1. IN SUMMARY

So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:

• Always keep your data safe and private.
• Never sell your data.
• Allow you to manage and review your marketing choices at any time.

2. CONTROLLER

We are the data controller responsible for your personal data and we are registered with the Information Commissioner’s Office with reference number A8300262.

3. WHAT DOES THIS POLICY COVER?

This privacy policy sets out how Peligoni Bookings Services Limited uses and protects any information that you provide us with when you use this website or speak to any of our sales consultants.

Peligoni Booking Services Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using our services or our website, then you can be assured that it will only be used in accordance with this privacy statement.

Peligoni Booking Services Ltd may change this policy from time to time by updating this page and you should check this page to ensure that you are happy with any changes. This policy is effective from 21 May 2018.

4. WHO ARE WE?

Peligoni Booking Services Ltd is a privately-owned UK company specialising in arranging holidays at our partner company in Greece.

Any personal information provided to or gathered by us is controlled by Peligoni Booking Services Ltd (“PBS”, “We”, “Us), a company registered in England at: Unit 5, The Bull Pen, Churchill Heath Farm, Kingham, Chipping Norton, Oxfordshire, OX7 6UJ. Registered number: 05355583.

5. DATA SECURITY

Data security is of the utmost importance to us and we are committed to ensuring information we collect from you is secure. In order to prevent unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect online and offline.

These include:

• Application & database encryption
• Individual File encryption
• Secure premises
• Secure IT equipment

6. WHAT INFORMATION DO WE COLLECT?

“Submitted Information” is information that you provide to us when completing the enquiry or contact forms on our website, completing feedback forms, subscribing to mailing lists or by corresponding with us (for example by phone, e-mail or via the chat functions on the website).

As such we may collect some or all of the following data from you:

• Name, address, contact information including phone and email.
• Subscription and demographic information such as villa preferences, age and family information.
• Information relating to your holiday such as reviews, blogs, image or video uploads, questionnaire data, holiday enquiries and brochure or marketing requests.
• Information relating to quoting and booking a travel service, including information regarding family and travel companion(s) such as names, emergency contacts and special service needs, such as any disability or medical or dietary restrictions (which may disclose your religious beliefs), passport information, dates of birth, insurance information, visa information, nationality and country of residence.
• We do not store financially sensitive information such as credit card numbers, bank details or security numbers.

“Device Information” is information automatically received by us when you use the website, access our marketing information or contact us by email or phone including: Browsing, purchase and search history. We may also use software tools such as Google Analytics to measure and collect session information, length of visits to certain pages, repeat visits and page interaction information (such as clicks and mouse movements).

• The domain and IP address that your computer uses to connect to the internet; your computer, browser, operating system, internet connection, referral information, search terms and other standard information collected by default by tools such as Google Analytics.
• Telephone information including phone numbers, call duration and call recordings that we use for training and quality control.
• Third party information about you from other sources which we may add to our account information.

Cookies

We use cookies to improve your experience on our website. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy.

7. WHAT DO WE DO WITH YOUR DATA?

We must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our “Legitimate Interest” to use it. We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

Submitted Information

• To carry out our obligations arising from any contractual agreement which you enter into with ourselves, specifically a holiday booking.
• To improve our products and services.
• To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
• To verify your identify to protect against fraud and to confirm your eligibility to use our products and services.
• To notify you about changes to our service.
• To contact you for market research purposes.
• We may use the information to personalise and customise the content of our website according to your interests.
• We may contact you by email, phone or mail unless requested otherwise.

Device Information

• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
• To improve our website to ensure that content is presented in the most effective manner for you and for your computer.
• We may use the information for marketing purposes via third party vendors such as Google who may show our adverts on the internet based on your prior visits to our website. Users may opt out of Google’s use of cookies by visiting the Google advertising settings.

By using the Peligoni Booking Services Ltd website, you imply consent to the use of cookies. However, if you do not consent to the use of cookies, please ensure that your browser or computer/device is set to reject or prompt before accepting third party cookies. This may prevent you from taking full advantage of the website.

8. WHAT DO WE MEAN WHEN WE SAY?

Legitimate Interest

This means the interest of ours as a business in conducting and managing Peligoni Booking Services Ltd to enable us to provide to you with our services, and offer the 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).

Fulfilling A Contract

This 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.

Our Legal Obligation

This means processing your data where it is necessary for the performance of a contract to which you are a party.

What We Use Your Information For	Type of Information	Our Reasons	Our legitimate Interests
To provide our services to you:
To carry out our obligations arising from any transactions you enter into with us and to provide you with the information, products and services that you request from us	Submitted Information	Fulfilling Contracts Our Legitimate Interests Our Legal Obligation	Being efficient about how we fulfil our legal and contractual duties. Our commercial interest in providing you with a good service.
To help market and provide products and services that interest you:
To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; To make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them;	Submitted Information Device Information Third Party Information	Our Legitimate Interests	Developing products and services for existing customers. Defining types of customers for new products or services. Being efficient about how we fulfil our legal and contractual duties. Seeking your consent when we need it to contact you.

 

9. DISCLOSURE OF YOUR INFORMATION

In order to respond to your holiday enquiry or booking we may need to disclose some of your information to our data processing partners including:

• Delivery companies such as the couriers, Royal Mail, City Link and their affiliates.
• Travel companies such as hotels, airlines, ground handlers, Taxi companies or car hire companies.
• Property owners and property managers for the property in which you are staying.
• Our partner company, Peligoni Club EPE (ΠΕΛΙΓΟΝΙ ΤΟΥΡΙΣΤΙΚΗ Μ. Ε.Π.Ε. , Registered company number EL999519639) in Greece, to accommodate your needs whilst you are at The Club.
• If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users (for example, women in London). In some instances we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience.
• We also use analytics and search engine providers that assist us in the improvement and optimisation of our site.
• We only pass on information that is required in order to fulfil the booking or enquiry, such as name and address to delivery companies and name and passport information to third party rental accommodation owners and managers.
• Please be aware that due to the nature of our business and of the internet, information and data you provide may be transferred outside the country where it is submitted to us. If you are submitting information or data from a country within the European Economic Area (EEA) it is possible that it may be transferred outside the EEA, where data privacy regulations may differ from within the EEA.
• Advanced Passenger Information (API) is required by many countries prior to arrival (or departure). API information includes personal identity information such as name, passport details, visa information, nationality, transit and destination data. Airlines and transport companies are required to transmit this information by law and data entry is requested at the time of ticket issue. To comply with these regulations Peligoni Booking Services Ltd passes the relevant information to the transport companies who transmit the information to the relevant authorities.
• Suppliers and subcontractors supporting or delivering our services including hosting, IT support, advertising platforms, booking systems, cloud-based software used by us, accountants and law firms.

10. CONTROLLING YOUR PERSONAL INFORMATION

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are legally obligated to do so.

Your Legal Rights

You may choose to restrict the collection or use of your personal information in the following ways:

• You may unsubscribe using the links on our marketing emails or you may contact us to unsubscribe for any or all marketing activity by email on [email protected].
• You may update and request details of any personal information which we hold about you by contacting our data manager at any time. You may also request for this data to be erased, or object or restrict the processing of this data.
• If you do withdraw consent at any time, we may not be able to provide our services to you. We will advise you if this is the case at the time you withdraw your consent.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the address below. We will promptly correct any information found to be incorrect.

Our Data Manager can be contacted by writing to:

Data Manager,
Peligoni Booking Services Limited

Unit 5
The Bull Pen
Churchill Heath Farm
Kingham
Chipping Norton
Oxfordshire
OX7 6UJ

or by emailing [email protected].

11. COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. LINKS TO OTHER WEBSITES

We use social buttons to enable users to share content and connect to social networks easily. These buttons include: Twitter, Google +1, and Facebook (like). These buttons use scripts outside of our website and these sites may collect information about you as well as registering an action on a social network. If you are logged into their services, these sites may even register where you are visiting even if you don’t click a button. You should check the respective policies of these social network sites.

13. RETAINING YOUR INFORMATION

Due to the yearly booking cycle of guests and the high number of repeat guests, we will keep your data indefinitely and securely. This is to ensure a better booking experience when you contact us. Should you wish for us to remove the data we have, please let us know by emailing [email protected].

14. CONSENT

By using this website, you accept this privacy policy. By providing your personal data, you consent to the use, processing, storing, transferring and disclosing of your information and data referred to in this policy statement for the purposes set out in this privacy policy statement.