Information On The Processing Of Personal Data Through A Video Surveillance System

GDPR

DATA CONTROLLER

The company under the trade name « ANTHOLOGY HOTEL SINGLE MEMBER SOCIETTETE ANONYME (s.a.)», located in Athens, 4 Andrea Syngrou Avenue, PC 11742 Tel. 2111034800

PURPOSE OF PROCESSING AND LEGAL BASIS

We use a surveillance system for the purpose of protecting people and property. The processing is necessary for the purposes of legitimate interests pursued by us as the controller (Article 6 § 1.6 GDPR).

LEGITIMATE INTERESTS

The legitimate interest of the Hotel, as data controller, consists in the need to protect our premises and the goods therein from illegal acts, such as, for example, theft. The same applies to the safety of life, physical integrity, health and property of our staff and third parties who are lawfully present in the monitored premises. We only collect image data and limit the recording to areas that we have assessed as having an increased likelihood of committing illegal acts (e.g. theft), such as our cash registers, E/M installation areas, elevator entrances/exits, stairwell areas and Hotel entrances (including side streets and sidewalks), without focusing on areas where the privacy of the persons whose image is taken may be excessively restricted, including their right to respect for personal data.

DATA RECIPIENTS

The material held is accessible only by our competent and authorized personnel who are responsible for the security of the area. This material is not transmitted to third parties, except in the following cases: a) to the competent judicial, prosecutorial and police authorities when it includes information necessary for the investigation of a criminal act, which concerns persons or goods of the controller, b) to the competent judicial, prosecutorial and police authorities when they request data, lawfully, in the exercise of their duties, and c) to the victim or perpetrator of a criminal act, when it concerns data which may constitute evidence of the act.

Furthermore, our competent and authorized personnel have agreed and committed to: a) maintain confidentiality, b) not send data to third parties (with the above exceptions), c) take appropriate security measures and d) fully comply with the legal framework for the protection of personal data, in particular Regulation 979/2016/EU and this policy.

DATA SECURITY

We are committed to safeguarding your personal data.

Recognizing the importance of the security of your personal data, we have taken all appropriate organizational and technical measures to secure and protect your data from any form of accidental or unlawful processing. We use the most modern and advanced methods to ensure maximum security.

The Hotel applies appropriate technical and organizational measures to secure the personal data of individuals that it processes in the context of its activities on a case-by-case basis and in particular the data collected through the video surveillance system it has in its facilities. In particular, network security and protection procedures and policies (firewall) are implemented, as well as a discrete subnet (VLAN) as part of the internal subnet during the transmission of image information data. Additionally, network security enhancement techniques, centralized secure access management, limited access, continuous security monitoring, availability preservation, physical security preservation are implemented, all of which contribute to maintaining the confidentiality, availability and integrity of the subjects’ personal data. Finally, limited access policies are implemented both in the recording infrastructure and in the recording information, while at the same time procedures for secure data transmission are implemented in the event of a request. Storage takes place in a specially configured infrastructure with limited and controlled access.

The above measures are reviewed and modified when deemed necessary.

RETENTION PERIOD

We keep the data for fifteen (15) days, after which it is automatically deleted. In the event that we detect an incident during this period, we isolate part of the video and keep it for up to one (1) more month, in order to investigate the incident and initiate legal proceedings to defend our legitimate interests, while if the incident concerns a third party, we will keep the video for up to three (3) more months.

DATA SUBJECTS’ RIGHTS

Data subjects have the following rights:

  • Right of access: you have the right to know whether we are processing your image and, if applicable, to receive a copy of it.
  • Right of restriction: you have the right to ask us to restrict processing, such as not deleting data that you consider necessary for the establishment, exercise or support of legal claims.
  • Right to object: you have the right to object to the processing.
  • Right to erasure: you have the right to get your data deleted.
  • Right to portability: you have the right to request that we transfer your data to another controller.

We note that exercising the right to object or erasure does not imply the immediate deletion of data or modification of the processing. In any case, we will respond to you in detail as soon as possible, within the deadlines set by the GDPR.

EXERCISE OF YOUR RIGHTS

To exercise your rights, you can submit a relevant request to us by sending an e-mail to the email address [email protected] or a letter to our postal address or by submitting the request to us in person at the Hotel address. In order for us to examine a request related to your image, you must specify to us approximately when you were within the range of the cameras and provide us with an image of you, in order to facilitate our identification of your data and the concealment of the data of third parties depicted. Alternatively, we give you the opportunity to come to our facilities to show you the images in which you appear.

RIGHT TO FILE A COMPLAINT

In case you consider that the processing of data concerning you violates Regulation (EU) 2016/679, you have the right to file a complaint with a supervisory authority.
The competent supervisory authority for Greece is the Data Protection Authority, 1-3 Kifissias Av., PC 115 23, Athens, https://www.dpa.gr, tel. 2106475600.

UPDATING POLICY

We update this video surveillance policy whenever necessary. If there are significant changes to it, we will publish the update of this policy before the changes come into force. We encourage you to read this policy regularly. This video surveillance policy was last modified on 15/11/2024.