Privacy Notice

Sunnyseeker Hotels (“we”, “us” or “our” in this privacy notice) respects your privacy. The protection of your personal data is of outmost importance to us. This privacy notice will inform you as to how we use and look after your personal data and inform you about your privacy rights and how the law protects them.

We commit to operating in compliance with the Cypriot and European Legislation in the areas of Personal Data Processing, Privacy and Data Security. The legislation includes inter alia, the General Data Protection Regulation (GDPR) and the ePrivacy Directive for the protection of your privacy in electronic communications. We also consider the Guidelines issued by the Office of the Commissioner for Personal Data Protection in Cyprus.

It is important that you read this privacy notice together with any other privacy notice we may provide on certain occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.

1. Important Information

Data Controller

Sunnyseeker Hotels Ltd is a hotel management company with its registered office at 41 Themistokli Dervi, Hawaii Tower, offices 301-303, 1066 Nicosia, Cyprus.

Contact Details:

Sunnyseeker Hotels Ltd

Address: 23 Artemidos Avenue, 6025 Larnaca, Cyprus
Tel.: +357 24663333
Fax: +357 24651787
E-mail: info@sunnyseekerhotels.com

Data Protection Officer (DPO)

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO using the details set out below.

DPO Contact Details:

E-mail: dpo@sunnyseekerhotels.com

Address: 23 Artemidos Avenue, 6025 Larnaca, Cyprus

Tel.: +357 24663333

2. What personal data do we collect about you?

We may collect personal information about you such as your name, address, telephone number, e-mail address when you contact us and provide us with any such information. We may use this information solely for the purposes of responding to your inquiry.

Cookies
We also collect certain non-personally identifiable information about your preferences to personalize and improve the quality of our communications with you. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about our use of cookies, please read our Cookie Notice available on our website.

3. Where and for how long do we store your personal data?

Your personal data is stored on our servers. Information provided to us by you when contacting us with an inquiry, will be retained for 1 year since our last communication with you, unless a longer retention period is required or permitted by law.

4. With whom do we share this personal data?

We may share your information with other organizations providing data processing activities to our company, such as IT support and our cloud services. Additionally, if required, we may share your information to governmental/regulatory/law enforcement agencies or other third parties provided that such obligation is based on national or EU law.

5. How do we protect your personal data?

As part of our effort to prevent any unauthorized access or disclosure of your personal data, we have implemented physical, technical and administrative safeguards. We also update and test our security technology on an ongoing basis and we restrict access to your personal data to the employees who will be providing our services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

6. What are your rights?

You have the following rights regarding your personal data:

Right of Access: You have the right to access your personal data. You can ask for a copy of the personal data we hold about you. There are situations where we may deny your request, for example, if making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information.

Right to Rectification: It is our objective to keep your personal data accurate, current and complete. You have the right to request the correction of any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.

Right to Erasure: You have the right to ask us to delete or remove your personal data in case that

• there is no good reason for us continuing to process it
• you have successfully exercised your right to object to processing (see below)
• we may have processed your information unlawfully
• we are required to erase your personal data to comply with local law

You should take into account, though, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you if applicable, at the time of your request.

Right to Object: You have the right to object to the processing of your personal data when we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds which override your rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes.

Right to Restrict Processing: This enables you to ask us to suspend the processing of your personal data in the following cases:

• if you want us to establish the data’s accuracy
• when our use of the data is unlawful but you do not want us to erase it
• when you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
• if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

Right to Data Portability: You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Right to Withdraw Your Consent: You have the right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before the withdrawal of consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the abovementioned rights, please contact us at dpo@sunnyseekerhotels.com.

Right to file a complaint

You have the right to lodge a complaint with the Office of Cyprus Commissioner for Personal Data Protection.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What do we need from you?

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal data is not disclosed to any other person. We may also contact you to ask for further information in relation to your request.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complicated or you have made more requests. In this case, we will notify you.

7. Can minors use this website?
   This website is for individuals over the age of 18. A minor who wishes to communicate with us may do so through his or her parents or legal guardians. If you are a parent or guardian of an individual under the age of 18 and you become aware that a minor has provided personal data to us without your consent, please contact info@sunnyseekerhotels.com to exercise your rights as described in this privacy notice.

8. Will this privacy notice change?
   We reserve our right to amend this privacy notice from time to time and any changes will become effective when we post the revised privacy notice on our website, without further notice. By using our website following these changes it means that you have accepted the revised Privacy Policy.

Your duty to inform us about changes in your personal details

It is important that the personal data we hold about you is accurate and current. Please keep us updated about your personal data changes during your relationship with us.

Links to Third–Party Websites

Our website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Updated 26/08/2019