Privacy Notice
At Titus, we want our guests to know what data they share with us and what we do with it. This document (called Privacy Notice) explains in simple words and clearly what data we collect about you in the context of your accommodation in one of the properties we manage and how we use it.
Data Controller
The company “
TITOS PANAGIOTIS KAI VRADI ASIMINA OE” [hereinafter referred to as “Titus” or “we”] located in Agios Markos, Corfu, Greece, P.C. 49083, is according to applicable legislation responsible for the processing of personal data of the visitors to the accommodation it manages. This processing is carried out in the context of the provision of services of acceptance and planning of reservations, communication with guests, reception at arrival and departure, coordination of additional services (e.g. car rental) and generally management of guest stay in tourist accommodations [hereinafter referred to as “Titus Services”).
Personal Data We Collect
In the context of providing the Titus Services, we collect and further process the following personal data that we receive either through the booking platform you use, or through the use of the special check-in form we send you, or through the use of our applications and websites, or during your communication with us or the property owner:
• Identification data, such as name and age of each visitor, passport/government ID number, VAT number and Tax Office, driving license, father’s name
• Contact details, such as email address, full postal address, phone number
• Details related to the platform of origin of the reservation, the number of nights, the cost of the reservation and the commissions on it
• Number of guests, time of arrival/departure, comments, preferences and special requests regarding your reservation
• Content of communications relating to booking acceptance, finalization of check-in/check-out details and support during the stay, between the Titus team and guests
• Information necessary to coordinate additional services, such as flight number at arrival
• Information we receive when you tell us what you think about the Titus Services, such as ratings, satisfaction surveys, and your feedback or suggestions to help us become better
• Details of suspicious incidents or events in general related to your reservation and / or stay at the accommodation
• Payment information, such as cardholder name, expiration date and pseudonymised bank card number (in the form 123456ΧΧΧΧΧΧΧ7899), when you make a payment directly through our website or digital platforms
• Information we collect through technological solutions such as cookies, or use of local storage, about your interaction with our website, our check-in form or mobile application, e.g. Titus Services usage statistics, login and browsing information, preferred accommodations, etc. In addition, we process data related to management and resolution of technical errors, to security of browsing and of transactions related to the provision of the Titus Services, as well as device login information, such as your IP address, the type and manufacturer of the device you used, your browser type, type and version of your operating system or application.
Why We Collect It
The abovementioned personal data of yours is processed by us exclusively in accordance with the following purposes and lawful bases:
Contract
Where Titus owns or subleases the accommodation, it processes your data in order to be able to perform the contractual relationship with you, i.e. to provide you with the agreed lease/sublease.
In particular, we process your information to provide the Titus Services and specifically in order to create a guest record, accept and manage reservations, process online payments, organize your arrival and departure, communicate with you as necessary regarding the reservation and stay (via e-mail, Whatsapp, call), the resolution and management of any issues and special requests of yours, for the submission and processing of reviews, for the general provision of service and support before and during your stay, for the calculation, allocation and processing of payments, for the provision of any additional services by us.
Moreover, Titus offers the possibility to rent one of its cars with or without a driver included, as a supporting Service. In this case, it is contractually necessary for the conclusion and performance of the rental contract between us, that we process your personal data, such as identification data, contact details, information on arrival/departure etc.
Legitimate Interest
In cases where Titus is a mere property manager (i.e. not owner or sub-lessor) of the accommodation, it processes your data in view of its legitimate interests in managing the reservation of the accommodation, based on the relevant agreement it has concluded with the property owner. As above, in such cases we have a legitimate interest in processing your information to provide the Titus Services; such as creating a guest record, accepting and managing reservations, processing electronic payments, organizing arrival/departure, necessary communication regarding reservation and accommodation (via e-mail, Whatsapp, call), resolving and managing any issues and special requests, submitting and processing reviews, providing service and support before and during your stay, calculating, allocating and processing of payments, managing any provision of additional services by us.
In particular, if you choose additional services as provided by our third-party partners, such as airport transfer, car rental, activities, experiences, etc., it is in our legitimate interest to disclose your strictly necessary information to the third-party provider in question, in order for them to contact you and prepare for the service you have requested. Please note that, especially in case of car rental with a driver included, when offered by a third-party partner and in view of applicable Greek regulatory framework, the said partner bears a legal obligation to receive by you in advance and submit to a relevant governmental portal, the ID or passport number, as well as the full name, father’s name and ride data for the main passenger. As intermediaries, it is in our legitimate interests to request this data from you, if you choose such a service, in order to further disclose it to them.
In addition, in the context of meeting the tax and other legal obligations of accommodation owners (e.g. in the context of the short-term lease register or the EOT accommodation door book), as mere managers or sub-lessors, we have a legitimate interest in disclosing to them your necessary information in order for them to become aware of the accommodation and submit it to the competent services (identification data, contact details, details related to the platform of origin of the reservation, the number of nights of stay, the cost of the reservation and the commissions on it). In this regard, we also have a legitimate interest in sharing with the owners your information that is necessary in the context of them processing any special request or query of yours.
It is in Titus’ legitimate interest to review and address any suspicious incidents or malicious use of the Titus Services that may harm Titus’ financial interests and/or reputation. At the same time, it is in Titus’ legitimate interest to ensure the smooth operation and security of its systems and digital platforms.
It is also in our legitimate interest to manage your incoming communication, as submitted, regardless of a reservation, e.g. by filling out the special contact form on our website.
Also, Titus, based on Law 3471/2006 as applicable, has a legitimate interest in using the contact details (e-mail address, telephone number) and preferences of the guests of the property (either owned, subleased or managed), to send them general and personalized direct marketing communication, such as satisfaction surveys, Titus news, special discounts and offers, via the following communication channels: e-mail, SMS, call, Viber, Whatsapp, push notifications, social media (targeted communication on Facebook, Instagram, Google). You may unsubscribe at any time by clicking on the relevant hyperlink (“unsubscribe”) or by contacting us.
We also have a legitimate interest in processing your data for any support and exercise of our legal claims, as well as corporate transformation, such as in case of acquisition, merger, absorption, etc. of Titus.
Legal Obligation
Titus, when acting as an accommodation owner, is obliged by law to process your personal data, such as passport/government ID number, VAT number, etc., for the registration of your details in the special short-term rental register, but also for other tax and legislative purposes. We are also obliged by law to manage and respond to your requests regarding the protection of your personal data.
Furthermore, in case you rent one of our cars with a driver included and in view of applicable Greek regulatory framework, we have a legal obligation to receive by you in advance and submit to a relevant governmental portal, the ID or passport number, as well as the full name, father’s name and ride data for the main passenger.
Consent
If you provide your consent, by subscribing to our newsletter, we will send you direct marketing communication with our Titus news.
If you consent to the use of technologies such as cookies and local storage on your device, information about you is automatically collected in accordance with Titus’ Cookies Policy. You can change your cookie preferences and withdraw your consent at any time at the very bottom of the Titus Cookies Policy.
Who We Share It With
Your personal data is collected and further processed by the authorized Titus team members, with full respect for your privacy. In the context of providing the Titus Services, the following categories of our partners may be recipients of your personal data:
• Providers of analytics and performance measurement services for our website and digital platforms, providers of data storage services, such as Microsoft and Google.
• Communications and marketing partners, such as Intuit, Meta Platforms and Google, to manage our communications with you.
• Providers of digital solutions for updating guest reservation details, such as Jotform.
• Providers of booking management software, such as Guesty, providers of data analysis, customer base management and other administrative functions.
Your data may be transferred outside the European Economic Area and especially to the USA by these companies, however the data is stored mainly within the EU and there are strict contractual clauses in place for this transfer.
• Payment service providers and banking institutions.
• Property owners, in the context of satisfying their rights and obligations as provided under the applicable legislation, but also in the context of managing any special request or question of yours.
• Collaborating third-party providers of additional services, if you choose such services.
• External consultants, accountants and lawyers.
• The police authorities and any other administrative, judicial or public authority or generally any legal or natural person to whom Titus may have an obligation or right by law or court decision to disclose such data.
How Long We Keep It
Titus retains your personal data for five (5) years after the completion of your booking, in particular for tax and proof of transactions purposes.
After this period ends and in case there is no outstanding financial debt, judicial or other dispute or specific legitimate interest stemming from the use of the Titus Services, the data shall be deleted or anonymized.
Our Commitment
We take appropriate technical and organizational measures, in accordance with the latest technological standards and applicable legislation, to ensure that the processing of personal data, either by us or by third parties on our behalf, is lawful, appropriate and suitably secured, in order to prevent all unauthorized or accidental access, processing, deletion, alteration or any other use thereof.
Your Rights
According to the legislation on the protection of personal data, you have and can exercise the following rights, after verification of your identity:
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the right of access, i.e. the right to be informed whether your personal data is being processed by Titus and to receive further information about the processing carried out,
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the right to request the correction of any inaccurate personal data or their completion (e.g. correction of VAT number),
as well as, in case the respective requirements set by the legislation are met:
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the right to erasure,
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the right to portability, i.e. the right to receive and transmit to another controller, the personal data which you have provided to Titus, in an appropriate format,
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the right to restriction of processing,
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the right to object, in particular with regard to processing based on our legitimate interests, such as sending marketing communications,
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the right to revoke at any time the consent you may have given us, without this withdrawal affecting the lawfulness of the processing of personal data carried out before such withdrawal.
In case of exercising the rights of rectification, deletion and restriction of your data, these requests will also be transmitted to the third-party recipients to whom this data may have been disclosed by us, in the context of providing the Titus Services.
The exercise of the abovementioned rights of yours is done by submitting a relevant written request to Titus, to which we shall respond within one (1) month following receipt. This deadline may be extended by two (2) additional months due to the complexity of the request, and/or the large volume of requests.
Contact
For any questions, clarifications or requests regarding the processing of your personal data, please contact us at:
info@tituscfu.gr , mentioning “Personal Data” as subject.
Complaint
If you deem that we have not adequately satisfied your request and the protection of your personal data is affected in any way, you may lodge a complaint with the Hellenic Data Protection Authority (1-3 Kifissias Avenue, Athens, Greece, PC 115 23 | tel: +30 210 6475600). Detailed instructions for lodging such a complaint are provided on the
Authority’s website.