Our Privacy Policy

PRIVACY POLICY

Progerasa Investment Limited,  (collectively as “Progerasa”,   “we” and “us”, also trading as “Ezoria”),  has prepared this privacy policy which provides an overview and explanation as to how we treat the personal information of individuals who are users of our website, www.ezoria.com   including but not limited to you using any of our products, services and/or bookings/applications in any manner, whether online or otherwise.

This privacy policy is directed to natural persons who are either current or potential clients of Progerasa and/or Ezoria,  or are authorized representatives/agents or beneficial owners of legal entities or of natural persons which/who are current or potential clients of Progerasa/Ezoria, whereby Progerasa/Ezoria will gather various types of information, which includes information identifying you as an individual,  this is known as “Personal data” and/or “data”. Progerasa/Ezoria is committed to protecting your personal data and respects your privacy.

By continuing to use the Progerasa/Ezoria website and/or any other services provided through Progerasa/Ezoria,  you confirm that you are of legal age, and expressly agree with this Privacy Policy and consent to Progerasa/Ezoria processing the data, by manual and/or automated means.  This includes the collections, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure and/or destruction of personal data.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES 

The new data protection law in Cyprus, will come into effect as of  25 May 2018, better known as the General Data Protection Regulation, (“GDPR”). This Privacy policy sets out most of the rights and duties within the new legislation related to GDPR, and we are here to service your request(s) related to personal data, subject to the systems being ready for such requests, although we undertake to provide you with the service required the soonest since any request is made by you relating to your data.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your business relationship with us.

THE DATA WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information that relates to an identified or identifiable living individual.   It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, process and transfer different kinds of personal data about you which we have obtained such as:

We may at times, also collect, use and share data  such as for statistical or demographic purposes.

We do not collect Special Categories of Personal Data about you such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic data, provided that you do consent to the provision of information relating to your health when making a reservation, so that we can best accommodate your need(s), for example:  in providing you with a wheelchair, and/or other medical assistance that may be available.

We may also collect and process personal data which we lawfully obtain not only from you but from other entities and/or other third parties,  companies/persons that introduce you to us, companies that process card payments such as JCC Payment Systems Ltd, payment providers, etc.  We may also collect and process personal data from publicly available sources, e.g. commercial registrars, the press, media and internet, which we lawfully obtain and we are permitted to process.

FAILURE TO PROVIDE PERSONAL DATA  

Where we need to collect personal data by law, or under the terms of a contract/service we have with you and you fail to provide that data when requested, we may not be able to perform the contract/service we have or are trying to enter into with you (for example, to provide you with goods and/or services). In this case, we may have to cancel/suspend a product and/or service you have/may have with us and as such you will be notified in such case.

PURPOSE OF DATA COLLECTION/PERSONAL INFORMATION COLLECTION

We process personal data so as to safeguard the legitimate interests pursued by us or by a third party in respect of the accommodation,  products and/or services rendered by us to you. The legitimate interest includes having the business or commercial reason to use your information.

When using the website as example, details of your usage are automatically registered by our server, such as your IP address, browser, the content you have visited, and how you landed on our pages, personal identification information, etc.)  In addition, we collect and store information such as your name, address, e-mail address, phone number, date of birth, gender and other data transmitted to us through completion of online forms/booking forms, and/or any other newsletters, etc.

The main purpose of collecting data is:

 

HOW IS YOUR PERSONAL DATA COLLECTED? 

We use different methods to collect data from and about you including through:

(a)  analytics providers such as Google based outside the EU/within EU;

(b)  advertising networks;

(c)  Third Party Service providers;

(d)  Banks and/or payment providers;

HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data for legitimate purposes and/or when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Generally, in relation to marketing,  we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at the following email: [email protected]

Recipients of personal data may include,  as  example:

  1. supervisory and other regulatory and public authorities, inasmuch as a statutory obligation exists, for example, the income tax authorities, criminal prosecution authorities, auditors, lawyers;
  2. marketing companies and market research companies;
  3. companies which help us to provide you with cards such as VISA and MASTERCARD:
  4. Card payment processing companies;
  5. Fraud prevention agencies;
  6. File storage companies, archiving and/or records management companies, cloud storage companies;
  7. Companies who assist us with offering technological expertise, solutions and support and facilitating payments;

DISCLOSURE OF DATA

Your personal data will be kept confidential and will be treated as such, it is to be noted that Progerasa/Ezoria will only disclose website usage data and/or personal data, to third parties as permitted by law(s),   where and if Progerasa/Ezoria is legally obliged to do so or if such disclosure becomes necessary to enforce Progerasa/Ezoria rights in particular to enforce claims arising from a contractual relationship, or required to comply with any judicial, and/or other proceedings, court order, legal process or pursuant to any governmental, intergovernmental and/or other regulatory bodies, whereby such disclosure may be executed by Progerasa/Ezoria without prior notice to you.

Progerasa/Ezoria will not be liable for unlawful or unauthorized use of your personal information/passwords/username/login, etc. due to misuse or misplacement of your passwords, negligent or malicious intervention and/or otherwise. You consent to Progerasa/Ezoria using any of your data which has come into our possession during any interaction for the purposes of intending to enter into agreement/making reservation(s),  and includes information after termination of the agreement(s) and/or upon “check-out” from accommodation.  The purpose for which Progerasa/Ezoria will use your information will always be related to the accommodation/services/activites offered and/or provided by Progerasa/Ezoria and for the purpose of performing any agreement(s) and/or related services.

You consent to the processing of data prior to the actual “contracting” stage, i.e with the intention to enter into agreement and/or making a reservation(s). You consent that it is possible at times, that data may be transferred outside the EU from time to time as the case may be for the purposes of securing the reservation made, for example, completion of a payment transaction.   Your personal data may be transferred to third countries in some cases, for example to execute your payment or if the data transfer is required by law.

You understand and consent that Progerasa/Ezoria may disclose your personal data to but not limited to affiliates, any sister companies, third party service providers, payment providers, in order to process obligations arising from the agreement/reservation(s) made, financial institutions, banks, other similar organizations that we deal with in course of business, external service providers and professional advisers, which may be located overseas, such as auditors, lawyers and accountants, any third parties where this is necessary to secure accommodation and/or activities and/or services related to the accommodation booking.

MONITORING AND RECORDING

Progerasa/Ezoria may monitor, store, and record any communication(s), whether orally/written form (documented including emails/telephone recording(s)).  The recording is carried out for the legal purposes related to safety and security and used to track history, client satisfaction and statistical data.

SECURITY MEASURES

Progerasa/Ezoria takes all appropriate security measures to ensure that the personal data/data collected and stored in connection with your visit to the website and/or in relation to the accommodation,  services and products provided by Progerasa/Ezoria is protected against any unauthorized access, misuse, loss and/or destruction.  Progerasa/Ezoria uses physical and electronic security measures, including but not limited to the use of firewalls, personal passwords, encryption and authentication technologies. Progerasa/Ezoria employees and service providers are bound by professional secrecy and comply with all data protection provisions. It is to be noted, that access to personal data is restricted to specific employees, contractors and third party service providers who require this access in order to process the agreement/accommodation request,  between Progerasa/Ezoria and you, on a “need to know” basis and to be able to process the booking request accordingly.  It should be noted that data transmitted via an open network like the Internet cannot be fully protected from third-party access, although we take the best possible precautions to avoid any leakage of information/data. Any transmission of data via the internet is at your own risk, although we will exercise all ways in order to protect your personal data. Please note that all your actions while using this website may be recorded and analyzed for various purposes, including security, marketing and system monitoring purposes. Progerasa/Ezoria adheres to strict security standards using the most up to date security technologies.

COOKIES

Progerasa/Ezoria website uses cookies for statistical purposes and in order to improve the quality of services to the user. Cookies are small files that are placed on your device via your web browser when you visit Progerasa/Ezoria website. Information is stored, such as the specific preferences when using the website. It is to be noted that you can configure your browser not to save any or only certain cookies on your device. There are different types of cookies such as ID cookies which do not expire when you close your browser, and persistent cookies with remains on your hard drive for a period of time. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to have your device notify you each time a cookie is sent to it, and thereby the choice to accept it or not.  It is strongly recommended that you allow cookies on our website to ensure you have best possible experience. Disabling the cookies may result in reduced performance of the website and may also impair the quality of the services that we provide you in relation to your booking request(s).

THIRD PARTY LINKS

Links may appear on the website that are not operated or monitored by us, known as “third-party websites”, whereby such third party websites are not bound by this privacy policy and we are not responsible for their content.  No warranties or liability related to the contents of such third party websites are made. Using links to third-party websites are at your own sole risk and discretion. When you leave our website, we encourage you to read the privacy notice of every website you visit.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time at the following email address: [email protected]

YOUR LEGAL RIGHTS

 Please note that you have certain rights under data protection laws in relation to your personal data:

GOVERNING LAW

This privacy policy, the use of our website, and/or the use of  any of our accommodation(s),  services and/or products,  shall be governed by the Laws of Cyprus.

RECORD KEEPING

Progerasa/Ezoria will keep your personal data/data for as long as we have a agreement with  you (as an individual or in respect of our dealings with a legal entity you are authorized to represent or are a beneficial owner).

Progerasa/Ezoria shall not be required to delete data made pursuant to automatic archiving and back-up procedures in its IT systems, where a deletion is not possible or not possible without commercially unreasonable efforts.

For prospective clients, personal data (or authorized representative/agents/or beneficial owners of a legal entity prospective client), Progerasa/Ezoria keeps your personal data for as long as legally entitled to or required to perform under any agreement,  unless you have officially requested deletion from our records.   Once we have notified you of our approval or rejection of your booking for accommodation, services and/or products the period we hold data is the time frame as per the applicable law at the time, unless request for deletion is given to us by you in a written form.

HOW TO CONTACT US

To exercise your rights, you can contact us directly.  We undertake to respond to your request without undue delay and at the latest within 1 month from date of which we received official written request. You understand that you may be asked to provide information to confirm your identity such as clicking a verification link, entering a username and/or password in order to exercise your rights.

If you want to:

Please contact us using the following contact details:

[email protected]

Contact number: +357 25500722

Notes:  The General Data Protection Regulation (EU) 2016/679 shall apply from 25 May 2018. These rights are applicable across the EU, regardless of where the data is processed and where the company is established.  These rights also apply when you buy goods and/or services from non-EU companies operating in the EU.

 

Copyright © 2018 Progerasa Investment Limited