Divine Property S.A. (referred to hereinafter “Divine Property/We/Our/Us”), a registered company in Greece, VAT EL800768001, offers, among other services, real estate, short and long term rental, accommodation, hospitality, tourism, leisure, booking, event management, food, catering and similar services related but not limited short-term house rental services collectively referred to hereinafter the “Services”. As part of and in connection with either or all of Our Services, We may collect and process personal data (“Personal Information”’) and other information (“Other Information”), collectively referred herein as “Information”, relating to you, either you are an employee, client and any third party service provider or any other third party We have dealings with.
We utmost value your privacy; At Divine Property S.A. it is of paramount importance to Us that your Information is safeguarded, treated with utterly confidentiality and secure. Thus, We take care to respect and comply with the data related rights of all individuals.
Divine Property S.A. is the processor and controller of the Personal Information (“Data Processor”/”Data Controller”) in accordance with the applicable EU General Data Protection Regulation on personal data protection.
About this Privacy Notice
This Privacy Notice (herein referred to as the “Notice”) explains what We do with your Information, whether We are in the process of helping you with your business or personal request, continuing Our relationship with you once We have entered an agreement with you and offered You our services, received a service from You or You are visiting our website.
In essence, this Notice applies to the Information collected of all the parties we have dealings with: Our website users, on-site visitors, guests, service providers, clients, (either directly engaged or independent third party service providers, sponsors and other people browsing for Divine Property S.A.’s property accommodation or utilizing Divine Property S.A.’s Services, herein referred to as "You / Your / User/ Client / Guest / Sponsor / Third Party Provider” whom We may contact. It also applies to Our staff (“Staff”).
This relates with Information collected, by all means, both online and offline; through Our website, including but not limited to www.divineproperty.com (herein the “Website”); through the software applications, channel managers and booking tracking software made available by Us for use on or through computers or mobile devices (the “Apps”); through Our social media pages and Apps to which the Website links (collectively, Our “Social Media Pages”), through HTML-formatted email messages that We send to You the link of this Notice, through Third Party Providers’ online systems (e.g., online booking services and boards) (collectively, including the Website, Apps, Our Social Media Page and Third Party Providers’ online systems, the “Online Systems”) and through Information collected directly from You. This Notice also covers all other means than Our Online Systems by which We collect Information (e.g., assessments, online booking systems, channel management software, telephone or in person discussions, internal and external communication etc.).
This Notice is regularly reviewed and may be updated from time to time to reflect changes in Our business or legal or commercial practice. Where an update is relevant to Our processing of Your data We will notify You.
How do We collect Information?
We may collect Information in a variety of ways in order to support Our Services and carry on Our business activity.
If you are a Guest or a Visitor, Personal Information might be contained in email, telephone, booking or registration forms either directly or from any Third Party Providers to which we subscribe (e.g., online booking engines, advertisements, social media, travel agencies), or direct conversations you have with Us, on the ground of the legal basis of processing. From time to time, We may also receive Personal Information about You from Third Party Service Providers, on the grounds of quality assurance and feedback.
Where We have collected Personal Information by independent Third Party Providers without Your knowledge, You may find specific Information regarding the source within the relevant sections of this Notice or by directly contacting the Third Party Provider.
If You are a Third Party Provider or a Client with whom We have dealings, We may obtain Your Personal Information from various sources like directly by You, including where Your have provided Us with Your contact details or other Information for the purposes of using Your services or rendering Our Services to You, Staff or other representatives of the organisation You represent, Marketing databases, Social media, The public domain, Conversations with You or Others, on the telephone or video conferencing (which may be recorded if you expressly agree) or in meetings, Notes following a conversation, with You or others, or meetings You attend etc. If you are a Client/Guest to whom We are engaged to, You should also refer to the relevant to the data protection relevant sections on the service agreement You sign with Us.
Anywise, it is our obligation to advise You of the source We have obtained Your Personal Information when We first communicate with You.
What Personal Information do We collect?
Divine Property S.A. collects a range of Personal Information about You on legitimate purposes in the course and pursuance of Our Services, as prescribed in this Notice.
This may indicatively include:
Your name, address, date of birth and contact details, including email address and telephone number;
● Details of Your stay
● Credit/Debit Card Number
● Visa, passport and other documents to verify Your identity
● Contact details for guests other than You
● Other sensitive personal Information such as food and accommodation requests as long as these are needed to make reasonable adjustments during the accommodation process
● Other data collected through online platforms of Third Party Providers
● Future travel plans, special requests, itinerary Information, and other private Information
● Information relating to Our relationship with You or the party for whom You work including records of any meetings or discussions
● Your marketing preferences
Do We Collect Other Information collected through Our Sites and Apps?
Divine Property S.A., Divine Property S.A.’s Partners, Subsidiaries, Associates and Our Third Party Providers collect Other Information that does not reveal Your specific identity in a variety of ways, including:
We may collect the physical location of Your device by, for example, using satellite, cellphone tower or Wi-Fi signals. We may use Your device’s physical location to provide You with location-based services and content. In some instances, You may be able to allow or deny collection of Your device’s location, but if You choose to deny such collection, We may not be able to provide You with the applicable location-based services and content.
Information such as Your preferred means or time of communication is collected when You voluntarily provide this Information. Unless combined with Personal Information, this Information does not personally identify You or any other User of the Online Systems.
By aggregating Information
Aggregated Information does not personally identify You or any other User of the Online Systems. For example, We may aggregate Information to gain analytics insights such as analyzing the geographic distribution of the market segment of Our Services, market data etc. You are welcome to search further Information regarding these matters within the relevant sections of this Notice.
As long as Other information is a non-identifier of Your personal identity, We lawfully may treat them for any purpose.
How do We handle Your Social Logins
If You choose to register or log in to Our Website using a social media account, We may have access to certain Information about You.
Our Online Systems offers You the ability to register and login using Your social media Third Party Provider account details (like Your Facebook login). Where You choose to do this, We will receive certain profile Information about You from Your social media Third Party Provider. The profile Information We receive may vary depending on the social media provider concerned, but will often include Your name, e-mail address, friends list, profile picture as well as other Information You choose to make public. If You log in using Facebook, We may also request access to other permissions related to Your account, such as friends and likes, and You may choose to grant or deny Us access to each individual permission.
Why and How does Divine Property S.A. process Information?
Divine Property S.A. has legitimate purposes in processing Personal information for rendering its Services and for keeping records of the process. We collect and use the Information from You which is necessary for the purpose of Our legitimate interests as described in this Notice, in order to support Our Services and Our related commercial activity. We use Your Information for:
Short and Long Term Real Estate Rental, Accommodation, Travel, Tourism, Leisure & HR Activities
We use Personal Information for rendering to You Services, using Your services for meeting our engagements and fulfill Our contractual obligations.
We may use and process Information on the following legitimate basis:
In the course of providing Our Services, We use Information that We have collected concerning Guests to identify and provide relevant Services that We think may be of interest. After explicit consent, We may contact potential Guests from time to time regarding such Services.
Processing Information from Guests allows Us to manage the accommodation process, assess and confirm Our Services. We may also collect Information about whether or not Guests need to make reasonable adjustments to Our Services. We also use Information to confirm booking requests and conduct quality and loyalty checks, as appropriate.
In this context, processing Information of Our Guests, allow us to take steps to fulfill Our contractual obligations to them related to the Services we have been engaged to render and to serve Our legitimate interests. We also use Information from Our Third Party Providers to support Our activity.
We also need to process data to take steps for the purposes of Our internal recruitment purposes (internal usage) preparing for Our Staff employment contracts, payrolling etc.
Importantly, for responding to Our obligations in respect to Our commercial activity and the provision of Our Services, We may use Personal Information to respond and fulfill Your inquiries and Your requests in regard both to Our Services and business activity. If You contact Us, We may keep a record of Your contact Information and correspondence, and We may use any Information You provide to respond to Your inquiry.
As part of carrying on Our business activity, we are called to use Personal Information to support Our business activities, such as running internal audits, communicating internally regarding You, determining the effectiveness of Our promotional activities, administering Our Services, maintaining and securing Our infrastructure, and for procurement and financial transactions.
After explicit consent, We may use your Personal Informational material such as Your e-mail from time to time to conduct campaign and marketing campaign e-mails and to send informational materials, such as articles, market trends, booking offers and other information regarding Our Services. Also, by seeking and receiving Your consent, We may use Your Personal Information in press releases and marketing materials. Please see the “Your Consent” section in this Notice regarding how you can withdraw Your consent from being contacted for marketing purposes at any time.
We may from time to time use Information regarding the Online Systems, changes to Our terms, conditions, and policies and/or other administrative Information. We may also contact You from time to time to verify that the Personal Information We have collected about You is accurate and current.
Analytics, Aggregating & Historical Information
We may retain and use Information about You for market trend analyses purposes, generating norms by level, geography etc., for monitoring accommodation statistics, conducting validation studies, compiling reports, publishing articles, to generate norms by geography, level, etc. or for purposes of improving Our Services, strengthening the knowledge base of Our market intelligence or developing new services. We may further use Personal Information that We collect for purposes of aggregating and disclosing diversity statistics and other statistical Information regarding the hospitality market, on a lawful and legitimate interests basis as described in this Notice. We may also process special categories of Information, such as ethnic origin, to monitor vacancy statistics. For these purposes, We may also use Your name and other identifiers to associate and combine Information about You that is collected from one Service with Information about You collected through other Service. Any published end product will refer only to larger aggregations of individuals and will not identify You personally or include any results attributable to You; such aggregated or de-identified Information is considered Other Information for the purposes of this Notice and We may use it for any purpose. Please see the related section of this Notice for further details on Other Information we collect and process.
We may also process Personal Information that forms historical data for purposes of monitoring and recording Our past business and recruitment activity on the lawful basis of Our legitimate interests as prescribed and in accordance with this Notice.
We may use or disclose Your Personal Information in order to:
comply with applicable laws
respond to inquiries or requests from public or government authorities, including those outsides of Your country of residence
comply with valid legal process
protect the rights, privacy, safety or property of Divine Property S.A., Users of the Online Systems or the public
help us to establish, exercise or defend legal claims
We cannot and do not assume any responsibility for the actions or omissions of either Third Party Providers or Clients, including the manner in which they use Personal Information received either from Divine Property S.A. or from other independent Third Party Provider.
Where do We collect and maintain the Information?
Your Information may be collected, used, processed, disclosed and transferred to any country where We have commercial activity, facilities or in which We engage service providers. Even though We will assess, monitor and pursue GDPR compliance for the service provider, By using our Services or Online Systems, You consent to the transfer of Information to countries outside of Your country of residence, which may have different data protection rules than in Your country.
Who has access to Information?
Your Information may be shared internally with Our Staff and externally with Our Subsidiaries, Partners, Affiliates, Clients and Third Party Providers for the purposes of rendering Our Services. External categories with whom We may share Your Personal Information for the provision of Our Services include:
Subsidiaries, Partners, Affiliates, Third Party Service Providers
We may disclose Your Personal Information to Clients who have engaged Our Services:
In the course of Our Services, this includes members of Divine Property and Hospitality teams and/or interviewers involved in the assessment process. In the course of delivering Our Services, Your Personal Information, including results of related data, can be shared with a Client/Partner that have engaged Divine Property S.A. to fulfill accommodation requests. In any case, We inform You who the Client is and seek for Your consent before We forward You Personal Information to the Client. Anonymized profiles and accommodation data may be sent to a Client without informing the Guest or seeking their consent. This will only be done for statistical, quality assurance or historical purposes.
Assessment results and other Information collected by our Staff or provided by Our Client may be maintained in Divine Property S.A. database, to which our Client, and certain personnel designated by Our Client will have access both during and after the conclusion of Our assignment. If You have completed an assessment at Our Client’s request as part of our HR Services or related to a Recruitment Service, We will not share Your assessment results with other Clients without obtaining the appropriate consent.
We may contact former employers or any other source to obtain references for You and to make necessary background checks
Any Affiliates, subsidiaries and strategic alliance partners, about which You are informed in this Notice
Third Party Providers which We obtain support and services (e.g., hotel management services, real estate agents, travel agencies, training institutions, technical online testing providers) and process data on Our behalf, which may include:
- Outsourced software providers
- IT staff if access to the data is necessary for the performance of their role
- Legal and professional advisers
- Online technical testing providers
Any regulatory authority or statutory body pursuant to a request for Information or any legal obligation which applies to Us
How do We Protect Your Information?
We take Our obligations in respect of the privacy of Your Information very seriously and will only process Information for specified, explicit and legitimate purposes as detailed in this Notice unless We inform You otherwise. In order to ensure that the Personal Information We hold about You is accurate and up to date, We kindly request that You inform Us of any relevant changes.
We have internal policies and controls in place to ensure that Your Information is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by Our Staff in the proper performance of their duties. We process Personal Information lawfully, fairly and in a transparent manner in relation to You.
Information data will be stored in a range of different places, including on Your accommodation record and on other Online systems (including email software, hotel channel management systems and booking engines). Divine Property S.A. has reasonable organizational, technical and administrative measures in place to protect against the loss, misuse and alteration of Personal Information about Users of the Online Systems which is under Our control. However please note that, no security system, or system of transmitting Personal Information over the Internet, cordless or mobile telephone and similar telecommunication and computer equipment can be guaranteed to be 100% secure. Therefore, unless You utilize encryption and other forms of security protection, You waive any action legal or otherwise against Divine Property S.A. and hold the latter harmless for any interception of Your Information resulting from the use of the above-mentioned equipment.
Nonetheless, If You have reason to believe that Your interaction with Us is no longer secure (for example, if You feel that the security of any account You might have with Us has been compromised), please immediately notify Us of the problem by contacting Us in accordance with the “Q&A” section below.
For how long does Divine Property S.A. keep Personal Information?
Divine Property S.A. will keep Your Personal Information for two (2) years from the last point of contact. You can request to have Your data deleted earlier, which We will comply subject to the applicable law. It is our policy to only store Your Personal Information for as long as is reasonably necessary for Us to comply with Our legal obligations and for Our legitimate business interests. However, We may retain data for longer than a two (2) year period where We have a legal or contractual obligation to do so, or We form the view that there is otherwise a continued basis to do so, for example where Your Personal Information identifies special requests, extraordinary feedback, form historical or reporting Information about past business activity or We are subject to a legal obligation which applies for a longer period. Such Information will not be used for any other purposes and any wise their processing will comply with this Notice.
If Your application for direct employment (internal usage) is successful for becoming Our Staff, Personal Information gathered during the search, selection & assessment process will be transferred to Your Human Resources file (electronic and paper-based) and retained during Your employment in Us. If you are a member of Our Staff, you should also refer to the Our Staff Data Protection section which is available on the employment contract you sign with Us.
Where Information from Third Party Provider sources is of no use to Us We shall discard it, however, We may maintain a limited record in order to avoid the duplication of process.
Where We consider that Information may be of use to Us in the process of providing of Our Services, any processing will be in accordance with this Notice.
You may request at any time:
access and obtain a copy of Your data on request
change incorrect or incomplete data
delete or stop processing Your data, for where the data is no longer necessary for the purposes of processing
object to the processing of Your data where Divine Property S.A. is relying on its legitimate interests as the legal ground for processing; and
withdraw Your consent at any time
Divine Property S.A. Website is hosted in ISO 27001:2013 certified hosting service, in E.U. based servers.
The Information You share with Us by using Our Website may be temporarily stored on a Website content management system database. This enables Us to securely transfer data submitted when using Our Websites to Our central database.
You need to take positive and affirmative action in giving us your consent – in some cases, we will provide a tick box for you to check, to secure that this requirement is met in a clear and explicit fashion. Otherwise, by browsing Our Οnline Systems, applying and/ or contacting Divine Property S.A. concerning accommodation requests or the provision of any of Our Services through any direct (e.g., Our Website,You) or Third-Party Provider, (e.g. an accommodation request, online booking sites, social media platforms etc.), means You freely provide Your consent, explicitly agree and unreservedly accept the processing of Your Personal Information for the purpose of the Services as described, either for Divine Property S.A. (internal usage) or on behalf of Our Client and You are free to withdraw Your consent at any time.
However, You must understand that withdrawing Your consent will not affect the lawfulness of processing based on consent before its withdrawal nor further processing of the same data under other legal basis such as contractor compliance with a legal obligation to which Divine Property S.A. is subject or under lawful and legitimate basis to retain historical Information about you for informing Our recruitment and business activity and avoid duplications. The related residual Information will not be used for commercial or/and marketing purposes.
You must be aware that, in particular cases (for instance, due to legal requirements) We may not be able to make Your request effective right away. In any case, within one month from Your request, We will inform You about the actions taken.
We may also be required to retain some Information about You, such as your email and name in order to be able to fulfill Your opt-out or similar inquiry and to record Our actions; Such residual Information will not be used for any other purposes.
If you would like to opt-out of receiving marketing communications from Us, please contact us at email@example.com to request your contact information removed from Our marketing database.
Q & A
If You have any question about this Notice or any issues in relation to data privacy, or would like to exercise Your rights, please contact Our person responsible for such matters:(firstname.lastname@example.org)
This policy specifically explains how we and our third-party service providers deploy cookies, as well as the options you have to control them.
What's a cookie?
A "cookie" is a piece of information that is stored on your computer's hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyze traffic and for advertising and marketing purposes.
Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as those who serve content or provide advertising or analytics services on the website (“third party cookies”).
Both websites and HTML emails may also contain other tracking technologies such as “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.
How can you control Cookies?
For more details on your choices regarding the use of your web browsing activity for interest-based advertising visit EU(EU based). On a mobile device, you may also be to adjust your settings to limit ad tracking.
You can opt out of Google Analytics by installing Google’s opt-out browser add-on.
to track your use of our Online Systems. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our Website and services in response to what our visitors want and need;
to help us advertise content to you that we think you'll be interested in. Hopefully, this means less time for you crawling through endless pages and will get you the accommodation you want quicker.
Our cookies are either:
These are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
A persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalization (see below).
Divine Property S.A. cookies are only read by Divine Property S.A. servers and are unable to execute any code or virus. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Online Systems, as well as for tracking purposes. We also gather statistical information about the usage of the Online Systems in order to continually improve the design and functionality, understand how the Online Systems are used and to assist us with resolving questions regarding the Online Systems.
The list below describes the cookies we use in your jurisdiction, why we use them and what types of cookies they are:
Strictly necessary cookies:
These cookies are essential to enable you to use the Website effectively, such as when making an accommodation request, submit a form, make a booking, set up an appointment and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
These cookies enable us to monitor and improve the performance of our Online Systems. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
These cookies allow our Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.
These cookies help us to advertise details of potential content that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the Website, you may see advertising for offering that is similar to accommodations preferences that you have previously browsed.
Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved. We use Google analytics cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our Online Systems works. These cookies collect information in an anonymous form
Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.
Site Management Cookies:
Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.
Advertising/Marketing cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to our Online Systems, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you.
We use Facebook cookies to register impressions on pages with the Facebook login button.