitted by law), which we may combine with other information that we receive directly from you, or in relation to you. We may also receive information about you from third party social networking services when you choose to connect to such services.
Other information we collect
We may also collect other information about you, your device or your use of services in manners described at the point of collection, or otherwise with your consent.
You may choose not to provide certain types of information, but this may influence the possibility to use certain Services.
5. When do we collect personal data?
We collect personal data in various cases, such as:
a) Hotel activities:
- Room reservation
- Check-in and payment
- Reservation of seat and/or use of hotel services, such as catering, and recreational services
- Various requests, complaints and/or disputes
b) Participation in marketing programmes or events:
- Participation in online and offline surveys (for example, Customer Satisfaction Survey)
- Participation in contests and games
- Subscription to mailing lists, in order to receive offers and other promotions by email
c) Transmission of information from third parties:
- Tourist agencies, tourist offices, GDS reservation systems, online reservation systems (such as e.g. booking.com, expedia.com, etc.) and other reservation systems
d) Actions through electronic devices
- Login on our websites
- Connection to the WiFi network of our hotels
- Completion of online forms (e.g. reservation forms, precheck-in forms, satisfaction survey forms, etc.)
6. Third party access terms to your personal data
At MONOGRAM HOTELS, it is part of our philosophy and basic principles to not disclose your information with third parties for their unrelated business or marketing purposes, without your consent.
However, we may disclose your information to the following entities:
- Business associates. We may also share your information with trusted business partners. These entities may use your information in order to provide you with services you have requested, to make provisions relating to your interests, and possibly to provide you with promotions, advertisements and other material.
- Service providers and/or any third parties that may process information on our behalf. We may also share your information with companies that provide services on our account or behalf, such as IT contractors, bulk mailers, banks, credit card institutions, law firms, mail service companies, printing services companies, etc.
- Credit Approvals: When applying for credit, your personal information is used and disclosed to appropriate third parties in accordance with applicable law to decide on the granting and maintenance of a credit limit for you.
- Other third parties, if so required by law or in order to protect our Services. Situations may arise in which we share your information with other third parties:
- in order to comply with the law or in order to comply with a mandatory legal procedure (such as search warrants or other court orders),
- in order to confirm or implement our compliance with the policies governing our Services; and
- in order to protect the rights, ownership or security of MONOGRAM HOTELS or any of our business partners or customers.
- Other third parties in relation to corporate transactions. We may share your information with third parties within the context of a merger or transfer, or in the event of bankruptcy.
In order to provide you the best possible service, we allow access to your personal data or to certain categories thereof to competent, authorised members of our personnel. This includes:
- Hotel staff
- Reservations departments
- IT department
- Marketing/Guest Relations department
- Legal Services department, if and when required
- Medical Services, if and when required
7. Protection of personal data during international transfer
For the purposes set out in Article 3 of this Charter, we may transfer your personal data to internal or external recipients who may be located in countries that offer different levels of protection for personal data.
Please note that data protection and other laws in the countries to which your information may be transferred may not be equally protective as in your country. The transfer will take place according to the legislation on the processing of personal data, in order to ensure sufficient protection of your personal data.
ΜΟΝΟGRAM HOTELS implements suitable measures in order to ensure safe transfer of your personal data to an external recipient located in a country that offers a different level of privacy than the one proposed by the country where the personal data are collected.
8. What we do to keep your information safe
We have taken reasonable organisational and technical measures in order to protect the information that we collect in relation to our Services, especially with regard to any sensitive personal data that happen to be collected. Our IT department implements the international standards and practices in order to ensure the safety of the networks and the encryption of the data.
Ensure the confidentiality of the transfer of your personal data
To ensure the confidentiality of data transfer, we use the SSL-128bit encryption protocol. Encryption covers all areas of the website as well as the transfer of data to and from our mail server (Mail Exchanger).
Controlled Access (Firewall)
Access to its systems MONOGRAM HOTELS (Servers) is controlled by Firewall, which allows the use of specific services by customers/users while prohibiting access to systems and databases with confidential data and company information. There are also additional security systems such as WAF, Antivirus, Antimalware, Cpanel Whm etc. which reduce the chances of malicious actions.
The system of MONOGRAM HOTELS It first decrypts the information it receives using the same key (predetermined when you start your connection with the service) and then processes it. The systems of MONOGRAM HOTELS. They send you information by following the same encryption process. At any point in the Site Enter personal data (name, address, phone number, etc.) there is SSL 128-bit encryption. Encryption is essentially a way of coding the information until it reaches its designated recipient, who will be able to decode it using the appropriate key.
That is, every time you send information to the system, the Browser Encrypts them first by using a 128 key Bits And then sends them to the system.
The system of MONOGRAM HOTELS first decrypts the information it receives using the same key (predetermined when you start your connection with the service) and then processes it. The systems of MONOGRAM HOTELS send you information by following the same encryption process.
However, you should bear in mind that despite the reasonable measures that we take for the protection of your information, no website, Internet transmission, computer system or wireless connection is ever completely safe.
9. Data storage
We take reasonable measures in order to ensure that the information concerning you will be stored no longer than needed for the purpose for which it has been collected and no longer than required by the contract or the applicable legislation.
Cookies are small files that store information on your computer, mobile phone, or other device. They allow the entity who places these files on your device to identify you across different websites, services, devices and/or browsing times. Cookies serve a range of useful purposes. For example:
- Cookies can remember your login credentials, so you do not have to enter them again each time you connect to a service.
- Cookies help us and third parties to understand what parts of our Services are the most popular; they help us see which pages and features are visited by the users, and how much time is spent on each. By studying this kind of information, we can better customise our Services and provide you with better experience.
- Cookies help us and third parties to understand which advertisements you have viewed, so that you do not receive the same advertisement each time you access the Service.
- Cookies help us and third parties to provide you with relevant content and advertisements by collecting information about your use of our Services and other websites and applications.
When you use a web browser in order to access our Services, you can make settings in your browser to accept all cookies, to reject all cookies, or to notify you when cookies are sent. Each browser is different. Refer to the “Help” menu of your browser in order to find out how you can change your cookie preferences. The operating system of your device may offer more control settings for cookies.
However, please note that certain Services may have been designed in order to work with cookies and that deactivating cookies may affect your ability to use these Services or a specific part there of.
10. Access and correction of your data - Right to erasure (‘right to be forgotten’)
According to the legislation in certain jurisdictions, you may be entitled to request details on the information that we collect and to correct any inaccuracies that may be contained in such information. All other lawful user rights remain unaffected. If permitted by law, we may charge you a small fee for the provision of this possibility. We may refuse to handle requests that are repeated to an unreasonable degree, require disproportional technical effort, jeopardise the privacy protection of others, are extremely unpractical, or involve access that is not otherwise required by domestic law. In case you want to modify or delete your personal data please visit our page https://monogramhotels.gr/privacy-policy, in which you will find our contact information. Stay confident that our team will serve you as soon as possible.
Υοu have the right to obtain from the controller the erasure of your personal data.