This Policy applies to the following companies: Aphrodite Hills Resort LTD, Property Management LTD, Services LTD, Tennis and SPA LTD hereinafter collectively referred to as “Aphrodite Hills” or “AH” as data controller of the personal data collected from this website.
2 Personal Data Collection and Use
Aphrodite Hills has designed a standard website contact form to initiate communication with any interested individual. This form is used for any inquiries or requests and it directs them to the appropriate division or staff member. Additionally, we provide Aphrodite Hills phone numbers for a more direct contact if required. Our landline phone calls are recorded for training and monitoring purposes, and our recordings are usually held for six months. In order to handle and address your inquiries and requests we might collect and store your name, email, telephone number and any other information you might choose to share with us. That information is strictly used to adequately respond to your inquiries or requests and will not be disclosed to third parties others than those mentioned in this policy or where disclosure is required or permitted by law.
Aphrodite Hills has designed other services through the website such as requesting information on buying or selling properties in Aphrodite Hills resort area. For these purposes, Aphrodite Hills needs to receive your name, email address, phone number, country, the special offer you prefer and anything else you choose to share with us.
For information processing to be lawful under the General Data Protection Regulation (GDPR), we identify a lawful basis before we can process your personal data. In case you were directed to agree with this policy, the legal basis for the data processing effected by us is the granting of your explicit consent to the processing, by submitting the consent form only in case you agree with this policy.
3 Transfer of Personal Data
Aphrodite Hills may disclose Personal Data collected to our suppliers or subcontractors insofar as reasonably necessary for dealing with your inquiries or requests. Such transfers will be protected by appropriate safeguards (e.g. appropriate contractual clauses, data processing contracts, intra-group disclosures of personal data, etc.). In addition, we may disclose Personal Data where such disclosure is necessary for compliance with a legal obligation to which we are subject. In any case that we might need to transfer personal data at third parties, Aphrodite Hills is committed to ask for your consent if we will not recognize any other legal basis.
Our website is not intended for children and we do not intentionally solicit or collect personal data from individuals under the age of 18. If we are notified or otherwise discover that a minor’s personal information has been improperly collected, we will take all commercially reasonable steps to delete that information.
In limited instances, we may have a campaign or program targeted towards children. In these instances, details on the information practices will be presented within the terms and conditions of the program or campaign.
5 Personal Data Retention and Deletion
Aphrodite Hills is committed not to retain personal data for a longer period than it is necessary regarding the reasons that the personal data was obtained and we will make sure we will delete it securely. For additional information on retention and deletion periods, please refer to Our Details section.
6 Rights of Data Subjects
In this section Aphrodite Hills addresses the rights deriving from Regulation (EU) 2016/679 and how these rights can be accessed from the Data Subjects. For any further clarifications please refer to Our Details section
7 Individual’s Right of Access or Rectification
Aphrodite Hills assumes that Personal Data collected directly from the individual will be accurate and complete. Individuals can access and update their own Personal Data using the Data Subject Request Form.
8 Individual’s Right to Erasure
The data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies. The Right to Erasure can be requested using the Data Subject Request Form.
Aphrodite Hills is obligated to erase personal data where one of the following applies:
personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
the data subject withdraws consent and no other legal basis for processing exists;
the data subject objects to the processing carried out on the grounds of the Data Controller’s legitimate interests and there are no other overriding legitimate grounds for the processing;
the personal data has been unlawfully processed.
If the request to erase Personal Data has been received, identity has been confirmed, the request meets one of the above requirements and there is no legal contrary reason for processing, Aphrodite Hills must delete the relevant data in its entirety. The request shall be recorded in the Data Subject Request Log.
If Aphrodite Hills cannot actually delete personal data, Aphrodite Hills will ensure that:
is not able, or will not attempt, to use the personal data to inform any decision in respect of any individual or in a manner that affects the individual in any way;
does not give any other organization access to the personal data;
protects the personal data with appropriate technical and organizational security; and commits to permanent deletion of the information if, or when, this becomes possible.
9 Individual’s Right to Restrict Processing
The data subject has the right to obtain from the controller restriction of processing using the Data Subject Request Form.
10 Individual’s Right to Object
Individuals have the right to object at any time to processing of their personal data using the Data Subject Request Form.
11 Individual’s Right to Data Portability
Upon request and provided that the relevant requirements stipulated in Article 20 of GDPR are met, a data subject should have the right to receive a copy of their Personal Data in a structured format using the Data Subject Request Form.
These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.
If Aphrodite Hills cannot respond fully to the request within 30 days, the DPO shall nevertheless provide the following information to the Data Subject, or their authorized legal representative within the specified time:
An acknowledgement of receipt of the request.
Any information located to date.
Details of any requested information or modifications which will not be provided to the Data Subject, the reason(s) for the refusal, and any procedures available for appealing the decision.
An estimated date by which any remaining responses will be provided.
An estimate of any costs to be paid by the Data Subject (e.g. where the request is excessive in nature).
The name and contact information of the contact person.
13 Our Details
If you have any concerns, questions or complaints about this policy, then please contact us at: firstname.lastname@example.org
In case you have any concerns regarding the processing of your data by us such us violation of the applicable laws, you may file a complaint to the corresponding supervising authority.
To make this site work properly, we might place small data files called cookies on your device but none of them are not being used to gather information unnecessarily. The cookies we use might store personally identifiable information (such as your IP address) but they cannot harm your computer. We want our website to be informative and as user friendly as possible and cookies help us to achieve that goal.
These cookies are not strictly necessary for the basic functionality of the website, but they are designed to provide a personalized navigation. However, in case you delete or stop accepting these cookies you might lose some of the functionalities which they provided. These related cookies information, are not used for any other reason beyond what is stated in this policy. For additional information please check “Our Cookies” section.
If you do not agree to such use, please refrain from the use of the website.
Please note that you can only reject cookies that are not absolutely necessary. Some cookies are necessary, as they allow you to provide some features, such as memorizing your preferences in cookies. Other cookies help us to collect statistics on the use of our site, to appreciate how well we meet the needs of users and make the necessary improvements.
2. About Cookies
Cookies are small text files that are stored by the browser (for example, Internet Explorer or Safari) on your computer or mobile phone. They allow websites to store things like user preferences. You can think of cookies as providing a ‘memory’ for the website, so that it can recognise you when you come back and respond appropriately.
remember users’ custom preferences,
help users complete tasks without having to re‑enter information when browsing from one page to another or when visiting the site later.
Cookies can also be used for online behavioral target advertising and to show adverts relevant to something that the user searched for in the past.
2.1. How are they used?
2.2. What are the different types of cookies?
A cookie can be classified by its lifespan and the domain to which it belongs. By lifespan, a cookie is either a:
session cookie which is erased when the user closes the browser or
persistent cookie which remains on the user’s computer/device for a pre-defined period of time.
As for the domain to which it belongs, there are either:
first-party cookies which are set by the web server of the visited page and share the same domain
3. Our Cookies
At this section we inform you for the categories of cookies our website uses.
Strictly necessary cookies: These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.
Performance cookies: These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
Functionality cookies: These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting / Advertising Cookies: Targeting and advertising cookies are usually third-party cookies that we do not have control on them. Our website uses trusted partners to help us serve advertising and analytics (such as Google, Adwords and Twitter). These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisations.
4. Control on Cookies
It is usually possible to stop your browser accepting cookies, or to stop it accepting cookies from a particular website. However, these options may cause malfunctions to some service provide by various websites, if not used properly
All modern browsers allow you to change your cookie settings. You can usually find these settings in the Options or Preferences menu of your browser.
5. Our Details