Thank you for using Athens Riviera Villas. Your trust is important to us and we’re committed to protecting the privacy and security of your personal information.
1.2 Data Controller
2. INFORMATION WE COLLECT
There are three general categories of information we collect.
2.1 Information You Give to Us.
2.1.1 Information that is necessary for the use of our Platform.
We ask for and collect the following personal information about you when you use the our Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
• Account Information. When you sign up for an Account, we require certain information such as your first name, last name, email address, and date of birth.
• Profile and Listing Information. To use certain features of our Platform (such as booking), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
• Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
• Payment Information. To use certain features of our Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
• Communications. When you communicate with us, we collect information about your communication and any information you choose to provide.
2.1.2 Information you choose to give us.
You may choose to provide us with additional personal information in order to obtain a better user experience when using our Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.
• Additional Profile Information. You may choose to provide additional information as part of your profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
• Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us, or use other features of our Platform.
2.1.3 Information that is necessary for the use of the Payment Services.
The Payments Data Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:
• Payment Information. When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
2.1.4 Information We Automatically Collect from Your Use of our Platform and Payment Services.
When you use our and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of our Platform and Payment Services.
• Usage Information. We collect information about your interactions with the our Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on our Platform.
• Log Data and Device Information. We automatically collect log data and device information when you access and use our Platform, even if you have not created an Account or logged in. That information includes, among other things: details about how you’ve used our Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using our Platform.
• Do Not Track Signals. While you may disable the usage of cookies through your browser settings, our Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
• Payment Transaction Information. Payments collects information related to your payment transactions through our Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Payments and to allow the provision of the Payment Services.
3. HOW WE USE INFORMATION WE COLLECT
We may use, store, and process personal information to (1) provide, understand, improve, and develop our Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with our Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.
3.1 Provide, Improve, and Develop our Platform. We may use the personal information to provide, improve, and develop our Platform such as to:
• enable you to access and use our Platform,
• enable you to communicate with other Members,
• operate, protect, improve, and optimize our Platform and experience, such as by performing analytics and conducting research,
• provide customer service,
• send you service or support messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,
• to operate, protect, improve, and optimize our Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), and facilitate claims with our Host Guarantee, Host Protection Insurance, Experience Protection Insurance or other similar host protection programs, we conduct profiling based on your interactions with our Platform, your search and booking history, your profile information and preferences, and other content you submit to our Platform, and
• enable your use of our enterprise products.
We process this personal information for these purposes given our legitimate interest in improving our Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
3.2 Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:
• detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
• conduct security investigations and risk assessments,
• verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide),
• conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
• comply with our legal obligations,
• Resolve any disputes with any of our Members and enforce our agreements with third parties,
• enforce our Terms of Service and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with our Platform, your profile information and other content you submit to our Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to our Platform if such processes detect activity that we think poses a safety or other risk to our Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.
We process this personal information for these purposes given our legitimate interest in protecting our Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:
• send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about our Platfomr or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
• personalize, measure, and improve our advertising,
• Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or its third-party partners,
• conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with our Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
• enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an Account by us
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
3.4 How the Payments Data Controller uses the Personal Information Collected. We may use the personal information as a part of Payment services such as to:
• Enable you to access and use the Payment Services.
• Detect and prevent fraud, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Conduct checks against databases and other information sources.
• Comply with legal obligations (such as anti-money laundering regulations).
• Enforce the Payment Terms and other payment policies.
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
The Payments Data Controller processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
4. SHARING & DISCLOSURE
4.1 Advertising and Social Media; Sharing With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Account by us or when you participate in promotional activities conducted by our partners or third parties.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or our Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal information are not controlled or supervised by us. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
Please note that you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to email@example.com.
4.3 Profiles and other Public Information.
Our Platform lets you publish information, including personal information, that is visible to the general public. For example:
• Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.
• Listing pages are publicly visible and include information such as the Accommodation or Experience’s approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share.
• After completing a booking, Guests may write Reviews and rate. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on our Platform (such as the Listing page).
• If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on our Platform, that content is publicly visible.
Based on our legitimate interest to promote our Platform we may display parts of our Platform (e.g., your Listing page) on sites operated by our business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
Information you share publicly on our Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
4.4 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Payments Procedures may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against us, (iii) to respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms (v) to protect the rights, property or personal safety of us, our employees, or members of the public. For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping our Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.
4.5 Service Providers.
We use a variety of third-party service providers to help us provide services related to our Platform and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.
For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of our services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.
We will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
4.6 Collection and Remittance of Occupancy Taxes.
In order to facilitate the Collection and Remittance of Occupancy Taxes as described in the “Taxes” section of the Terms of Service, Guests, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose Guests data and other information relating to them or to their transactions, bookings, Accommodations and Occupancy Taxes to the relevant tax authority, including, but not limited to, the Guest’s name, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) and contact information.
4.7 Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
5. OTHER IMPORTANT INFORMATION
5.1 Analyzing your Communications.
We may review, scan, or analyze your communications on our Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
These activities are carried out based on our legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5.2 Linking Third Party Accounts.
You may link your Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:
• some of the information you provide to us from the linking of your accounts may be published on your Account profile;
• your activities on our Platform may be displayed to your Friends on our Platform and/or that third party site;
• a link to your public profile on that third party social networking service may be included in your public profile;
• other users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
• other users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service;
• the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
• the publication and display of information that you provide to us through this linkage is subject to your settings and authorizations on our Platform and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
5.3 Third Party Partners & Integrations
Our Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). We doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. YOUR RIGHTS
Consistent with applicable law, you may exercise any of the rights described in this section before your applicable Data Controller and Payments Data Controller.
6.1 Managing Your Information.
You may access and update some of your information through your Account settings. If you have chosen to connect your Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Account).
6.3 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the erasure of your personal information:
• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain information from that Account to prevent that Member from opening a new Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations.
• Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on our Platform, even after your Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain our Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.5 Withdrawing Consent and Restriction of Processing.
If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of us override your own.
6.6 Lodging Complaints.
You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the Contact Us section.
10. CONTACT US