Privacy policy

INTRODUCTION

Welcome to the Holistays Limited’s privacy policy.

Holistays Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we collect, use and look after your personal data. It further describes your privacy rights and the control you can exercise in relation to your personal data.

1.  IMPORTANT INFORMATION

CONTROLLER

This privacy policy is issued on behalf of Holistays Limited, a limited liability company registered in the Republic of Cyprus with registration number HE 271518;

This privacy policy is addressed to individuals outside Holistays Limited with whom we interact, including individual clients, representatives, visitors of our website as well as other users of our services and suppliers.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices or if you would like to exercise your legal rights, please contact our Data Privacy Manager in the following ways:

Email address: hello@holistays.com.cy

Postal address: Data Privacy Manager

HOLISTAYS LIMITED 
Suite 211, MITSI BUILDING 3
1 Archbishop Makarios III Avenue
1065 Nicosia, Cyprus
Telephone number: 00357-22-817141

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

We keep our privacy policy under regular review.

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 relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.  THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, relationship to a person, position, role, employer, gender, copy of passport or national identity, utility bill.

  • Contact Data includes billing address, delivery address, email address, fax number and telephone numbers (including mobile telephone number(s)), postal address.

  • Financial Data includes payment related information, financial information related to anti-money laundering or compliance purposes.

  • Payment Details Data includes billing address, payment method, bank account number, accountholder name, account security details, invoice records, payment records, SWIFT details, IBAN details, payment amount, payment date, records of cheques;

  • Attendance Records Data includes details of your visits to our premises;

  • Preference Data includes your consent to receive newsletters, updates or any other communication from us;

  • Consent Records Data includes records of any consents you have given us, together with the date, means of consent and any other information provided such as the subject matter of the consent provided;

  • Supplier Data includes contact details and other information about you or your company or organisation where you provide services to Holistays Limited;

  • Any other information relating to you which you may provide us with, such as health personal data, if required by us to be able to provide legal and other services to you such as defending you in legal proceedings against you.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?

We regularly collect or receive personal data as part of our professional services and or activities. We use different methods to collect data from and about you including:

  • Directly from you through our website or that is otherwise captured during the course of your relationship with us, by filling in our forms or by corresponding with us by post, phone, email or otherwise. This includes personal data from the forms and documents used from your access to or use of our services.

  • We collect personal data when we monitor or record our communications with you or through use of certain technology as detailed further below.

  • We collect data when you process a payment through any type of credit/debit card in EUR or any other currency. The payment details you provide which are directly linked to your credit/debit card are retained by us and not shared with any other third party.

  • We may also obtain personal data from our service providers acting on our behalf, from third parties authorised to provide us with such information, such as credit reporting bodies, other credit providers or other agencies used for running due diligence checks, authorised third parties performing identity verification procedures on our behalf and/or from third parties who provide services to you such as your financial adviser, financial planner, dealer group, accountant or other professional adviser. Some of this information is publicly accessible and/or reliable and independent databases that we access through an authorised third party to whom we disclose your personal data for the purpose of performing required identity verification procedures. Where you are an individual associated with a corporation or institution with whom Holistays Limited does business with, your personal data will also be provided to us via that corporation or institution. Such personal data includes personal and contact details, financial information, identification documents and, where permitted by applicable law and only to the extent needed, information relating to political affiliations, trade union membership or criminal convictions.

4.  HOW WE USE YOUR PERSONAL DATA

We will only use your personal data for the following purposes:

  • Service provision: providing access to our website and services;

  • Business relationship: managing and improve our products and services;

  • Communication: sending emails, newsletters and other messages to keep you informed of developments, market insights and for marketing of our services;

  • Site security: to provide security to our offices and other premises;

  • Online security: protecting our information assets and technology platforms from unauthorised access or usage and to monitor for malware and other security threats;

  • Conducting investigations and fraud prevention: detecting, preventing and investigating fraud;

  • Financial management: managing and administering the payment of our invoices and the fulfilment of your financial obligations towards us;

  • Managing suppliers: who deliver services to us, including processing payments, accounting auditing billing and collection;

  • Managing IT systems and provision of security: managing and administering our IT systems and ensuring that we have adequate security measures in place;

  • Legal proceedings: establishing, exercising and defending legal rights/claims;

  • Legitimate interest: to pursue the legitimate business interests listed in the “Legitimate Interests” section of this policy below.

If you have given us your express consent, we may process your personal data to communicate with you with respect to developments, announcements, events and services. You may withdraw your consent at any time by contacting our Data Privacy Manager using the contact information provided at the beginning of this Privacy Policy

5.  DISCLOSURES OF YOUR PERSONAL DATA

We may disclose your information with others as follows:

  • Other companies belonging to or directly affiliated to Holistays Limited, always in accordance with this privacy policy;

  • Trusted third parties: we may share your personal information with certain trusted third parties which provide services to Holistays Limited of companies, such as our professional advisers and auditors, suppliers and processors to whom we outsource certain support services, IT service providers, software providers, communication suppliers. We shall take measures to protect the confidentiality and security of the personal data in such circumstances;

  • Any third party: we may share your personal data provided we have received your approval and full consent.

6.  DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, disclosed used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7.  DATA RETENTION

Personal data may be kept on our personal IT systems, those of our contractors or in paper files.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We will further retain your personal data where required for Holistays Limited to assert or defend against legal claims until the end of the relevant retention period or until the claims in questions have been satisfied.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8. WHAT INFORMATION IS COLLECTED FROM THE WEBSITE VISITORS

Holistays Limited collects and processes personal data related to individual visitors of our website and fills in the role of the Controller for this specific set of information. Personal data collected by third parties that remain legally and economically independent from Holistays Limited do not fall within the scope of this definition. Please refer to our Cookie Policy for further information. During the course of your visit to our website, the following types of personal data is collected:

(a) Due to the use of cookies on our website, Holistays Limited may obtain information about a website visitor’s computer and about a website visitor’s number of visits to and use of our website. This includes information on the website visitor’s IP address (Internet Protocol), geographical location, internet access services provider, browser type, referral source, length of visit and number of page views.

(b) In the course of using the contact form provided in the “Contact Us” section, Holistays Limited obtains personal information relating to an individual website visitor.

(c) For the purpose of subscribing to our website services, email notifications and/or newsletters Holistays Limited may obtain personal information and data related to the individual website visitor.

(d) Any other information that a website visitor chooses to send to us.

(e) Telephone calls may be recorded for training and monitoring purposes.

12.  YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to exercise or discuss any of the rights set out above, please contact the Data Privacy Manager as listed above in this Policy. We may require proof of your identity prior to giving effect to those rights.

You have the right to:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to lodge a complaint with the supervisory authority in Cyprus, the Office of the Commissioner of Personal Data (www.dataprotection.gov.cy).

13. DIRECT MARKETING

We may use the information you give us for direct marketing from us only if you give us your consent. You can opt-out of receiving direct marketing from us at any time by sending an email to the Data Protection Manager using the details set out at the beginning of this policy.

14. CHILDREN

We do not knowingly collect information from children or other persons who are under 14 years old. If you are under 14 years old, you may not submit any personal data to us.

15. CHANGES TO THIS POLICY

This Privacy Policy was last updated in August 2024. This policy may be changed from time to time to reflect changing legal requirements or change in our processing practices.  If we change anything important about this policy, we will highlight those changes at the beginning of the policy.

16. HOW TO CONTACT US

If you would like more information about the way we manage personal data that we hold about you please contact our Data Privacy Manager as set out at the beginning of this policy.