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Protection of Guests Information is our Top Priority

Manifest Hospitality I.K.E and its affiliates hold the protection of your personal data as their highest priority. We make every effort to carefully store and process the information you share with us.

Because we appreciate your trust, we have created this Privacy Policy to inform you about how we collect, use, and share your information. The collection, use, and disclosure of your information are based on your consent and the provisions of applicable law.

Manifest Hospitality I.K.E and our affiliates protect your personal data through technical data security measures, internal management procedures, and physical data protection measures. We continually strive to improve our systems and procedures.

Thank you for your continued interest and support.


1. Consent

“Personal data” means any information that is collected or recorded in a way that may allow direct (e.g. surname) or indirect (e.g. phone number) identification of a natural person.

We recommend that you read this text, which describes the privacy policy, before providing us with personal data.

This “Customer Personal Data Protection Charter” is a part of the terms and conditions that govern our hotel services. By accepting these terms and conditions, you explicitly accept the provisions of this Charter.

2. Scope

At Manifest Hospitality I.K.E (hereinafter referred to as ” Manifest Hospitality” or “we”, “us”), we know how important it is to protect the privacy of our customers; we try to be as clear as possible about how we collect, use, share, transfer and store your information. This Privacy Policy summarises the practices we follow regarding your data.

This Privacy Policy applies to all hotels operated by Manifest Hospitality and our affiliate companies. This Privacy Policy also applies to this website, all websites, online applications, and online and offline promotional actions by Manifest Hospitality as well as any Service or function provided by us that refers to this Privacy Policy or provides a link hereto (collectively referred to as our “Services”).

Please note that the Privacy Policy applies to your use of our Services, regardless of whether you use a computer, mobile phone, tablet, TV, or any other device to access our Services. Additionally, this privacy policy applies to Services that are provided without the use of electronic means.

It is important that you carefully read this Privacy Policy because with every use of our Services you agree to the practices described herein. If you do not agree with the practices described in this Privacy Policy, you should not use our Services.

3. For what purposes do we collect data?

We collect and use personal data to manage your relationship with Manifest Hospitality and to offer our Services to you. Certain personal data is collected to provide you with personalized and improved services.

We collect personal data for the following purposes:

a) To manage reservations and other hospitality services
• Create and store legal documents in accordance with applicable law.
• Collect data to meet requests relating to your stay (e.g. room preferences).

b) To manage your hotel stay
• Manage access to your room.
• Monitor the use of services (room telephone, mini bar, online room service, Wi-Fi access, etc.).
• Manage lists with customers’ personal data for operational purposes, e.g. daily customer arrival and departure lists and a list of special category customers.

c) To improve our hotel services
• Tailor products and services to better meet your requirements.
• Process your personal data using marketing programs for marketing and promotional purposes.
• Provide you with useful information for offers or other promotional messages.
• Inform you about special offers and new Services.
• Provide customized content and recommendations based on your previous activities.

d) To manage our relations with you before, during, and after your stay
• Manage loyalty programs.
• Manage customer databases.
• Evaluate and analyze the market, our customers, our products, and Services.
• Create statistical data and reports.
• Gain knowledge and manage the preferences of new and recurring customers.
• Send newsletters, promotion products, and offers, or contact you by telephone.
• Manage requests for deletion from update lists.
• Create and manage questionnaires and statistics.
• Organise lotteries, contests, and offers.

e) To improve our services
• Conduct market research/analysis of questionnaires and customer comments.
• Manage customers’ claims and complaints.
• Offer loyalty program privileges

f) To improve system security
• Record data to ensure security and to prevent fraud.

g) To comply with Greek and European law

h) To ensure safe use of services provided by fitness facilities

i) To conduct market research/analysis of questionnaires and customer comments.

j) To conduct focused marketing campaigns, direct marketing, and sales promotion activities.

k) Digital Key Functionality – We use background location services and collect location data even when the app is closed or not in use for the digital key functionality on the app.

4. What personal data do we collect?

Information provided directly by you

For example:

• Several of our Services allow users to create accounts or user profiles. Along with these Services, we may ask you to provide personal details to set up your account or profile. For example, during the creation of a Guest portal, you can submit details such as your name and email address.
• When ordering a paid product or service from us, we may ask for certain additional details to process your order, such as your name, room details, and billing data.
• When participating in an online or offline contest or promotional action, we may ask you for your name, contact details, email address, age and gender, personal and occupational interests, other personal characteristics, and your opinion of our products and/or services.
• Some of our Services allow you to communicate with other people. This communication will be stored on our systems.

We are obliged to request the following details about you and/or your family members:

• Contact details (e.g. surname, given name, father’s name, passport number, ID-card details, telephone, home address, email)
• Personal data (e.g. date of birth, nationality, place of birth)
• Billing details (e.g. credit card number, VAT number)
• Loyalty program member number (member number for loyalty programs of other parties, such as airline operators)
• Date of arrival and departure, flight number, and room number
• Preferences and interests (e.g. non-smoking room, preferred floor, type of bed, sports, cultural interests)
• Data about your health, such as medical reports and certifications, medical test results, data on pathological diseases, etc.
• Questions and comments submitted during or after your stay.

The data we collect on persons under the age of 16 are restricted to a given name, surname, nationality, passport/identity number, and date of birth. This data can only be provided by an adult or guardian. Please ensure that children do not send us personal data without your consent, especially through the internet. Should any information of this type be sent to us, you can communicate with the Data Privacy department (see section “Questions and contact”) to arrange for the deletion of such information.

Moreover, information such as your passport number, recreational activities, hobbies, health issues, or whether you are a smoker or not can be described as sensitive. We retain such information only if we are obliged to do so by applicable law or if you have explicitly given us your consent (e.g. to provide you with an appropriate Service, such as special dietary needs).

Information on your use of our Services

Apart from the information you provide directly, we may collect information on your use of our Services through the software of your device or by other means. For example, we may collect:

• Device information, such as hardware model, International Mobile Equipment Identity (IMEI), and other unique device identity data, MAC address, IP address, operating system issue, and setting of the appliance you use to access our Services.
• Connection information, such as the time and duration of use of the Service, search commands entered in the Services, as well as information that may be stored in cookies we have placed on your device.
• Location information, such as GPS signal of your appliance or information on WiFi access points that may be transmitted to us when you use our Services (e.g. WiFi, Guest portal, mobile apps, etc.).
• Audiovisual information, such as voice recordings (which may be stored on our servers) when you use voice commands to use a Service or audiovisual information collected through closed-circuit television (CCTV) for security reasons.
• Other information that relates to your use of our Services, such as the applications that you use, the websites that you visit, and the way in which you interact with content offered through a Service.

Information from third parties

We may receive information about you from available public and commercial sources. This, we may combine with other information that we receive directly from you or in relation to you. We may also receive information about you from third-party social networking services when you choose to connect to such services.

Other information we collect

We may collect other information about you, your device or your use of services in manners described at the point of collection or otherwise with your consent.

You may choose not to provide certain types of information, but this may limit your access to certain Services.

5. When do we collect personal data?

We collect personal data in various cases, such as:

a) Hotel activities
• Room reservation
• Check-in and payment
• Reservation of seat and/or use of hotel services, such as catering, spa, and recreational services
• Various requests, complaints, and/or disputes

b) Participation in marketing programs or events
• Registration in loyalty programs (e.g. our Airline partners)
• Participation in online and offline surveys (for example, customer satisfaction survey)
• Participation in contests and games
• Subscription to mailing lists in order to receive offers and other promotions by email

c) Transmission of information from third parties
• Tourist agencies, tourist offices, GDS reservation systems, online reservation systems (e.g. booking.com, expedia.com, etc.), and other reservation systems or booking channels.

d) Actions through electronic devices
• Login on our websites
• Connection to our WiFi network at our hotels
• Completion of online forms (e.g. reservation forms, precheck-in forms, satisfaction survey forms, etc.)

e) Digital Key Functionality

Manifest Hospitality app offers during-stay services to hotel guests to enhance their stay. In this context, the Manifest Hospitality app provides an e-key functionality, the app uses the background location services and collects location data even when the app is closed or not in use, only for this specific functionality. These data are not used for any other reason.

6. Third-party access terms to your personal data

Manifest Hospitality and its affiliates do not disclose your information to third parties for their own business or marketing purposes without prior consent.

However, we may disclose your information to the following entities:

• Affiliates. Your information may be shared between affiliates of Manifest Hospitality
• Business associates. We may also share your information with trusted business partners. These entities may use your information to provide you with services you have requested, make provisions relating to your interests, and offer you promotions, advertisements, and other material.
• Service providers and/or any third parties that may process information on our behalf. We may also share your information with companies that provide services on our account or behalf, such as IT contractors, bulk mailers, banks, credit card institutions, law firms, mail service companies, printing services companies, etc.

Credit approval: Upon submission of a credit approval claim, personal data are utilized and disclosed to designated third parties according to applicable legislation in order to decide on the credit approval and its subsequent level.

• Other third parties, if so required by law or in order to protect our Services. Situations may arise in which we share your information with other third parties:
o To comply with the law or mandatory legal procedure (such as search warrants or other court orders)
o To confirm or implement our compliance with the policies governing our Services
o To protect the rights, ownership, or security of Manifest Hospitality or any of our affiliates, business partners, or customers
• Other third parties in relation to corporate transactions. We may share your information with third parties within the context of a merger or transfer, or in the event of bankruptcy.
• Other third parties with your consent or at your command. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties if you give your consent or if you request us to do so.

To provide you with the best possible service, we allow access to your personal data or certain categories to competent, authorized members of our personnel. This includes:

• Hotel staff
• Reservations departments
• IT department
• Marketing/Guest Relations department
• Legal Services department, if and when required
• Medical Services, if and when required

7. Protection of personal data during international transfers

For the purposes set out in Article 3 of this Charter, we may transfer your personal data to internal or external recipients who may be located in countries that offer different levels of protection for personal data.

Please note that data protection and other laws in the countries to which your information may be transferred may not be as protective as those in your country. To protect your privacy, the transfer will take place according to the legislation governing the processing of personal data.

Manifest Hospitality takes all reasonable measures to safeguard the transfer of personal data to an external recipient in a country that offers a different level of privacy than the country where the personal data is collected.

8. What do we do to keep your information safe?

We have taken organizational and technical measures to protect the information that we collect in relation to our Services, especially sensitive personal data. Our IT department implements international standards and practices to ensure the safety of networks and the encryption of data.

However, please bear in mind that despite the reasonable measures that we take to protect your information, no website, internet transmission, computer system, or wireless connection is ever completely safe.

9. Data storage

We take reasonable measures to ensure that your personal information will be stored no longer than needed for the purpose for which it has been collected and no longer than required by the contract or the applicable legislation.

10. Cookies, beacons, and similar technologies

We and certain third parties who provide content, advertisements, or other features for our Services may use cookies, beacons, and other technologies in certain parts of our Services.


Cookies are small files that store information on your computer, mobile phone, or another device. They allow the entity that places these files on your device to identify you across different websites, services, devices, and/or browsing times. Cookies serve a range of useful purposes. For example:
• Cookies can remember your login credentials so you do not have to enter them again each time you connect to a service.
• Cookies help us and third parties to understand the most popular parts of our Services; they help us see which pages and features are visited by the users and how much time is spent on each. By studying this kind of information, we can customize our Services and provide you with a better experience.
• Cookies help us and third parties to understand which advertisements you have viewed so you do not receive the same advertisement each time you access the Service.
• Cookies help us and third parties provide you with relevant content and advertisements by collecting information about your use of our Services and other websites and applications.

When you use a website to access our Services, you can make settings in your browser to accept all cookies, reject all cookies or notify you when cookies are sent. Each browser is different. Refer to the “Help” menu of your browser to find out how you can change your cookie preferences. The operating system of your device may offer more control settings for cookies.

However, please note that certain Services may have been designed to work with cookies and that deactivating cookies may affect your ability to use those Services or part of those Services.

Other local storage

We and certain third parties may use other kinds of local storage technologies, such as Local Shared Objects (commonly called “Flash cookies”) and local HTML5 storage (HTML5 Web Storage) in conjunction with our Services. These technologies are similar to the cookies mentioned above as they employ storage on your device and can be used to store information concerning your activities and preferences. However, these technologies may use different parts of your device than typical cookies, and therefore may not be controlled with the standard tools and browser settings.


We and certain third parties may also use technologies called “beacons” (or “pixels”) that send information from your device to a server. Beacons can be embedded in internet content, videos, and emails to allow a server to read certain types of information from your device. Beacons can also be embedded to determine when you have viewed specific content or a specific email message, the time and date on which the beacon was viewed, and the IP direction of your device. We and certain third parties use beacons for a variety of purposes, such as to analyze the use of our Services and (in combination with cookies) to offer you more relevant content and advertisements.

By accessing and using our Services, you agree to the storage of cookies, other local storage technologies, beacons, and other information on your devices. You also allow us and the aforementioned third parties to access these cookies, local storage technologies, beacons, and information.

11. Access and correction of your data – right to erasure (‘right to be forgotten’)

In addition to existing lawful user rights, according to the legislation in certain jurisdictions, you may also be entitled to request details on the information that we collect and to correct any inaccuracies that may be contained in such information. If permitted by law, we may charge you a small fee for the provision of this possibility. We may refuse to handle requests that are repeated to an unreasonable degree, require disproportional technical effort, jeopardize the privacy protection of others, are extremely impractical, or involve access that is not otherwise required by domestic law. If you wish to submit a request for access to your data, please contact the Data Privacy department (see section “13 . Questions and contact”).

Υου have the right to obtain the erasure of your personal data from the controller.

12. Updates

This policy may be amended from time to time. To ensure that you are aware of any changes, please check this policy regularly, especially before submitting a reservation request with our hotel. By accessing or using our Services after we have posted an updated version of the Privacy Policy, you agree with the new practices contained in the update. The most recent version of the privacy policy will always be available here: XXXXXXXXXXXX (keywe to provide link).

A printed version of this Privacy Policy can be found at the reception desk at all our hotels. You may also request a copy by contacting the Data Privacy department (see section “Questions and contact”).

13. Questions and contact

If you have any questions regarding this policy or the protection of data at Manifest Hospitality and our affiliates, please contact the Data Private Department at the following address:

Manifest Hospitality

Data Privacy Department – Attn. Angelos Sotiropoulos
Karavostasi Oitylou, Oitylos 23062 Greece
Telephone: +30 210 9248 990

Email: [email protected]