At Luxury Key we are committed to protecting and respecting your privacy. Please read this policy as it contains important information about how we use the personal data that we collect from you or that you provide to us.
When this policy mentions “booking system,” “booking engine,” “system,” “website,” “platform,” “app,” “webapp,” “services,” “online services,” it refers to all pages and functions under https://www.luxurykey.com unless specified otherwise.
By accessing the platform or providing information, you agree to our privacy practices as set out in this privacy statement. We may change this policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version.
When this policy mentions “we,” “us,” or “our,”, “data controller,”, “controller,”, it refers to Luxury Key Ike
Luxury Key operates this booking system through a data processor, as explained below. For the purposes of the General Data Protection Regulation (“GDPR”) (EU) 2016/679, we are the Data Controller. There is a strict contractual framework between the data controller and the data processor for the protection of your personal information. We are:
Luxury Key IKE
Dimosthenous 8, Agia Paraskevi, 15343
WebHotelier operates this booking system on behalf of Luxury key Ike and is committed to protecting the privacy of the users of this system. WebHotelier is:
WebHotelier Technologies Limited
Mnasiadou 9 (Demokritos Building, Office 16)
For the purposes of the GDPR, where WebHotelier processes your personal data on behalf of Luxury key Ike, WebHotelier is the Data Processor. When this policy mentions “data processor,” “processor,” “WebHotelier,” it refers to WebHotelier Technologies Limited.
The User may contact WebHotelier’s Data Protection Officer:
The data requested in the forms accessible from the booking engine are, in general, mandatory (unless specified otherwise in the required field) to meet the stated purposes. Accordingly, if they are not provided or are not provided correctly, we will be unable to process the request.
This will include:
We grant permission to our data processor:
In the event of registration and/or access through a third-party account, we may collect and access certain information of the User’s profile from the corresponding social network, solely for internal administrative purposes and/or for the purposes indicated above.
Third-party data (e.g. book for a friend)
Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).
Use of Services by Minors
The Services are not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Data through the Services.
Depending on the User’s requests, the personal data collected will be processed in accordance with the following purposes:
The criteria used to determine our retention periods include:
· The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services or if you have a booking that has not yet been fulfilled)
· Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
· Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)
Legitimate interest for processing your data
The data processing required in fulfilment of the aforementioned purposes that require the User’s consent cannot be undertaken without said consent.
Likewise, in the event that the User withdraws their consent to any of the processing, this will not affect the legality of the processing carried out previously.
To revoke such consent, the User may contact us through the appropriate channels.
By the same token, in those cases in which it is necessary to process the User’s data for the fulfilment of a legal obligation or for the execution of the existing contractual relationship between us and the User, the processing would be legitimized as it is necessary for compliance with said purposes.
We will use and disclose Personal Data as we believe to be necessary or appropriate:
· to comply with applicable law, including laws outside your country of residence;
· to comply with legal process;
· to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements;
· to enforce our terms and conditions;
· to protect our operations;
· to protect the rights, privacy, safety or property of our own, you or others; and
· to allow us to pursue available remedies or limit the damages that we may sustain.
We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.
International transfers of personal data
We may transfer your personal information to our data processor(s) or/and sub-processor(s) based outside of the EEA for the purposes described in this policy. If we do this, your personal information will continue to be subject to one or more appropriate safeguards set out in the law. These might be the use of model contracts in a form approved by regulators, or having our suppliers sign up to an independent privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme).
Our data is stored in the cloud using Amazon Web Services in N. Virginia, USA and in Frankfurt, Germany. If you are accessing any of our systems from outside the USA, you acknowledge that your personal information may be transferred to the USA, a jurisdiction which may have different privacy and data security protections from those of your own jurisdiction, to be processed and stored.
Guarantees that they are of legal age or legally emancipated, where applicable, fully capable, and that the information furnished to us is true, accurate, complete and up-to-date. For these purposes, the User is responsible for the truthfulness of all the data communicated and will keep the information updated, so that said data reflects their actual situation.
Guarantees that he/she has informed third parties on whose behalf he/she has provided data, where applicable, of the aspects contained in this document. Also guarantees that he/she has obtained the third party’s authorisation to provide their data to us for the purposes indicated.
Will be responsible for false or inaccurate information provided through the Website and for damages, whether direct or indirect, that this may cause to us or third parties.
Exercise of Rights
The User may contact us at any time free of charge, to:
· To obtain confirmation about whether or not personal data concerning the User are being processed by us.
· To access their personal details.
· To rectify any inaccurate or incomplete data.
· To request the deletion of their personal data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
· To confirm revocation of consent.
· To obtain from us the limitation of data processing when any of the conditions provided in the data protection regulations are met.
· To request the portability of your data.
Likewise, the user is informed that at any time he/she may file a complaint regarding the protection of their personal data before the competent Data Protection Authority.
We will process the User’s data at all times in an absolute confidential way and maintaining the mandatory duty to secrecy with regard to said data, in accordance with the provisions set out in applicable regulations, and to this end adopting the measures of a technical and organisational nature required to guarantee the security of their data and prevent them from being altered, lost, processed or accessed illegally, depending on the state of the technology, the nature of the stored data and the risks to which they are exposed.