THE NEWEL PRIVACY POLICY

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PRIVACY POLICY CELOSIA GROUP – NEWEL

December 24, 2024

CELOSIA GROUP (referred to as ‘we’, ‘us’, ‘our’, ‘NEWEL’) is committed to protecting your privacy and handling your data in an open and transparent manner. NEWEL recognizes that privacy is important to you and wants you to be familiar with how we collect, use, and disclose your personal data.

For the purposes of this Policy, personal data shall mean any information relating to you which identifies or may identify you and which includes, for example, your name, address, identification number etc.

This Policy describes the privacy practices of the CELOSIA GROUP as a data controller and is compliant with the General Data Protection Regulation EU 2016/679 and national law 4624/19 as well as the guidelines of the Hellenic Data Protection Authority. It explains what information we collect about you when you visit our site and/or when you make a reservation with us and how we handle your information to ensure that your rights are always respected.

Who We Are

CELOSIA is a hospitality management organization based in Greece.

Headquarters:
7 Stadiou str, 10562 Athens 6th floor
Tel: +30 210 3615179
Website: https://www.the-newel.com/

Hotels and other accommodation units concerned:

Newel ACROPOLIS
Newel METAXOURGEIO
Newel PSYCHICO

Data Protection Officer: dpo@the-newel.com

WHAT PERSONAL DATA WE COLLECT

When you directly register to make a reservation or use our services and upon your check-in at our hotel we may ask you to provide certain personal information including your full name, identity card, passport, physical and email address, credit card number, telephone number, registration, payment details etc.

When you visit our websites, we may also collect information on an ongoing basis through Google Analytics about what pages you access or visit, and information about your use of our site, for example the pages viewed, the website from which you came to visit our site, changes you make to information you provided to us and your transactions including by use of cookies.

CHILDREN’S DATA

Our website is not intended for children under the age of 15 and we do not knowingly collect information from children to promote our services. We may process data of minors such as date of birth, age and gender in the context of offering hospitality services to families with the explicit consent of their parents.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We process your personal data in accordance with the EU Regulations for one or more of the following reasons:

1. Necessary for the execution of a contract

To carry out our obligations with respect to any contractual agreements between us with respect to information and services that you may request from us

To process a hotel reservation

To process your check-in

To process your payment

To take your reservation for events

To facilitate your participation in tours

2. Necessary for CELOSIA to comply with a legal obligation

To fulfil our tax, accounting, and reporting obligations

3. To serve our (and third party) legitimate business interests

Legitimate interest is when we have a business or commercial reason to use your information. But even then, such use is consistent with the fundamental rights of individuals, for example:

To provide you with effective customer service and support
To respond to your requests
To improve the security and usability of our website and services
To perform customer satisfaction surveys
To execute business transactions with you
To keep you updated on our new services and offers
To operate CCTV systems to prevent illegal actions, to protect you and our staff and our property
Etc

4. You have given us your consent.

Subject to a valid consent you have freely provided the lawfulness of such processing is based on that consent.

HOW WE SHARE YOUR DATA

In the course of the performance of our contractual and legal obligations your personal data may be provided to various service providers and suppliers. Those service providers and suppliers are bound by Data Processing Agreements, and they are obliged to safeguard confidentiality and data protection according to the data protection regulation.

Such service providers and suppliers may be:

External legal consultants
Information technology companies
Financial and business advisors
Cloud providers
External auditors and accountants
Marketing Companies
Outsourcing services companies
Law enforcement agencies
Third parties you have used to contact us
Card payment companies
Travel Agencies
etc

TRANSFERS OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

Your personal data may be transferred to third countries to fulfil a legal or contractual obligation or because you have given us your consent. Processors in third countries are obligated to comply with the European data protection regulations and to provide appropriate safeguards in relation to the transfer of your data in accordance with GDPR Article 46.

DATA RETENTION

We will process and store your Personal Data for the duration of our relationship with you, and as long as necessary to fulfill our contractual and legal obligations.

We will delete your data:

Within 15 days from collection for the CCTV system data
When it is no longer necessary for the purposes for which that information was collected and processed
Upon your request or objection, provided there are no overriding legal grounds requiring NEWEL Beach Resort to maintain that information
When necessary to comply with our legal obligations and
If our collection of information was based on your consent, upon the withdrawal of your consent

AUTOMATED DECISION AND PROFILING

In executing our business activities, we do not use any automated decision-making. We may from time to time process some aspects of your data automatically, to enter into a business relationship with you.

HOW WE USE YOUR PERSONAL DATA FOR MARKETING ACTIVITIES

We may process your personal data to tell you about products, services and offers that may be of interest to you or your business.

The personal data that we process for this purpose consists of information you provide to us and data we collect when you use our products. We can only use your personal data to promote our products and services to you if you have given us your consent to do so, or if we consider that it is in our legitimate interest to do so

You have the right to object at any time to the processing of your personal data for marketing purposes, which includes profiling.

YOUR DATA PROTECTION RIGHTS

You have the following rights in terms of your personal data:

Receive access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
The right to have your Personal Data corrected or rectified. This enables you to have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to erase your personal data [known as the ‘right to be forgotten’] where there is no legitimate reason for us to continue to process it.
The right to object to the processing of your Personal Data, where we are relying on a legitimate interest and there is something about your situation which makes you want to object to processing on this ground. If you lodge an objection, we will no longer process your personal data unless we can demonstrate the legitimate grounds for the processing which override your interests.
The right to restrict the processing of your Personal Data, this enables you to ask us to restrict the processing of your personal data if any of the following is valid:
1. it is not accurate,
2. it has been used unlawfully but you do not wish for us to delete it,
3. it is not relevant anymore, but you want us to keep it for use in possible legal claims,
4. you have already asked us to stop using your personal data, but you are waiting us to confirm if we have legitimate grounds to use your data
The right to data portability, i.e., request to receive a copy of the personal data concerning you in a format that is structured and commonly used and transmit such data to other organizations.
The right to withdraw your consent, any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn by you

To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us in person or by letter/email. You can also contact our Data Protection Officer at dpo@the-newel.com

RIGHT TO LODGE A COMPLAINT

You have the right to lodge a complaint with the supervisory authority (www.dpa.gr) If you have exercised any of your data protection rights and still feel that your concerns about how we use your personal data have not been adequately addressed by us.

COOKIES

Our website uses small files known as cookies to enhance user experience and for functionality purposes.

To find out more about how we use cookies please review our cookie policy.

COMMUNICATION

If you have any questions about this privacy policy, or how the company processes your personal data, or if you wish to submit a comment or complaint, please contact us by email at dpo@the-newel.com

CHANGES TO THIS PRIVACY POLICY

This Privacy policy was published on December 24, 2024. We reserve the right to modify this Privacy Policy at any time. We will notify you appropriately when we make changes to this privacy Policy, and we will amend the revision date.