Welcome to the Hotelscy by Orthodoxou Travel & Tours LTD website (the “Website”). This Privacy Statement outlines Hotelscy by Orthodoxou Travel & Tours LTD ("we", "our" or the "Company") practices with respect to information collected from users and customers who access the Website or communicate with us in any other way, including without limitation, our API, support calls, emails and letters and so on (collectively: "the Service"). This Privacy Statement is based on our goal to provide our clients with quality information in our field of practice while maintaining personal privacy.
1.1. In this Privacy Statement we will explain to you about the information we collect from you when you visit our Website or communicate with us directly in any other way. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data. Please note that we may also act as a data processor in certain instances, if our business partners provide us with information for their own processing needs. It is important to note that such information is provided to us only for the purposes of processing it in accordance with the instructions of our business partners. We cannot process this information for our own needs and cannot decide on any new purposes for its processing without our business partner's instructions. Therefore, such information is not subject to the provisions of this Privacy Statement.
1.2. As you use our Website or communicate with us in any other way or provide us with information in order to access and/or use our services, we may collect and process information related to you as an individual and which allows you to be identified, either directly or together with additional information. This information can be collected by us both when you choose to provide it (e.g., when you request any services provided by us over the Website or when you submit an enquiry via our Website) or simply by analyzing your behavior on the Website.
1.3. For certain services, such as for when you book any of the travel products offered on our Website, you will be asked to provide certain personal information. It is not mandatory for you to provide us with any of your information, including personal information; however, if you will choose not to, we may not be able to provide you certain services requested by you and your usage of our Website may be limited in scope.
Any personal information you provide us with or which we collect is provided or shared on a voluntary basis.
2.1. We are Hotelscy by Orthodoxou Travel & Tours LTD address is United Nations Str. 44, 6042 , Larnaka , Cyprus . You can contact us either by post at the above address, by email at incoming@orthodoxou.com.cy or by telephone on +357 22841108.
2.2. For EU-related questions, you may contact us by the above email or by post at United Nations Str. 44, 6042, Larnaka , Cyprus; Phone: +35724841108; Fax: +357 24841001.
We generally collect two types of information:
The first type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via the user's use of the Services (“Non-personal Information”). We are not aware of the identity of the user from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.), in order to enhance the functionality of our Services. We may also collect information on your activity on the Service (e.g. pages viewed, online browsing, clicks, actions, etc.). The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information may include:
3.1. When you submit an enquiry via our Service (including, without limitation, booking a travel product or purchase of other products), we ask you for your name, contact telephone number and email address. In order to complete purchases, we may also ask for identification number and VAT registration number; address; bank details and/or credit card information; and any additional information requires for billing (e.g. authorization codes, passport number or national ID number).
3.2. If you sign up to receive our newsletter, we will ask for your name and your email address.
3.3. We also record your IP (Internet Protocol) address, which is the internet address of your computer.
3.4. If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
We process Personal Information for the following purposes:
We keep Personal Data for as long as necessary to provide our services, respond to requests, comply with our legal obligations and resolve disputes. Retention periods shall be determined considering the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
Note that we do not retain your credit card information.
As part of our Services, the Personal Data of clients and end users of our customers may be shared with us. This data may include, for example, specific information regarding travel arrangements for individual clients.
Such data is provided to us solely by the customer and is processed by us as a “data processor”, acting under the sole direction of its customers. Therefore, in processing such information we will act in accordance with the provisions of a data processing agreement we will sign with our customers and in accordance with their documented instructions and the provisions of this Privacy Statement will not apply directly to such processing.
In compliance with EU Directive 2009/136/CE, we would like to inform you that our website accepts the use of “cookies”, to determine how users reach our website and to track general usage patterns once a user is on our website. Cookies are messages that web servers pass to your web browser when you visit Internet sites. Your browser stores each message in a small file, which will give us information about your last visit to our web page. This information is collected and analyzed in the aggregate in order to improve the function, content, overall appearance, and capability of our website.
Most of Internet browsers accept the use of cookies automatically, but you can always choose not to accept a cookie by changing your computer settings to refuse cookies or to prompt you to accept each cookie, but doing so will limit the range of features available to you on the Web site.
Specifically, we use the following cookies:
Analytics cookies - Allow us to see how visitors move around the website and to record which content viewers view and are interested in. This helps us to improve the service which we offer to you by helping us make sure our users are finding the information they are looking for.
Social media cookies - Are necessary for Social Networks (Facebook, Google and Twitter). Its function is to control the interaction with Social Widgets on the page. Such Cookies are used in the domains: "facebook.com", "google.com" and "twitter.com".
Behavioral and advertising cookies - This collect information about your preferences and choices in this website. They target advertising networks, who then use them to show customized ads on other websites.
Technical cookies - These are strictly necessary for the use of this Website.
Functionality cookies - These are strictly necessary to provide the services requested by users on this Website. Such cookies are used in the site: "lcc-orthodoxou.com".
New Relic - We use New Relic analytics to monitor the performance of our website, its underlying systems and architecture. With this information we can make changes to make the site perform more efficiently.
Our website may contain links to websites operated and maintained by third parties over whom we have no control. The information practices of those websites are not covered by this privacy policy. Any information you provide to third-party Web sites or that we provide in relation to travel reservations you made will be governed under the terms of each such Web site's privacy policy. Please note that when you click on one of these links, you are entering another Web site, and we have no responsibility or liability whatsoever for the content, actions, or policies of such third-party Web sites. We encourage you to read the privacy policies of all third-party Web sites that link to the Web site, because such privacy policies may be materially different from this privacy policy.
We collect and process your Personal Data based on your consent, where it is necessary for the performance of contract between us and where it is necessary for our legitimate interest.
7.1. In the framework of our activity and for the purposes specified above, your information, including your Personal Information may be shared with the following: suppliers of Travel Products offered on our Site, providers of infrastructure services, payment service providers, other third party providers who assist us in providing our Service such as storing or processing information on our behalf (e.g. on cloud computing services) or assist us with our business operations, to authenticate your access and to provide and improve our Service.
7.2. In addition, your information, including Personal Information, may be disclosed to third parties in the event we shall enter into a corporate transaction.
7.3. We may also disclose Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of yourself, our users, us or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
9.1. You can ask us if and what information we hold about you, and you can ask us to correct it if it is inaccurate, incomplete or out of date. If we have asked for your consent to process your personal data, you may withdraw that consent at any time, and, if we process your personal data solely on the basis of your consent, we will stop processing, subject to our overriding rights, if applicable.
9.2. If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
9.3. If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
9.4. In certain circumstances, you have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.
Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint.
Please find below the contact details of our Data Protection Officer:
Davinia Christodoulou
dchristodoulou@orthodoxou.com.cy
Telephone: +357 24 841 152
However, you can also contact the Cypriot Protection of Privacy Authority at: commissionerdataprotection.gov.cy
If you are a resident of the EU, you may also lodge a complaint with the relevant supervisory authority.
We take great care in implementing and maintaining the security of the Website and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Statement. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.
We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.
We will update the version number and date of this document each time it is changed.
Last Updated January 2020.