Privacy Notice

Last Updated: May 24th, 2018

At AFOI KAVOURA SA / Villas Branch Office / Branch Establishment 4, we are committed to protecting and respecting your privacy. Please read this notice as it contains important information about how we use personal data that we collect from you or that you provide to us.

Information & Consent

This Privacy Notice describes how we collect, use, process, and disclose your information, including personal information about you (hereinafter, the “User”), in conjunction with your access to and use of our booking system.

By reading this Privacy Notice, the user is hereby informed on how we collect, process and protect personal data furnished through the booking engine.

The User must carefully read this Privacy Notice, which has been written clearly and simply, to facilitate its understanding, and to freely and voluntarily determine whether they wish to provide their personal data, or those of third parties, to AFOI KAVOURA SA / Villas Branch Office / Branch Establishment 4.

When this notice mentions “booking system,” “booking engine,” “system,” “website,” “platform,” “app,” “webapp,” “services,” “online services,” it refers to all pages and functions under https://naxosroyalvillas.reserve-online.net/ 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 notice from time to time. You should check this notice frequently to ensure you are aware of the most recent version.

Identity

When this notice mentions “we,” “us,” or “our,”, “data controller,”, “controller,”, it refers to AFOI KAVOURA SA / Villas Branch Office / Branch Establishment 4.

Data Controller

AFOI KAVOURA SA / Villas Branch Office / Branch Establishment 4 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:

Naxos Royal Villas “AFOI KAVOURA SA / Villas Branch Office / Branch Establishment 4”
Stelida
84300, Naxos
GR

Data Processor

WebHotelier operates this booking system on behalf of AFOI KAVOURA SA / Villas Branch Office / Branch Establishment 4 and is committed to protecting the privacy of the users of this system. WebHotelier is:

Revplus Hellas S.A.
5th Km Rhodou-Lindou Ave.
851 00, Rhodes
Greece

For the purposes of the GDPR, where WebHotelier processes your personal data on behalf of AFOI KAVOURA SA / Villas Branch Office / Branch Establishment 4, WebHotelier is the the Data Processor. When this notice mentions “data processor,” “processor,” “WebHotelier,” it refers to WebHotelier Technologies Ltd.

WebHotelier is a certified PCI-DSS Level 2 Service Provider audited quarterly by Sectigo Limited.

The User may contact WebHotelier's Data Protection Officer:

Data Protection Officer
dpo@webhotelier.net

Obligatory nature of providing the data

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.

Personal data we collect and process

This will include:

personal information about you which we ask you for (e.g. your name, address, and email address) when you make a booking from our booking engine;
financial details in order to process your booking when we require pre-payment;
details of transactions you carry out through our booking engine and details of the fulfilment of your orders.
our data processor may only collect and process personal data collected and/or processed on behalf of us in accordance with our instructions. WebHotelier cannot process it in any other way or for any other purpose.

We grant permission to our data processor:

to use your personal information for reserving rooms and/or other services for you at AFOI KAVOURA SA / Villas Branch Office / Branch Establishment 4;
to pass on your financial details to AFOI KAVOURA SA / Villas Branch Office / Branch Establishment 4 and/or appropriate third party (for example, credit card company) for the purpose of confirming or paying for a booking;
to use your information for marketing purposes (where you explicitly agree to this); and
to pre-complete forms and other details on our website to make your next visit to our booking engine easier (e.g. when amending or cancelling a booking).

Social Login:

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)

In the event that the User provides third-party data, they declare that they have the third party’s consent and undertake to provide the interested party -the data holder- with the information contained in this Privacy Notice, duly exonerating us and our data processor from any liability in this regard. However, we may carry out the necessary verifications to verify this fact, adopting the corresponding due diligence measures, in accordance with the data protection regulations.

Sensitive Data

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.

Purpose of processing personal data

Depending on the User’s requests, the personal data collected will be processed in accordance with the following purposes:

To manage the bookings made, including payment management (where applicable) and the management of the user’s requests and preferences.
To manage registration in loyalty or membership programs, as well as obtaining and redeeming points.
To manage the User’s contact requests with us through the channels provided to this end.
To manage the sending of personalised commercial communications from us, by electronic and/or conventional means, in cases in which the User expressly consents.
To manage the provision of the contracted accommodation service, as well as additional services.
To manage surveys and/or evaluations regarding the quality of the services provided by us and/or the perception of its image as a company.

Data Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law or if the User requests their withdrawal from us, opposes or revokes their consent.

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.

Data Disclosure

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 notice. 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.

User's Responsibility

The User:

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.

Security Measures

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.

Privacy Notice

Last updated: 07/07/2026

This Privacy Notice explains how AFOI KAVOURA SA, trading as NAXOS ROYAL VILLAS (“Naxos Royal Villas”, “we”, “us”, “our”), collects, uses, stores and protects personal data relating to guests, website visitors, bookers and other users of our services.

This notice applies to personal data collected through our website, booking engine, direct communications, reservations, accommodation services, guest support, payment handling, complaints, marketing communications and any related hotel or villa services.

This notice is provided for transparency purposes. It does not replace the booking terms, cancellation policy, payment policy or any other contractual terms applicable to your reservation.

1. Data Controller

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Data Controller is:

AFOI KAVOURA SA
Trading name: NAXOS ROYAL VILLAS
Address: STELIDA, NAXOS, 84300, GREECE
Tax/VAT number: 9993472111
Email: reservations@naxosroyalvillas.com
Telephone: 0030 22850 29261

Where this notice refers to “we”, “us”, “our”, “controller” or “data controller”, it refers to the above legal entity.

2. Booking Engine and Data Processor

Our online booking engine is operated through WebHotelier Technologies Ltd. or another authorised booking technology provider acting on our behalf.

Where WebHotelier processes personal data on our instructions for the purpose of managing online bookings, payment-related booking information, reservation amendments or cancellations, WebHotelier acts as our Data Processor under GDPR.

WebHotelier’s Data Protection Officer may be contacted at: dpo@webhotelier.net

We maintain contractual arrangements with our processors requiring them to process personal data only according to our documented instructions, to apply appropriate security measures, and not to use the data for their own unrelated purposes.

3. Personal Data We Collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

A. Identity and contact data

Name, surname, nationality, address, telephone number, email address, booking reference, guest names and contact details.

B. Reservation data

Arrival and departure dates, room or villa type, number of guests, guest preferences, special requests, package details, booking source, cancellation or amendment history.

C. Payment and transaction data

Payment method, transaction references, deposit or balance information, invoicing details, billing address, card-related information where required for guarantee or payment processing, and chargeback or refund information.

We do not intentionally store full payment card details unless this is technically required and lawfully supported through our authorised booking or payment provider.

D. Communication data

Emails, messages, telephone notes, guest requests, complaints, reviews, support requests and correspondence before, during or after the stay.

E. Service and stay data

Check-in/check-out information, housekeeping or maintenance requests, extras ordered, transfers, concierge services, damage reports, incident reports and guest service history.

F. Legal and compliance data

Identification documents or information where legally required, tax invoice data, accounting records, complaint records, dispute records, insurance-related information and information required by public authorities.

G. Website and technical data

IP address, browser type, device information, operating system, pages visited, date and time of access, cookie identifiers and website usage information, where applicable.

H. Marketing data

Marketing preferences, newsletter subscription status, consent records, communication preferences and interaction with our promotional emails, where applicable.

4. Special Categories of Data

We ask you not to send us sensitive personal data unless it is necessary for your stay or for a specific request.

Sensitive personal data may include health information, accessibility needs, dietary information revealing health or religious information, biometric data, racial or ethnic origin, political opinions, religious beliefs, criminal record information or similar data.

Where you voluntarily provide such information, for example to allow us to accommodate an accessibility, health, safety or dietary request, we will process it only where necessary and only under an appropriate lawful basis, such as explicit consent, vital interests, legal obligation or the provision of the requested service.

5. Data Relating to Children

Our website and booking engine are not directed at children under the age of 16.

Where children are included in a booking, their personal data must be provided by a parent, guardian or authorised adult. The person making the booking confirms that they have authority to provide such information.

6. Data Provided About Third Parties

If you make a booking on behalf of another guest, family member, friend, employee or travel companion, you confirm that:

you have the authority to provide their personal data;
the information provided is accurate;
you have informed them that their data will be processed by us for the purposes described in this notice; and
you will provide them with access to this Privacy Notice.

You are responsible for any inaccurate or unauthorised third-party information you provide to us.

7. Why We Process Personal Data and Legal Bases

We process personal data only where we have a lawful basis under GDPR.

Purpose	Examples	Legal basis
Reservation management	Creating, confirming, amending or cancelling bookings	Contractual necessity
Accommodation services	Providing the villa, guest support, housekeeping, maintenance and requested services	Contractual necessity
Payment handling	Deposits, balances, refunds, payment guarantees and chargebacks	Contractual necessity; legal obligation; legitimate interests
Guest communication	Replying to requests, complaints, questions or operational messages	Contractual necessity; legitimate interests
Legal compliance	Tax, accounting, invoicing, guest registration, authority requests and regulatory duties	Legal obligation
Safety and security	Incident handling, damage reports, emergency support, protection of guests, staff and property	Legitimate interests; legal obligation; vital interests where applicable
Fraud prevention and debt recovery	Preventing misuse, unpaid balances, false claims, chargebacks or damage disputes	Legitimate interests
Legal claims	Establishing, exercising or defending legal claims	Legitimate interests; legal obligation
Marketing communications	Newsletters, offers, promotions and direct marketing	Consent, or legitimate interests where legally permitted
Service improvement	Guest feedback, surveys, reviews and internal quality control	Legitimate interests; consent where required
Website operation	Security, functionality, analytics and cookie management	Legitimate interests; consent where required

Where we rely on legitimate interests, we balance our business needs against your rights and freedoms. You may object to processing based on legitimate interests as described in the “Your Rights” section below.

8. Mandatory Data

Certain personal data is required in order to process a booking, provide accommodation, issue invoices, comply with legal obligations, process payments, manage safety matters or respond to guest requests.

If required data is not provided, we may be unable to confirm or perform a booking, provide certain services, issue legal documents, process payments or comply with our legal obligations.

9. Recipients of Personal Data

We may share personal data only where necessary and lawful with:

booking engine providers, including WebHotelier;
payment processors, banks, card networks and payment gateways;
accountants, auditors, tax advisors and legal advisors;
IT providers, website hosting providers, cloud providers and software providers;
email, communication and customer support providers;
travel agents, tour operators or reservation partners involved in your booking;
transfer, excursion, concierge or other service providers where you request such services;
insurance providers, claims handlers or debt recovery providers where necessary;
public authorities, tax authorities, courts, regulators, police or other competent authorities where legally required;
business successors in the event of restructuring, sale, merger or transfer of business operations, subject to lawful safeguards.

We do not sell personal data.

10. International Transfers

Some of our processors, sub-processors, cloud providers or technology partners may process personal data outside the European Economic Area.

Where personal data is transferred outside the EEA, we will take steps to ensure that appropriate safeguards are in place, such as:

an adequacy decision issued by the European Commission;
Standard Contractual Clauses approved by the European Commission;
transfer impact assessments where required;
supplementary technical, organisational or contractual safeguards where appropriate.

We do not rely on outdated transfer mechanisms that are no longer legally valid.

11. Data Retention

We keep personal data only for as long as necessary for the purposes for which it was collected, unless a longer period is required or permitted by law.

Data category	Indicative retention approach
Booking and stay records	For the duration of the booking relationship and afterwards as needed for accounting, legal claims and business records
Accounting and invoice data	For the period required by Greek tax and accounting law
Payment and transaction records	For the period required for payment processing, refunds, chargebacks, accounting and legal claims
Guest correspondence	For as long as needed to manage the request, complaint, reservation or legal position
Marketing data	Until consent is withdrawn, objection is made, or the data is no longer needed
Website analytics data	According to the cookie settings and applicable retention periods
Legal claim or dispute records	For as long as necessary to establish, exercise or defend legal claims

When personal data is no longer required, we will delete, anonymise or securely restrict it, unless we are legally required to keep it.

12. Marketing Communications

We may send marketing communications only where legally permitted.

Where marketing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Where marketing is based on legitimate interests, you may object at any time.

All marketing emails should include an unsubscribe option or clear instructions on how to opt out.

13. Cookies and Tracking Technologies

Our website and booking engine may use cookies and similar technologies.

Cookies may be used for:

necessary website and booking engine functionality;
security and fraud prevention;
remembering user preferences;
analytics and website improvement;
marketing or advertising, where applicable.

Strictly necessary cookies may be used without consent where they are required for the operation of the website or booking system.

Non-essential cookies, including analytics, advertising or tracking cookies, will be used only where legally permitted and, where required, after obtaining your consent.

You may manage or withdraw cookie consent through the cookie settings available on the website, where applicable.

A separate Cookie Policy or cookie banner may provide more detailed information about the cookies used, their providers, purposes and duration.

14. Security Measures

We apply appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

These measures may include access controls, secure systems, confidentiality obligations, limited access rights, secure communication channels, processor controls, staff instructions and data handling procedures.

No system is completely secure. However, we take reasonable and appropriate steps to protect personal data according to the nature of the data, the risks involved and the available technology.

15. Guest Responsibility

You are responsible for ensuring that the information you provide to us is accurate, complete and up to date.

You must not provide false, misleading, incomplete or unauthorised information.

If your personal data changes, you should inform us so that we can update our records where necessary.

16. Your Rights

Subject to GDPR conditions and limitations, you may have the following rights:

Right of access — to ask whether we process your personal data and receive a copy of it.
Right to rectification — to correct inaccurate or incomplete personal data.
Right to erasure — to request deletion of your personal data where legally applicable.
Right to restriction — to request restriction of processing in certain circumstances.
Right to data portability — to receive certain data in a structured, commonly used and machine-readable format.
Right to object — to object to processing based on legitimate interests or direct marketing.
Right to withdraw consent — where processing is based on consent.
Right not to be subject to automated decision-making — where such processing has legal or similarly significant effects.

To exercise your rights, contact us at: reservations@naxosroyalvillas.com

We may need to verify your identity before responding. We will respond within the time limits required by applicable data protection law.

Some rights may be limited where we must retain or process data for legal obligations, contractual obligations, safety reasons, fraud prevention, accounting purposes or legal claims.

17. Complaints

If you believe that your personal data has been processed unlawfully, you may contact us first so that we can review and address your concern.

You also have the right to lodge a complaint with the competent supervisory authority.

For Greece, the competent authority is:

Hellenic Data Protection Authority
Website: www.dpa.gr
Address: Kifissias 1-3, 115 23 Athens, Greece
Telephone: +30 210 6475600
Email: contact@dpa.gr

18. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect legal, technical, operational or business changes.

The latest version will be published on our website with the relevant “Last updated” date.

Where required by law, we will notify you of material changes or request renewed consent.

19. Contact

For any question regarding this Privacy Notice or the processing of your personal data, please contact:

AFOI KAVOURA SA
Trading as: NAXOS ROYAL VILLAS
Email: info@naxosroyalvillas.com
Telephone: 0030 22850 29261
Address: Stelida, Naxos, 84300, Greece