Privacy Policy

Welcome to the Kefalonia Vacation Services Privacy Notice.

Kefalonia Vacation Services respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you. We keep our website policies under regular review and will update the webpages as required. Please also refer to the Glossary that we have set out at the end of the Policy, if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.

Important Information And Who We Are

We do not collect and process data except when voluntarily provided by you. Each visitor can navigate in our website without giving any personal information.
You will need personal data (first name, last name, email, phone number, address, zip code, city, country) when you proceed with your booking or when you fill the website contact form.

Purpose of this privacy notice

This privacy notice aims to give you information on Kefalonia Vacation Services collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you purchase travel services, when you sign up to our newsletter, when you take part in a competition etc. This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of travel services and you have children in your party. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Kefalonia Vacation Services is the controller and responsible for your personal data (collectively referred to as ” Kefalonia Vacation Services “, “we”, “us” or “our” in this privacy notice). We have appointed a data controller who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data controller using the details set out below.

Contact details

Our full details are:
Full name of legal entity: Kefalonia Vacation Services Name or title of Data Compliance Officer: Kefalonia Vacation Services GDPR Enquiries: info@kefaloniavacationservices.com
Postal & Registered Address: PO BOX 111, Argostoli, Kefalonia. Greece. 28100
Telephone number: +30 6942899075

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

A. Identity Data
This includes data relating specifically to your identity, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

B. Contact Data
This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.

C. Financial Data
This includes data relating to your means and methods of payment, such as your bank account and payment card details.

D. Transaction Data
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.

E. Technical Data
This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

F. Profile Data
This includes the data that we receive if or when you create a profile on our website and make use of that policy, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

G. Usage Data
This includes information about how you use our website, products and services.

H. Marketing and Communications Data
This includes your preferences in relation to whether or not you want to receive marketing from us and also your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice. Special Categories of Personal Data We collect the following special categories of personal data about you.

How Your Personal Data Is Collected

We use different methods to collect data from and about you including through:

Direct interactions You may give us your Identity information, Contact information and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

make a booking of travel services;
create an account on our website;
subscribe to our newsletter or other publications;
request marketing to be sent to you;
enter a competition, promotion or survey;
give us some feedback;
raise any formal complaint
notify us of any personal injury

Automated technologies or interactions As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you, if you visit other websites employing our cookies. Please see our cookie policy /cookie-policy for further details.
Third parties We may receive personal data about you from various third parties as set out below:

Technical Data from the following parties:
(i) analytics providers, such as DoubleClick based outside the EU; Adthena based inside the EU.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract, we are about to enter into, or have entered into, with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on, to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of Data	Lowful basis for processing including basis of legitimate interest
To register you as a new customer	(a)Identity (b)Contact	Performance of contact with you
To Process & deliver your booking including; (a) Manage Payments (b) Collect & recover money owed to us	(a)Identity (b)Contact (c)Profile (d)Marketing & Communications	(a) Performance of a contract with you (b) Necessary for your legitimate interests (to recover debts due to us)
To manage our relationship with you which will include (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a)Identity (b)Contact (c)Profile (d)Marketing & Communications	(a)Performance of a contract with you (b)Necessary to comply with a legal obligation (c)Necessary for our legitimate interests (to keep our records upto date and to study how customers use our products/services)
To enable you to partake in a prize draw, competition, complete a survey, or assist us with feedback for a new product/service launch	(a)Identity (b)Contact (c)Profile (d)Marketing & Communications	(a)Performance of a contract with you (b)Necessary for our legitimate interest (to keep our records upto date and to study how customers use our products/services, to develop them & grow our business)
To administer and protect our business and this website (including, troubleshooting, data analysis, testing, system maintenance, support, reporting & hosting of data)	a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interest (for running our business, provision of administration & IT services, network security, to prevent fraud & in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content & advertisements to you & measure or understand the effectiveness of the advertising that we server to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing & Communications (f) Technical	Necessary for our legitimate interest (to study how customers use our products/service, to develop them to grow our business & to inform our marketing strategy)
To use data analytics to improve our website, products/service, marketing customer relationships & experiences	(a) Technical (b) Usage	Necessary for our legitimate interest to define customer types for our products & services to keep our website updated & relevant to develop our business & to inform our marketing strategy
To make suggestions & recommendations to you about goods & services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage(br) (e) Profile	Necessary for our legitimate interests (to develop our products/services & grow our business)
To investigate & respond to any formal complaint/claim notified to us or our service companies during your stay and on your returm from stay	(a) Identity (b) Contact (c) Financial (d) Transaction	Necessary for our legitimate interests in investigation or any alleged deficiency of your contract with relevant service agents or owners, or with regulatory bodies or regulatory legal bodies
To investigate & respond to any formal claim for personal injury notified to us or our services companies during your stay and on your return from stay, notifeby you,or us to a regulatedlegal body/company	(a) Identity (b) Contact (c) Financial (d) Transaction	Necessary for our legitimate interest in investigation & notification with or to our appointed insurance brokers, Underwriters, or Loss Adjustes

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Marketing Loyalty programme
Kefalonia Vacation Services may on occasion send you a gift or item, as an existing customer loyalty gesture. There is no inducement or requirement to make a further booking. Should you not wish to participate in this programme, please email: info@kefaloniavacationservices.com

ANONYMOUS DATA / “COOKIE” TECHNOLOGY
To make this site work properly, we sometimes place small data files called cookies on your device. Cookies are a standard method of registering user preferences when people use websites, to ensure a better and more personalized experience. These preferences are stored in a file on your computer’s hard disk drive. For example, a cookie would contain your preferred country of residence so we do not have to ask you this question each time you visit. Our website uses both persistent and session cookies. Persistent cookies are cookies that stay on your computer permanently until you “manually” delete them. Session cookies delete themselves automatically when you leave a website and go to another one or shut down your browser. We also use analytical cookies. These allow us to recognize and count the number of visitors and to see how visitors move around the site when they are using it. This helps us improve the way our website works, for example by making sure users find what they need easily. The visitor / user of this website may adjust his schedule for navigation and web browsing (web browser) so that either warns him to use “cookies” on certain services or to refuse to accept the use of “cookies “in any case. If the visitor / user of the services and pages do not wish to use “cookies” to identify himself may have limited access to some of the services, uses or functions provided by this website. You can control and/or delete cookies as you wish – for details, see aboutcookies.org

Change of purpose
We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How We Disclose Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

A.Internal Third Parties as set out in the Glossary below, section 10
B. External Third Parties as set out in the Glossary below, section 10
C. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

When We Transfer Your Data Overseas

We share your booking data within the Company and if shared outside the EEA, is only within the context of an intra-group transfer (such as our IT development team) Booking data held in databases outside the EEA for the purpose of ensuring that all required information has been provided to confirm your booking, will be automatically deleted after a 1 week period, post processing and transfer to our central booking system. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the in order to transfer your personal data to countries outside the EEA (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA. For all other transfers of data that are unrelated to the provision of travel services to you, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

How We Secure Your Data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How Long We Retain Your Data For

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, insurance, dispute resolution or other related requirements in order to conduct our business, such as the detection and preventions of fraud or other illegal activities. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In addition to the above, by law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. If you have a question about a specific retention period for certain types of personal data we process about you, please contact us. In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data to request certain aspects of your data

Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us at: info@kefaloniavacationservices.com

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 we may 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 personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us info@kefaloniavacationservices.com
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Thirt Parties Other companies within Kefalonia Vacation Services [acting as joint controllers or processors] such as Team Marvel, based in the UK who provide IT and system administration services.
External Third Parties
1. Suppliers of travel services [acting as processors] based in Kefalonia, who provide the travel services that make up any booking of travel services that you make with us. These may include Airlines, Car Hire Providers, Transfer Services, Credit & Debit card companies, Insurance Policy suppliers, Destination Authorities (Visitor Registrations), Property Owners and other providers as necessary to complete your booking contract with us.
2. Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in Greece who provide [consultancy, banking, legal, insurance and accounting services].
3. HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based in Greece, who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS
You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, 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.
Object to processing of your personal data where 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which over-ride your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where 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; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
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. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw 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 you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.